Owner and Data Controller
CH-6300 Zug, Switzerland
Company Registration Number: CHE-110.598.195 for IMR Metallurgical Resources AG
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies and Usage Data (Google Analytics).
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Users who are uncertain about which Personal Data is mandatory are welcome to contact IMR.
Methods of processing
IMR takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
In addition to IMR, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by IMR.
The updated list of these parties may be requested from IMR at any time upon request.
Legal basis of processing
IMR may process Personal Data relating and/or submitted by Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations IMR may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which IMR is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in IMR;
- processing is necessary for the purposes of the legitimate interests pursued by IMR or by a third party.
In any case, IMR will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at IMR’s operating offices.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by IMR to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with IMR using the information provided in the contact section.
Data Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between IMR and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of IMR’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by IMR within the relevant sections of this document or by contacting IMR.
IMR may retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, IMR may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow IMR to provide its Services, as well as for the following purposes: Analytics and responding to customer enquiries.
The rights of Users
Users may exercise certain rights regarding their Data processed by IMR.
In particular, Users have the right to do the following:
- Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data.Users have the right to learn if Data is being processed by IMR, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, IMR will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from IMR.
- Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in IMR or for the purposes of the legitimate interests pursued by IMR, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether IMR is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to IMR through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by IMR as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by IMR in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that IMR may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from IMR at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, IMR shall collect new consent from the User, where required