Last Modified: 21/06/2022

Please note that the website Archroma.com (the "Website") is operated by Archroma Management GmbH (Archroma), with registered address at Hardstrasse 1, 4133 Pratteln, Switzerland. More information about Archroma can be found in "About" and "Who we are" section of the Website. "You" and "Your" refer to You as a user of our Website.

This Privacy Policy ("Privacy Policy") is intended to inform You of how we collect, define and use Your Information.

The provision of the Website service is limited to the period during which You are connected to the Website or to any of the services provided through the Website. Therefore, You should read this Privacy Policy carefully each time You intend to use the Website, as it may change.

1. Definitions

Personal data

Means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data controller

Means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data processor

Means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. In the present case, and unless otherwise indicated, Archroma Management GmbH is the data controller of the data processed in www.archroma.com.

Recipient

Means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Consent

Means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. What information do we process in www.archroma.com?

a. Information You provide to us when You use the data forms on the website or when You communicate with us through means such as e-mail.

The data will be processed with the purpose specified in each form. If You send us a message, we will process it in order to manage the communications that may be established, based on Your request. We may obtain Your express consent for the purpose of sending You commercial. In such cases, we will always inform You in advance of all the aspects required by the applicable legislation on data protection. If You no longer wish to receive commercial communications after You have given Your consent, You may revoke Your consent by sending an e-mail to dpo@archroma.com.

b. Data that the website automatically collects during Your browsing, if You have previously given Your consent in the terms specified in this privacy policy.

Like most commercial websites, our website uses a technology called "cookies" (small pieces of data that Your browser stores on Your terminal's hard drive) and web server logs to collect information about how our website is used. For more information on how we use cookies, please see our Cookies Policy.

3. Who is the data controller?

Information on the company data controller of the personal data

Unless otherwise indicated, the entity controller is Archroma Management GmbH (Archroma) with registered address at Hardstrasse 1, 4133 Pratteln, Switzerland.

DPO contact information: dpo@archroma.com

4. What data do we process, for what purposes, for how long and on what legal basis?

4.1. Reception of Curriculum Vitae and participation in personnel selection processes

a) Data controller
Controller: Archroma Management GmbH and the Archroma company identified in the job offer and to which You submit Your application.
DPO Contact: dpo@archroma.com

b) Categories of personal data concerned
We will process the data You provide us with in Your curriculum vitae, in our forms for recruitment processes and, where appropriate, in the subsequent interviews and tests that may be carried out during the process.

c) Purposes of the processing

Your data will be processed in order to manage Your participation in personnel selection processes in our company. The data will not be used for any other purpose.

If You give us permission to do so, we will keep Your data for future job offers.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?
The data will be processed during the recruitment process. If You authorise us to do so, we will keep Your data for future job offers, in which case we will keep Your data for one year.

f) Legal basis for the processing
In relation to the recruitment process, the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

In relation to the storage of Your curriculum vitae for future recruitment processes, the legal basis for the processing of Your data is the unequivocal consent.

g) Obligation to provide the data and consequences of not providing them
The submission of data is completely voluntary. However, in the event that You provide us Your data via a specific data form, You may need to provide us with a minimum set of data in order to properly identify Yourself in order to participate in the personnel selection process.

h) Origin of the data
The actual data subject.

i) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, whose parent is the US entity S.K. Capital Partners LLP, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.2. Information about data processing within the scope of B2B relationships

Summary: the corresponding company of the Archroma Group will process Your data for managing the business relationships with the legal person (“Partner”) for whom the data subject provides their services.

a) Data controller

Controller: Archroma Management GmbH and the company of the Archroma Group that has the (potential) business relationship with the (potential) customer.

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

We will process the minimum essential data so that You can be located professionally, such as Your name, surnames, title, department, email address, telephone number and data about the company where You provide Your services.

c) Purposes of the processing

Maintaining the relationships of any nature with the legal person for whom the data subject provides services.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

The data will be processed while the contractual relationship is maintained between the Controller and the Partner and subsequently after the relationship has ended, for the period of time during which contractual liabilities between the parties may be determined.

f) Legal basis for the processing

The legal basis for processing Your data is the legitimate interest of the Controller in maintaining and managing its relationships with customer entities or suppliers.

g) Obligation to provide the data and consequences of not providing them
The data is necessary for the maintenance and management of the commercial relationship between the companies.

h) Origin of the data
The actual data subject.

i) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, whose parent is the US entity S.K. Capital Partners LLP, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.3. Data protection information regarding registration for events and webinars

Summary: Archroma will process the data of the people attending the events and webinars that it organises for the correct management of the registration applications and their subsequent management. If You expressly authorise us to do so, we will also use Your data to contact You and send You information about our products and services.

a) Data controller

Controller: Archroma Management GmbH

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned
Archroma will process the data requested in the different application forms.

c) Purposes of the processing

  1. Management of Your registration request for the event.
  2. If You have expressly authorized it, Archroma or any of its companies will use Your personal data to contact You and send You information by e-mail about additional events, trainings and new solutions related to the textile industry.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

The data will be deleted after the conclusion of the event, unless You have given Your permission for us to contact You for commercial purposes. In the latter case, we will keep Your data until You revoke Your consent.

f) Legal basis for the processing

For both purposes of the data processing, the legal basis is the unequivocal consent You give by accepting the privacy policy.

g) Obligation to provide the data and consequences of not providing them
Each event registration data form shall expressly indicate which data are voluntary and which are mandatory.

h) Origin of the data
The actual data subject.

i) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.4. Data protection information regarding compliance

Summary: Archroma has a Code of Conduct for employees, signed by the Chief Executive Officer and publicly available, which sets out the binding rules and guidelines to the employees and officers of Archroma. This enables employees to rely on the Code as a navigation guide, and one another’s good judgement, to uphold a high standard of integrity for the individual and Archroma.

a) Data controller

Controller: Archroma Management GmbH

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

Archroma will process identification data, employment data if You are employed by us, business information (such as activities and business), transaction data (such as Goods Received, Goods Delivered, Compensation/Compensation and Financial Transactions) as well as any other personal information that You provide to us when You make a communication relating to our code of conduct.

c) Purposes of the processing

The questions You submit to us in relation to Archroma's code of conduct will be handled in order to attend to Your request as well as to carry out the actions arising from it.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

Queries and issues processed by the Compliance Department will be dealt with during the period for which each of the parties may be held liable.

f) Legal basis for the processing

The legal basis for the processing of data in the context of actions and competences of the Compliance department, insofar as they do not affect the whistleblowing channel is that the processing is necessary for the purposes of the legitimate interests pursued by the controller.

This legal basis is based in fraud prevention and compliance with internal regulations.

g) Origin of the data

  1. The data subject himself
  2. Other persons within the company, or external entities

h) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

i) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.5. Data protection information regarding the whistleblowing channel

Summary: Archroma has a whistleblowing policy in place that allows the anonymous reporting of any suspicious situation of violations of our Code of Conduct or the law. This privacy policy details the processing of data in this context.

a) Data controller

Controller: Archroma Management GmbH and the relevant company(s) of the Archroma Group which may be affected.

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

Archroma will process identification data, employment data, business information (such as activities and business), transaction data (such as goods received, goods delivered, compensation/compensation and financial transactions) as well as any other personal information that You provide to us, when You make a complaint through the complaints channel, including special categories of data such as race or ethnic origin, political opinion, religious or philosophical belief, trade union membership, health, sex life or sexual orientation.

c) Purposes of the processing

The personal data collected in the whistleblowing channel shall be processed for the sole purpose of processing any complaints received as a result of acts or conducts that may be contrary to the applicable general regulations or Archroma's Code of Conduct and, where appropriate, to investigate the reality of the facts reported, in accordance with the whistleblowing policy in place that allows the anonymous reporting of any suspicious situation of violations of our Code of Conduct or the law.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

The data will be blocked 6 months after the conclusion of the investigation, unless applicable law indicates a different time limit.

f) Legal basis for the processing

The legal basis for the processing of data within the scope of the whistleblowing channel is:

  1. Processing is necessary for compliance with a legal obligation to which the controller is subject.
  2. Processing is necessary for the performance of a task carried out in the public interest.

These legal basis fall within the framework of the processing of data for the purpose of the prevention and discovery of possible conduct that contravenes both current legal regulations and Archroma's Code of Conduct; including, in particular, those classified as criminal offences which, due to the circumstances in which they occur, may entail the criminal liability of Archroma.

g) Obligation to provide the data and consequences of not providing them
The whistleblowing channel specifically indicates which data are voluntary and which are mandatory for the correct management of Your communication.

h) Origin of the data

  1. The data subject himself.
  2. Other persons within the company, or external individuals or legal entities that could provide information through complaints or in the course of the company's investigative actions.

i) Recipients

To Security Forces and Corps, and to Courts and Tribunals for the presentation of complaints and legal claims, in compliance with the applicable legal obligations.

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.

4.6. Data protection information regarding the website contact form

Summary: On our corporate website You will find a contact form (https://www.archroma.com/contact) through which You can communicate with different areas and departments of the Archroma Group entities.

These areas are not associated with Archroma entities located in a specific country, so when You use the form, Your data may be processed by Archroma staff belonging to different companies of the group, located in different countries.

a) Data controller

Controller: Archroma Management GmbH and the company of the Archroma Group that has the (potential) business relationship with the (potential) customer.

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

Archroma will process the information You provide us with through the contact form, and any information You may subsequently provide us with in future communications between the parties.

c) Purposes of the processing

Manage Your request and communications between the parties.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

Your data will be processed for the time necessary for the management of communications between the parties.

In the event of a contractual relationship with You or the company You represent, the data will be processed for the duration of such contractual relationship.

f) Legal basis for the processing

If communication falls within the scope of B2B business relations, the legal basis for processing Your data is the legitimate interest of the Controller in maintaining and managing its relationships with customer/potential customers, or suppliers/ potential suppliers.

If Your communication is in the context of a recruitment process, the legal basis is to take steps at the request of the data subject prior to entering into a contract.

In all other cases, the legal basis for processing Your data is the legitimate interest of the data controller in the management of the company's communications.

g) Obligation to provide the data and consequences of not providing them

The data form specifically indicates which data are voluntary and which are mandatory to use the form.

h) Origin of the data

The data subject himself.

I) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

The contact form is not structured by country or by individual Archroma group company. It is structured by transversal areas or departments that can be managed through different companies of the Archroma group. Accordingly, Your communications may be handled by persons belonging to several entities of the Archroma Group.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.7. Data protection information regarding Archroma (potential) customer web applications

Summary: Archroma provides its (potential) customers with various web applications to complement and support the (potential) business relationship between the parties. These applications require online registration and allow access to a private user area.

a) Data controller

Controller: Archroma Management GmbH and the company of the Archroma Group that has the (potential) business relationship with the (potential) customer.

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

Archroma will process the information You provide us with through the registration form, and any information You may subsequently provide us via the web application and/or in future communications between the parties.

c) Purposes of the processing

Management of the use of the web application and the services associated with it, as well as the private area for registered users.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

As long as You remain a registered user, and in any case for the duration of the contractual relationship between the parties.

f) Legal basis for the processing

The legal basis for processing Your data is the legitimate interest of the Controller in maintaining and managing its relationships with contact persons, of customer/potential customers.

g) Obligation to provide the data and consequences of not providing them

The data form specifically indicates which data are voluntary and which are mandatory to use the form.

h) Origin of the data

The data subject himself.

I) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


4.8. Data protection information regarding newsletters and sending of commercial information

Summary: On certain data forms, we will ask for Your permission to send You information about our products and services.

a) Data controller

Controller: Archroma Management GmbH

DPO Contact: dpo@archroma.com

b) Categories of personal data concerned

We may process Your e-mail address, name and surname, as well as other information that may be requested in the data forms for subscribing to our newsletters or sending commercial communications.

We also use cookies and similar devices in our electronic communications for statistical and analytical purposes. For example, we can find out which users have clicked on certain graphics in the e-newsletter and adapt the content of future communications to the areas or topics that are most frequently visited.

c) Purposes of the processing

Management of electronic communications to send You Archroma news, such as new products and system solutions, invitations to webinars, or trade shows and events.

d) Automated decision-making, including profiling
No profile segmentation or automated decisions are made.

e) How long will we keep Your data?

We will process Your data until You revoke Your consent.

f) Legal basis for the processing

The legal basis for processing Your data is the unequivocal consent of the data subject.

g) Obligation to provide the data and consequences of not providing them

In order to receive our newsletters and commercial communications, it is necessary that you provide us with the personal data that will be indicated in the subscription requests.

h) Origin of the data

The data subject himself.

I) Recipients

Archroma is part of a group of companies (“Archroma Group” or “Group”), in which the different companies that integrate it, can provide different corporate services which involve access to personal data. The provision of these services is covered by data processing contracts in accordance with the applicable legislation on data protection.

Archroma has the support of information technology service providers who process the data on behalf of our Group. In order to select our suppliers, we carry out a strict selection control based on the guarantees of compliance with data protection regulations, and we subscribe the relevant data processing contract with these entities.

j) International data transfers

For the purposes detailed in this policy, Your personal data may be transferred to Archroma Group, and to service providers acting on their behalf. These entities may be located in third countries that do not have data protection legislation comparable to that of Switzerland, or the European Union.

Archroma uses the European Commission's standard contractual clauses and other guarantees applicable in other jurisdictions, to ensure the processing of personal data in compliance with applicable law.

Each of these Archroma Group companies (and their authorised data processors) complies with Archroma's data processing procedures to ensure an adequate level of data protection.


5. Your rights

You have the right to access the information and have it rectified without delay if it is inaccurate or incomplete.

You can ask to have it blocked under certain circumstances.

You can also object to it, in certain circumstances, on grounds relating to Your specific situation.

You can request that any of the above changes be communicated to other parties to whom Your data have been disclosed.

You have also the right not to be subject to automated decisions (made solely by machines) affecting You, as defined by law.

You have the right to receive Your personal data in a standardized format in case You wish to transfer it to another controller (data portability).

Likewise, in the event that You consider that there is a problem or incident in relation to the processing of data, You may contact Archroma through the contact address dpo@archroma.com, and in any case, You have the right to make a complaint to the Data Protection Authority.

If Archroma is processing Your personal data and You would like to exercise Your data protection rights, please send us a written request by e-mail to our Data Protection Officer (dpo@archroma.com).

We cannot accept verbal requests (telephone or face-to-face) as we may not be able to deal with Your request immediately without first analyzing it and reliably identifying You.

Your request should contain a detailed, accurate description of the data You want access to. When there are reasonable doubts regarding Your identity, You might be asked to provide a copy of a document, which help us to verify Your identity. It can be any document such as Your ID card or passport. Should You provide any other documents, personal details such as Your name and Your address should be in clear in order to be able to identify You, while any other data such as a photo or any personal characteristics, may be blacked out.

Our use of the information on Your identification document is strictly limited: the data will only be used to verify Your identity and will not be stored for longer than needed for this purpose.

Affiliations & memberships

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