Privacy Policy

Issue date: 02 – 09 – 2021

1.     What is it about?

This present privacy policy (“Policy”) sets out the basis on which any personal data Bugnion SA (“BUGNION” or “We”) collects from you or that you provide Us will be processed by Us. This includes the various ways in which you interact with Us, in particular through our website accessible at this address (“Website”), by phone, email or in person.

“Personal data” means any information relating to an identified or identifiable natural or legal person, according to the Federal Act on Data Protection (“FADP”).

Please read the following carefully to understand our views and practices regarding your Personal data and how We will process it.

This Policy is translated in English for information purposes only. The French version shall prevail in case of conflict.

2.     Who is responsible for your Personal data ?

BUGNION is the data controller for Personal data covered by this Policy. Its headquarters are at Route de Florissant 10, 1211 Geneva. We may be contacted by email at this address

We hope to be able to answer your questions regarding the way We process your Personal data. Should you have any concern in this regard, please do not hesitate to contact Us in writing or by email.

3.     Which Personal data do We collect from you and for what purpose ?

3.1        When you use our Website

When you use our Website, We may automatically collect the following Personal data :

–        information regarding the use of our Website, including language, date and hour of your visit, browser used, location, volume of data transmitted, links you might follow, visited web pages and content, and duration of the visit ;

–        technical information, including the IP (Internet Protocol) address used to connect your computer to the Internet, the type of device you use, a unique device identifier (for example your device’s IMEI number, the MAC address of the wireless network interface or the mobile phone number used by the device) ;

–        any information you may share with Us ;

–        if applicable, login information.

This Personal data is in particular collected through cookies and similar technologies as described in art. 6.

The purpose of this processing is to allow you to use our Website while storing your settings and optimizing your overall user experience.

In addition, our evaluation tools are used in order to understand your usage patterns and to develop statistics on the latter.

3.2        When you contact Us

When you contact Us by mail, email, phone, in person or through social networks, We may process Personal data you share with Us to answer your request and better understand your needs. We may also use that data to invite you to some events.

3.3        When you use social media

When you allow a third-party social media (like LinkedIn) to share your Personal data with Us, We are entitled to receive any Personal data that you share publicly on the social media, that is part of your profile or that you allow the social media to share (like your name, email address, gender, profile picture, friend list or contact list, preferences, etc.).

BUGNION will also receive Personal data related to your profile when you use a functionality of the social media that is integrated to the Website or when you interact with Us through the social media. You should at all times be aware of the applicable terms of use and the privacy policy of each social media that you use and that for which We have no responsibility.

4.     Who do We share your Personal data with?

4.1        With our data processors

We may share your Personal data with those who provide Us with services as data processors, in particular IT services.

Our data processors are bound by an obligation of confidentiality and are entitled to use your Personal data only in accordance with our instructions and this Policy.

4.2        With third-parties

When allowed or required by law, when it is necessary to defend our interests or with your consent, We may share your Personal data with third-parties, for example at the request of judicial authorities or to assert our rights in court.

5.     Google Analytics

The Website uses Google Analytics, a website analysis service supplied by Google LLC (“Google”).

Google Analytics mainly uses first-party cookies to report on visitor interactions in the Website. You may disable cookies or delete any individual cookie, as well disable measurement by Google Analytics through the following link:

Google Analytics collects an app-instance identifier – a randomly generated number that identifies a unique installation of an App. Google Analytics also collects IP (Internet Protocol) addresses to provide and protect the security of the service, and to give Us a sense of which region the users come from (also known as “IP geolocation”). Google Analytics provides a method to mask IPs that are collected. [AA1]

6.     Cookies

6.1        Our cookies

Type of cookies (including our data processors’ cookies) that We use on our Website and the reason why We use them are described below :

Category 1 : strictly necessary cookies

These cookies are essential in order to enable you to move around our Website and to use its features. Without these cookies, some elements of our Website may be blocked and/or not function correctly.

We use these cookies in order to let you access the services that We offer on our Website.

Category 2 : performance cookies

These cookies collect information on how you or other users use our Website, for instance which pages you go to more often, and if you get error messages from web pages.

We use these cookies in order to preserve our Website’s efficiency and ease of use and to know the way it is used. Most of the time, these cookies don’t collect information that identifies the user.

Category 3 : functionality cookies

These cookies allow our Website to remember choices you have made (such as your user name, language, or the region where you are) and may also be used to provide the services you have asked for.

We use these cookies to maintain the Website’s efficiency, ease of use, and to provide you with a seamless experience.

You can at any time refuse these cookies through your browser’s settings.

6.2        Third-parties’ cookies

We may include on our Website third-parties’ computer applications allowing you to share our Website’s content with other people and let them know your consultation or opinion about a content of our Website.

These cookies use is subject to third-parties’ privacy policies over which We have no control. Please refer to their respective privacy policies in order to learn more about the way they use their cookies.

7.     Transfer of Personal data abroad

Your Personal data may be processed abroad when appropriate, in particular when using data processors. We respect all applicable rules and shall adopt all required and necessary measures prior to the transmission of Personal data to a country that provides a lower level of protection than Switzerland.

8.     Security

BUGNION uses standard technology and security precautions, and organizational procedures to protect your Personal data from unauthorised access, improper use, disclosure, loss or destruction. Industry standard firewalls and passwords protection are also used to protect your Personal data.

9.     Right of access

You have the right to ask Us at any time if We process Personal data about you. We will provide information according to art. 8 FADP.

10.   How will We let you know of changes to our Policy ?

We may update this Policy from time to time without notice. So, please check it regularly. We will however aim to bring any significant changes to your attention.

11.   Applicable law and jurisdiction

This Policy, as well as all matters arising out or in relation to it (including non-contractual disputes or claims and their interpretation) shall be governed by the laws of Switzerland, to the exclusion of the rules on conflicts of laws.

Any claim and dispute in relation to this Policy (including non-contractual disputes or claims and their interpretation) shall be subject to the exclusive jurisdiction of the Courts of Geneva, Switzerland.

12. Content of our website

The entire content of this Site (its general structure, as well as the software, texts, animated or still images, know-how, drawings, graphics and any other element making up the Site) are the exclusive property of BUGNION SA. The photographs were purchased from the Istock website.

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