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Privacy Notice

1. What is this Privacy Notice about?

Swissgrid Ltd (also «we», «us») ensures non-discriminatory, reliable and efficient operation of the transmission system and determines cross-border transfer capacities in coordination with the grid operators of neighbouring countries. We collect and process personal data that concerns you and also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

In this Privacy Notice, we describe what we do with your data when you use the Swissgrid website1 (hereinafter the «website»), communicate with us or otherwise interact with us. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, such as colleagues, etc., we assume that you are authorised to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that such third parties are informed about this Privacy Notice.

This Privacy Notice is aligned with the requirements of the currently applicable version of the Swiss Federal Act on Data Protection («FADP»).


2. Who controls the processing of your data?

Swissgrid Ltd, Bleichemattstrasse 31, 5001 Aarau («Swissgrid») is the controller for Swissgrid’s processing under this Privacy Notice.

Your primary point of contact for data protection concerns and to exercise your rights under Section 10 is as follows:

Data Protection Advisor in accordance with Art. 10 FADP:

Swissgrid Ltd
Data Protection Advisor
Bleichemattstrasse 31
P. O. Box
5001 Aarau
Switzerland
datenschutz@swissgrid.ch


3. What data do we process?

We process various categories of data about you. The main categories of data are the following:

Most personal data is provided to us by you on a voluntary basis, i.e., you are not obliged or required to disclose data to us. However, we must collect and process the personal data that is necessary for the performance of a contractual relationship and the fulfilment of the obligations associated with it or that are required by law. Otherwise, we will not be able to conclude or continue the contract in question. We may also need to process data in order to fulfil our tasks as a transmission system operator.

As far as it is not unlawful, we also collect data from public sources (for example, debt collection registers, land registers, commercial registers, the media or the internet) or receive data from public authorities and from other third parties (such as associations, contractual partners, etc.).


4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Section 11 and 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data to ensure the non-discriminatory, reliable and efficient operation of the transmission system. This also includes determining cross-border transfer capacities in coordination with the grid operators of neighbouring countries.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

We process data for the conclusion, administration and performance of contractual relationships.

We process data for marketing purposes and relationship management. This may happen in the form of newsletters and other regular contacts, through other channels for which we have contact information from you, but also as part of marketing campaigns, and may also include free services. You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes.

We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

We also process data for the purposes of our risk management and as part of our corporate governance, including business organisation and development.

We process your data in order to fulfil our duty of care, for example when contacting and providing information to emergency services (e.g. professional paramedics, hospitals, doctors, etc.) and emergency contact persons.

We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and trainings.


5. On what basis do we process your data?

Where we ask for your consent for certain processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future; see our contact details in Section 2. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of your withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations.

Where we receive sensitive personal data (for example, health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal bases, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defence of legal claims. In some cases, other legal bases may apply, which we will communicate to you separately as necessary.


6. With whom do we share your data?

In relation to our services, contracts, the website, our offerings, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

All these categories of recipients may involve third parties, so that your data may also be disclosed to them.


7. Is your personal data disclosed abroad?

As explained in Section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in Europe or, in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exemption. An exemption may apply, for example, in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected to the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.


8. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or for as long as storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete or anonymise your data once the storage or processing period has expired as part of our usual processes.


9. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorised or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorised disclosure or access.


10. What are your rights?

To help you control the processing of your personal data, you have the following rights in relation to our data processing:

If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example, by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 6, and additional information in Section 11.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example, to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know.


11. Do we use online tracking?

We use various techniques on our website that allow us and third parties engaged by us to recognise you during your use of our website, and possibly to track you across several visits. This section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and conduct analysis. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognised as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (known as a «cookie»).

We use these technologies on our website. You can set your browser to block certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

We currently use offers from the following service provider:

Google Analytics: The entity responsible for data protection for the service «Google Analytics» is Google Ireland Limited (Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). Google Analytics tracks how many visitors use our website. However, the behaviour of visitors to the website is not tracked and no conclusions are drawn about the identity of visitors.


12. What data do we process on our social network pages?

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example, when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyse your use of our online presences and combine this data with other data they have about you (for example, about your behaviour and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example, to personalise advertising) and to manage their platforms (for example, what content they show you) and, to that end, they act as separate controllers).

We process this data for the purposes set out in Section 4, in particular for communication and for marketing purposes. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (such as comments on an announcement), for example on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example, inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subject’s rights and how you can exercise them or obtain further information.

We currently use the following platforms:


13. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

 

Last updated: 1 September 2024

1With the exception of the Swissgrid Recruitment Portal, which is covered by a separate Privacy Notice.

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