PRIVACY POLICY

Last updated December 10, 2024

We, Zondra AG (“Zuondra”, the “Company” “we”, ”us” or “our”), are committed to protecting your privacy. We have created this privacy policy (“Privacy Policy”) to let you know what to expect when you interact with us on the zuondra.com website (the “Website”), over the phone, via e-mail, by subscribing to our newsletter, registering for and participation in events or otherwise (collectively the “Services”).

This Privacy Policy describes how we collect and further process personal data in accordance with the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DPA”), and the New Federal Act on Data Protection (“nFADP”) when you use our Services.

If you provide us with personal data of any other persons, please make sure the respective persons are aware of this Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct.

Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our practice, please do not use our Services. If you still have any questions or concern, please contact us at contact@zuondra.com.

1. About us

Zuondra provides home and office furnishing products. The Company headquarters in Zurich, Switzerland. Our Company registration is CHE-346.656.796. Our registered office is Zürichbergstrasse 35, 8044 Zürich, Switzerland. Contact: contact@zuondra.com.

Zuondra will function as the “controller” within the meaning of Article 4 number 7 of the GDPR.

2. Collection and processing of Personal Data

We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our Website and other applications. Insofar as it is permitted to us, we may obtain certain personal data from publicly accessible sources, or we may receive such information from authorities or other third parties.

Apart from data you provided to us directly, the categories of data we receive about you from third parties may include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities, information about you in correspondence and discussions with third parties, credit rating information (if we conduct business activities with you personally), information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g., references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our Website (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

3. Purpose of Data Processing and Legal Basis

We primarily use collected data to conclude and process contracts with our clients and business partners mainly in connection with the sale of furnishing products to our clients and the procurement of products and services from suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:

• providing and developing our products, services and websites, apps and other platforms, on which we are active;
• communication with third parties and processing of their requests (e.g., job applications, media inquiries);
• review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
• advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
• market and opinion research, media surveillance;
• asserting legal claims and defense in legal disputes and official proceedings;
• prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
• ensuring our operation, including our IT, our Website, and other appliances;
• video surveillance to protect our domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets owner by or entrusted to us (such as e.g. access controls, visitor logs, network and mail scanners, telephone recordings);
• acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of Zuondra.

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters) we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

4. Cookies

We might also use cookies to collect data.

Cookies are small text files that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our Website. If you revisit our Website, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the Website ("session cookies"), we may use cookies to save user configurations and other information for a certain time period (i.e. 100 days) ("permanent cookies"). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We may use permanent cookies for the purpose of saving user configuration (e.g. automated log in), in order to understand how you use our Services and content, and to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain website). Certain cookies may be sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions are no longer available to you. In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting. By using our Website and subscribing to our newsletter and other marketing e-mails you agree to the use of such techniques. If you object, you must configure your browser or e-mail program accordingly.

5. Datatransfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:

• our service providers (e.g. banks), including processors (such as e.g. IT providers);
• dealers, suppliers, subcontractors and other business partners;
• acquirers or parties interested in the acquisition of business divisions, companies or other parts of Zuondra;
• other parties in possible or pending legal proceedings.

6. Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible.

7. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse. Despite these security measures, we cannot fully eliminate the security risks associated with data processing.

8. Obligation to Provide Personal Data To Us

In the context of our business relationship, you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent).

9. Your Rights

In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you may have the following rights:

• access, correct and erase your personal data;
• restrict or object personal data processing;
• 'port' your personal data (i.e. to transfer in a structured, commonly used and machine-readable format, to you or another data controller);
• withdrawn prior consent given at any time. This will not affect data processed prior to withdrawal.

Please note, however, that your rights are subject to certain restrictions, which we may invoke on a case-by-case basis.

In order to assert these rights, please contact us at the addresses provided in Section 1 above. In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

10. Changes to this Privacy Policy

We may amend this Privacy Policy at any time without prior notice. The current version published on our Website shall apply.