Privacy Policy

1. Introduction

Paradox Engineering SA (here shortened as “PE”) is the IoT competence center of MinebeaMitsumi Group.

The processing of any personal data disclosed to PE is managed in compliance with clause 19 of the Federal Data Protection Law (LDP) and clause 13 of the General Data Protection Regulation (GDPR), in accordance with honesty, legitimacy, and transparency principles, and all limitations aimed at data storage, minimization, and correctness in respect of personal integrity and confidentiality of any sensitive information.

This Privacy Policy refers to www.pdxeng.ch website (here shortened as “website”).

Data processing is handled by Paradox Engineering SA.

For further information about personal data processing or to assert applicable rights, the user can contact PE at:

Paradox Engineering SA

Via Passeggiata 7, 6883 Novazzano, Switzerland

e-mail: privacy@pdxeng.ch

2. Definition of personal data and data processing

Personal data are pieces of information relating to an identified or identifiable natural person, directly or indirectly, referring to his/her physical identity, behaviors, relationships, etc. Personal data include, but are not limited to, a name, a surname, an address, contact details, an identification number, or an online identifier.

Data processing is 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, organization, storage, adaptation or alteration, consultation, erasure or destruction.

3. Data processing: objectives and types of data

1. Browsing data: Through information systems and software procedures, this website collects a series of personal data that are implicitly transmitted whenever using Internet communication protocols. Data are not collected to be associated with identified subjects, but by their nature could be used to identify the user through elaboration or correlation with third-party data. Data may include: IP (Internet Protocol) addresses or domain names of computers used to browse the website; URI (Uniform Resource Identifier) addresses; the date and time of website access; any other parameter related to the user’s operating system or IT (Information Technology) environment. These data are only used to get anonymized statistics about the website and its correct operation, detect anomalies and abuses, and they are immediately erased after processing. Data may be used in the event of attacks against PE or third parties to ascertain accountability.
2. Data voluntarily submitted via the contact form of the website: Data shared as mentioned are collected by PE at the time of the online contact form entry and processed with the sole objective of managing the request.
3. Data voluntarily submitted via the Login area of the website: Data shared as mentioned are collected by PE at the time of the Login access with the objective of sharing confidential information and documents with the user.
4. Data voluntarily submitted by the user: Data that the user may optionally, explicitly, and voluntarily send by e-mailing PE require the acquisition of the user’s e-mail address and are processed with the sole objective of managing his/her request.
5. Data voluntarily submitted via the Human Capital Management (HCM) Platform: Data shared as mentioned are collected by PE at the time of the HCM access and the related online contact form entry. Applicants’ personal data are processed for recruitment purposes and are stored for a maximum of 36 months after they have been received.

PE can use services of third-party providers who have been formally appointed Data Processors to evaluate the Applicant:  ie. video conference service, online platform that allows to measure the linguistic and professional skills of the candidates by means of adaptive tests, and online psychometric testing platform.

4. Legal conditions for data processing

Personal data processing is legitimized by one of the following legal conditions:

• Legal obligation: Data processing is mandatory to comply with a legal obligation.
• Legitimate or prevalent interest: Data processing is necessary to pursue the legitimate or prevalent interest of PE, provided it does not prevail on interests, rights, or fundamental freedoms of the user requiring personal data protection.
• Consensus: Data processing is allowed when the user gives permission for specific objectives. The user may revoke the consensus at the time by contacting PE as stated in clause 1 of this Privacy Policy.

5. Possible data recipients

Referring to PE activities and the above-described objectives, the user’ personal data may be shared with:

• Duly appointed Data Processors, providing specific data processing or similar services to PE. The user may request the updated list of Data Processors at any time.
• Autonomous Data Processors who may be entitled to data processing by law or authority directive.
• Third-party subjects, duly authorized by PE, processing data to perform specific activities related to the delivery of their own services, provided they signed a confidentiality agreement with legal and contractual obligations (ie. PE employees and contractors).

6. Data storage: location

All personal data are electronically stored in servers located in Switzerland and Europe.

7. Data storage: period

The user’s personal data are processed upon the implementation and continuous update of technical and organizational security measures aimed at preventing data accidental loss, unauthorized access or use, alteration, or distribution.

Data storage is envisaged for the time necessary to fulfill the aforementioned purposes or to comply with possible legal or publication obligations.

In order to determine the appropriate period of personal data storage, PE considers the quantity, nature, and sensitivity of personal data, possible damages resulting from unauthorized use or disclosure, the objectives of data processing, and applicable legal requirements.

8. Links to external websites and third-party services

PE website contains links to external websites and third-party services. PE cannot be held responsible for data processing by those third parties. If the user provides personal data to third-party websites, their own privacy policies and terms of use apply. PE suggests users to carefully read those privacy policies and terms of use.

PE cannot be held responsible for data collection, use, disclosure, and protection by third-party companies such as Meta Platforms Inc., Apple Inc., Alphabet Inc., Microsoft Corp., or any other developer or provider of applications, social media or social networks, operating systems, or wireless devices, even related to personal data the user may share with other companies through PE social media accounts.

9. User rights

The user can ask at any time the confirmation as to whether or not his/her personal data are being processed. Each user has the right to:

• access his/her data and get information about the purposes of the processing, possible recipients or categories of recipients, the envisaged period of personal data storage (if possible), the existence and consequences of data processing based on profiling.
• obtain the rectification of inaccurate or incomplete personal data.
• request the erasure of personal data, provided they are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• request the limitation of data processing, if applicable and legally compliant.
• be granted the portability of his/her personal data to a different Data Controller, receiving data in a structured, commonly used, and machine-readable format.
• object to the processing of his/her personal data and to any decision uniquely based on personal data processing, including profiling.

In order to assert these rights, the user can contact PE as stated in clause 1 of this Privacy Policy, or address the Swiss authority at https://www.edoeb.admin.ch

10. Revision and policy update

PE reserves the right, at its sole discretion, to change or update this Privacy Policy or some of its contents, even in response to applicable changes of legal requirements. Changes will be effective as soon as published on this website. If browsing the website and accessing its services after the publication, it is acknowledged that the user has read and understood the updated Privacy Policy and agrees to abide by it without reservation. Please check this Privacy Policy periodically for changes.

11. Revision

This Privacy Policy was last revised on March 27, 2023.

 

Cookie Policy

1. Cookies

The Cookie Policy provides information on how data is collected when users browse the website and how this data is used.

Cookies are texts strings that act as computer markers sent by a server (the website’s server, in this case) to the user’s device (normally, an Internet browser) when the user accesses a given page of a website. Cookies are automatically stored by the browser and retransmitted to the server which generated them each time the user accesses the same web page. In this manner, for example, cookies facilitate access to several web pages to improve the user’s browsing (or allow storage of pages visited or other specific information, such as the most frequently consulted pages, connection errors, etc.).

2. Technical Cookies

Strictly necessary cookies (so-called Technical Cookies): these cookies are necessary to allow the user to browse the website and use its functions. In particular, they enable features without which the user would not be able to fully use the website, since their presence enables basic functions such as page navigation and access to protected areas of the website.

If “Strictly necessary cookies” (Technical Cookies) are disabled, the user browsing experience may be less functional or completely compromised. The user may not be able to use all of the features and functionality of the website.

User’s consent is not required for the use of “Strictly necessary cookies” (Technical Cookies).

3. Google Analytics

This website uses “cookies”, which are text files stored on the user’s computer to enable analysis of website usage. The controller has integrated the component of web analytics service Google Analytics (with the anonymizer function), with the purpose of collecting, gathering, and analyzing data about the behavior of website visitors. This service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing this website from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on this website. Google uses the collected data and information, inter alia, to evaluate the use of this website and to provide online reports, which show the activities on this website, and to provide other services concerning the use of this Internet site for Paradox Engineering SA.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of this website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of this website by the data subject. With each visit to this Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may prevent the setting of cookies through this website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. Please notice that, if the data subject deactivates the setting of cookies in the Internet browser used, not all functions of this website may be entirely usable.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html

Google Analytics is further explained under the following link https://www.google.com/analytics

4. Transparency

Through the use of Google cookies, we may transfer some personal information to countries that according to the Federal Commissioner for Data Protection and Transparency (IFPDT)  and the European Commission do not provide adequate data protection: the United States of America.

Risks for users: in regard to Google cookies, in fact, all the security measures taken by Google to allow the transfer of data do not guarantee, at present, an adequate level of protection of personal data of users because the information related to the IP address of the user’s device (as well as: browser used, operating system, screen resolution, language selected, date and time of visit to the website) would in effect pseudonymized information, therefore easily traceable to data subjects through the combination of these with other data available to Google.

In addition, Google, as “provider of electronic communications services”, pursuant to art. 1881, par. 4, lett. b), Title 50 of the U.S. Code (cd. “Foreign Intelligence Surveillance Ac” – FISA 702) is subject to surveillance by US intelligence agencies, which may, therefore, collect online identifiers, such as IP addresses and “Unique Identification Numbers” for the collection of information and the surveillance of individuals; control which is further strengthened by the federal measure cd. “Cloud Act” (“Clarifying Lawful Overseas Use of Data Act”), introduced in March 2018, which allows the latter to acquire IT data from cloud computing service operators “regardless of whether such communications, records or other information are located within or outside of USA”; so even where servers are located in Europe.

Therefore, by giving consent to the use of such cookies, the User agrees to assume the risks they may incur, based on the information provided above.

5. Revision

This Cookie Policy was last revised on March 27, 2023.