Version effective as of 14 February 2024
Privacy Policy
In this privacy policy (this "Privacy Policy"), we, Palegria GmbH and affiliate partnerships
like GTM Platform.io (hereinafter, we or us), explain how we collect and otherwise process
personal data.
The term "personal data" or “data” refers to all information that relates to a specific or
identifiable person.
If you provide us with the personal data of other persons (for example, family members, data
of work colleagues), please make sure that these persons are aware of this Privacy Policy
and only share their data with us if you are allowed to do so and if this personal data is
correct.
Note that other privacy policies or general terms and conditions, conditions of participation,
and similar documents may govern specific data privacy topics.
This Privacy Policy is aligned with the EU General Data Protection Regulation (“GDPR”) and
the Swiss Data Protection Act (“DPA”). However, the application of these laws depends on
each case.
The terms used are not gender-specific.
1 Controller and Data Protection Officer
The company responsible for the data processing described here can be found in the imprint
or is the Palegria GmbH and affiliate partnerships like GTM Platform.io company with which
you have a business relationship or which is either indicated or identifiable for the specific
data processing. If you have data privacy concerns, you can reach Palegria GmbH and
affiliate partnerships like GTM Platform.io’s data protection officer under Art. 10 DPA and 37
GDPR, respectively, at:
Postadresse: Palegria, Paulo Germann, Freistrasse 216, 8032 Zürich, Switzerland
Email: paulo.germann@palegria.com
Please mention, if possible, to which company within the Palegria GmbH and affiliate
partnerships like GTM Platform.io you are referring.
2 Collection and Processing of Personal Data
We primarily process the personal data that we receive from our customers and other
business partners in the course of our business relationship with them and other persons
involved in it, or that we collect from their users in the operation of our website(s). To the
extent permitted, we also collect certain data from publicly accessible sources (for example,
debt collection registers, land registers, commercial registers, the press, and the Internet) or
receive such data from other group companies, public authorities, and other third parties
(such as credit agencies or address providers).
In addition to the data about you that you give us directly, the categories of personal data
that we receive about you from third parties include, in particular, information from public
registers, information that we learn in connection with official and legal proceedings,
information relating to your professional functions and activities (for example, to enable us to
enter into and process transactions with your employer with your assistance), information
about you in correspondence and meetings with third parties, credit reports (to the extent
that we process transactions with you personally), information about you provided to us by
persons close to you (family, advisors, legal representatives, etc.) to enable us to enter into
contracts with you, conclude or process agreements with you or involving you (for example,
references), your address for deliveries, powers of attorney, information on compliance with
legal requirements such as anti-money laundering and export restrictions, information from
banks, insurance companies, (e.g. payments made, purchases made), personal data from
the media and the Internet (if this is appropriate in the specific case, for example as part of
an application, press review, marketing/sales, etc.). ), your addresses and, if applicable,
interests and other socio-demographic data (for marketing), data in connection with the use
of the website (for example, IP address, MAC address of the smartphone or computer,
information about your device and settings, cookies, date and time of visit, pages viewed
and content, functions used, referring website, location information).
3 Purpose of Data Processing and Legal Grounds
We use the personal data we collect primarily to enter into and perform our agreements with
our customers and business partners, so in particular in the context of the following activity:
Consulting, Coaching and operational ad-interim leadership for Scale-ups and Startups
As part of this activity, we collect personal data for transactions with our customers and the
purchase of products and services from our suppliers and subcontractors, as well as to
comply with our legal obligations at home and abroad. If you work for such a customer or
business partner, your personal data may of course also be concerned in this capacity.
We also process your and other person's data, to the extent permitted and as we deem
appropriate, for the following purposes, in which we (and sometimes also third parties) have
a legitimate interest:
• Offering and further developing our products, services and websites, apps, and other
platforms on which we are present;
• Communicating with third parties and processing their inquiries (for example, job
applications, media inquiries);
• Testing and optimizing procedures for analyzing needs to address customers directly,
as well as collecting personal data from publicly available sources for customer
acquisition;
• Advertising and marketing (including the organization of events), unless you have
objected to the use of your data (if we send you advertisements as an existing customer
of ours, you can object to this at any time; we will then place you on a blocking list
against further advertising mailings);
• Assertion of legal claims and defense in connection with legal disputes and official
proceedings;
• Prevention and investigation of criminal offenses and other misconduct (for example,
conducting internal investigations, data analysis to combat fraud);
• Ensuring that our operations, in particular IT, our websites, apps, and other platforms,
are running properly;
• Purchase and sale of business units, companies, or parts of companies and other
transactions under company law and the associated transfer of personal data, as well as
measures for business management and, to the extent necessary to comply with legal
and regulatory obligations and our internal regulations.
4 Cookies / Tracking and Other Techniques Regarding the Use of Our Website
We typically use "cookies" and similar techniques on our website(s), which allow for the
identification of your browser or device. A cookie is a small text file that is sent to your
computer and automatically saved by the web browser on your computer or mobile device
when you visit our website(s). If you revisit our website, we may recognize you, even if we
do not know your identity. Besides cookies that are only used during a session and deleted
after you visit the website ("session cookies"), we may use cookies to save user
configurations and other information for a certain period (for example, two years)
("permanent cookies"). Notwithstanding the foregoing, you may configure your browser
settings in a way that rejects cookies, only saves them for one session, or deletes them
prematurely. Most browsers are preset to accept cookies. We use permanent cookies to
save user configuration (for example, language, automated log-in), to understand how you
use our services and content, and to show you customized offers and advertisements (which
may also happen on websites of other companies; should your identity be known to us, such
companies will not learn your identity from us; they will only know that the same user is
visiting their website has previously visited a certain website). Certain cookies are sent to
you from us, others from business partners with whom we collaborate. If you block cookies,
certain functions (for example, language settings, shopping basket, and ordering processes)
may be no longer available to you.
Under applicable law, we may include visible and invisible image files in our newsletters
and other marketing e-mails. If such image files are retrieved from our servers, we can
determine whether and when you have opened the e-mail, so that we can measure and
better understand how you use our offers and customize them. You may disable this in your
e-mail program, which will usually be a default setting.
By using our website(s) and consenting to the receipt of newsletters and other marketing emails
you agree to our use of such techniques. If you object, you must configure your
browser or e-mail program accordingly.
We may use Google Analytics or similar services on our website. These are services
provided by third parties, which may be located in any country worldwide (in the case of
Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google
LLC (located in the United States) as its sub-processor (both “Google”, www.google.com)
and which allow us to measure and evaluate the use of our website (on an anonymized
basis). For this purpose, permanent cookies are used, which are set by the service provider.
We have configured the service so that the IP addresses of visitors are truncated by Google
in Europe before forwarding them to the United States and then cannot be traced back. We
have turned off the «Data sharing» option and the “Signals” option. Although we can assume
that the information we share with Google is not personal data for Google, it may be possible
that Google may be able to conclude the identity of visitors based on the data collected,
create personal profiles and link this data with the Google accounts of these individuals for
its purposes. If you have registered with the service provider, the service provider will also
know your identity. In this case, the processing of your data by the service provider will be
conducted under its data protection regulations. The service provider only provides us with
data on the use of the respective website (but not any personal information of you).
In addition, we use plug-ins from social networks such as Facebook, Twitter, YouTube,
Pinterest, or Instagram on our websites. This is visible for you (typically based on the
respective symbols). We have configured these elements to be disabled by default. If you
activate them (by clicking on them), the operators of the respective social networks may
record that you are on our website and where on our website you are exactly and may use
this information for their purposes. This processing of your data lies in the responsibility of
the respective operator and occurs according to its data protection regulations. We do not
receive any information about you from the respective operator.
5 Transfer of Data to Third Parties and/or Within Our Group Companies
In the context of our business activities and in line with the purposes of the data processing
set out in Section 3, we may transfer data to third parties, insofar as such a transfer is
permitted and we deem it appropriate, for them to process data for us or, as the case may
be their purposes. In particular, the following categories of recipients may be concerned:
• our service providers (within our group or externally, such as banks or insurance, for
instance), including processors (such as IT providers);
• dealers, suppliers, subcontractors, and other business partners;
• clients;
• domestic and foreign authorities or courts;
• the media;
• the public, including users of our websites and social media;
• competitors, industry organizations, associations, organizations, and other bodies;
• acquirers or parties interested in the acquisition of business units, companies, affiliates,
or other parts of our group;
• other parties in potential or pending legal proceedings;
• affiliates of the Palegria GmbH and affiliate partnerships like GTM Platform.io;
together "Recipients".
If we pass on data to third parties, we comply with the relevant legal requirements and, in
particular, conclude data processing agreements or similar agreements with the
respective Recipients to protect your data.
6 Transfer of Data Abroad
We may share data with persons, authorities, organizations, companies, or other entities
abroad. In particular, we may transfer personal data to all countries in which Palegria GmbH
and affiliate partnerships like GTM Platform.io is represented by affiliates, branches, or other
offices and representatives, as well as to the countries in which our service providers
process personal data.
If a Recipient is located in a country without adequate statutory data protection, we require
the Recipient contractually to comply with the applicable data protection (for this purpose, we
use the revised standard contractual clauses of the European Commission, which are
available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the Recipient is
already subject to a legally recognized set of rules to ensure data protection and we cannot
rely on an exemption provision. An exception may apply in particular in the case of legal
proceedings abroad, but also in cases of overriding public interests or if the performance of a
contract requires such disclosure, if you have consented to it, or if it is a matter of data made
generally available by you, the processing of which you have not objected to.
7 Duration of the Retention of Personal Data
We process and retain your data for as long as it is necessary for the fulfillment of our
contractual and legal obligations or otherwise the purposes pursued with the processing, i.e.,
for example, for the duration of the entire business relationship (from the initiation,
processing to the termination of an agreement) and beyond that under the statutory retention
and documentation obligations. In this context, we may retain personal data for the period
during which claims may be asserted against our company and to the extent that we are
otherwise required to do so by law or legitimate business interests so require (for example,
for evidence and documentation purposes). As soon as your data is no longer required for
the above-mentioned purposes, it will be deleted or anonymized as a matter of principle and
to the extent possible. For operational data (for example, system records, and logs), shorter
retention periods of twelve months or less generally apply.
8 Data Security
We take appropriate technical and organizational security measures to protect your data
from unauthorized access and misuse.
These include the following measures: Encryption of data, access controls and restrictions
We already take the protection of personal data into account during the design or choice of
hardware, software, or processes using appropriate technical and organizational measures.
Furthermore, we ensure data protection-friendly default settings.
9 Obligation to Provide Personal Data
In the course of our business relationship, you must provide those personal data that are
necessary for the start and performance of a business relationship and the fulfillment of the
associated contractual obligations (you generally do not have a statutory obligation to
provide us with data). Without this data, we will generally not be able to enter into or perform
an agreement with you (or the entity or person you represent). Also, our websites cannot be
used if certain traffic-securing information (such as IP address) is not disclosed.
10 Profiling and Automated Individual Decision-Making
We may partially process your data automatically to evaluate certain personal aspects
(profiling). In particular, profiling allows us to inform and advise you about products possibly
relevant to you more accurately. For this purpose, we may use evaluation tools that enable
us to communicate with you and advertise to you as required, including market and opinion
research.
In establishing and carrying out a business relationship, we generally do not use any fully
automated individual decision-making (such as under Art. 21 DPA and 22 GDPR,
respectively). Should we use such procedures in certain cases, we will inform you separately
on this and advise you of your relevant rights if required by law.
11 Your Rights
Following and as far as provided by applicable law (as is the case where the GDPR is
applicable), you have the following rights:
• the right to request information from us as to whether and what data we process about
you;
• the right to have us correct data if it is inaccurate;
• the right to request that we delete data;
• the right to request that we provide certain personal data in a commonly used electronic
format or transfer it to another controller;
• the right to withdraw consent, insofar as our processing is based on your consent;
• the right to obtain, on request, further information necessary for the exercise of these
rights;
• the right to express your point of view in the case of automated individual decisions
(Section 10) and to request that the decision be reviewed by a natural person.
Please note, however, that we reserve the right to assert the restrictions provided for by law
on our part, for example, if we are required to retain or process certain data, have an
overriding interest in doing so (to the extent that we are entitled to rely on this) or if we need
it for the assertion of claims. If you incur costs, we will inform you in advance. We have
already informed you about the possibility of withdrawing your consent in Section 3. Please
note that exercising these rights may conflict with contractual arrangements and may have
consequences such as early termination of the agreement or costs. We will inform you in
advance if this is not already specified in the agreement.
The exercise of such rights usually requires that you prove your identity (for example, using
a copy of your identity card, where your identity is otherwise not clear or cannot be verified).
To exercise your rights, you may contact us at the address provided in Section 1.
Every data subject also has the right to enforce their claims in court or to file a complaint with
the competent data protection authority. The competent data protection authority in
Switzerland is the Federal Data Protection and Information Commissioner
12 Amendments to this Privacy Policy
We may amend this Privacy Policy at any time without prior notice. The current version
published on our website shall apply. If this Privacy Policy is part of an agreement with you,
we will notify you by e-mail or other appropriate means in case of an amendment.