- Where we may obtain your personal data;
- What categories of your personal data we may process;
- Why we collect and process your personal data, i.e. for what grounds we process it;
- How we collect and process your personal data, including the protection measures we implement.
Privacy is of utmost importance at LEM and its respect is taken into account at every step of data processing. We especially do not trade or sell personal data that has been entrusted to us and value overall the trust people place in us. We promote industry best practices to ensure privacy concerns are addressed and that personal data is protected.
1. All individuals who provide personal data to us (customers, suppliers, business partners, shareholders, ultimate beneficial owners, job applicants, agents, among others, to the exclusion of LEM employees, whose personal data is processed according to specific internal regulations).
2. All locations where we operate, even where local regulations do not exist.
3. All online or offline methods of contact such as Internet, mail, telephone or email.
Each LEM Entity may obtain your personal data from several sources, such as:
We may collect various categories of personal data that can specifically identify you, especially:
We do not collect sensitive personal data about you, except upon your express prior consent or unless required by law.
We process your personal data based on the following grounds:
Overall, we limit the collection and processing of personal data to what is required in order to achieve our goal of providing superior quality and value. For example, we use email addresses to send consumers or shareholders or job applicants information they have requested and/or should receive based on the relationship with us. Consumer feedback on products and services is used to improve our products and services.
We do not keep personal data any longer than necessary to meet the business purpose for which it was collected, respect our operational requirements or respect legal or regulatory imperatives. At the end of the applied retention period, we shall delete your data without it being required that any further information be provided to you.
Should you wish specific information on the retention period applied to your data and/or the criteria used to determine such period, please contact us at the email address provided below (“CONTACT INFORMATION”).
data sharing and transfer
Your personal data may be transferred to various LEM Entities, especially through the use of common databases or a common management of data to LEM and the LEM network. Especially, the processing of your personal data as described above may require that your personal data be ultimately transferred to and/or stored at a destination outside of your country of residence.
Overall, our global privacy program requires the same high level of security and protection of personal data in all countries and locations, with procedures and contracts in place to help ensure this. Especially, any transfer of personal data from the European Economic Area (EEA) or Switzerland to countries that do not provide an adequate level of protection by law, take place using an acceptable data transfer mechanism, especially through the use of Standard Contractual Clauses.
Your personal data may also be transferred to third parties contractors and processors, especially agents, vendors and professional advisors. Such contractors provide services to LEM, including mailing information or samples, cloud services and other IT services. These agents, vendors and business partners are bound by obligations of confidentiality and are required to protect and manage your personal data to the same high standards as the ones that apply to LEM.
LEM may also be required to disclose your personal data to regulatory and supervisory authorities in order to comply with any law, regulation, court order or government request.
In the event that all or part of LEM’s business is acquired by a third party, your personal data may be transferred to the new owner. Such transfer may also intervene prior to such acquisition in the context of a due diligence process, in which case the reviewing party shall be bound by obligations of confidentiality and be required to protect and manage your personal data in conformity with applicable laws.
LEM HOLDING SA, whose equity securities are listed on SIX Swiss Exchange, is required to forward data on LEM’s directors, officers and agents, as well as any other person who would be linked to LEM's listing, to SIX Exchange Regulation Ltd on the basis of legal and regulatory requirements. This relates in particular to the Federal Act on Financial Market Infrastructures and Market Conduct in Securities and Derivatives Trading and the Federal Act on the Swiss Financial Market Supervisory Authority, as well as the respective regulations and self-regulation of the FINMA and SIX.
LEM’s directors, officers and agents, as well as any other person who would be linked to LEM's listing, are informed that:
LEM is committed to keeping personal data secure and protects it by industry standard security practices and measures, in order to prevent loss, misuse, unauthorized access, disclosure, or alteration. We apply to this purpose appropriate technical, administrative and physical procedures in place.
Access to data is limited to individuals who have a business need consistent with the reason the data was provided.
In accordance with applicable regulation, you may also be entitled to file a complaint with the competent supervisory authority if you feel your personal data has been mishandled or if we have failed to meet your expectations. You are encouraged to contact us about any complaints or concerns prior to such a step, but you are naturally entitled to complain directly to the relevant supervisory authority.
Please note that, in order to ensure that you are the data subject allowed to exercise these rights, we may ask you for a proof of identity (copy of official identification document with a photo mentioning your date and place of birth).
Any request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such personal data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, we may charge you a reasonable request fee according to applicable data protection legislation.
In any case, we may refuse, restrict or defer the provision of personal data where the applicable regulation allows us to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.
You can exercise any of your rights by contacting us at the email address provided below (“CONTACT INFORMATION”).
If you have any queries or comments in relation to processing your personal data or exercising of any of the rights listed above, please contact us via the following email address: email@example.com.