Privacy policy of BULA CONCEPT AUDIOVISUEL SA

Version of 1^er September 2023

Introduction

We attach great importance to data protection. In this privacy policy we explain how we collect and process personal data.

THE " personal data » is information which relates to an identified or identifiable natural person. A natural person is deemed identifiable when he or she can be identified directly or indirectly, in particular by comparison based on a characteristic which may be, for example, the name, email address or telephone number.

By " treatment ", we mean any processing of your data, whatever the means and processes used, in particular collection, conservation, use, modification, communication, archiving or destruction.

If you communicate to us the personal data of third parties (e.g. family members, data of work colleagues), you should ensure that these people are aware of this confidentiality policy and only communicate their personal data to us if you have the right to do so and if they are correct.

This Privacy Policy complies with the revised Swiss Data Protection Act (“ LPD ") and the EU General Data Protection Regulation (" GDPR "). Whether and to what extent these laws are applicable, however, varies on a case-by-case basis.

This privacy policy applies in particular to any processing of personal data when using our website. www.bula-sa.ch, as well as in the conclusion of any service contract.

This is not an exhaustive description; where applicable, other data protection declarations or general terms and conditions of sale, conditions of participation and similar documents regulate specific questions.

Our website may contain links to other websites to which this privacy policy does not apply. Consider the privacy policy of third-party sites. We have no influence on data processing by third parties.

1. Responsible company

Unless otherwise stated in a specific case, the company responsible for processing the data described here is Bula Concept Audiovisuel SA, Rue Grenade 22, 1510 Moudon.

If you have any questions regarding data protection, you can let us know at the following contact address: info@bula-sa.ch, Bula Concept Audiovisuel SA, Rue Grenade 22, 1510 Moudon.

2. Collection and processing of personal data

We primarily process personal data provided to us by our customers and other business partners as part of the business relationship we have with them, and by other persons involved, or data we collect from users when operating our website and others. We collect your personal data when you use our services, create a new account, provide us with information via a web form (contact form), add or update information to your account, subscribe to a newsletter, participate participate in a game or contest or contact us in any other way.

Where permitted, we extract certain data from publicly accessible sources (e.g. debt collection register, land register, commercial register, press, Internet). This data may also be transmitted to us by other companies, by authorities or by third parties.

In addition to the data about you that you communicate directly to us, the categories of personal data that we receive from third parties about you include, in particular, information from public registers, information that we receive in the context of administrative and judicial procedures, information in connection with your professional functions and activities (so that we can, for example, with your help, conclude and transact business with your employer), information about you taken from correspondence and interviews with third parties, information about your creditworthiness ( to the extent that we personally do business with you), information about you provided by people around you (family, advisor, legal representative, etc.) so that we can enter into or execute contracts with you or using you (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal constraints such as anti-money laundering and export restrictions, information from banks, insurance companies, our business partners and other contractual partners regarding the use or provision of services by you (e.g. ex. payments made, purchases made)), information about you from the media and the Internet (to the extent that this is specifically indicated, e.g. in the context of an application, a press review, the marketing/sales, etc.), your addresses and, where applicable, your interests and other socio-demographic data (for marketing purposes), data relating to the use of the website (e.g. . IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of consultation, pages and content consulted, functions used, referring website, geolocation data).

Using server log files, we collect anonymous data about access to our website. This access data includes in particular: name of the website consulted, name of the file, date and time of consultation, quantity of data transmitted, notification of successful consultation, type and version of the browser, operating system of the user, referring URL (the previously viewed page), IP address and requesting provider. This data is used for statistical evaluations for operational purposes, to ensure the security of our IT systems and to optimize the website. This is to allow you to use it safely and without disruption.

3. Purpose of data processing and legal bases

We process your personal data for different purposes and based on different legal bases which permit such processing.

We use the personal data we collect primarily to enter into and perform our contracts with our customers and business partners. In addition, we process personal data for the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations in Switzerland and abroad. If you work for one of these clients or business partners, your personal data may also be affected in this capacity.

In addition, to the extent permitted and deemed appropriate to us, we also process personal data about you and others for the following purposes which constitute a legitimate interest for us (and sometimes third parties):

Offer and development of our offers, services and websites, applications and other platforms on which we are present;
Communication with third parties and processing their requests (e.g. applications, media requests);
Examination and optimization of needs analysis procedures with a view to directly approaching customers and collection of personal data from publicly accessible sources for prospecting purposes;
Advertising and marketing (including holding events), as long as you have not objected to the use of your data (if we send you advertising because you are one of our customers, you can opt out). object to it at any time; we will then put you on a list objecting to advertising mailings);
On our websites, individuals can participate in competitions, such as competitions or sweepstakes. The data transmitted to us is used to personalize any offers or newsletters as well as to develop a customer profile;
Market research and opinion polls, media observation;
Exercise of legal rights and defense in the event of legal disputes and administrative procedures;
Prevention and investigation of crimes and other misconduct (e.g. carrying out internal investigations, data analysis to combat fraud);
Guarantee of our activity, in particular IT, our websites, applications and other platforms;
Video surveillance for respecting freedom of home and other measures for IT security, buildings and installations as well as for the protection of our staff and other persons as well as the values which belong to us or which have been entrusted to us (e.g. . access controls, visitor lists, network and email scanners, telephone records);
Purchase and sale of domains, companies or parts of companies and other transactions falling under corporate law, transfer of personal data relating thereto and measures for the purposes of business management and compliance with legal and regulatory obligations as well as internal management requirements. Bula Concept Audiovisuel SA;

To the extent that you have authorized us to process personal data concerning you for specific purposes (e.g. when subscribing to newsletters or installing an application), we process personal data concerning you in the framework and on the basis of the consent granted, provided that a legal basis is required and we have no other legal basis than this consent. Consent given may be revoked at any time, which, however, has no impact on data processing already carried out.

Cookies, Tracking and other technologies related to the use of our services

On our websites and applications, we typically use “cookies” or other similar techniques to identify your browser or device. A cookie is a small file sent to your computer, or more precisely sent by your Internet browser and automatically saved on your computer when you visit our websites and applications. Cookies make your use of the Internet easier by saving your settings, preferences, contact details, etc. When you visit these websites or our applications again, we can recognize you through these cookies, even if we do not know who you are (anonymization). In addition to cookies, which are only used during a session and deleted after your visit to our sites ("session cookies"), cookies may also be used to save user settings or other information (permanent cookies ).

However, you can configure your browser so that it rejects cookies, saves them for a single session or, otherwise, deletes them early. Most browsers are set to accept cookies. We use permanent cookies to better understand how you use our offers and content, and to be able to display personalized offers and advertisements (which may also occur on the websites of other companies; these do not However, they do not learn from us who you are – as far as we ourselves know – because they only see that a user who previously visited one of our sites is currently on their own site). If you decide to block the sending of cookies, certain functions (e.g. choice of language, shopping cart, ordering process) may be disabled. We use location information, e.g. ex. your current location or the places visited, in order to personalize the services according to the user. We allow companies represented on our websites by advertisements to collect data about our users using “targeting cookies” for analysis purposes. The advertisements placed by these companies are clearly identifiable or declared as such on the websites.

Our websites use the following types of cookies in particular:

Necessary: Necessary cookies help make a website usable by ensuring basic functionality such as navigation from one page to another or access to secure areas of the site. Without these cookies, the site cannot function properly.

Preferences: Preference cookies allow a website to remember information that influences its nature or appearance, e.g. ex. your preferred language or the region you are in.

Statistics: Statistics cookies help website operators understand how visitors interact with sites, by collecting and reporting information anonymously.

Unclassified: Unclassified cookies are cookies that we are currently trying to classify in collaboration with other individual cookie providers.

Marketing: Marketing cookies are used to track users across websites in order to show them relevant adverts that match their preferences and are therefore more useful to publishers and other advertisers.

Social media plugins

On our websites we also use plug-ins for social networks such as Facebook, X (formerly Twitter), YouTube, Snapchat, Pinterest or Instagram. We have configured these items to be disabled by default. If you activate the plug-ins (by clicking/tapping), the operators of the respective social networks can see that you use our offers (websites/apps) and how you do so. The processing of your personal data is then the responsibility of this operator, in accordance with its data protection provisions. We do not receive any information about you from them.

Below is a list of marketing and social media plugins that can be integrated into our websites:

Facebook Remarketing/retargeting/pixel

Our websites and applications may contain remarketing tags from the social network Facebook. When you visit our pages, remarketing tags establish a direct connection between your browser and the Facebook server. Facebook is thus informed that you have visited our site and/or made a purchase using your IP address. Facebook can thus make the link between the consultation of our pages and a possible purchase and your Facebook user account. We may use the information obtained in this way for the display of Facebook ads as well as for marketing analyzes and other targeting measures. We draw your attention to the fact that we have no knowledge of the content of the data transmitted or their use by Facebook.

The controller of your data is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Further information on this can be found in Facebook's data protection declaration at https://www.facebook.com/about/privacy.

Youtube

YouTube can be integrated into our pages. YouTube is operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. YouTube's data protection declaration is binding. Further information on this can be found at: https://www.youtube.com/intl/de_be/howyoutubeworks/user-settings/privacy.

Instagram

Our websites may use features of the Instagram service, operated by Meta Platforms Ireland Limited. The corresponding plug-ins are marked with an Instagram logo, for example in the form of an "Instagram camera". If you visit a page of our website that contains such a plug-in, your browser establishes a direct connection to the Instagram servers. The content of the plugin is transmitted directly from Instagram to your browser and integrated into the page. In this way, Instagram is informed that your browser has visited the corresponding page of our website, even if you do not have an Instagram profile or are not logged in to Instagram. This information (including your IP address) is transmitted directly by your browser to an Instagram server in the United States and stored there.

If you are logged in to Instagram, Instagram can directly link your visit to our website to your Instagram account. If you interact with the plug-ins, for example by clicking on the "Instagram" button, this information is also transmitted directly to an Instagram server and stored there. The information is also published on your Instagram account and communicated to your contacts.

We hereby expressly draw your attention to the fact that, as the provider of this website, we have no knowledge of the content and scope of the transmitted data or their use by Instagram. Further information on this can be found in Instagram's data protection declaration at https://help.instagram.com/155833707900388 as well as in general information about https://help.instagram.com. If you do not want Instagram to directly link the data collected on our website to your Instagram account, you must log out of Instagram before visiting our website. You can also block the loading of Instagram plugins entirely using extensions for your browser, such as the “NoScript” blocker (http://noscript.net).

4. Integration of third-party services and content

In order to be able to provide you with information that is as interesting and comprehensive as possible, we partly use content from third parties, such as videos from YouTube, maps from Google Maps, RSS feeds or graphics from other websites. This always presupposes that the providers of this content (hereinafter referred to as “ third-party providers ") know your IP address. Without this IP address, third-party providers cannot send content to your browser. We integrate this content into our site in order to send you useful information or to facilitate an operation for you without further processing of the data. Our legitimate interest lies in being able to offer you this content as a service. In addition, certain services are only activated in the sense indicated above if you actively select them. In this case, data processing is based on consent. If you do not wish to use these contents, you can configure your browser settings accordingly. We strive to only use content whose respective providers use the IP address solely for the purpose of content transmission. However, we have no influence on whether third-party providers record the IP address, e.g. for statistical purposes. To the extent that we become aware of it, we inform users of it.

We send you occasionally, that is to say in the context of an existing or non-existent customer relationship and on the basis of your consent, advice, comments and information on our services and our offers via various communication channels such as emails (newsletter), downloadable documents and push notifications (applications).

When you subscribe to a newsletter on our website, we send you a confirmation e-mail in which you must confirm your registration (double opt-in). You can unsubscribe from the newsletter at any time. At the bottom of the newsletter, you will find the words “Unsubscribe from the newsletter”. You can configure the settings of your mobile device at any time so as not to receive push notifications. Unsubscribing from the newsletter or blocking push notifications does not automatically result in the deletion of your personal data. To do this, you can contact the address mentioned at the beginning of this declaration (point 1). The revocation has no impact on the legality of the data processing before the revocation.

In our newsletters and other marketing e-mails, we integrate partly and to the extent permitted visible and invisible visual elements, from which our servers allow us to know whether and when you have opened the e-mail message, so that Here we can also measure and better understand how you use our offers and adapt them to your needs. You can block these items in your email program. By agreeing to receive newsletters and other marketing emails, you agree to the use of these techniques.

Documents containing information are regularly made available for download on our websites. In return, we collect data such as your name, address, ownership structure, telephone number, email address, etc. based on your consent. and use it for marketing purposes, in particular to personalize the newsletter, develop a customer profile and transmit this data internally in order to offer you products. downloading the documents implies your consent. You can revoke your consent by contacting the address mentioned at the beginning of this declaration (point 1).

5. Transmission and transfer of data abroad

In the course of our business activities and for the purposes mentioned in point 3., we also communicate data to third parties, as far as this is permitted and we deem it appropriate, either because they process it for us or because they want to use them for their own purposes. These include

from our service providers (within Bula Concept Audiovisuel SA and externally, e.g. banks, insurance companies), including subcontractors (e.g. IT suppliers);
distributors, suppliers, subcontractors and other business partners;
customers;
Swiss and foreign authorities, offices or courts;
media;
the general public, including visitors to websites and social networks;
competitors, sectoral organizations, associations, organizations and other bodies;
buyers or persons interested in acquiring areas of activity, companies or other parts of Bula Concept Audiovisuel SA;
other parties in potential or actual legal proceedings;

all being collectively referred to as the recipients.

These recipients are partly located in Switzerland, but can be located anywhere in the world. In particular, you should expect that your data will be transmitted to other countries in Europe and to the United States, where the service providers we use are located, such as Adobe, Microsoft, SAP.

If a recipient is located in a country without adequate data protection legislation, we contractually oblige them to comply with the applicable data protection (for this we use the revised standard contractual clauses of the European Commission, available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), insofar as it is not already subject to recognized regulations guaranteeing data protection and we cannot rely on an exception clause. An exception may apply in particular in the event of legal proceedings abroad, but also in cases of overriding public interest or when the performance of a contract requires such disclosure, when you have given your consent or when This is data that you have made public and to which you have not objected to the processing.

6. Duration of retention of personal data

We process and retain your personal data for as long as necessary for the performance of our contractual and legal obligations or for the purposes pursued by the processing, in particular for the entire duration of the business relationship (from preparation to termination of a contract through its execution) and beyond, in accordance with legal retention and documentation obligations. Personal data may be stored for the period during which claims can be asserted against our company and to the extent that we are otherwise required to do so by law or if legitimate business interests require it. require (e.g. for evidentiary and documentation purposes). As soon as your personal data is no longer necessary for the aforementioned purposes, it will be deleted or anonymized. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

7. Data security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access and misuse, including the publication of guidelines, training, access restrictions and controls.

8. Obligation to make personal data available

As part of our commercial relationship, you must provide the personal data necessary for the establishment and execution of a commercial relationship as well as the fulfillment of the contractual obligations linked to it (as a general rule, you do not you have no legal obligation to provide us with data). Without this data, we will generally not be able to enter into or perform a contract with you (or the organization or person you represent). The website cannot be used either if certain information intended to guarantee the flow of data (such as the IP address) is not disclosed.

9. Profiling

We process your personal data in a partially automated manner for the purpose of evaluating certain personal aspects (profiling). In particular, we use profiling to inform you and advise you in a targeted manner about our products. To do this, we use evaluation instruments that enable us to tailor communication and advertising, including market research and opinion polls.

10. Rights of the data subject

Within the framework of the data protection legislation applicable to your case, you have a right of access, rectification, erasure, a right to limitation of data processing as well as the right to object to our data processing and request the communication of certain personal data with a view to their transmission to another organization (data portability).

Please note, however, that we reserve the right to enforce restrictions provided by law, e.g. ex. when we are legally required to retain or process certain data, have a strong interest in it or need it to assert rights. If you are responsible for any costs, we will notify you in advance. Where data collection is based on your consent, you have the right to revoke your consent at any time. The revocation does not affect the legality of the data collection carried out to date. You have the possibility to revoke your consent at any time by contacting the address mentioned at the beginning of this declaration. Please note that exercising these rights may conflict with certain contractual agreements. If applicable, we will inform you in advance if this is not already stipulated in the contract.

The exercise of such rights generally requires you to clearly prove your identity (e.g. upon presentation of a copy of an identity document enabling you to clarify or verify your identity). To assert your rights, you can contact us at the address indicated in point 1.

Any data subject also has the right to assert their claims in court or to lodge a complaint with the competent data protection authority. The authority responsible for data protection in Switzerland is the Federal Data Protection and Transparency Commissioner (https://www.edoeb.admin.ch/edoeb/fr/home.html).

11. Automated individual decisions

To ensure the efficiency and consistency of our decision-making processes, we may also make certain decisions in a fully automated manner (computer-assisted, according to certain rules and without human influence or control by employees). These decisions can also be made based on profiles.

In the case of an automated individual decision, you will be informed separately about its implementation, provided that it results in negative legal consequences or comparable considerable harm for you. In this case, you have the possibility to present your point of view on the outcome of the decision and to demand that an employee of Bula Concept Audiovisuel SA verifies the decisions.

12. Changes

We may modify this privacy policy at any time without notice. The current version published on our websites and in the applications is binding. If the data protection declaration is part of an agreement with you, we will inform you of updates by email or in another appropriate way.