As of January 2022
This Privacy Notice describes how and for what purpose USM collects, processes and uses personal data.
Personal data means any information that can be linked to a particular person. Processing means any handling of personal data, such as collection, storage, management, alteration, usage, sharing, disclosure etc.
The Privacy Notice applies to all persons whose personal data we process (you), regardless of how you contact us, e.g. whether in a branch, over the telephone, in an online shop, on a website, in an app, via a social network, at an event etc.
The Privacy Notice is applicable to the processing of personal data already collected as well as to the processing of personal data collected in future.
USM, we (or us) primarily refers to USM U. Schärer Söhne AG, Thunstrasse 55, 3110 Münsingen, Switzerland. If the respective service is rendered by another USM Group company, the respective national company as specified under Section 1.1 shall be responsible.
We have based this Privacy Notice on the European General Data Protection Regulation (GDPR), as the GDPR has established itself globally as a benchmark for strong data protection. Whether and to what the GDPR is applicable depends, however, upon the particular case concerned. For Swiss customers, for example, the Swiss Federal Data Protection Act (FDPA) may also be applicable or be exclusively applicable.
1. Who we are
The controller for your personal data is:
1.1. With regard to the website and in respect of marketing and advertising:
- USM U. Schärer Söhne AG, Münsingen, Thunstrasse 55, 3110 Münsingen, Switzerland, telephone +41 31 720 72 72, [email protected]
1.2. In all other respects, also in the case of online sales: the respective national company
- USM U. Schärer Söhne AG, Münsingen, Thunstrasse 55, 3110 Münsingen, Switzerland, telephone +41 31 720 72 72, [email protected]
- USM U. Schärer Söhne GmbH, Siemensstrasse 4 A, 77815 Bühl, Germany, telephone +49 7223 80940, [email protected]
USM U. Schärer Söhne GmbH, Bühl, Germany has appointed a data protection officer, whom you can contact as follows:
USM U. Schärer Söhne GmbH, Data Protection Officer, Siemensstraße 4 A, 77815 Bühl, email: [email protected]
- USM U. Schaerer Sons ltd., Ground Floor, 49-51 Central St., EC1V 8AB London, United Kingdom, telephone +44 207 183 3470, [email protected]
- USM U. Schärer Fils SA, Showroom 23, Rue de Bourgogne, 75007 Paris, France, telephone +33 1 53 59 30 37; [email protected]
- USM U. SCHAERER FIGLI S.r.l., Via Tortona 25, 20144 Milan (MI), Italy
- USM U. SCHAERER SONS, S.L.U., Calle Roc Boronat, 147, 10a planta, 08018 Barcelona, Spain
- USM U. Schaerer Sons Inc., 28-30 Green Street, New York, NY 10013, USA, telephone +1 212 371 1230, [email protected]
- USM U. Schaerer Sons K.K., 2-1-1 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan, telephone +81 3 5220 2221, [email protected]
2. What personal data we process
We process various categories of personal data. You can find the key categories below for your information. However, we may also process further personal data in individual cases.
- Master data: This encompasses, in particular, your name and your contact details (e.g. address, telephone number or email address), information about your relationship with us, possibly information about your employer, the title of your occupation, industry or business, academic degree, year of birth, civil status, and comparable basic information;
- Contract data: This encompasses all personal data arising in connection with the conclusion and/or processing of the contract, i.e. information relating to the initiation and conclusion of contracts, e.g. the date, application process, information about the type and duration of the contract concerned as well as contact details, delivery addresses, deliveries that have taken place or that have failed, and information about payment instruments. This may also include information relating to acquired claims and demands as well as information relating to customer satisfaction;
- Communication data: This encompasses, in particular, name and contact details such as address, email address and telephone number, content of emails and written correspondence, communication via social media, answers to customer and satisfaction surveys, including information about the type, time and place of the communication, as well as marginal data relating to the communication;
- Behaviour and transaction data: Behaviour and transaction data include the following information, for example, insofar as this information is available to us in personalised form: your purchasing behaviour in our online shop and elsewhere on our website (shopping basket ordered and shopping basket cancelled, watch lists, viewed items, search terms and search results, submitted ratings and comments etc.), information about the visiting of events or about participation in competitions, prize draws and similar events, information about the installation and use of mobile apps (e.g. apps for electronic locking systems), information about your use of electronic messages (e.g. whether and when you opened an email or clicked on a link, particularly with regard to the sending of newsletters);
- Preference data: In order to optimally tailor our offerings and services to you, we also process data relating to your interests and preferences. To this end, we may link behaviour and transaction data (e.g. in the case of interaction with newsletters, or in connection with purchases at sales partners) with other data and evaluate these data on a personalised and non-personalised basis. This enables us to draw conclusions about characteristics, preferences and likely behaviour, e.g. your likes and affinities relating to certain products. We can thus form segments, i.e. groups of persons, that show similarities regarding certain characteristics. Preference data can be used on a personalised basis (e.g. to show you ads you are interested in), but also on a non-personalised basis (e.g. for market research or product development). In certain circumstances, these processes are classified as so-called profiling (see Section 7 in this respect);
- Technical data in connection with use of the website, including the product configurator, or one of our apps. This includes, in particular, the IP address, possibly a device ID, identification numbers allotted to your device by cookies or similar information (pixel tags), information about your device and its configuration, information about the browser used by you to access the website, information about your movements and actions on our website, information about your Internet provider, your approximate location and the time of use, as well as system records relating to access and other processes (log data). If one of our apps is installed, we also process data in connection with its installation (in particular the date and time of installation, the manufacturer of the app, the operating system, the app version) as well as possibly technical data on how products controlled by the app, e.g. electronic locking systems, are used.
3. How we collect personal data
We receive the aforementioned data when you contact us, e.g. when you contact our employees with an enquiry, order something in our online shop or otherwise establish a business relationship with us, when you register to receive newsletters, information and/or brochures and other marketing material, when you download and install one of our apps and register to use it, or when you participate in a competition or prize draw, a meeting, a seminar or any other event.
In certain circumstances, we also receive your personal data from third parties or in collaboration with third parties:
- In particular, such third parties may be sales partners (which may possibly also be called "trading partners" on the USM website) that have been diligently selected by us and support us in the distribution of our products. Our sales partners' contact details can be viewed on the following website: https://www.usm.com/en-gb/home/how-to-buy/sales-partners/
- Third parties may also include advertising partners. For example, we collect together with our advertising partners data from persons interested in our products on social media. In particular, we use Facebook Lead Ads to collect personal data about you via ads on Facebook. You can find further information in the clause about social media (Section 13.2).
In certain circumstances, we also access publicly accessible databases. If necessary, we use search engines on the web, for example, to contact you or update your details.
4. What we use your personal data for
We use your personal data as follows:
- For communication purposes, i.e. in order to establish and maintain contact with you. This encompasses answering enquiries, contacting you if questions arise, customer service and customer care, authentication, e.g. when our online offerings are used, as well as quality assurance and training;
- For processing the contract. This encompasses all activities necessary or appropriate for entering into, carrying out and enforcing a contract, e.g. the processing of orders in our online shop, the conclusion of a contract and registration to use one of our apps, the management of contractual relations, including payment processing, as well as possibly payment collection;
- For customer care and marketing purposes in order to inform you of the goods and services offered, special offers, competitions and prize draws or other special promotions corresponding specifically to your personal interests and likes, e.g. by means of newsletters, notifications, updates, invitations to events, personalised advertising etc. (for further information about this see Sections 7 and 13). This also includes the carrying out of competitions, prize draws and similar events in which you can voluntarily participate. If you make available to us pictorial or other marketing material, e.g. as a photographer, we shall, with your consent, publish certain personal data, e.g. on our website, or use personal data in the context of the newsletter;
- For market research and product development. In order to constantly improve our offerings and make them more appealing to you, we carry out customer surveys, polls and studies, for example. This serves to further develop our offerings, optimise and improve the user-friendliness of websites and apps as well as to observe the market, e.g. in order to understand and respond to current developments and trends. For this purpose, we may also carry out statistical evaluations, e.g. in order to evaluate on a non-personalised basis customers' interactions with us or customers' behaviour on our website (for further information about this see Section 13.1);
- For compliance with legal requirements: This includes, for example, taking receipt of and processing complaints and other reports, complying with orders issued by a court or a public authority, measures for detecting and clearing up improper use, as well as general measures we are obliged to take under applicable law, self-regulation or industry standards;
- For ensuring IT security and prevention: We process personal data for security purposes, for ensuring IT security, for preventing theft, fraud and improper use and for evidence purposes. This encompasses, for example, evaluating system records of use of our systems (log data), preventing, defending against and investigating cyber attacks and malware attacks, analysing and testing our networks and IT infrastructures, system tests and error checking as well as monitoring access to electronic systems (e.g. log-ins for user accounts);
- For the protection of rights: In certain circumstances, we also process personal data in order to enforce claims judicially, prior to court proceedings or extrajudicially and before public authorities in Switzerland and abroad or to defend ourselves against claims;
- For administration and support within the Group: In order to shape our internal processes efficiently, we process personal data for the administration of IT, for accounting, for archiving data or for education and training, where necessary.
5. The legal bases for the data processing
We process your personal data on the following legal bases insofar as such basis is required according to applicable data protection law:
- for the performance of a contract, including steps to be taken prior to entering into a contract, e.g. for checking a contract request, and for enabling you to use our services;
- on the basis of your consent expressly given;
- for asserting or defending legal claims or civil cases;
- for compliance with statutory or regulatory provisions;
- if we have a legitimate interest in the data processing, which shall be determined in the particular case concerned.
6. With whom we share personal data
We may share the personal data we receive from you or from third-party sources with other USM Group companies. Sharing may serve to facilitate administration within the Group or support the Group companies concerned and their own processing purposes, e.g. the personalisation of marketing activities, the development and improvement of products and services, the conducting of credit checks or endeavours to prevent theft, fraud and improper use.
If necessary, we transfer your personal data to other companies, such as:
- sales partners (see Section 3 above) that sell our products and support us in the dispatch and logistics of our deliveries. This applies in particular to sales partners that have integrated our configurator into their website and can therefore help us to answer enquiries and deliver the products purchased in our online shop and to send you information about USM products and offerings relating to USM products until such time as you declare an objection. By sharing your contact details with your nearest sales partner, we enable you to have a point of contact in your immediate vicinity for offering you the best possible customer service;
- cooperation partners that support us in the operation and maintenance of certain products, e.g. the company Burg F.W. Lüling KG (currently Hegestrasse 6, D-58300 Wetter), which is responsible for the operation and maintenance of the app for electronic locking systems;
- third parties involved in order processing on our behalf, in particular for processing credit card payments, for transport or as external service providers for data processing;
- third parties (such as publishers or platforms) involved in carrying out our competitions or prize draws;
- advertising partners such as, in particular, Facebook, Instagram and Google. In this connection, we also refer to our Cookie Notice relating to data collection by third-party providers whose tools we have integrated into our websites and apps (see Section 13 below);
- third parties involved in organising events or seminars;
- IT service providers as well as providers of cloud solutions for all areas;
- our auditors.
Where the aforementioned companies process personal data as processors, they are obliged to process personal data exclusively in accordance with our instructions and to take suitable data security measures. We have, in this respect, concluded the corresponding data processing agreements. Certain companies are also responsible jointly with us or independently (e.g. debt collection agencies). By selecting the companies and entering into suitable contractual agreements, we ensure that data protection is safeguarded throughout the entire processing of your personal data.
Moreover, we may be compelled to disclose personal data under statutory provisions or legal proceedings, e.g. due to a court order or a request from a law enforcement agency, or if we are of the opinion that sharing is necessary or appropriate for the protection of our rights, for example in preventing harm or financial loss, in connection with an investigation of suspected or actual fraudulent or other illegal activity, and in the event that we sell or transfer all or a portion of our assets (e.g. due to restructuring, dissolution, or liquidation).
7. How we carry out profiling
«Profiling» means any automated processing of personal data for analysing personal aspects or making predictions, e.g. analysing personal interests, preferences, affinities and habits or predicting likely behaviour. In particular, preference data (see Section 2) may be derived by means of profiling.
For example, profiling may be carried out in the event of the automated processing
- of master, contract, behaviour and transaction data when purchases are made at our showrooms, at sales partners and in our online shop;
- of behaviour and transaction data as well as technical data in connection with our websites and apps;
- of information in connection with the visiting of events and participation in competitions, prize draws and similar events;
- of communication data, e.g. your response to advertising and other messages.
Profiling helps us, for example, to continually improve our offerings, present our content and offerings to you in line with your needs and show you ads and offerings probably relevant to you, where possible, in order to better support you with our customer service and, in certain circumstances, to decide on the basis of a credit check which payment options to offer you.
8. When your personal data are transferred abroad
We may possibly transfer your personal data to foreign recipients (if necessary, to recipients globally, i.e. also outside of Switzerland, the European Union (EU) and the European Economic Area (EEA)). The countries concerned may possibly not have laws that protect your personal data to the same extent as those of Switzerland and/or the EU/EEA.
If we transfer your personal data to a country that does not have an adequate level of data protection, we are obliged to ensure that your personal data are adequately protected, e.g. by concluding data transfer agreements with the foreign recipients beforehand. Normally, we agree in this way to the application of EU standard contractual clauses, which are accessible here. Please contact us at the aforementioned addresses if you wish for more information about this or for a copy of our data transfer agreements or a copy of the list of countries to which we transfer personal data.
Moreover, we reserve the right to transfer personal data abroad with your express consent or on the basis of further circumstances constituting authorisation under applicable data protection law.
9. For how long we retain your personal data
We store your data in personalised form as long as this is necessary for the specific purpose for which we collected the data and as long as we have a legitimate interest in retaining your personal data (e.g. for enforcing or defending against legal claims, for archiving purposes or the benefit of IT security). Additionally, we store your personal data as long as these data are subject to a statutory retention duty. In respect of cookies, further information about the storage period criteria can be found in Section 13.1, and precise information about the storage period can be found in our cookie table in section 13.4.
10. How we protect your personal data
We take appropriate security measures of a technical and organisational nature in order to protect your personal data against unauthorised or unlawful access and processing as well as to counter the risk of loss, unintended alteration or unwanted destruction of data. We continually improve our security measures in line with technological development.
11. Your rights
You have the following rights:
- You have the right to obtain information on the personal data we hold about you and how we process these data.
- In certain circumstances, you have the right to receive certain personal data in a structured, commonly used and machine-readable format.
- You have the right to rectification of incomplete or inaccurate personal data.
- You have the right to obtain the erasure or destruction or anonymisation of your personal data.
- You have the right to obtain restriction of the processing of your personal data.
- Where processing is based on consent given by you, you have the right to withdraw your consent at any time with effect for the future. Please note that, even after you have withdrawn your consent, we are entitled to continue processing your personal data to the extent permissible by law.
To exercise your rights, you can contact us at the addresses stated above (Section 1). Please note that your rights may possibly be limited or precluded in individual cases, for example where there are doubts about your identity, or where this is necessary for protecting other persons, for safeguarding legitimate interests or for complying with statutory obligations.
Additionally, you have the right to lodge with a relevant supervisory authority a complaint about the way in which your personal data are processed. As a rule, this is the supervisory authority of the country where you live.
- The relevant supervisory authority in Switzerland is the Swiss Federal Data Protection and Information Commissioner (FDPIC).
- You can find the contact addresses of the supervisory authorities of the EU/EEA Member States here.
12. Changes to this Privacy Notice
This Privacy Notice may be updated over time, especially if we change our data processing activities, or if new legal provisions become applicable. In the event of significant changes, we actively communicate these to persons whose contact details are registered with us, if this is possible without disproportionate effort and expense. In general, the respective version of the Privacy Notice in effect at the time when the data processing activity concerned commences shall be applicable.
13. Information about cookies, social media and the sending of newsletters and other marketing emails
13.1.1. What is this about?
This Cookie Notice describes how and for what purpose we collect, process and use personal data and other data – particularly in connection with cookies and similar technologies – when our website and apps are used. Where we generically refer to websites below for the sake of simplicity, this also invariably includes apps.
13.1.2. What are log data?
Every time our website is used, certain data automatically arise for technical reasons and are temporarily stored in log files, so-called log data. These include the following technical data for example:
- IP address of the requesting terminal device and information about the operating system of your terminal device (tablet, PC, smartphone etc.),
- information about the browser used, your Internet service provider and the referring URL,
- date and time of access and content accessed when visiting the website.
These data are processed for the purpose of enabling the use of our website (establishment of a connection) and ensuring its functionality, safeguarding system security and stability and enabling the optimisation of our Internet offering, as well as for statistical purposes.
In the event of attacks on the IT infrastructure or other potentially unlawful use or improper use of the website, the IP address together with the other log data and further data available to us, if applicable, will also be evaluated for investigation and defence purposes and, if necessary, be used in criminal proceedings for the identification of persons concerned and for action taken under civil and criminal law against these persons.
13.1.3. What are cookies and similar technologies?
Cookies are data files that your browser automatically stores on your terminal device when you visit our website. Cookies contain a unique identification number (ID) that enables us to distinguish individual visitors from others, but normally without identifying them. Depending upon their intended use, cookies contain further information, e.g. about sites accessed and the duration of a visit to a site. We use both session cookies, which are deleted when the browser is closed, and permanent cookies, which remain stored for a certain period after the browser is closed (normally between a few days and two years) and serve to recognise visitors on a subsequent visit.
We may also use similar technologies such as pixel tags, fingerprints and other technologies for storing data in the browser. Pixel tags are small, normally invisible images or a programme code that are loaded from a server and thereby provide the server operator with specific information, such as whether and when a website was visited. Fingerprints are information that relates to the configuration of your terminal device or your browser and is collected during your website visit and makes your terminal device distinguishable from other devices. Most browsers also support, for storing data in the browser, further technologies that are similar to cookies and that we may also use (e.g. «web storage»).
13.1.4. How can cookies and similar technologies be deactivated?
In some cases, you have the option, when accessing our website, of activating or deactivating certain categories of cookies via a button displayed in the browser. Furthermore, you can configure the settings in your browser to block certain cookies or similar technologies or delete existing cookies and other data stored in the browser. You can also expand your browser with software (so-called “plug-ins”) to block tracking by specific third parties. You can find further information about this in your browser's help pages (normally under the key words "data protection"). Please note that our website may no longer function to its full extent if you block cookies and similar technologies.
13.1.5. What types of cookies and similar technologies do we use?
We use the following types of cookies and similar technologies:
- Necessary cookies help us to make websites usable by enabling basic features such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Preference cookies enable information affecting the appearance or content of the website to be remembered, such as your preferred language or the region where you are located.
- Statistical cookies help us, by collecting and reporting information anonymously, to understand how you interact with websites. This enables us to understand which sites are most popular. These cookies serve to simplify and speed up website visits and generally improve user-friendliness.
- Marketing cookies help us and our advertising partners to approach you on our website and on third-party websites with ads for products or services that may be of interest to you, or to display our ads to you whilst you continue to use the Internet after having visited our website.
A list of our cookies currently used is accessible in our cookie table under point 13.4.
The cookies and/or similar technologies that we use may originate from us or from third-party companies, e.g. when we use features provided by third parties. Such third-party providers may also be located outside of Switzerland and the EU/EEA insofar as the protection of your personal data is adequately safeguarded.
For example, we use analysis services to evaluate your use of our website in order to optimise and personalise it. Additionally, cookies and similar technologies from third-party providers enable these providers to approach you with individualised ads on our website or on other websites as well as in social networks that also collaborate with such third party, and to measure how effective ads are (e.g. whether you arrived at our website via an ad, and what actions you then carry out on our website).
Two of the key third-party providers are Google and Facebook. Further information about these can be found below. Other third-party providers normally process personal data and other data in a similar way.
We have configured the service in such a way that the IP addresses of the website visitors are truncated by Google within Europe prior to being forwarded to the USA, and therefore cannot be traced back. Google supplies us with reports and can be regarded as our processor in this respect. However, Google also processes certain data for its own purposes. In certain circumstances, Google may be able to draw conclusions about the identity of the website visitors on the basis of the data collected and thus create profiles with the aid of personal data and link the acquired data to any existing Google accounts of these persons. Information about Google Analytics' data protection can be found here; if you have a Google account yourself, you can find further information here.
Facebook Custom Audiences
Furthermore, our website may use the so-called «Facebook Pixel» and similar technologies from Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). We use these technologies to display our placed Facebook ads exclusively to users who are on Facebook and on partner sites cooperating with Facebook (so-called “audience network”) and have shown an interest in us or whose characteristics correspond to those that we communicate to Facebook for this purpose (e.g. an interest in specific topics or products that becomes evident from the websites visited; "custom audiences"). We may also use these technologies to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been forwarded to our website after having clicked on a Facebook ad (so-called "conversion measurement"). Further information about this can be found here.
We are responsible jointly with Facebook for the exchange of data that Facebook collects or receives via the pixel or comparable features, for displaying advertising information corresponding to the users' interests, for improving the delivery of ads, and for personalising features and content (but not for further processing). We have, therefore, concluded a corresponding additional agreement with Facebook. Users may, accordingly, submit information requests and other enquiries from data subjects in connection with this joint responsibility directly to Facebook.
13.2. Data collection via social media: Facebook Lead Ads
We use Facebook Lead Ads to collect contact details (first name and surname, email address) from persons interested in our products. Facebook users can enter their contact data in the lead ads via a contact form. We process the contact details only if the users have consented to our using the contact details for sending newsletters and for marketing measures. In this respect, the sending of newsletters involves further data processing activities (see Section 13.3).
We are responsible jointly with Facebook for the collection of data via Facebook Lead Ads. We have, therefore, concluded a corresponding additional agreement with Facebook. Users may, accordingly, submit information requests and other enquiries from data subjects in connection with this joint responsibility directly to Facebook.
Further information about how Facebook processes personal data, including Facebook's legal basis for this, and the data subjects' options for exercising their rights in relation to Facebook can be viewed in Facebook’s data policy.
13.3. Sending of newsletters
If you give us your consent, we use your name and your email address to email you newsletters, notifications, updates or invitations for events, as well as further information. If you receive ads from us and no longer wish to receive these, you can unsubscribe at any time via the link in the emails concerned.
We evaluate your user behaviour when sending the newsletter and associate your user behaviour with your email address/your user profile within our database. In particular, the newsletter sent by us provides us with receipt and read confirmations as well as information about the links you have clicked on in our newsletter. By creating a personal user profile, we wish to target our advertising to your interests so that you can receive information tailored to your personal interests, and to optimise our offerings on our website for you.
If you have subscribed to our newsletter and have consented to data processing by third-party providers, we may also use your contact details to approach you on third-party providers' platforms with advertising. In this respect, we collaborate with established providers customary on the market and transfer your data to these in encrypted form. The providers carry out an overlap analysis with the data encrypted at the providers. If this analysis reveals that you are also registered with the respective provider and have consented to their data processing, advertising from us may possibly be displayed to you. We are responsible jointly with the provider according to European data protection law and have concluded the corresponding contracts.
Specifically, we use the following tools:
- We use «Google Customer Match» to approach you in the Google ad ecosystem. More information about customer match by Google can be found here. How Google otherwise collects and processes data can be viewed here.
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