This Privacy Notice (Privacy Notice) informs you (you) about how Blue Horizon Corporation Ltd, Tödistrasse 61, 8002 Zurich, Switzerland (Blue Horizon, our, we, or us), and, to the extent applicable, its subsidiaries, treats your personal data (Data) according to the Swiss Federal Act on Data Protection (DPA) and/or (as applicable) the EU General Data Protection Regulation (GDPR) when accessing our Website (www.bluehorizon.com) and as otherwise specified herein.
1. Controller and Contact Details
Controller is Blue Horizon Corporation Ltd, Tödistrasse 61, 8002 Zurich, Switzerland (or, in case of one of our subsidiaries using this Privacy Notice by reference, such subsidiary). You may contact us via the contact form on our website or by email (DPO@bluehorizon.com).
Our EU representative is Blue Horizon Growth sarl, 15, Boulevard F.W. Raiffeisen, L-2411 Luxembourg, Grand Duchy of Luxembourg.
2. What Kind of Data We Process
We process the following categories of Data:
3. Purpose and Legal Basis of Data Processing
We collect and process Data in the following situations for the indicated purpose(s) and, within the scope of applicability of the GDPR, based on the legal basis as indicated:
Under certain circumstances, we may also collect and process Data for the following purpose(s) and, within the scope of applicability of the GDPR, based on the legal basis as indicated:
4. How Personal Data Is Collected
We use different methods to collect Data. In most cases, you provide such Data to us in your direct interactions with us, e.g. by filling in forms on our Website, providing information through the client portal, corresponding with us via email, subscribing to our newsletter or in personal interactions with our staff, e.g. at conferences, fairs or other business events.
5. No Obligation to Provide Data
You are under no obligation to provide Blue Horizon with any Data. However, if you do not make the necessary Data available to us, we may not be able to interact with you or provide the corresponding services to you (e.g. communicate with you, send a newsletter to you, grant you access to the client portal, or enter into a contract with you).
6. How Long we Retain Data
We retain / store Data in general as follows:
After the above storage periods, your personal data will be deleted (or anonymized), if and to the extent (a) we are not legally obliged to retain such data (e.g. for accounting or document retention purposes) and (b) we do not have an overriding legitimate interest to retain such data for the assessment or exercise of, or for the defence against, legal claims.
7. Data Transfers
We may use service providers (including other members of the Blue Horizon group) for the hosting and operation of our Website, cloud and database services and further services, including the client portal. Such service providers may have access to your Data, strictly limited to the performance of their services for us. Otherwise, we do not transfer your Data to any third parties.
In general, your Data is processed in Switzerland, the European Union (EU) or the European Economic Area (EEA), or in other countries that are considered to guarantee an adequate level of data protection according to the DPA and the GDPR, such as e.g. the United Kingdom. If we transfer Data to (or grant access to Data from) a third country which does not meet this requirement, we ensure that appropriate safeguards are in place, such as the EU Standard Contractual Clauses, amended to comply with Swiss data protection law. For additional information regarding the safeguards or a copy thereof please contact us as specified in Section 1.
8. Data Security
We have put appropriate technical and organizational security policies and procedures in place to protect your Data from loss, misuse, alteration, or destruction. Such measures include:
We limit access to personal data in general. Those individuals who have access to the data are required to maintain the confidentiality of such information.
9. Right to Object
You have the right to object to the processing of your Data if (a) the processing takes place for direct marketing purposes; or (b) the processing is based on our legitimate interest (GDPR 6.1.f), by explaining the particular reasons and circumstances of your objection.
Regarding cookies through which certain personal data may be collected, you can block the setting of such cookies at any time by changing the settings in your browser accordingly or taking appropriate steps as set out in our Cookies Policy. You will then be notified whenever your browser attempts to create a cookie and you can decide whether you want to allow the cookie or not. Please note that a deactivation of cookies may result in a limited user experience and you may not be able to use every function of our Website or services or to access the services in an appropriate manner altogether. For further information, please refer to our Cookies Policy.
10. Your Rights
You have the right to request information about your Data we process. In particular, you have – or may have, depending on the circumstances – the right to:
In case you wish to exercise any of these rights, please contact us as specified in Section 1. Before responding to your request, we may ask for proof of identity. This helps us to ensure that your Data is not disclosed to any person who has no right to receive it.
11. Complaint / Regulatory Authority
If you believe that our processing of your Data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the competent data protection authority.
The data protection authority for Blue Horizon is the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Berne, Switzerland (https://www.edoeb.admin.ch).
Last Updated: 9 February 2022