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Data Protection Provisions of Exelero AG
Version 1.0 as of 08/28/2023
Welcome to our privacy policy.
Here we explain what data we collect and how we use it.

Foreword

The protection of your personal data has the highest priority at Exelero. We always use your data in accordance with applicable data protection laws, in particular the Swiss Data Protection Act (hereinafter: "DPA") and the EU General Data Protection Regulation (hereinafter: "GDPR"), as well as in accordance with these data protection provisions (hereinafter, collectively, "applicable data protection laws"). With the following Privacy Policy we would like to inform you comprehensively about the data processing carried out through our offer and the use of our platform, pages, applications and services. We encourage you to read our privacy policy carefully. If you have any questions or comments about our processing of your personal data, you can contact us at any time at the e-mail address listed in #2 ("Who is responsible for processing your personal data and how can you contact us?").

1. Overview

The following privacy policy informs you about the nature and scope of the processing of personal data by Exelero AG, Via Livio 1, 6830 Chiasso, Ticino (TI), Switzerland (hereinafter: "Exelero", "we", "us" or "our"). Personal data is information that can be attributed or assigned directly or indirectly to a person. The processing of your personal data as part of your use of our Platform and all related pages, applications, products and services is subject to this Privacy Policy.

These data protection provisions apply to the processing of data from the Exelero offering, in particular through our platform https://exelero.com (hereinafter "Platform" or "Product").

Data processing by Exelero can be summarized essentially as follows:

  • For the purpose of contract processing or making our platform available, all data necessary for the fulfillment of the terms of use or service agreement with Exelero, as well as for the further development of our offer, will be processed. If external service providers, e.g. companies advertising jobs, optimization services, hosters, CRM tools, etc., are also involved in the processing of the agreement, your data will be transmitted to them to the extent necessary in each case and in accordance with applicable data protection laws.
  • When you access our platform, various information is exchanged between your terminal and our server. This may also include personal data. The information thus collected is used, among other things, to analyze the use of our offer and to further optimize it.
  • If you contact us by e-mail, contact form or other means of contact, if we have an existing business relationship with you or if you register for an event or to receive advertising or a newsletter from us, we process your personal data to the extent necessary in each case to communicate with you and to send you this advertising/newsletter.

In accordance with the requirements of applicable data protection laws, you have several rights that you can assert against us. These include the right to object to certain data processing, in particular data processing for advertising purposes, the right to receive information about your data processed by us, or, in some cases, the right to have your personal data stored by us deleted. Further information about your rights can be found in Section 6 ("What rights do you have in relation to your personal data?") of this Privacy Policy.

If you have any questions about our privacy policy, you are welcome to contact our data protection officer directly at any time via the e-mail address given in Section 2 ("Who is responsible for processing your personal data and how can you contact us?"). We will always strive to answer your questions in a complete and timely manner.

2. Who is responsible for processing your personal data and how can you contact us?

Exelero is responsible for processing your personal data in accordance with this Privacy Policy. Our data protection officer can be contacted at: Exelero AG, Data Protection Department, Via Livio 1, 6830 Chiasso, Ticino (TI), Switzerland or at hello@exelero.com.

3. Why and on what legal basis do we process your personal data?

3.1 Visiting our website If you visit our website, especially our platform, information is automatically sent to our servers from the platform and the browser used on your end device and stored temporarily in a so-called log file. The following information is collected without your intervention and stored in the log file until it is automatically or manually deleted:

  • the IP address of the device used,
  • the device used,
  • the date and time of access
  • the name and URL of the file accessed, the website from which the access was made (referral URL),
  • the unique identifier of the browser used,
  • the name of your Internet provider. The processing of this data is based on our legitimate interest d as provided by the DPA for Switzerland and the GDPR for EU countries. Our legitimate interest derives from the purposes of data collection listed below. At this point, we would like to emphasize that it is not possible for us to draw conclusions about your identity from this collected data, nor will we. The IP address of your terminal and the other data listed above are used by us for the following purposes:
  • To ensure a smooth connection and functionality of the platform,
  • Ensuring comfortable use of our offering
  • Evaluating the security and stability of the system, and
  • other administrative purposes. In addition, we use cookies, tracking tools, targeting methods and interfaces with other services, such as social media platforms or job boards, for our offer. The exact procedures and how your data is used for this purpose are explained in more detail in section 3.5 ("Online Presence and Website Optimization") of this privacy policy and in our cookie banner.

3.2 Termination, implementation, or termination of terms of use for applicants.

We view our offering as an innovative placement platform. Our stated goal is to be able to offer each user the job offers that are a perfect fit. If you register on our platform by creating a user login, we use your data to fulfill this purpose, that is, to help you apply for a job through our platform (see Section 3.2. 2, "Data Processing for Applying for a Specific Job") and to find new companies where it might be interesting for you to work, and to offer you jobs that match your requirements profile and your presumed personal interests and needs as specifically as possible and, consequently, not to bother you with unnecessary job offers (see Section 3.2.3 below, "Data Processing for Transmitting Job Vacancies"). For this purpose, we classify and add additional information to your profile. For this purpose, we use statistical information and information about you (e.g., your basic user login data and application documents that have not been deleted or completed), data from your previous application processes through Exelero, as well as publicly accessible data about you to increase the placement rate. The legal basis for the purposes described above is our fulfillment of the contract with you under LC, OC and DPA for Switzerland and GDPR for EU countries. If your consent is required for this data processing, we will explicitly obtain it from you before collecting your personal data. You have the option to change or delete the settings and data of your user login and related application process at any time. Please note that if you do not provide the necessary data for the fulfillment of the purpose, you may no longer be able to fully use our services. Below you will find a detailed list of the processing purposes and categories of data we process to fulfill our obligations to you, provided you have a user login with us or have not terminated your contractual relationship with us:

3.2.1 Data processing during the creation and use of a user login

To create and manage a user login, we need and process the following user data:

  • Email address (required for creating the user login),
  • Contact data,
  • First and last name (mandatory for creating the user login),
  • Curriculum vitae, if applicable,
  • References, if applicable,
  • Data that you have sent or entered yourself and that were generated from the use of our offer, such as cover letter or letter of application, stated qualifications, work experience, preferences, diplomas, certificates, continuing education, etc., if applicable.

3.2.2. Data processing when applying for a specific job.

If you apply for a specific position advertised through our platform, we will process and transmit the following data to the advertising company:

  • Email address,
  • Contact data.
  • Full name,
  • Curriculum vitae, if applicable,
  • References, if applicable,
  • Data that you yourself provide or enter and that is generated through the use of our service, such as your cover letter or application, qualifications, work experience, preferences, publicly available profiles, diplomas, certificates, further education, answers to questions a company asks in connection with an application, etc. To enable you to apply for certain job vacancies through our platform and to manage your application process, as well as to be able to offer you suitable jobs, we also process your personal data to send you informational, confirmation or feedback e-mails. We may send these emails directly to you or on behalf of and on behalf of the companies to which you have applied. If you apply for a specifically advertised position, we will forward your data, particularly your application documents and related information, to the advertising company. The advertising company can then view your user login.

3.2.3. Data processing for the transmission of job vacancies ("proposal function")

We use your user login data to propose job vacancies to you as interesting and corresponding to your real or presumed needs as possible without disturbing you with unsuitable offers. To carry out this analysis and forward you suitable job offers, we analyze your personal data and match them with the requirements of job vacancies. As soon as a new vacancy is posted on our platform, we process the following data to check whether it matches your profile and whether we should forward the job offer to you:

  • Curriculum vitae, if applicable,
  • all data submitted or entered by you, such as your cover letter or application letter, indicated qualifications, work experience, preferences, etc,
  • publicly accessible data about you,
  • data generated through your use of the platform, such as metadata including, but not limited to, your start date or salary preferences, which are communicated through our platform,
  • data generated through interactions with your Exelero profile, including your applications, such as responses to questions asked by a company in connection with an application, undeleted application materials, contacts with companies or Exelero, notes about pending or completed applications, information about the status of the application process, etc. If the matching process described above shows that you are likely interested in the vacancy, we will use your e-mail address and more general contact information or contact you through our platform to make you aware of this vacancy. You can then decide for yourself whether to apply for this position. If you do not wish to receive such offers in the future or if you wish to revoke your consent to the automatic transmission of your profile data to advertising companies, you can unsubscribe from such notifications or revoke your consent at any time. To do so, you can use the appropriate unsubscribe button in the e-mail that was sent to you or send us a brief note via e-mail to the e-mail address given in Section 2 ("Who is responsible for processing your personal data and how can you contact us?"). Please note that if you cancel, you may no longer be able to make full use of our services, particularly the transmission of job offers.

3.3 Conclusion, execution or termination of the service agreement for companies/corporate clients.

We see our offering as an innovative placement platform. Our goal is to offer our clients a platform on which they can, among other things, post job ads and receive and manage application data. Therefore, both you and the company you work for must register with us in order to

  • post job ads on our platform (including multiposting),
  • hire new employees, interns or other staff,
  • receive and manage applications for open positions, or
  • use our service to analyze the Exelero profiles of registered candidates and suggest suitable job postings to them. To provide these services, we process your personal data that you provide to us through the platform. The legal basis for the purposes described above is our fulfillment of the contract with you or your organization under the LC, OC and DPA for Switzerland and GDPR for EU countries. If your consent is required for this data processing, we will explicitly obtain it from you before collecting your personal data. You have the ability to change or delete your employee login and company account/company profile settings and data, the applicant management tool, and our platform in general at any time. Please note that if you do not provide us with the necessary data to fulfill the above purposes, you may no longer be able to fully utilize our services. Below you will find a detailed list of the categories of data we process to fulfill our obligations to you, provided that you have an employee login or your company has a company account/company profile with us or your service contract has not been terminated.

3.3.1 Data processing while creating and using a corporate account

To use our platform, you and the company you work for must register with us and create a corporate account. Thereafter, other employees in your organization can also register and use our platform or offering (see the section "Data Processing During Employee Login Creation"). To create and manage a company account, we need and process the following data about you and your company:

  • E-mail address (mandatory for user account creation),
  • Contact information (mandatory for user account creation),
  • First and last name (mandatory for user account creation),
  • Information about the company you work for, such as company name, company address, contact details of company representatives, etc.

3.3.2 Data processing when creating employee logins

Once the company account has been created, you may be invited as additional employees to register on our platform in connection with the company account and create your own login to create and post job ads, manage applications or contact candidates. In this context, we require and process the following personal data:

  • Email address (mandatory for the creation of the employee's user account),
  • First name, last name (mandatory for the creation of the employee's user account),
  • Contact data,
  • Data related to the user's role in the company, such as position or title.

3.3.3 Data processing when creating job advertisements and company profile

If you create a job announcement for a vacant position in your company on our platform and have us handle it or create a company profile, we process the following data about you, your company's employees, and your company:

  • E-mail address and other contact information of the person responsible for the job announcement in your company,
  • Contact information of the person who will receive applications,
  • All information about the company that you include in the company profile, such as company name, company address, contact information of company representatives, number of employees, turnover, key figures, key employees, text, images, graphics and links, logos, etc,
  • any other personal data or other information you include in the job description (e.g., job title, department, salary details, potential supervisor contact details, job requirements profile, company information, etc.,)
  • data generated by the use of Exelero, such as metadata, which includes information about how long the ad is to remain online, where it is to be displayed, how often an ad is clicked on, how many applications you receive for the ad, etc.,. This personal data is processed to enable us to manage the job ads on behalf of you and your company and to enable your company to create a company profile on our platform. The job ads we post and manage for you are generally publicly accessible.

3.3.4 Data processing for managing the application process.

If a candidate applies for a job advertisement in your company, we process the following personal data for the purpose of forwarding the application to you and managing the application process:

  • contact details of the candidate and the person responsible for the application process in your company,
  • all documents that the candidate sends us as part of the application through the platform and that we forward to you,
  • all information related to the application process that is captured on our Platform, such as messages you send through our Platform, information about the application process and a candidate's progress in the application process that is captured on our Platform, or questions asked as part of the application process that are captured on our Platform, etc,
  • publicly available data about your company,
  • data generated by the use of Exelero, such as metadata. These include information about the duration of the application process, the number of candidates who applied, the progress of the application process, etc, Through your interactions with your Exelero profile, including data generated by the candidate management tool, such as answers to questions asked of candidates, your self-reported and undeleted data in the candidate management tool, contacts with candidates or with Exelero, etc. This personal data is processed to enable you to use our platform to process and manage the application process.

3.3.5. Data processing for finding perfect candidates ("suggestion function")

In order to help you and your company find the perfect candidate for a job advertised by you, we analyze the personal data of candidates registered on our platform and match them with the requirements of job vacancies. In order to suggest suitable candidates for the job vacancies you advertise, we process the following data:

  • Data related to your company, such as company name, company address, contact details of company representatives,
  • Company profile data, such as company name, company address, contact details of company representatives, number of employees, turnover, key figures, key employees, texts, images, graphics and links, logos, etc,
  • information contained in the job description, such as job title, department, salary details, contact details of potential supervisor, job requirements profile, company information, etc...,
  • publicly available data about your company,
  • data generated by the use of Exelero, such as metadata. These include, among other things, information on the length of the application process, the number of candidates who applied, how they applied, how long the ad stays online, where it is to be displayed, how often the ad is clicked on, the number of applications received for the ad, etc..., Through your interactions with your Exelero profile, including data generated by the candidate management tool, such as answers to questions you ask candidates, your self-registered and undeleted data in the candidate management tool, contacts with candidates or Exelero, etc. Once we identify a candidate who might be interested in the vacant position, we forward the advertised position to them so that they can apply to you and your company. During the process, all personal information contained in the job description, including the contact information provided, will be forwarded by the person responsible for your company. An application after being contacted by us is completely at the discretion of the candidate and we cannot guarantee that the candidate will act. If a candidate has consented to the forwarding of his or her contact information directly to you and your company in case of probable interest, you may contact him or her yourself in case of interest.

3.3.6. Data processing for billing purposes

If you use one of our paid services or products we process the following personal data about you for the purpose of billing or processing any other charges:

  • Your contact information, such as (billing) address, telephone number, e-mail address, last name and first name,
  • Information about the company where you work, such as company name, company address, contact details of company representatives,
  • Payment information, such as bank details.

3.4 User and customer support

3.4.1 Intercom

To process service, support and other user requests, we use the support tool of Intercom Inc., 55 2nd Street, 4th Floor, San Francisco, CA 94105, USA ("Intercom") as part of our contractual obligations and services. If you submit a support request through one of our channels (e.g., contact form, live chat, email, etc.), the following data - depending on the content and contact channel selected - will be processed through Intercom's servers:

  • Data entered by the user,
  • Name,
  • E-mail address,
  • Browser information,
  • IP address,
  • Current page you are on at the time of the request,
  • date and time. For the secure transfer of your data to Intercom abroad, we have obtained contractual guarantees through standard contractual clauses in accordance with Section 5 ("Recipients of your personal data outside Switzerland or the EU") of this Privacy Policy. More information about Intercom's processing of data is available in Intercom's Privacy Policy. If you have any questions, you may also contact Intercom's Data Protection Officer directly at legal@intercom.com.

3.5 Online presence and website optimization.

We will not sell or rent your information to third parties for their marketing purposes without your explicit consent. Only to provide you with the best possible offer, to improve the quality of our offer from time to time, and to protect the interests of our users, we will share some data with third parties under certain circumstances; however, sharing is always subject to strict limitations, described in more detail below:

3.5.1 Cookies - General Information

We use so-called cookies on our website. Cookies are small files created by your browser and stored on your device (laptop, tablet, smartphone, etc.) when you use our services. The cookies used do not cause any harm to your end device and do not contain viruses, Trojans or other malware. Information is stored in the cookie that occurs from time to time in relation to the specific end device used. However, this does not mean that we learn directly about your identity. The use of cookies serves on the one hand to make the use of our offer more pleasant. We use so-called session cookies to recognize that you have already visited individual pages of our website or that you have already logged in with your user account. If you use our offer again at a later time, the cookie automatically recognizes that you have already been to us and what entries and settings you have made, so that you do not have to enter them again. We also use temporary cookies to make it easier for you. These are automatically deleted after the user has left our website. If you already have a user account and have logged in, the information stored in cookies will be assigned to your user account. On the other hand, we use cookies to statistically record and analyze the use of our offerings and to evaluate them in order to optimize them for you, as well as to display personalized information, such as current job openings. These cookies allow us to automatically recognize, when you visit our site again, whether you have already been to us or whether you arrived at us through a job ad we posted with third-party vendors. These cookies are deleted automatically after a specified period of time. Without your explicit consent, we do not use cookies beyond what is necessary for the optimal display and functionality of our site. You can manage or revoke your consent at any time, free and easy, here. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or that a message is always displayed before a new cookie is created. However, disabling cookies completely may result in unavailability of all functions of our platform. The retention period of cookies depends on their purpose and is not the same for everyone.

3.5.2 Google Analytics

For the purpose of demand-driven design and continuous optimization of our platform, we use the analytics service Google Analytics from Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google creates pseudonymized usage profiles using cookies. The lifetime of these cookies is three months. The information generated by the cookie about your use of our platform is as follows

  • browser type/version
  • operating system used
  • the device being used,
  • Referring URL (the page previously visited),
  • Host name of the accessing computer (IP address),
  • time of the request to the server,
  • demographic data This data is transferred to a Google server in the United States and stored there. The information is used to evaluate bid usage, to compile activity reports, and to provide other services related to bid usage for the purposes of market research and demand-driven design. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. IP addresses are anonymized so that no attribution is possible (so-called IP masking). You can prevent the collection of data generated by the cookie and related to your use of our offer (including your IP address), as well as the processing of this data by Google and object to further processing by the cookie by downloading this browser add-on. You can object to the use of the cookie at any time with effect for the future by clicking here. On mobile devices, we recommend using the private mode. For more information about privacy in relation to Google Analytics, please visit the Google Analytics website. If you have a Google account and are logged in when you visit our site, Google may combine and store data collected on our site with data Google already has on you and use it for its own purposes.

3.5.3 Bing Ads

To recognize whether someone clicked on one of our ads, was redirected to our website, and reached a previously determined landing page ("conversion site"), we use Bing Ads (bingads.microsoft.com) technologies, provided and operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft"). Microsoft sets a cookie on your device if you have accessed our website through a Microsoft Bing ad. The lifetime of these cookies is one year. Microsoft only learns about the total number of users who clicked on a Bing ad and were then redirected to the conversion site. Microsoft collects, processes, and uses information via the cookie, from which usage profiles are created using pseudonyms. These usage profiles are used to analyze visitor behavior and to display advertisements. No personal information about the user's identity is processed. The information generated by the cookie is

  • browser type/version
  • the operating system used
  • the device being used
  • Referral URL (the page previously visited),
  • Host name of the accessing computer (IP address),
  • time of the request to the server,
  • Demographic data This data will be transmitted and stored by Microsoft on servers located in the United States or Europe. If you do not want Microsoft to use information about your behavior as explained above, you can prevent the collection of cookie-generated data about your use of the website, as well as Microsoft's processing of that data, by declaring your objection here. For more information about privacy and cookies used by Microsoft and Bing Ads, please see the privacy policy on Microsoft's website.

3.5.4 Facebook Ads

To use Facebook campaigns as needed, to further optimize them and to measure their conversion, we use a so-called visitor action pixel from Facebook Ireland Ltd. a so-called visitor action pixel from Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). This pixel is integrated into the code of our platform. On the one hand, this allows us to ensure that the Facebook ads we initiate are displayed only to Facebook users who have shown interest in our offer. In this way, we want to ensure that our Facebook ads match the respective user's potential interest and do not annoy them. On the other hand, this allows us to track the actions of Facebook users after they have seen or clicked on one of our Facebook ads. This helps us measure the conversion of the respective campaign for statistical, market research and billing purposes. The following information is processed during distribution:

  • Timestamp,
  • URL,
  • campaign-related information (especially impression specification, form field, activated button). The data collected in this way are anonymous for us and therefore do not allow us to draw conclusions about the identity of the respective user. If you log into your Facebook account after activating the pixel, or if you visit our website while logged in, it is possible that this data is stored and processed by Facebook, which we inform you about here. Facebook may link this data to your Facebook account and use it for its own advertising purposes, in accordance with Facebook's data usage policy: https://www.facebook.com/about/privacy/. You may allow Facebook and its partners to serve ads on and off Facebook. You can opt out of this specific data processing at any time by changing your Facebook settings. Please note that the stated objection applies only to the respective device used. For more information, see Facebook's privacy policy and privacy protection information.

3.5.5 Stripe payment processing service

If a company has decided to use our paid services, for the purpose of payment processing, with the consent of the contact person or for the fulfillment of our contractual obligations, we will use Stripe. We will forward the data transmitted by the performing person, e.g. name and e-mail address, to our payment service provider Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland ("Stripe"). By using Stripe's library, the information you enter during the order process (e.g., address, account number, bank code, possibly credit card number, invoice amount, currency, and transaction number) is not processed by us, but is transmitted directly to Stripe by the browser you use. The data is used by Stripe exclusively for the execution and implementation of payment processing and is transmitted securely using the "SSL" encryption method. The lifetime of cookies used by Stripe is one year. Stripe is certified according to PCI DSS standards. Stripe transfers, processes and stores personal data outside the EU, if applicable.

3.5.6 Google Single Sign-In

To facilitate the registration process for our users, they are offered the option of registering an account through an existing Google account. The procedure is called Google Single-Sign-In (SSO) and is managed by Google Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The purpose of this data processing is to facilitate your registration or access to our platform and thus the use of our services. By using SSO, your web browser automatically establishes a direct connection with Google's server. To register you will be redirected to Google's page. There you can log in with your user information. This links your user account with Google to our service. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or not logged in, it is possible for Google to obtain and store your IP address and possibly other identifiers. For information about the type and extent of data processing, the purposes served by Google, your rights in this regard, and setting options to protect your personal information, please refer to Google's privacy policy and terms of use. Exelero's use and transfer to any other app of information received from Google's API will comply with Google's API Services User Data Policy, including limited use requirements.

3.6 Further processing of data.

Where anonymized data processing is not possible, we also process your personal data to run our business (e.g., to perform administrative and organizational processes), to monitor and analyze our offerings, and to improve our offerings for you. We also use your personal data to promote and develop our business relationship with you, to identify services that may be of interest to you, to perform business development activities, to send you publications and communications, or to invite you to events. The legal basis for the purposes described above is our legitimate interest under the DPA for Switzerland and GDPR for EU countries, provided that your interests, fundamental rights and freedoms do not prevail. You can object to this data processing at any time. To do so, please use the contact options of our data protection officer in section 2 of this privacy policy. If your consent is required for the data processing described here, we will explicitly obtain it from you when collecting your personal data.

4. With whom do we share your personal information?

Where necessary or appropriate for our services or to fulfill the purposes defined in this Privacy Policy, we may disclose to the third parties mentioned in section 3.4 ("User and Customer Support") and 3.5 ("Online Presence and Website Optimization") your personal data that we collect, for example, in the course of providing our services, when you contact us, or when you visit our site.

Detailed information about the service providers we use in connection with user and customer support (see Section 3.4, "User and Customer Support") as well as our online presence and Web site optimization (see Section 3.5, "Online Presence and Web Site Optimization") can be found in the corresponding sections of this privacy policy.

We may also disclose your personal information to third parties if:

  • You have given your consent to do so, where required, or the organization you work for has received your consent to do so, where required;
  • we are required to do so by legal, regulatory or business obligations;
  • this is necessary in connection with a corporate sale, merger, restructuring, dissolution or similar event, as well as in the event of bankruptcy, insolvency or similar events;
  • this is necessary in connection with legal proceedings or to assert or defend claims.

Pursuant to Article 19 OC (for Switzerland), references may only be provided by persons expressly authorized by you through the appropriate area.

5. Transfer of your personal data outside of EU Switzerland.

We may also transfer your personal data to recipients located outside Switzerland, the European Union ("EU") or the European Economic Area ("EEA"). This applies in particular to the aforementioned processing of analytics or targeting technologies, which may involve a transfer of data to the servers of service providers. Other recipients may be affiliated service providers that we need in order to provide our services, e.g., hosters, CRM tools, analytics service providers, job listing portals for multi-posting or bidding companies. These servers may be located outside Switzerland, the EU or the EEA, particularly in the United States.

We take great care to ensure that our service providers and other recipients of your data meet data protection standards equivalent to DPA for Switzerland and GDPR for EU countries and that applicable guidelines are followed. For example, we only transfer your data to recipients that are located in a country that has been recognized by the relevant authority (in Switzerland, the Swiss Federal Data Protection and Information Commissioner (or the Federal Council) and in the EU, the European Commission) as having adequate data protection. If a recipient is located in a country that is not recognized as adequate, such as the United States, we take additional protection measures in accordance with applicable data protection laws or require such recipients to provide us with appropriate contractual safeguards that ensure compliance with these Swiss and EU standard provisions and the enforcement of data subjects' rights, for example, based on the so-called EU Commission or FDPIC standard contractual clauses.

6. How long do we keep your personal data?

In principle, your personal data will only be processed and kept by us for as long as necessary for the purpose for which it was collected (see in detail section 3, "Why and on what legal basis do we process your personal data and with whom do we share it?") or we are legally obliged to do so. We keep your data for up to six months after your last activity on your Exelero account (understood as accessing any page of exelero.com that you accessed by identifying yourself with your personal credentials) and in any case until you authorize us to do so (at any time you can request deletion of all your data, from the appropriate area).

If your account is considered inactive, we will send several reminder emails before taking any action or deleting account content. You will receive these reminder emails at least 2 months before any action is taken on your account. At the end of the sixth month with no activity on your Exelero account, your information will be permanently deleted automatically.

Therefore, unless otherwise specified in this Privacy Policy, among other things:

  • Personal data processed for the purpose of fulfilling a contract concluded between Exelero and you will be retained at least until that contract is fulfilled in full.
  • Personal data processed to safeguard Exelero's legitimate interests (e.g., in the context of providing our site, for user and customer support, for further development of our offerings, etc.) will be retained for as long as necessary to fulfill those purposes.
  • In addition, Exelero may retain personal data for a longer period of time if you have consented, until consent is revoked, or if this is necessary to fulfill a legal (retention) obligation (e.g., accounting regulations or tax law) or by order of an authority or as part of a procedure.

After the retention period expires, your personal data will be deleted, unless Exelero has a legitimate interest in retaining your data.

7. What rights do you have in relation to your personal data?

7.1 Overview

You can exercise several rights in relation to your data processed by Exelero. Specifically, you have the right to do the following:

  • Know whether your data is being processed by Exelero, receive information about individual aspects of the processing, and receive a copy of your data.
  • If your data is transferred abroad, the right of access or reference to appropriate or adequate safeguards and how to obtain a copy or where they are available,
  • Verify the accuracy of your data and to request that it be updated or corrected.
  • Restrict the processing of your data in certain circumstances.
  • Request deletion of your data in certain circumstances.
  • To receive your data in a structured, common, machine-readable format and, if technically possible, to have it transferred to another data controller without hindrance. If you have consented to the processing of your personal data for a specific purpose, you may revoke your consent for that specific processing at any time. If you inform us that you withdraw your consent, we will no longer process your personal data for these specific purposes unless there is another legitimate interest. You can exercise your rights by e-mail in accordance with section 2 ("Who is responsible for processing your personal data and how can you contact us?") of this Privacy Policy directly to our Data Protection Officer. We have the right, in that case, to request information from you to verify your identity. The granting of these rights may be denied or limited in part for legal reasons or under applicable data protection laws. We will inform you of the reasons for our decision if legally required or permitted. If you believe that we have not handled your request or concern satisfactorily, or that we are not processing your personal data in a data protection compliant manner, you may also contact the relevant supervisory authority (the so-called right of complaint): in Switzerland, the Federal Data Protection and Information Commissioner.

7.2 Right to object

The general right to object applies to all processing purposes described in this Privacy Policy that are processed on the basis of our legitimate interest under the DPA for Switzerland and GDPR for EU countries. Unlike the specific direct right of objection to the processing of data for promotional purposes, we are obliged under the DPA for Switzerland and GDPR for the countries of the European Union to implement such a general objection only if you provide us with overriding reasons for doing so (e.g., a possible risk to life or health). However, we may continue to process your personal data if we can demonstrate a legitimate interest that overrides your interests, fundamental freedoms and rights.

8. How do we protect your data?

We use the highest information security standards for our infrastructure and processing of your data. For example, we use protection mechanisms for computers, such as firewalls and data encryption. Physical access controls apply to our buildings and data. Access to our customers' personal data is limited to those employees who need it to do their jobs.

All data transmitted personally by you, including payment data, will also be transmitted using the generally accepted and secure Secure Socket Layer (SSL) standard. You can recognize a secure SSL connection by the s added to http (e.g. https://...) in the browser address bar or by the padlock symbol at the bottom of the browser.

We also use appropriate technical and organizational security measures to protect personal data stored with us from manipulation, partial or total loss and unauthorized access by third parties. Our security measures are constantly monitored in accordance with technological developments, regularly adapted to the respective risk and improved if necessary.

9. Updating of privacy policy.

We reserve the right to update and amend this Privacy Policy from time to time to reflect changes in the way we process your personal information or changes in legal requirements. Any changes made to our Privacy Policy in the future will be posted on our website and will be emailed to you 30 days before they take effect.

Any changes to these provisions require your consent, which you can provide when you first log into your Exelero account.

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Contacting Exelero
We welcome your data protection questions. For more information about how we handle your personal data, please contact us.