Collection of information
GLOBAL LEDGER collects information to provide better services to its users and to better understand the visitors to its websites and what content is of interest to them. GLOBAL LEDGER collects information in the following ways:
- information you affirmatively choose to submit to us (such as your name, contact details, company name, title, and country) for the purpose of accessing various downloads, viewing specific content, subscribing to GLOBAL LEDGER newsletters, registering for events and your preferences in receiving marketing from GLOBAL LEDGER and its third-party partners and your communication preferences, etc. Information we have obtained about you from publicly available sources such as social media, marketing platforms or on events, you attended. You will receive marketing communications from GLOBAL LEDGER if you have requested information from GLOBAL LEDGER or you or your employer has purchased services from GLOBAL LEDGER;
- information GLOBAL LEDGER receives from your use of GLOBAL LEDGER websites, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to GLOBAL LEDGER’s websites;
- location information when you use GLOBAL LEDGER’s websites as GLOBAL LEDGER may collect and process information about your location. GLOBAL LEDGER use various technologies and tools to determine location;
- information that is considered aggregated data such as statistical data which GLOBAL LEDGER may use for marketing purposes. Aggregated data may be derived from your personal information but is not considered personal information in law as it does not directly or indirectly reveal your identity.
GLOBAL LEDGER collects technical data from various third parties and public sources, such as analytics providers, advertising networks, and search information providers.
Other than as required by law, GLOBAL LEDGER websites do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). GLOBAL LEDGER will not collect any information about criminal convictions and offences.
GLOBAL LEDGER will only use your personal information for the purposes for which it was collected unless it reasonably considers that it needs to use it for another reason that is compatible with the original purpose. If GLOBAL LEDGER needs to use your personal information for an unrelated purpose, GLOBAL LEDGER will notify you and provide you with the legal basis which allows GLOBAL LEDGER to do so or request additional consent if necessary.
The purposes of collecting the above-mentioned proprietary personal data are:
- improving business decisions,
- supporting the activities you choose to engage in, and
- providing higher quality solutions and services to GLOBAL LEDGER’s customers.
To determine the appropriate retention period for personal information, GLOBAL LEDGER considers the necessity, legal obligations, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which GLOBAL LEDGER processes your personal information and whether it can achieve those purposes through other means, and the applicable legal requirements.
As explained above, GLOBAL LEDGER will collect and use your personal data for marketing purposes.
Your data will be stored in our CRM system. We will use your data to inform you about GLOBAL LEDGER products and services we think may be of your interest and send you our newsletters. For statistical purposes, we will collect information about your response to our emails and our interaction with you to make decisions on future marketing. If you wish to stop that we collect and use this information please click here
How long do we keep your personal data?
We retain information for different periods of time depending on the nature of the information and our legal obligations. In general, we will retain your personal information to fulfil the purposes for which it was collected, as necessary to comply with our legitime interests, business requirements, and legal obligations, resolve disputes, protect our assets, and enforce our agreements. We may also retain cached or archived copies of your personal information for a reasonable period of time in accordance with applicable law.
Our principles relating to the processing of your personal data
- We use principles relating to the processing of personal data according to Article 5 of General Data Protection Regular:
- “(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);
- (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
- (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
- (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’);
- (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).”
Sharing of information
GLOBAL LEDGER may disclose your personal information to the following categories of recipients:
- to its group companies, professional advisers, third-party services providers and partners who provide data processing services to GLOBAL LEDGER (for example, to support the delivery of, provide functionality on, or help to enhance the security of GLOBAL LEDGER websites), or who otherwise process personal information for purposes that are described in Privacy Notices or notified to you when GLOBAL LEDGER collects your personal information.
- to any competent law enforcement body, regulatory, government agency, court or other third party where GLOBAL LEDGER believes disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend its legal rights, or (c) to protect your vital interests or those of any other person.
- to any other person with your consent to the disclosure.
Legal basis for processing
If your personal information is protected by EU data protection law, GLOBAL LEDGER’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which GLOBAL LEDGER collects it.
However, GLOBAL LEDGER will normally collect personal information from you only (a) where it needs the personal information to perform a contract with you, (b) where the processing is in its legitimate interests and is not overridden by your rights, or (c) where it has your consent to do so. In some cases, GLOBAL LEDGER may also have a legal obligation to collect personal information from you.
If you have questions about or need further information concerning the legal basis on which GLOBAL LEDGER collects and uses your personal information, please contact GLOBAL LEDGER using the contact details provided under the “Contact Details” heading below and in the right-hand side column.
SHARING OF INFORMATION
We may disclose your information to our affiliates or subsidiaries, subcontractors, partners from a EU and non-EU countries, which may help us to better process it. We may disclose some of your data to the service providers, who perform functions on our behalf, such as website management, hosting, technical support, and marketing analytics, only if it is required by the project flow. We’ll make sure that they treat it as protective as we do. In all cases these services have implemented separate privacy policies and procedures, we encourage you to familiarise yourself with those policies. Should you not wish for any of these services to process your data, you need to stop using GLOBAL LEDGER websites and services.
GLOBAL LEDGER protects your personal information in the same way that it protects its other confidential information, such as storing it on secure servers that only select GLOBAL LEDGER personnel have access to, and by encrypting it to help prevent access by any unauthorized parties. GLOBAL LEDGER has put in place procedures to deal with any personal information breach and will notify you and any applicable regulator of a breach when legally required to do so.
Your data protection rights
If your personal information is protected by EU data protection law, you have the following data protection rights which you may be able to exercise by contacting GLOBAL LEDGER using the contact details provided under the “Contact Details” heading below and in the right-hand side column:
- If you wish to access, correct, update or request the deletion of your personal information, you can do so at any time by contacting GLOBAL LEDGER.
- In addition, you can object to the processing of your personal information, ask GLOBAL LEDGER to restrict the processing of your personal information or request portability of your personal information by contacting GLOBAL LEDGER.
- You have the right to opt out of marketing communications that GLOBAL LEDGER sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails GLOBAL LEDGER sends you or by using the relevant opt-out mechanism for non-email-based marketing.
- Similarly, if GLOBAL LEDGER has collected and processed your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing GLOBAL LEDGER conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about GLOBAL LEDGER’s collection and use of your personal information. For more information, please contact your local data protection authority:
Federal Data Protection and Information Commissioner (FDPIC)
CH – 3003 Berne Switzerland
T +41 (0)58 462 43 95
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, GLOBAL LEDGER may charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive. GLOBAL LEDGER tries to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is particularly complex or you have made a number of requests. In this case, GLOBAL LEDGER will notify you and keep you updated.
*If you wish to access or amend any personal data we hold about you, or to request that we delete any information about you may contact us. When technically feasible, GLOBAL LEDGER will transfer your personal data to you or transmit it directly to another controller. At any time, you may also object to the processing of your personal data for direct marketing purposes or ask us to restrict the processing of your personal data. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us. You also have a right to lodge a complaint with data protection authorities.
For more information about your rights and how to exercise them, we recommend visiting this resource from the European Commission, which is available in many languages.
Changes to the policy
Address: Schochenmühlestrasse, 4, Baar, 6340, Switzerland