Swissgas, Schweizerische Aktiengesellschaft für Erdgas (hereinafter referred to as “Swissgas”, “we” or “us”) undertakes to process all personal data (hereinafter referred to as “personal data”) collected via the website www.swissgas.ch and www.ksdl-erdgas.ch (hereinafter referred to as “Portal” or “Website”) in accordance with applicable data protection law and to implement appropriate security measures to protect it from unauthorized access. In this Privacy Policy, we inform you in particular about which personal data is collected and processed in connection with the use of the Portal, for what purposes it is used, with whom it may be shared if applicable, and what your rights are in connection with the use of your personal data by Swissgas. Personal data means all information related to an identified or identifiable natural person, e.g., surname, first name, address, e-mail, date of birth or telephone number.

By accessing the Portal and using our offered services and products, you declare that you have carefully read this Privacy Policy and agree to the data processing described. Any questions in connection with this Privacy Policy may be addressed by e-mail to datenschutz@swissgas.ch at any time. If you do not agree with this Policy, you must refrain from accessing the Portal and using our services and products.

Swissgas, Grütlistrasse 44, 8002 Zurich, e-mail: datenschutz@swissgas.ch, is the data controller within the meaning of data protection law.

Swissgas determines the purposes and means of processing your personal data and is therefore responsible for the processing and use of your personal data in accordance with this Privacy Policy. If you have any questions or concerns about this Privacy Policy or the processing of your personal data, please contact us at any time by sending an e-mail to datenschutz@swissgas.ch.

All personal data collected through the Website is processed in accordance with the applicable data protection laws. We collect and process personal data with due care and for the purposes described in this Privacy Policy. In accordance with applicable law, we may also use your personal data in ways other than those described in this Privacy Policy. In this case, we will provide you with specific privacy policies or notices at the time of collection and, if necessary, obtain your consent. Whenever possible, we make every effort to collect information in anonymized or pseudonymized form so that we cannot determine your identity.

Swissgas collects and stores information that your browser automatically sends us in “server log files” when you visit our Website. Data is collected based on your willingness to visit and interest in visiting our Website and our legitimate interest in running the Website. This information may contain the following data:

• Browser type and version
• Operating systems used
• Referrer URL (i.e. the previously-visited website)
• Host name of the accessing computer
• date and time of the server request
• Internet Protocol address (IP address)
• amount of data transferred
• other similar data and information used for averting threats in the event of attacks on our IT systems

This personal data will not be combined with other personal data and will be stored separately from any other personal data transmitted by the user. We will delete them after no more than three months.

Swissgas uses the personal data collected automatically to serve the following purposes:

• Enabling the display, operation and functionality of the Portal
• Ensuring the stability and security of the system
• Improving and protecting our services
• For statistical purposes in the event of attacks on the network infrastructure on which the Website is made available

Swissgas collects and processes personal data that the user voluntarily transmits to Swissgas directly via the on-line form on the Portal, via our contact e-mail address, through any other applications connected to the Portal, by telephone or in another way. This information includes, for example, the following personal data:

• Surnames, first names, postal addresses, e-mail addresses, telephone numbers, dates of birth, sex
• Your message or request

Provision of this personal data is made expressly on a voluntary basis. Without this personal data, however, we will not be able to provide the services requested by the user in the desired quality or at all.

Swissgas uses the personal data that the user transmits to us to serve the following purposes:

• Providing, maintaining, protecting and optimising the services and information offered
• Communicating with you and providing you with the best possible and personalised information you need from us (e.g. about our products and services)
• Complying with legal or other regulatory requirements and internal regulations
• Establishing, exercising and/or defending against actual or potential legal claims, investigations or similar proceedings
• For other lawful purposes when such processing results from the circumstances or was indicated at the time of collection

The processing of the aforementioned personal data is based on the following legal bases:

• Your consent, only if it can be revoked at any time
• For performing any contract with you or for the intent to conclude any contract with you
• To comply with a legal obligation (e.g. for tax reasons or for the purposes of judicial investigations or proceedings), or
• To safeguard our legitimate interests (e.g. protection and security of our services, systems, assets; compliance with legal, regulatory, and contractual obligations; establishment, exercise, or defence of legal claims; maintenance and efficient organization of business operations; improvement and development of our services; and sale and marketing of our services).

If the processing is based on your consent or our legitimate interests, you may withdraw the consent at any time or object to such processing by contacting us directly at datenschutz@swissgas.ch. Please note, however, that revocation of your consent does not affect the lawfulness of the processing based on this consent prior to its revocation.

Swissgas takes the necessary measures to ensure that only our authorised personnel and our vicarious agents with the necessary knowledge have access to your personal data in order to serve the purposes for which your personal data was collected.

We may disclose your personal data to the following possible categories of recipients in accordance with the purposes and legal bases for processing described above to the extent necessary for the intended data processing:

• Service providers that process personal data on behalf of and at the instruction of Swissgas (called commissioned data processors; for example, in the areas of IT, hosting and support)
• Customers, partners, suppliers, insurance companies and other business partners
• Industry organisations, associations, and other committees
• Courts, arbitration bodies, criminal prosecution authorities, regulatory authorities, attorneys and other parties in potential or actual legal proceedings, where necessary to comply with laws or to establish, exercise or defend rights or legal claims

We carefully select our partners and commissioned data processors and only when they provide sufficient assurance that they have appropriate technical and organisational measures in accordance with the statutory requirements. Our commissioned data processors may process personal data only based on documented instruction from us. They are all subject to confidentiality requirements and are only permitted to use your personal data to the extent necessary to fulfil the purpose for which your personal data was collected, unless otherwise required by law.

The personal data collected via our Website is stored in Switzerland. In addition, we may transfer, store and process your personal data at data locations around the world, e.g. where our third-party service providers or partners are located. We may therefore transfer your personal data outside the European Economic area (EEA) if this is necessary for the data processing described in this Privacy Policy in accordance with applicable law.

If data is shared with countries that do not provide an adequate level of protection, we will ensure appropriate data protection by taking appropriate safeguards, such as contractual guarantees (e.g. based on EU standard clauses), based on binding corporate rules, the transfer of data in accordance with your explicit consent, for the conclusion or performance of a contract with you or in connection with the establishment, exercise or enforcement of legal claims.

In principle, personal data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected, unless longer retention is necessary in order to fulfil legal obligations (e.g. retention and documentation obligations), contractual or pre-contractual obligations or legitimate business interests (e.g. to establish, exercise or defend legal claims).

On this basis, we generally process personal data in compliance with the following rules and obligations:

• The personal data transmitted automatically by you through the use of our Portal (see the chapter Collection of personal data and purposes of data processing, paragraph: Personal data transmitted automatically via use of the Portal) for the purpose of displaying, operating and ensuring the proper functioning of the Portal will be deleted within three to six months.
• The personal data that you transmit to us in connection with the use of our services and products offered on our Portal or that you otherwise transmit to us via the e-mail contact address (see the chapter Collection of personal data and purposes of data processing, paragraph: Personal data that the user transmits to us) is generally stored with us until you ask us to delete it, withdraw your consent to storage, or the purpose for data storage has lapsed (e.g. after your inquiry has been dealt with).
• For contract-related personal data (including business documents and notices), we store personal data for as long as the contractual relationship exists, and thereafter for ten additional years after the end of the contractual relationship, unless (i) a shorter or longer statutory retention obligation applies in individual cases, (ii) retention is required for evidentiary reasons or for another valid reason under applicable law, or (iii) deletion of the data is necessary earlier (e.g. because the data is no longer needed or because we have to delete the corresponding data).

When you access or use the Website, we may place cookies – small text files – or similar tools on your computer. We use these cookies to recognize you as a user of the Website, to adapt content, to improve the performance of the Website and to improve user-friendliness for you.

Depending on the function and purpose of the cookies we use, they can be divided into the following categories: necessary cookies, preference cookies, statistical cookies and marketing cookies.

• Necessary cookies: Necessary cookies facilitate using a website by enabling basic functions such as site navigation and access to secure areas of the Website. Without these cookies, the Website cannot function properly.
• Preference cookies: Preference cookies allow a website to remember information that influences the way a website behaves or looks, such as your preferred language or the region in which you are located. In addition, preference cookies serve a wide range of other purposes for the presentation, functionality and performance of a website and, in particular, to improve the experience and pleasure of visitors to the website. They enable a website to store information already provided (e.g. user name, location or language selection) and offer visitors enhanced, more personal functions.
• Statistics cookies: These cookies are used to collect information about how a website is used – e.g. how visitors came to our website, which pages a visitor most often opens, how you navigated on our Website during your visit, and whether you receive error messages from a page. We may also use these cookies to provide us with certain statistical and analytical information, e.g. how many visitors have come to our Website. These cookies are used to monitor the level of activity of the Website and to improve the performance of the Website.
• Marketing cookies allow us or a third-party provider to place advertisements on our Website or on third-party websites with products that the user likes, so that the advertisement the user sees can be more relevant to the user’s preferences or interests (sometimes also referred to as “targeting cookies”). They may also be used to assess the effectiveness of advertising and sales promotion. Whether such cookies are currently in use, and if so, which specific ones are used, can be found in the details of the cookie banner, which you can access at any time (even retroactively) in the footer navigation via the link “Cookie settings”.

These cookies may be placed by us or by a third party on our behalf. You can find out more about cookies and how they are used at: www.allaboutcookies.org/.

The legal basis for the data processing derives from your consent (Art. 6(1)(a) GDPR) or our legitimate interest (Art. 6(1)(1)(f) GDPR). Our legitimate interest in processing data derives from the need and desire to guarantee the quality, performance and convenience of our Website. We use functional cookies to enable the basic functionalities of our Website and ensure the safe operation of the Website. This includes, for example, retention of your registration data during a meeting or the provision of secure registration. We also use performance cookies to further improve the user experience and provide us with valuable insights into the use and performance of our Website. This enables us to analyse and improve the functionality and efficiency of our Website, which ultimately benefits our users. It is important to note that use of these cookies does not constitute unnecessary interference with the privacy of our users as all information is anonymized and is only used to improve the functionality and user experience of our Website. You can configure your browser settings in such a way that no cookies are saved on your computer. A full deactivation of cookies may mean that you are not able to use all of our Website’s functions.

By using our Website combined with consenting to this Privacy Policy, you consent to cookies being placed by us and therefore to the collection, storage and use of personal usage data, even after the end of the browser session. You can revoke this consent at any time by activating the browser default setting to refuse third-party cookies. In addition, when you first visit the Website, you have the opportunity to receive detailed information about all implemented cookies and to individually approve or reject certain cookie categories in the cookie banner displayed in the middle of the browser window. You can retroactively change and adjust this information and the individual settings at any time by clicking on the link “Cookie settings” in the footer navigation.

On its Website, Swissgas uses the Google Analytics website analysis service, which is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The cookies used by Google Analytics are stored on your computer and allow for an analysis of how you have used the Website.

We use Google Analytics based on our legitimate interests to analyse and regularly improve our Website as well as to regularly improve our content and make it more interesting for you based on the statistics obtained. In addition, Google Analytics is used based on your consent to the tracking of your browsing behaviour on our Websites and its analysis, unless you have objected to or subsequently object to this use in the cookie banner by accessing the “Cookie settings” link in the footer navigation and making the corresponding settings.

The information generated by the cookies about your use of this Website is generally transferred to a Google server in the USA and stored there. These cookies may contain, for example, the following information: IP address, number, date and time of the visit, duration of the visit, your access page from which you use the Website (reference URL), the pages visited on our Website, browser type/version and the operating system used. Google will use this information on our behalf because we have a legitimate interest in analysing user behaviour so that we can optimise the offerings on our website. Google uses this information to evaluate the use of our Website, to compile reports about the Website activities, and to provide additional services for us related to use of the Website and Internet usage. Pseudonymized user profiles of users can also be created from the processed personal data.

We have enabled the IP anonymisation function on this Website (known as IP masking). In this way, your IP address is shortened by Google within a Member State of the European Union, in another Contracting State to the Agreement on the European Economic Area as well as in Switzerland prior to transmission to the USA. Full IP addresses are only transferred to a Google server in the USA and shortened there in exceptional cases.

You can prevent the cookies from being stored by changing the corresponding setting in your browser software. Please note, however, that if you do this you may not be able to use the full functionality of this Website. In addition, you can prevent the transfer to Google of the personal data generated by the cookie and related to your use of the Website (including your IP address), as well as the processing of this personal data by Google, by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout. For additional information about the handling of user data at Google Analytics, see the Google Privacy Policy: support.google.com/analytics/answer/6004245.

In addition, Google may review the user’s use of the Website and possibly combine the collected personal data with other information about the user that Google has independently collected from other websites visited by the user and may use this for its own purposes (e.g. to control advertising) on its own responsibility on the basis of its own privacy policy. Further information on this and on how Google processes personal data can be found in Google’s corresponding privacy policies: policies.google.com;

You can receive a list of all cookies and their purpose and storage period by clicking on the link “Cookie settings” in the footer navigation and by opening the corresponding folding elements under “Details”.

Swissgas has implemented organisational and technical measures to safeguard the security of personal data and protect it against unauthorised or unlawful processing, accidental loss, alteration, publication or access.

Swissgas may use third parties as data processors to collect and process your personal data. The data processors commissioned by us will only process your personal data in accordance with our instructions and are required by law to take strict security precautions when handling personal data.

Unfortunately, the transmission of information via the Internet is not entirely secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our Website in all cases; each transfer is made at your own risk. For this reason, you are free to transfer your personal data to us by other means at any time, e.g. by telephone. Once we have received your data, we use strict procedures and strict security features to prevent unauthorised access.

Please note that if you click on the link to a third-party website, you will be directed to a website that we do not control, and our Privacy Policy will no longer apply. Your browsing and the interaction on another website are subject to the terms of use and the privacy policies and notices of these third-party websites. Moreover, we also cannot guarantee the correctness and topicality of these links.

We recommend that you read the terms of use and the privacy policies and notices of other websites carefully before you transmit personal information via these websites. We are not responsible or liable for the information content and data processing of such third-party websites.

Our website is not intended for children and we do not knowingly collect personal data from children under 16 years of age unless we have the parents’ express consent. If we are notified or otherwise learn that personal data of a child under 16 has been improperly collected, we will take all reasonable steps to delete such personal data.

You can request information from Swissgas as to whether personal data about you is being processed. In addition, you have the right to request the correction, destruction or restriction of personal data about you and to object to the processing of your personal data. To the extent that the processing is based on your consent or our legitimate interests, you may revoke this consent at any time or object to such processing by contacting us directly by e-mail to datenschutz@swissgas.ch. In certain cases, you have the right to receive personal data arising from the use of on-line services in a structured, commonly used and machine-readable format so that further use and transmission to any third-party provider is possible.

Any requests in this regard should be addressed to Swissgas via the following e-mail address: datenschutz@swissgas.ch. Swissgas reserves the right to restrict your rights within the scope of applicable law and, for instance, not to disclose comprehensive information or delete personal data.

If we reject your application or if you are not satisfied with our processing, you also have the right to lodge a complaint with the competent supervisory authority and appeal to the competent authority. For users based in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC). (www.edoeb.admin.ch). For users resident in EU countries, a list of supervisory authorities can be found under ec.europa.eu/newsroom/article29/item-detail.cfm.

Swissgas reserves the right to amend, supplement or otherwise modify this Personal Data Privacy Policy at any time and without stating any reasons. The Personal Data Privacy Policy as currently published on the Portal shall apply.