1. Preamble

Fricode Sàrl, located at Boulevard de Pérolles 93, 1700 Fribourg, collects and processes personal data about you. We comply with current legal provisions, particularly the LPD.

In this data protection declaration, we describe how we handle your data when you use our website, subscribe to our newsletter, purchase our products and services, are in contact with us within the framework of a contract, communicate with us, or deal with us in any other way. We may also separately inform you about the processing of your data, for instance, in consent forms, general terms and conditions, supplementary declarations, forms, and other notices.

If you provide us with data or share data about other people, such as family members or colleagues, we assume you are authorized to do so. By sharing data about other people with us, you confirm this authorization. Please ensure that these individuals have been informed about this data protection declaration.

2. Who processes your personal data?

Fricode Sàrl, Boulevard de Pérolles 93, 1700 Fribourg (hereinafter "the company"), is responsible for data processing under this data protection declaration.

You can contact us regarding data protection issues and to exercise your rights under Section 8 as follows:

By postal mail: Fricode Sàrl, Boulevard de Pérolles 93, 1700 Fribourg;
By email: contact@fricode.ch;
By phone: +41 26 422 16 00.

3. What data do we process about you?

We process the following main categories of data:

• Identity and Contact Data: We process your basic data if you are a customer or another business contact, or if you work for one (e.g., as a contact person for a business partner), or because we wish to contact you for our own or a contractual partner’s purposes. This includes your name, first name, functional role, postal address, email address, phone number, bank details, date of birth, customer history, and consent declaration. We receive this data from you (e.g., when you make a purchase or register, particularly for our newsletter), from the people you work for, or from third parties such as contractual partners.
• Contract Data: This includes data collected in the context of contract conclusion or execution, such as contract information and services provided or to be provided, as well as data related to the period before contract conclusion, required or used information for contract execution, and customer feedback (e.g., complaints, customer satisfaction data, etc.). We typically collect this data from you, contractual partners, and third parties involved in contract execution, as well as from third-party sources (e.g., credit information providers) and public sources.
• Accounting Data: In the context of our contractual relationship, we record billing-related data, such as invoices, invoice amounts and due dates, reminders, receipts, VAT numbers, etc. We may also collect payment method information.
• Registration Data: Subscription to our newsletter service can only be used after registration, which can be done directly with us. In this context, you need to provide your email address, and we collect data on the use of the service.
• Communication Data: When you contact us via the contact form, email, phone, chat, mail, or other means of communication, we collect and record the data you exchange with us, including your contact details and any communication metadata, possibly via reports. If we need to determine your identity, for instance in the context of an access request, we collect data to identify you (e.g., a copy of an identity document).
• Technical Data: When you use our website or other online offers, we collect various technical data (notably IP address, information about your device's operating system, the region, and time of use) to ensure the functionality and security of these offers. This also allows us to optimize our services. This data includes usage logs of our systems.
• Behavioral and Preference Data: Depending on our relationship with you, we try to better understand you and tailor our products, services, and offers to your needs. To this end, we collect and process data about your behavior and preferences, particularly in connection with our website. We do this by evaluating information about your behavior in our field and may also supplement this information with data from third parties, including public sources. Based on this data, we may, for example, determine the likelihood of you using certain services or behaving in a certain way. The data processed for this purpose is either already known to us (e.g., where and when you use our services), or we collect it by recording your behavior (e.g., how you navigate our website). We anonymize or delete this data when it is no longer relevant to the purposes pursued, depending on the type of data. Preference data indicates your needs, which products or services might interest you, or when and how you are likely to respond to our messages. We obtain this information from analyzing existing data, such as behavioral data, to better understand you, tailor our advice and offers more precisely to your needs, and generally improve our offers. To improve the quality of our analyses, we may combine this data with other data we also obtain from third parties.
• Other Data: We also collect data about you in other situations. For instance, we process data that may concern you (such as records, evidence, etc.) in the context of administrative or judicial proceedings. We may also collect data on people entering certain buildings, and when, or on people with access rights (including in the context of access controls, based on registration data or visitor lists, etc.), on people participating in events or campaigns (e.g., contests), and on people using our infrastructure and systems and when.

4. For what purposes do we process your data?

We process your personal data to:

• Conclude and execute contractual relationships according to the provisions of the contracts;
• Communicate with you by any appropriate means of communication to answer your questions about our services, offer our services and help, and record complaints and claims;
• Communicate your data to our contractual partners so they can contact you if you consent beforehand;
• Perform statistical analyses;
• Ensure our activities comply with applicable laws and our internal regulations. Data processing also allows us to defend against any claims from you;
• Analyze risks, detect abuses, implement security measures, and verify their effectiveness;
• Respond to your questions and requests regarding data protection, especially when you wish to exercise your rights provided by law;
• Send you commercial or promotional communications (marketing) through channels you choose, such as our newsletter, perform profiling by combining various personal data to better understand your interests and preferences among our products and services. Some marketing processes involve sharing your data with contractual partners; you can object to marketing processes at any time free of charge.

5. What legal bases do we use to process your data?

Most of our data processing is strictly necessary for concluding, executing, and liquidating contracts with you. Without this processing, we cannot guarantee the services we commit to providing under the contracts.

Other processes are based on our legitimate interest or that of a third party. This includes processing for marketing, security, and statistical purposes. The same applies to defending our interests in court and managing disputes, especially those without a contractual basis.

Some processes may be required by Swiss or foreign law. If not directly imposed by law, they will be based on our legitimate interest in complying with applicable legal provisions.

Your consent will also serve as a basis when necessary (e.g., for certain marketing processes or sending newsletters). In such cases, we will specifically inform you of the processes requiring your consent, and you remain free to give it or not. Upon request, we will inform you of the consequences if you refuse to consent. When you give your consent, you remain free to withdraw it at any time, without justification and easily. The withdrawal is effective for the future and does not affect the processes carried out until the withdrawal. The process concerned by the withdrawal of consent will stop immediately unless it can continue based on another legal basis (e.g., our legitimate interest).

6. To whom do we communicate your data?

In the context of the contractual relationship with you and other purposes mentioned in section 4 above, we may communicate all or part of your data to the following recipients:

• Contractual Partners: We collaborate with partners to provide the services specified in the contracts binding us to you. We only communicate personal data about you that is absolutely necessary for providing their services. This may include leasing providers for financing printing equipment.
• Service Providers: We work with various service providers to implement certain data processes and carry out certain activities. These include IT providers (hosting), financial services (e.g., banks, insurers, financial intermediaries, online payment services), accounting service providers (trustees, auditors), or legal service providers.
• Third-party service providers who allow us to analyze data related to the use of our website, such as Google Analytics (cf. cookie policy).
• Authorities: When legally required, allowed, or in our interest, we communicate personal data about you to Swiss or foreign authorities.

7. Do we transfer your data abroad?

We work with providers and partners not all located in Switzerland. We transfer certain personal data to them when this transfer is necessary for the purposes described in section 4 above and complies with applicable legal frameworks.

We also use IT services from foreign providers. We strive to keep the data in Switzerland, but this is sometimes impossible. In such cases, we prioritize the European Economic Area and countries offering an adequate level of protection. For example, one of our hosting providers is located in France.

8. What are your data protection rights?

Your rights regarding your personal data include:

• Requesting information about your personal data that we process and a copy of said data;
• Requesting correction or completion of incorrect or incomplete data;
• Requesting deletion of your data, unless a legal basis or our legitimate interest requires or authorizes us to keep your data longer;
• Requesting the limitation of the processing of your data;
• Revoking your consent to data processing for which your consent was requested at any time;
• Objecting at any time to the processing of your personal data for promotional and advertising purposes;
• Objecting at any time to any other processing, unless a legal basis or our legitimate interest requires or authorizes us to continue processing;
• Requesting your data in a portable format when the data processing is automated, based on your consent or a contract;

• Contacting the FDPIC (when processing falls under the LPD) at Feldeggweg 1, 3003 Bern.

9. When do we update this declaration?

This declaration can be updated at any time. The version published here on our website is the most recent and authoritative version. It replaces all previous or conflicting general data protection clauses. Users of our website or social media pages are required to read our data processing policy and stay informed of its developments. By continuing to access or use our website or social media pages after the modification takes effect, you agree to be bound by this revised data processing policy. If you do not accept these changes, please refrain from using our website and social media pages. For our contractual and commercial partners, you will be informed by email or any other means deemed equivalent in case of substantial changes to our data processing policy.

Last update: June 2024.