Last updated on 2019/09/18

1.    PREAMBLE AND CONSENT
The present Web and Privacy Policy (“Policy”) governs your relationship with the travauxsansdanger.ch website (the “Website”) and our dedicated pages on the following social media and platforms: LinkedIn, Twitter, Facebook, Instagram and YouTube, all operated by Etat de Genève (“us”, “we”, “our”), which main office is located in Geneva.

Please read carefully this Policy, which explains how your personal data will be collected, used and protected, before using the Website and our dedicated pages on the social media and platforms. Your access and use of the Website and social media pages are conditional upon your acceptance of, and compliance with this Policy.

By checking the “I have read and agree to the Privacy Policy” box on the sign-up page of the Website, you agree to be bound by this Policy and you agree and consent to the collection, use and processing of Personal Data in accordance with this Policy.

Please also note that you have the right to withdraw your consent at any time, it being however specified that such withdrawal:
-    will not affect the lawfulness of processing based on your consent before its withdrawal;
-    may prevent you from using some features of our Website or dedicated pages on social media.

2.    DATA PROTECTION OFFICER (DPO)
2.1.    Should you have questions or complaints regarding this Privacy Policy, please contact us online at sabra@etat.ge.ch
2.2.    You can also reach us by physical mail at Rue Sainte Clotilde, CP 78,  1211 Genève 8.

3.    GENERAL PRINCIPLES
3.1    Our Website and social media platforms contain the following information and provides the following services:
(i)    information about the services offered by our organization, its affiliates and members,
(ii)    various channels to get in touch with us (contact forms, links to social media account, chatbot, etc.),
(iii)    links to other websites and social media platforms,
(iv)    registration to newsletters,

3.2    This Privacy Policy lays out our policies and procedures surrounding the collection and processing of any information that identifies you (i.e. “Personal Data”), which you may for instance provide to us when visiting our Website or social media platforms or using one of the services described under 3.1.
3.3    This Privacy Policy applies only to our Website and our dedicated pages on social media. Please further note that if you access to our dedicated pages on social media, information you provide will also be subject to the privacy policy of operator of the social media platform.
3.4    This Privacy Policy does not apply to any offline services offered by our organization.  

4.    PERSONAL DATA WE COLLECT, AND WHY WE COLLECT THEM

A.    General information
4.1.    Data we collect via our website and social media are divided in three main categories based on the following sources:
(i)    Cookies, analytics and other similar tools (below B)
(ii)    Personal Data you provide to us (below C),
(iii)    Data from other sources (below D).

B.    Cookies, analytics and other similar tools

1.    What are Cookies and what information they collect ?
4.2.    Cookies are files with small amount of data which are sent to your browser from a website and stored on your device (computer or mobile device). Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website.

4.3.    Through cookies and similar technologies, we may collect Personal Data from you when you visit our Website or dedicated pages on social media. We may log in particular usage data when you view or click on content.
4.4.    The following information and Personal Data are collected through the cookies:
(i)    IP address of the requesting internet-enabled device,
(ii)    date and time of access,
(iii)    accessed resources on the Website,
(iv)    name and URL of the retrieved file,
(v)    website/application from which the access was made (referrer URL),
(vi)    browser you use and, if necessary, the operating system of your internet-capable computer as well as the name of your access provider,
(vii)    Location of the requesting internet-enabled device.

4.5.    In order to control / limit the collection of this information, you can:
(i)    if available, set up your browser to refuse all cookies or to indicate when a cookie is being sent,
(ii)    when reaching our Website, select what cookie you allow and what cookie you want to block,
(iii)    delete cookies and clear your browsing data directly from your browser’s settings.
However, please note that if you do not accept certain cookies, you may not be able to use some features of our Website.
4.6.    List of the Cookies we use:
(i)    Session Cookies: Cookies used to operate our Website.
(ii)    Analytics Cookies: Cookies used to collect standard internet log information and details of visitor behavior patterns, such as Google Analytics. We do this to find out such things as the number of visitors to the various parts of the Website and monitor the Website traffic, to identify any service issues, improve our services, and generate statistics.
(iii)    Functionality Cookies : Cookie drupal (has_js), cookie vimeo (vuid, player, ab_t)

2.    Why we collect information through cookies (purpose) ?
4.7.    We use cookies and the Personal Data collected:
(i)    to authorize access to our Website,
(ii)    to make the functionalities of our Website available to you and to offer you additional functionalities,
(iii)    to improve the Website or our dedicated pages on social media,
(iv)    to store information about your preferences, allowing us to customize our Website according to your individual interests,
(v)    to speed up your searches,
(vi)    to compile statistical information about use of our Website or our dedicated pages on social media, in particular to estimate our audience size and usage patterns,
(vii)    to produce aggregate insights that do not identify you,
(viii)    to identify you and log your use, recognize you when you return to our Website, track the activity on our Website and hold certain information.

3.    Legal basis for processing
4.8.    The purpose for implementing all of the above is to maintain and monitor the performance of our Website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
4.9.    In addition, cookies and other functionalities mentioned above which would go beyond the purposes of our legitimate interests (for example: Analytics Cookies), are implemented upon your acceptance through the means of our cookie banner.
C.    Personal Data you provide us with
1.    What Personal Data you provide us with?
4.10.    We collect Personal Data offered by you voluntarily when, on our Website, you:
(i)    fill out a contact form,
(ii)    subscribe to newsletters. For newsletters, we use MailChimp  to manage email marketing subscriber lists and send emails to our subscribers. You can find more information on MailChimp’s privacy commitments: https://mailchimp.com/legal/cookies/

4.11.    These data may include your names, title, gender, date of birth, nationality, address, country of residence, e-mail address, telephone number, account number, personal and business addresses, professional details and qualification, records and copies of your correspondence.

2.    Why we collect such Personal Data (purpose) ?
4.12.    We use the Personal Data you provide us with for the following purposes:
(i)    to allow you to participate in interactive features of the Website when you choose to do so,
(ii)    to provide customer support,
(iii)    to provide you with congress related news and information,
(iv)    to fulfill the purposes for which you provide the data.

4.13.    We may use your Personal Data to send you marketing information, in an electronic or paper format, which is related to the information available on our Website or our dedicated pages on social media and which we think may be of interest for you.
4.14.    In this connection, we may use identifiers such as cookies so that we can build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our Website or dedicated pages on social media, you do not miss offers and information that might be of interest for you (online targeted advertising).
4.15.    You may opt out from receiving any such information by sending an email to sabra@etat.ge.ch. Upon receipt of your request, we will promptly notify you by email that your request is being handled. Please note that it may take up to ten days to have your request fully processed. You may therefore receive marketing information during this period of time.
 

3.    Legal basis for processing
4.16.    The legal basis we rely on to process the Personal Data you provide us is article 6(1)(a) of the GDPR, which allows us to process personal data when the data subject has given consent to the processing of his or her personal data.
D.    Personal Data collected about you from other sources
1.    What information we collect from other sources?
4.17.    We may collect Personal Data about you from other sources, such as Personal Data you make available on social media.
a)    Search Engine on our website
4.18.    Our Website search engine is powered by Drupal. Search queries and results are logged anonymously to help us improve our Website and search functionality. No identifiable personal information is collected by us.
2.    Purpose and legal basis for processing
4.19.    The purpose for collecting your Personal Data from other sources is to support our business and to maintain and to constantly look to improve our Website and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

5.    PERSONAL DATA COLLECTED BY THIRD PARTIES (LINKS TO OTHER WEBSITES AND SOCIAL MEDIA)
5.1.    Where we provide links to websites of other organizations, this privacy policy does not cover how that organization processes your Personal Data. We encourage you to read the privacy policies related to the other websites you visit.
5.2.    Our Website and our dedicated pages on social media contain links that direct you to the social networks such as Facebook, Twitter, Instagram, YouTube and LinkedIn (the “Social network”) or to another website, in order to connect you with the content displayed in these platforms. When you access a Social network or another website via our Website or one of our dedicated pages on social media, responsibility for compliance with data protection is to be guaranteed by the respective providers.
5.3.    If you establish a connection with the Social network of your choice or another website, your browser connects directly to the provider’s servers. Through this integration, the Social network or the other website receives the information that your browser previously accessed the corresponding page of our Website or our dedicated page on a social media, even if you do not have a profile or are currently not logged in to your account. This information (including your IP address) will be transmitted from your browser directly to a provider’s server and stored there. If you are logged in to your account, the provider can immediately assign the visit to our Website or our dedicated page on a social media to your profile. If you interact with the Website or our dedicated page on a social media, for example by clicking a "Like" or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.
5.4.    For information about the purpose and scope of the data collection and the further processing and use of the data by the requested Social network or the other website, as well as related rights and settings options for the protection of your privacy, please refer to the privacy policy of the selected provider.

6.    SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
6.1.    As noted above, we may compile usage statistics relating to our Website or our dedicated pages on social media based notably on your Personal Data. We may publish those statistics or share them with third parties in an aggregated form so that they do not include your Personal Data.
6.2.    Your Personal Data may be transferred to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Etat de Genève’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Etat de Genève about our Website users is among the assets transferred.
6.3.    We may give certain independent contractors and affiliates access to the Personal Data you made available to us through our Website or our dedicated pages on social media in order to assist us with the operation of our Website or our dedicated pages on social media, as well as data management and marketing activities. To date, those contractors are the following:
(i)    IT Provider: Informaniak
(ii)    Other service providers: Mailchimp, Vimeo
6.4.    We will take all necessary steps to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable laws. All those contractors are required to sign contracts in which they promise to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.
6.5.    The purpose for sharing your personal data to the above-mentioned third-party is to support our business and to maintain and to constantly look to improve our Website and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

7.    SHARING YOUR PERSONAL DATA WITH AUTHORITIES
7.1.    We may also share or transfer your Personal Data (including your communications) if we think it’s necessary for security purposes, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Website or our dedicated pages on social media. Hence, we may share or transfer your Personal Data to investigate, respond to and resolve complaints and issues relating to our Website or our dedicated pages on social media.
7.2.    It is possible that we will need to disclose your Personal Data when required by law or if we have a good faith belief that disclosure is necessary to:
(i)    investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies,
(ii)    enforce our agreements with you,
(iii)    investigate and defend ourselves against any third-party claims or allegations,
(iv)    protect the security or integrity of our Website or our dedicated pages on social media, or
(v)    exercise or protect the rights and safety of our users, personnel, or others.
7.3.    We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment and technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
7.4.    The purpose for sharing your personal data to the above-mentioned authorities is to support our obligation within the meaning of article 6(1)(c) of the GDPR, which allows us to process personal data when its necessary for compliance with a legal obligation to which we are subject.

8.    No commercial disclosure of your Personal Data
8.1.    We will not sell your Personal Data to third parties. We will not share or otherwise make available your Personal Data to third parties except as provided in this Privacy Policy.

9.    STORAGE OF YOUR PERSONAL DATA
9.1.    We are taking data protection issues seriously and we have chosen to store your Personal Data on servers in Infomaniak.

10.    CROSS-BORDER DATA TRANSFER
10.1.    For some of the third-party service providers, we may transfer your data to one of their databases outside Switzerland or the European Economic Area, potentially including countries which may not have an adequate level of protection for your Personal Data compared with that provided in Switzerland or the European Economic Area. In such event and unless provided otherwise in this Privacy Policy, we enter into agreements with such third-parties ensuring an adequate level of protection for your Personal Data.
10.2.     In case we share data with third-parties outside of Switzerland and the EEA, this will occur under safeguard mechanisms provided by the European Union (EU) and the Swiss Government as providing adequate protection for your Personal Data.

11.    PROTECTION OF YOUR PERSONAL DATA AND DATA BREACH NOTIFICATION
11.1.    We exercise commercially reasonable efforts to prevent unauthorized exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (comprising administrative, physical, and technical safeguards) for managing unauthorized disclosure or exposure of your Personal Data.    
11.2.    In the event of a data breach, or in the event that we suspect a data breach, we will (i) do our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach, including without limitation by providing reasonable assistance to you in notifying injured third-parties. We will give you prompt access to such records related to a data breach as you may reasonably request; provided that we shall not be required to provide you with records belonging to, or compromising the security of, other users.
11.3.    In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.  

12.    MANAGEMENT OF YOUR PERSONAL DATA (YOUR RIGHTS)
12.1.    Right to access, update or to delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us at the following at: sabra@etat.ge.ch.
12.2.    Right of rectification: You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.
12.3.    Right to object: You have the right to object to our processing of your Personal Data.
12.4.    Right of restriction: You have the right to request that we restrict the processing of your Personal Data.
12.5.    Right to data portability: You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
12.6.    Right to withdraw consent: You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data.
12.7.    Right to complain to an Authority: You have the right to complain to a data protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or in Switzerland.
12.8.    Please note that we may ask you to prove your identity before responding to requests based on the previous rights or somehow related to your Personal Data.

13.    RETENTION OF YOUR PERSONAL DATA
13.1.    We retain the Personal Data you provide to the extent necessary to provide you access to and use of our Website or our dedicated pages on social media and of their functionalities (like for instance our newsletters), as well as to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
13.2.    The storage period of cookies depends on their purpose and is the same for everyone.
13.3.    We may retain de-personalized (anonymous) information after the deletion of your Personal Data.

14.    SECURITY OF YOUR PERSONAL DATA
14.1.    The security of your Personal Data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use technical and organizational commercially acceptable means to protect your Personal Data against manipulation, partial or complete loss and unauthorized access by third party, we cannot guarantee its absolute security.

15.    PERSONAL DATA RELATING TO CHILDREN
15.1.    We do not provide services directly to children or proactively collect their personal information.

16.    AMENDMENT OF THIS PRIVACY POLICY
16.1.    We may change this Privacy Policy at any time by posting a new version on this page or on a successor page, without prior notification. If we make changes to this Policy, we will notify you through a notice on the Website home page. By continuing to access or use our Website or our dedicated pages on social media after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Website and our dedicated pages on social media.
16.2.    However, we will always handle your Personal Data in accordance with the Privacy Policy that was in effect at the time of collection.
16.3.    The new version will become effective on the date it's posted, which will be listed at the top of the page as the new effective date.

17.    MISCELLANEOUS
17.1.    Our failure to enforce any right or provision of this Policy will not be considered a waiver of those rights.
17.2.    If any provision of this Policy is held to be invalid or unenforceable by a court, the remaining provisions of this Policy will remain in effect.
17.3.    This Policy constitute the entire agreement between us regarding the Privacy Policy of our Website and our dedicated pages on social media, and supersede and replace any prior agreements we might have between us regarding the Website and our dedicated pages on social media.