PRIVACY POLICY
The Sustainable Infrastructure Foundation (hereinafter, “SIF") is committed to safeguarding the privacy of the users of SIF's public website (the “Website") and SOURCE. This Privacy Policy describes SIF's practices regarding its processing of Personal Data and sets forth the Data Subject privacy rights in the context of the use of SOURCE and access of the Website, as well as SIF's dedicated pages on social media.
This Privacy Policy is compliant with the Swiss Federal Act on Data Protection of 25 September 2020 (FADP), as well as the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation – GDPR).
DEFINITIONS
“Controller" means SIF, the foundation responsible for the use of and processing of the User's Personal Data.“Processor" means a natural or legal person which processes personal data on behalf of the controller.
“Personal Data or Information" means all information relating to an identified or identifiable person. Personal Data does not include publicly available information that has not been combined with non-public Personal Data, nor does it include information that has been anonymized.
“Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
DATA CONTROLLER
The entity responsible for the processing of Personal Data as described in this Privacy Policy is the Sustainable Infrastructure Foundation (“SIF"), with offices at 13, ch. des Serves, 1228, Geneva, Switzerland.
In the event where the user provides SIF with Personal Data of another person (such as an employee or colleague), the user represents that he or she is authorized to do so, and that the data is accurate.
The user also represents that the he or she has implemented privacy and security practices consistent with this Privacy Policy. If the user submits Personal Data of a third party such as a co-worker, the user has informed such third party about the processing and their rights according to the applicable data protection regulation.
DATA PROTECTION OFFICER
SIF has appointed an external data protection officer for any questions or concerns about SIF's personal data policies or practices. SIF's data protection officer's name and contact information are as follows:
Mr. Dan FUOCHI
+41 (22) 575 87 70
legal@sif-source.org
INFORMATION COLLECTED BY SIF
The use of SOURCE requires the user to provide SIF with certain data, as part of the user's contractual obligations. The processing of some data is also inevitable when the user accesses SIF's Website. Most of the data SIF collects is directly provided by the user. SIF does not knowingly attempt to solicit or receive information from children. SIF does not collect any sensitive data such as data relating to the user's health, religion, ethnic background, philosophical beliefs or political views.
Personal information
When concluding or performing contracts with the user or with the user involvement, SIF collects information about the user including the user's name, personal and/or work address, phone number, job title, company name and address.
If the user participates in software training provided by SIF, the user may sign up directly through SIF in which case the user's name and contact information will be directly collected from the user. The User may, alternatively, sign up for a training – or be signed up for training – by or through a third party such as one of SIF's training partners, or the user's own employer.
SIF may also use independent contractors to conduct the training and third parties to provide the training venue. The user's Personal Information may also be shared with SIF's training partners, trainers, and/or the venue hosting the event.
SIF's training partners, trainers, and training venue hosts have agreed not to share the user's Information with others and not to use the user's personal information other than to provide the user with the requested services.
Registration data
When the user registers (directly with SIF) to access and use SOURCE, a user account is created and login credentials, such as username and password, are provided to the user.
Communication data
If the user corresponds with SIF by email, the postal service, or other form of communication, SIF may retain such correspondence and the information contained in it and use it to respond to the user's inquiry; to notify the user of SIF's activities or services; or to keep a record of the user's complaint, accommodation request, and the like.
Website or application usage
SIF may also collect technical information related to the use of the Website or SOURCE, including visitor's IP address, operating system, browser software, date, time and visited pages, including through the use of cookies.
SIF collects certain information related to the use of its Website automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where the user's computer or device is accessing the internet, browser type, operating system and other usage information about the use of the Website, including a history of the viewed pages. SIF uses this information to help design the Website to better suit its users' needs. The User's IP address may also be used to help diagnose problems with the server and to administer the Website, analyze trends, and gather broad demographic information that assists SIF in identifying visitor preferences. SIF's website also uses cookies.
Personal Data obtained from third parties
From time to time, SIF receives personal data about individuals from third parties. This may happen if the user's employer signs up the user for training.
COOKIES
The Website and SOURCE use cookies, which are text files placed on the user's computer.
The Website uses cookies to provide enhanced functionality and aggregate traffic data. These cookies are delivered in a first-party context. The Website also captures limited information (user-agent, HTTP referrer, last URL requested by the user, client- side and server-side clickstream) about visits to the Website; SIF may use this information to analyze general traffic patterns and to perform routine system maintenance
SOURCE only uses required cookies to enable the platform functionality.
The user has many choices with regards to the management of cookies on the computer. All major browsers allow the user to block or delete cookies from the user's system. To learn more about the ability to manage cookies, the user may consult the privacy features in the browser.
PURPOSES AND LEGAL BASIS FOR PROCESSING THE USER'S PERSONAL DATA
SIF primarily processes the user's data for the conclusion, administration and performance of the contractual relationship relating to the services the user has requested or purchased from SIF.
SIF has a legitimate interest in understanding how users and visitors use its Website or SOURCE. This allows SIF to provide more relevant services, communicating value to stakeholders, and providing appropriate staffing to meet users' needs.
When the user's consent has been requested to process the user's Personal Data for specific purposes (such as sending newsletters or for marketing management), SIF will inform the user separately about the relevant processing purposes. The Personal Data will be processed within the scope of and based on this consent. The User may withdraw his or her consent at any time. Such withdrawal shall not affect the lawfulness of processing based on consent prior to its withdrawal.
SIF may use the collected data for the following additional purposes, which are in the legitimate interests of SIF or other third parties:
- General corporate operations and due diligence;
- Provision, development, and enhancement of SIF's services, such as the optimization of the Website and SOURCE and its operating environment;
- Communication with the user;
- Marketing intelligence and relationship management including, but not limited to, information to the user relating to the use of the Website and/or SOURCE;
- Statistical analysis;
- Security, access control, fraud detection and prevention of abuses;
- Legal compliance, including compliance with the terms and conditions of the applicable Terms of Use;
- Dispute resolution.
Personal Data collected by SIF is processed only for the purposes set out in this Privacy Policy. It is not used or disclosed for any other purpose without the User's consent or as authorized or required by law.
SHARING OF PERSONAL INFORMATION WITH OTHERS
SIF may share the user's Personal Data with its contractual partners and third-party service providers only for the purposes stated in this Policy. The user's Personal Data is treated by SIF, its contractual partners and third-party service providers as strictly confidential and is neither passed nor sold to other third parties.
SIF works with third-party service providers, such as the United Nations International Computing Centre, who process the user's data on SIF's behalf or as joint controllers with SIF, with data centers located in Europe. The user's Personal Data may therefore be processed both in Switzerland and Europe. If a recipient is located in a country without adequate statutory data protection, SIF ensures that an adequate level of protection is guaranteed by using contractual safeguards.
SIF may disclose the user's information to governmental agencies or entities, regulatory authorities, or other persons as it deems necessary to satisfy any applicable law, regulations, court order or governmental request, or similar processes as either required or permitted by applicable law.
SECURITY OF INFORMATION
SIF has implemented adequate technical and organizational measures to protect the user's Personal Data against unauthorized access and processing, misuse, alteration, falsification, loss or destruction.
SIF restricts access to the user's Personal Data to those employees or consultants who need to know that information and are bound by legal or contractual confidentiality obligations.
DATA SUBJECT'S RIGHTS
The user has the following rights in relationship to SIF's processing of his or her personal data, subject to conditions, exceptions or restrictions under applicable data protection law:
The user may request information as to whether and what data SIF is processing from him or her.
The user may request his or her personal data to be corrected if it's inaccurate.
The user may request erasure of his or her personal data.
The user may request SIF to provide him or her with his or her personal data or, when technically feasible, transmit it directly to another controller.
When SIF's processing is based on the user's consent, the user has the right to withdraw consent. Such revocation does not affect the lawfulness of any processing carried out prior to the revocation and
based on the user's consent.
In some circumstances, applicable data protection laws grant the user the right to object to the processing of his or her data.
The user may request further information that is helpful for the exercise of the aforementioned rights.
To exercise these rights, the user can contact SIF's Data Protection Officer by e-mail at legal@sif-source.org. Before responding to a request based on the aforementioned rights or linked in any other way to the user's personal data, SIF may ask the user to provide a means of identification, in order to prevent misuse.
If the user is located in the EEA, the United Kingdom or in Switzerland, the user has a right to lodge a complaint with the appropriate data protection authority.
DATA RETENTION
SIF retains the user's data for the duration of the user's business relationship with SIF or as long as SIF has a legitimate interest in doing so, or in accordance with SIF's legal obligations.
LINKS
SIF's public Website or SOURCE may offer links to other organizations' websites. By clicking on such a link, the user will be leaving the Website or SOURCE. SIF is not responsible for content provided by these third-party websites or their privacy practices or policies.
CHANGES AND UPDATES TO THIS PRIVACY POLICY
Information privacy is an ongoing responsibility. As the activities and the services provided by SIF evolve, this Privacy Policy is expected to change as well. SIF reserves the right to amend this Privacy Policy at any time, for any reason, without prior notice. The updated Policy will be effective immediately upon publishing the new Privacy Policy on SIF's website. The provisions contained herein supersede all previous privacy notices or statements regarding SIF's privacy practice.
QUESTIONS, CONCERNS OR COMPLAINTS
Any questions, complaints or objections regarding SIF's data protection practices should be directed to SIF's Data Protection Officer by e-mail at: legal@sif-source.org.
This Privacy Policy has been last updated on 10th of November, 2023.
