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Data Protection

Data Protection Statement of DOLFINOS Ltd

Version: 10 December 2019

With this Data Protection Statement we, DOLFINOS Ltd, a company registered in the Commercial Register of the Canton of Aargau, Switzerland, under the company number CHE-408.777.608 with corporate seat in Baden and address at c/o Dr. Yahya Bajawa, Meierhofstrasse 15, 5400 Baden (hereinafter, we or us), describe how we collect and process personal data. 

The term "personal data" in this Data Protection Statement to shall mean any information that identifies, or could reasonably be used to identify any person. 

If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct. 

This Data Protection Statement is in line with the principles EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union (EU), it may be relevant for us. The Swiss data protection legislation (FADP) is heavily influenced by the law of the European Union. In addition, companies outside of the European Union or the European Economic Area (EEA) must comply with the GDPR in certain cases. 

  1. Controller / Data Protection Officer / Representative

 

You can notify us of any data protection related concerns using the following contact details: privacy@dolfinos.com. 

Our representative in the EU is: K&L Gates LLP, Markgrafenstrasse 42, 10117 Berlin, Germany; Phone: +49 (0)30 2200290; email: andreas.menge@klgates.com.

  1. Collection of Personal Data 

We only collect personal data that we obtain from you (including through your employees and representatives) in the context of our contractual relationships with you, or from your use of our websites. We do not collect personal data from third parties. 

  1. Purpose of Data Processing and Legal Grounds

We only process collected data in order to conclude and process contracts with our customers and business partners, in particular in connection with the selling of violin and viola chin and shoulder rests to our customers, as well as in order to comply with our domestic and foreign legal obligations. We may also process your personal data in your capacity our employee, as an employee of a customer or business partner. 

In addition, we may process your personal data for the following purposes, which are in our legitimate interests, such as: 

  • providing and developing our products, services and website; 
  • review and optimization of procedures regarding needs assessment for the purpose of direct customer approach; 
  • advertisement and marketing, provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings); 
  • market and opinion research; 
  • asserting legal claims and defense in legal disputes and official proceedings; 
  • ensuring our operation, including our IT, our websites and other appliances; 
  • acquisition and sale of business divisions or parts of companies and other corporate transactions and compliance with legal and regulatory obligations. 

 

We may further process your personal data for other identified purposes, provided we obtain your valid consent. You may withdraw your consent at any time.

 

 

 

  1. Cookies / Tracking and Other Techniques Regarding the Use of our Website 

We typically use "cookies" and similar techniques on our websites, which allow for an 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. 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 your visit of the website ("session cookies"), we may use cookies in order to save user configurations and other information for a certain time period (e.g., two years) ("permanent cookies"). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. If you block cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you.  

We 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 LLC is in the U.S., 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. The service provider does not receive directly (and does not retain) any personal data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and which are also tracked by the respective service provider and  may use this information for its own purposes (e.g. to controlling of advertisements). If you have registered with the service provider, the service provider will also know your identity. The service provider only provides us with data on the use of the respective website (but not any personal information of you). 

  1. Data Transfer and Transfer of Data Abroad 

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 our business partners, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us. In particular, the following categories of recipients may be concerned:  

  • our service providers (such as e.g. IT providers, payment providers);
  • dealers, suppliers and other business partners;
  • domestic and foreign authorities or courts;
  • acquirers or parties interested in the acquisition of our business;
  • other parties in possible or pending legal proceedings;

together Recipients

Certain Recipients may be within Switzerland, but they may also be located in any other country in the world. If we transfer data to a country without adequate legal data protection, we ensure an appropriate level of protection as legally required by way by using appropriate contracts (in particular the standard contract clauses of the European Commission) or we rely on the statutory exceptions of consent, performance of contracts, the establishment, exercise or enforcement of legal claims or overriding public interests. 

  1. Retention Periods for your Personal Data 

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, as well as beyond this duration in accordance with legal retention and documentation obligations (i.e. up to 10 years). Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible.

  1. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse.

  1. Your Rights 

In accordance with applicable law, you have the right to access, rectification and erasure of your personal data, in addition to the right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. In order to assert these rights, please contact us at the addresses provided in Section 1 above. 

In addition, you have  the right to enforce your rights in court or to lodge a complaint with the competent data protection authority, as provided by applicable law. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/auftrag.html).

  1. Amendments of this Data Protection Statement

We may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of a permanent contract with you, we will notify you by e-mail or other appropriate means in case of an amendment.