Interogo Holding AG Privacy Notice

Last updated: 22 June 2023

1. Introduction

This Privacy Notice outlines the processing of Personal Data on this website (the “Website”) and applies to our Website visitors, partners, suppliers and journalists. This Privacy Notice describes our policies and practices regarding our collection and use of your Personal Data and sets forth your right to privacy.

Personal Data will be processed in compliance with European data protection legislation (including the EU General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”)) and any other EU or national legislation which implements or supplements the foregoing as well as other Data Protection Laws such as the Swiss Federal Act on Data Protection (together the "Applicable Data Protection Laws")). “Personal data”, “Controller” and “Processor” have the meanings given in the Applicable Data Protection Laws.

2. Who is the Controller for the processing of your Personal Data?

This Website is operated by Interogo Holding AG a company incorporated under Swiss law whose principal place of business is at Bahnhofstrasse 15, CH – 8808 Pfäffikon SZ, Switzerland, hereafter referred to as “Interogo Holding”, “us” or “we” or “our”.

3. Which categories of Personal Data do we process?

We collect the following types of Personal Data when you visit and use the Website:

• Information you provide to us: We collect Personal Data when corresponding with us on this Website, when entering into business with us as partner or supplier. Such Personal Data includes:

• Information automatically collected by us: When you visit or interact with this Website, we automatically collect Personal Data about you and your visit. Such information includes:

We gather such information through the use of web technologies that are required for our website to function. More information on the use of cookies can be found in our Cookie Notice here. IP addresses are stored for 30 days and are never stored together with other Personal Data.

4. Why and under which lawful basis do we process your Personal Data?

We process your Personal Data when you visit the Website for the following purposes and based on one of the following lawful bases:

• To perform our contract with you or enter into such contract with you (art. 6(1)(b) GDPR and/or equivalent provisions in other Applicable Data Protection Laws):

• For our legitimate and/or overriding (business or legal) interest (art. 6(1)(f) GDPR and/or equivalent provisions in other Applicable Data Protection Laws):

(Please refer to our Cookie Notice for more information).

• For compliance with our legal obligations (art. 6(1)(c) GDPR and/or equivalent provisions in other Applicable Data Protection Laws): to comply with our legal obligations when required under applicable local laws within and outside of Switzerland. These can be specific regulations, court orders or governmental regulations. 

5. When and how we share your information with others

We may share your information with other third parties (such as persons employed by or working on behalf of our affiliates or data processors engaged by us) for the purposes described below. We will only disclose your Personal Data to those with a legitimate business need and after we have taken steps to ensure that your Personal Data is processed in a manner consistent with this Privacy Notice. 

These include:

• Our affiliates to provide you with the services: For the purpose of providing you with the services and due to the internal structure of Interogo Holding, we may disclose Personal Data that you provide via this Website to our affiliates (i.e. other companies within the Interogo Holding Group and the Inter IKEA Group) that are entrusted to process your information on our behalf in accordance with our instructions, this Privacy Notice and other appropriate measures for privacy and security.
• Our Service Providers: Your Personal Data may be disclosed to our service providers who perform services on our behalf. They provide services such as cloud hosting and website maintenance. Our service providers are subject to contractual obligations to safeguard your Personal Data and to only process the Personal Data as instructed.
• Other third parties when necessary pursuant to regulatory obligations: We may disclose your Personal Data to third parties to comply with court orders, other legal obligations, to enforce or apply our terms of use and other agreements and protect the rights, property, or safety of Interogo Holding or its affiliates or others. 

We do not sell Personal Data to anyone and only share it with third parties when this is necessary.

6. Transfers outside the European Economic Area, the United Kingdom and Switzerland

Your Personal Data will be processed by Interogo Holding AG which has its headquarters in Bahnhofstrasse 15, CH – 8808 Pfäffikon SZ, Switzerland. Switzerland has received an adequacy decision from the European Union under Article 45 of the GDPR which means that we may transfer Personal Data to Interogo Holding for processing in Switzerland. Countries in the European Economic Area (the "EEA"), which covers the EU member states as well as Iceland, Liechtenstein and Norway, as well as the United Kingdom (the "UK") are considered to provide an adequate level of data protection under Swiss data protection law. This means that we may also transfer Personal Data from Interogo Holding AG in Switzerland to EEA member states or to the UK for processing.

Personal Data may also be transferred to a country outside the EEA and the UK. Non-EEA/UK countries may not offer the same level of Personal Data protection as EEA/UK countries and Switzerland.

If your Personal Data is transferred outside the EEA, UK and Switzerland, we will put suitable safeguards in place to ensure that such transfers are carried out in compliance with the Applicable Data Protection Laws. These include, for instance, relying on adequacy decisions or standard contractual clauses issued by the European Commission and acknowledged for use by the Swiss Federal Data Protection and Information Commissioner (the "FDPIC")  together with binding and enforceable commitments by the recipient.

Personal Data can be transferred to Sweden and Belgium.

You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below. 

7. Data subject rights

Subject to applicable laws, you are entitled to a number of rights over the processing of your Personal Data. You may exercise these rights at any point by contacting us via [email protected]. We will consider all such requests and, in accordance with the Applicable Data Protection Laws, will provide our response within a reasonable period, or within the period prescribed by law. If we do not comply with your request within such time frame, we will explain why. We may request you to provide us with information necessary to confirm your identity before responding to any request you make. 

You have the following rights:

• The right to access: subject to exceptions, you have the right to request access to the Personal Data we hold about you;
• The right to rectification: if the Personal Data we hold about you is inaccurate you are entitled to have it updated or rectified;
• The right to deletion: subject to exceptions, you can ask us to delete your Personal Data.
• The right to object: under certain circumstances, you have the right to ask us to stop processing your Personal Data. For example you may object to processing for direct marketing activities (for example, by clicking on the unsubscribe link in our emails) and where we are relying on our or a third party’s legitimate interests to process the Personal Data (unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data);
• The right to withdraw consent: where we rely on your consent to process Personal Data, you have the right to withdraw consent at any time. Such withdrawal will not impact the lawfulness of any data processing activities prior withdrawal;
• The right to restriction of processing: under certain circumstances you have the right to restrict the processing of your Personal Data such as if you believe (i) the Personal Data we have about you is not accurate; (ii) the Personal Data is not being processed lawfully, but instead of deleting the Personal Data, you would prefer us to restrict processing; or (iii) we no longer need your Personal Data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims;
• The right to data portability: under certain circumstances you have the right to obtain Personal Data (in a structured, commonly used and machine-readable format) you've provided us with and to reuse it elsewhere or to ask us to transfer this to a third party of your choice; and
• The right to lodge a complaint with a supervisory authority: you also have the right to file a complaint to the data protection authority in the country where you usually live or where the alleged infringement of Applicable Data Protection Laws has taken place. The FDPIC is the competent Swiss data protection authority. You can find more information here.

Please note that if you ask us not to contact you by email at a certain email address, we will retain a copy of that email address on our “master do not send” list in order to comply with your no-contact request.

8. How do we protect Personal Data?

We have implemented adequate technical and organizational measures to safeguard the Personal Data we process. We update and test our security technology on an ongoing basis. In addition, we restrict access to your Personal Data to employees on a need-to-know basis and train all staff about the importance of confidentiality and maintaining the privacy and security of your information.

9. How long do we keep and store your Personal Data?

We will not retain your Personal Data longer than necessary in relation to the purposes for which the data are processed. In principle, we will retain your data for 90 days after which it will be archived and subsequently deleted after two years after the end of your relationship with us, unless we are required by statutory obligations or have an overriding interest to retain your Personal Data for a longer period of time. Such an extended period of time applies to correspondence related to media matters. We may also retain your Personal Data for a longer period in the event of complaints or disputes to the extent that this is necessary to protect our interests and/or the interests.

10. Changes to this Privacy Notice

We may change this Privacy Notice from time to time by posting the updated version of the Notice on our Website. We will give you reasonable notice on our Website of any material change. The “effective date” at the top of this Notice indicates when such changes will take effect. We encourage you to visit our Website frequently to stay informed about how we use your Personal Data.

11. Questions, concerns or complaints

To ask questions or to comment about our Privacy Notice and our privacy practices, you may contact [email protected]. You may also at any time write to our Personal Data Representative at: Interogo Holding, The Personal Data Representative, Bahnhofstrasse 15, CH – 8808 Pfäffikon SZ, Switzerland.

12. Questions of journalists

If you are a journalist or otherwise have a media related question, please contact the Media Team of Interogo Holding by emailing [email protected].

13. Cookie Notice

Please refer to our Cookie Notice available here for more information on our use of cookies with this Website.