Edition august 2023
1 Short and succinct
General personal data
We process general personal data about you.
We process your financial data.
We process your health data.
We process intimate data about you.
We process personal data that you provide to us.
We process personal data that we collect about you.
We process personal data about you that we receive from third parties.
To fulfil legal obligations
We use your personal data to fulfil our legal obligations (e.g. under the AIA, MilIA).
We use your personal data for purposes other than to fulfil our legal obligations.
- Recruiting staff
We use your personal data to fill vacant job roles.
- Real estate
We use personal data to manage our real estate portfolio.
- Investment and lending activities
We use personal data to process our investment transactions and to issue loans.
- Operation of rehabilitation clinics
For information on data processing by the rehabilitation clinics, please refer to their separate privacy policies: rehabellikon.ch
, crr-suva.ch .
- Claims processing for third parties
We process personal data on behalf and on the instruction of third party insurers.
- Prevention counselling
We use personal data to provide counselling and training to promote occupational health within companies.
- Development and sale of safety products
We use personal data to create our range of safety products.
- Medical research
We support selected medical research projects relating to the AIA.
Profiling as part of fulfilling our legal obligations
Profiling may be carried out, for example when verifying an accident, to combat fraud and abuse and to assist with case management.
Profiling for other purposes
Profiling may be carried out to enable us to offer you prevention services that may interest you.
No automated decision-making
We do not currently use auto-mated decision-making as out-lined in the FADP.
Transfer of data for the purpose of fulfilling legal obligations
We do not disclose your personal data to third parties, such as authorities, unless obligated to do so by law, with your consent, or we are otherwise entitled or obligated to do so for reasons of legitimate interest.
Transfer of data for other purposes
Outside of our legal obligations, your data will only be transferred to selected service providers that process the personal data on our behalf and on our instruction.
Switzerland and Europe
We primarily process your data in Switzerland and the EEA.
If we process your personal data outside of Switzerland and the EU, we agree standard contractual clauses with the contractor concerned and take appropriate security measures.
2 What is this Privacy Notice about?
Suva (hereinafter also "we", "us") collects and processes personal data that concerns you or other individuals ("third parties"). We use the word "data" here interchangeably with "personal data".
"Personal data" means data relating to identified or identifiable individuals, which means that the rele-vant data, in combination with additional data, makes it possible to draw conclusions about the identity of these individuals. "Sensitive personal data" is a subset of personal data that is specially protected under applicable data protection law. This includes, for example, data revealing racial or ethnic origin, health data, information on religious or philosophical beliefs, biometric data for identification purposes, and information relating to trade union membership. In Section 4, you will find information about the data we process in accordance with this Privacy Notice. "Processing" means any operation that is per-formed on personal data, such as collection, storage, use, alteration, disclosure and erasure.
In this Privacy Notice, we describe what we do with your data when you obtain services or products from us, interact with us in relation to a contract, communicate with us or oth-erwise deal with us. When appropriate, we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.
If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorised to do so and that the rele-vant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.
This Privacy Notice is aligned with the Swiss Data Protection Act ("FADP") and the revised Swiss Data Protection Act ("revFADP"). However, the application of these laws depends on each individual case.
3 Who is the controller for processing your data?
Suva, Fluhmattstrasse 1, CH-6002 Lucerne, ("Suva") is the controller for Suva’s data processing under this Privacy Notice, unless we tell you otherwise in an individual case, for example in additional privacy notices, on a form or in a contract.
For each processing activity, there are one or several parties that are responsible for ensuring that the processing complies with data protection law. This party is called the controller. It is responsible, for example, for responding to information requests (Section 12) or for ensuring that personal data is processed securely and not used in an unlawful manner.
Additional parties may be joint controllers for the processing set out in this Privacy Notice if they participate in determining the purpose or means of the processing. If you wish to receive information about the controllers for a specific processing activity, you are welcome to ask us as part of your right to information (Section 12). Suva remains your primary contact, even if there are other joint controllers.
In Section 4, Section 8 and Section 13, you will find additional information about third parties with whom we work and who are the controllers for their processing. If you have any questions for these third parties or if you wish to exercise your rights with regard to them, please contact them directly.
You may contact our Data Protection Advisor in accordance with Art. 10 revFADP for data protection concerns and to exercise your rights under Section 12 as follows:
General Secretariat, Data Protection Department
4 What data do we process?
We process various categories of data about you. The main categories of data are the following:
- Technical data: When you use our website or other electronic offerings, we collect technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for up to 14 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 13). Technical data in itself does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This can help us to provide an appropriate layout of the website or to show you a website customised for your region, for example. We know which provider you access our offerings through (and therefore also the region) because of the IP address, but this does not usually tell us who you are. However, this changes when you create a user account, for example, because personal data can then be linked with technical data (for example, we can see which browser you use to access an account through our website). Examples of technical data include protocols ("logs") that are created in our systems (for example, the log of user logins to our website).
- Registration data: Certain offerings/services (e.g. login areas such as the customer portal, newsletter distribution, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. You must provide us with certain data in this regard, and we collect data about the use of the offering or service. Registration data may be required in relation to access control for certain facilities. We generally keep registration data for six months from the date on which the use of the service ceases or the user account is closed.
Registration data includes the information you provide when you create an account on our website (e.g. username, password, name, e-mail). It also includes the data that we may request from you before you can use certain free services. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges, biometric data for identification) under certain circumstances (see also the "other data" category).
- Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or another means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we have to determine your identity, for example in relation to a request for information or a request for press access, etc., we collect data to identify you (e.g. a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least  years. We usually keep recordings of (video) conferences for six months.
Communication data is your name and contact details, the means, place and time of the communication and usually also its content (i.e. the content of e-mails, letters, chats, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID document number or a password set by you or your press pass. For secure identification, the following required information must be provided for media enquiries: publisher, name of publication, title, first name, surname, postal address, e-mail address and telephone number of the reporter.
- Master data: By master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, e.g. in the area of legal prevention and prevention counselling as secondary employment, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorisations and declarations of consent. We process your master data if you are a customer or another business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process health data and information about third parties as part of master data. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Master data includes data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, and copies of ID documents; moreover, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (e.g. from the media), or official documents (e.g. excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.
In relation to contact persons and representatives of our customers, suppliers and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about supervisors, co-workers and subordinates and information about interactions with these persons.
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity.
- Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). This includes health data and information about third parties. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
Contract data (e.g. in the Real Estate Division) includes information about the conclusion of the contract, about your contracts, for example, the type and date of conclusion and information about the relevant contract (e.g. its duration) and the performance and administration of the contracts (e.g. information related to billing, customer service, technical assistance and enforcement of contractual claims). Contract data also includes information about deficiencies, complaints and changes to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contract data also includes financial data, such as credit information (meaning information that allows us to draw conclusions about the likelihood that receivables will be paid), and information about reminders and debt collection. We receive this data partly from you (e.g. when you make payments), but also from credit agencies and debt collection companies and from public sources (e.g. a commercial register).
- Behavioural and preference data: Depending on our relationship with you, we inform you about our products and services that may interest you (e.g. prevention counselling) and try to tailor them to your needs. We do so by evaluating information about your behaviour in our domain, and we may also supplement this information with third-party information, including from public sources. The data processed for this purpose is either already known to us (for example where and when you use our services), or we collect it by recording your behaviour (for example how you navigate our website or by analysing data about your operation). We describe how tracking works on our website in Section 13.
Behavioural data is information about certain actions, such as your response to electronic communications (for example if and when you have opened an e-mail) or your location, as well as your interaction with our social media pages and your participation in prize draws, competitions and similar events. For example, we may collect your location data when you use our website. We will use signage at the relevant locations to tell you about the collection of anonymous motion profiles.
Preference data tells us what your needs are, which products or services might be of interest to you or when and how you are likely to respond to messages from us. We obtain this information from the analysis of existing data, such as behavioural data, so that we can get to know you better, tailor our advice and offerings more precisely to you and generally improve our offerings. To improve the quality of our analyses, we may combine this data with other data that we also obtain from third parties.
Behavioural and preference data may be analysed on a personally identifiable basis (for example to show you personalised advertising), but also on a non-identifiable basis (for example for market research or product development). Behavioural and preference data may also be combined with other data (for example, motion data may be used for contact tracing as part of a health protection concept).
- Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection schemes). We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example at events, with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.), who participates in events or campaigns (e.g. competitions) and who uses our infrastructure and systems and when. Moreover, we collect and process data about our target groups, in addition to master data, including the specific concerns of the target groups and meetings with them. The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which is usually kept for three months, to several years or more for reports about events with images. The retention period for data relating to target groups depends on the processing purpose and is limited to what is necessary.
Much of the data set out in this Section 4 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.
We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services or has accepted an invitation to an event, because it is a technical requirement or because we wish to communicate with you. If you or the person you represent (e.g. your employer) wishes to enter into or perform a contract with us, we must collect master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offerings for this purpose. If you do not provide us with the data necessary for the conclusion and performance of the contract, you should expect that we may refuse to conclude the contract, that you may commit a breach of contract or that we will not perform the contract. Similarly, we can only submit a response to a request from you if we process communication data and – if you communicate with us online – possibly also technical data. Also, the use of our website is not possible without us receiving technical data.
Insofar as it is not unlawful, we also collect data from public sources (for example debt collection registers, land registers, commercial registers, the media, or the internet including social media) or receive data from other companies, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).
The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and judicial proceedings, information in relation to your professional functions and activities, information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity), information about you that persons related to you (family members, advisors, legal representatives, etc.) share with us so that we can conclude or perform contracts with you or involving you (for example references, your delivery address, powers of attorney, information about compliance with legal requirements such as those relating to fraud prevention and combating money laundering and terrorist financing, export restrictions, information from banks, insurance companies, our sales and other contractual partners about your use or provision of services (e.g. payments, purchases, etc.), information from the media and the internet about the use or provision of services by you (for example payments made, purchases made, etc.), information from the media and the internet about you (where appropriate in a specific case, for example in the context of an application, marketing/sales, prevention products, granting of credit, etc.), your address and potentially interests and other socio-demographic data (especially for marketing and research purposes) and data in relation to the use of third-party websites and online offerings where such use can be linked to you.
5 For what purposes do we process your data?
On the one hand, we process your data for the purpose of providing compulsory accident insurance (AIA) and military insurance (MilIA), for prevention, and as an implementing organisation for preventing occupational accidents and occupational diseases. On the other, we process your data for additional purposes not associated with fulfilling our legal obligations. Staff recruitment, real estate, investment and lending transactions, claims processing for third parties, prevention counselling, development and sale of safety products, and, where applicable, for supporting selected research projects relating to accident insurance. Your data is very valuable for research purposes. However, taking part in research and supporting it are voluntary. You can exercise your right to object at any time. If you do not wish us to make your data available, please let us know by writing to the following address with “Objection to research” in the subject line: Suva General Secretariat, Fluhmattstrasse 1, CH-6002 Lucerne, or email@example.com (for further information
We process your data for purposes related to communication with you, in particular in relation to responding to enquiries and the exercising of your rights (Section 12) and to enable us to contact you in case of queries. For this purpose, we use, in particular, communication data and master data, and registration data in relation to offerings and services that you use. We keep this data to document our communication with you , for training purposes, for quality assurance and for follow-up enquiries.
The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an information request. Our processing also serves to document the communication and its content.
Further information is set out in Sections 13 and 14. These purposes and their objectives represent our interests and potentially those of third parties. You can find further information on the legal basis of our processing in Section 6.
We process data for the conclusion, administration and performance of contractual relationships.
We conclude various contracts with our business and private customers, suppliers, subcontractors and other parties, such as partners in projects or parties in legal proceedings. In particular, we process master data, contract data and communication data and, depending on the circumstances, registration data relating to the customer or the persons for whose benefit the customer has received a service.
During the process of initiating a business relationship (e.g. real estate, prevention offers), personal data – in particular master data, contract data and communication data – is collected from potential customers or other contractual partners (for example in an order form or a contract) or is derived from communications. In connection with the conclusion of a contract, we also process data to assess creditworthiness and to establish a customer relationship. In some cases, this information is reviewed in order to comply with legal requirements.
As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, advertising service providers, banks, insurance companies or credit information providers, who may in turn provide data to us), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the performance, as are accounting, termination of contracts and public communication.
We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalised advertising for products and services from us and from third parties (for example from providers in the field of occupational safety). This may take place in the form of newsletters and other regular contacts (electronically, by post or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (e.g. events, competitions, etc.), and may also include free services (e.g. invitations, vouchers, etc.). You can object to such contact at any time (see the end of this Section 5) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 13).
For example, if you consent we may send you information, advertising and product offers from us and from third parties (e.g. providers in the field of occupational safety), as printed material, electronically or by telephone. For this purpose, we process communication and registration data in particular. Like most companies, we personalise communications so that we can provide you with customised information and offers that meet your needs and interests. To do this, we combine data that we process about you and collect preference data and use this as a basis for personalisation (see Section 4). We also process data in relation to competitions, prize draws and similar events.
Relationship management also includes targeting existing customers and their contacts, possibly in a personalised way on the basis of behavioural and preference data. In the context of relationship management, we may also operate a customer relationship management system ("CRM") in which we keep the data of customers, suppliers and other business partners that is required for relationship management, for example data about contact persons, relationship history (e.g. information about products and services purchased or supplied, interactions, etc.), interests, wants, marketing measures (newsletters, invitations to events, etc.) and other information.
All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.
We further process your data for market research, to improve our services and operations, and for product development.
We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We therefore analyse, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 13). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioural data and preference data, but also communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the internet and other public sources. We use pseudonymised or anonymised data for these purposes to the extent possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data in order to conduct media monitoring or to understand and respond to current developments and trends.
We may also process your data for security and access control purposes.
We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We therefore analyse, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 12). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioural data and preference data, but also communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the internet and other public sources. We use pseudonymised or anonymised data for these purposes to the extent possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data in order to conduct media monitoring or to understand and respond to current developments and trends.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations ("Compliance").
This includes, for example, the implementation of health security schemes or the legally regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers ("Know Your Customer") or to report to the authorities. Disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offences and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example by a law enforcement or supervisory authority or by a mandated private entity. For all these purposes, we process, in particular, master data, contract data and communication data, but also, under certain circumstances, behavioural data and data from the category of "other data". The legal obligations may arise under Swiss law but also under foreign regulations to which we are subject, as well as internal regulations, industry standards, our own "corporate governance" and instructions and requests from authorities.
We also process data for the purposes of our risk management and as part of our corporate governance, including business organisation and development.
For these purposes, we process, in particular, master data, contract data, registration data and technical data, but also behavioural and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyse data for relevant patterns of such activities. We may also conduct profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activity (see also Section 7). In the context of planning our resources and organising our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (e.g. outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the exchange and processing of data (including from you, for example as a customer or supplier or as a supplier representative).
We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and training.
These further purposes include, for example, training and educational purposes, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and continuously improving IT infrastructure), protecting our rights (for example to enforce claims in or out of court, and before authorities in Switzerland and abroad, or to defend ourselves against claims, for example by preserving evidence, conducting legal assessments and participating in judicial or administrative proceedings) and evaluating and improving internal processes. We may use recordings of (video) conferences for quality assurance purposes and training. These further purposes also include safeguarding other legitimate interests that cannot be named exhaustively.
6 On what basis do we process your data?
To provide compulsory accident insurance (AIA), military insurance (MilIA) and prevention measures and as an implementation organisation for the prevention of occupational accidents and occupational diseases, we refer to the applicable legal regulations.
Where we ask for your consent for certain processing activities (for example for the processing of marketing mailings and for advertising management and behaviour analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us with written notice (by post) or, unless otherwise noted or agreed, by sending an e-mail to us. For withdrawing consent for online tracking, see Section 13. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis for doing so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third party's legitimate interest, in particular in pursuing the purposes set out in Section 5 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognised as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and Swiss law). This also includes the marketing and further development of our products and services that may interest our customers and other target groups.
If we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal bases, for example, in the event of a dispute, as required in relation to potential litigation or for the enforcement or defence of legal claims. In some cases, other legal bases may apply, which we will communicate to you separately as necessary.
7 What applies in case of profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you ("profiling") based on your data (Section 4) for the purposes set out in Section 5, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analyses or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioural and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics. We may also create anonymous and – with your consent – personalised motion profiles of you.
If you are our customer, we may, for example, use "profiling" to determine which other products are likely to be of interest to you based on your purchases. We may also use profiling to assess your creditworthiness before offering you the option to pay for a purchase by invoice. An automated data analysis may also determine, for your own protection, the likelihood of a particular transaction being fraudulent. This allows us to suspend the transaction for further clarification. "Profiles" are to be distinguished from "profiling". "Profiles" refers to combining different data in order to draw conclusions on essential aspects of your personality (for example what you like, or how you behave in certain situations) from the totality of this data. Profiles may also be used for marketing, for example, or for security purposes.
We use anonymous motion profiles for non-personal purposes, for example to improve safety on ski slopes.
In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these could give rise to legal effects concerning you or impact on you to a significant extent, we generally ensure human review.
In certain situations, to ensure the efficiency and consistency of decision-making processes, it may be necessary for us to automate discretionary decisions that give rise to legal effects concerning you or may impact on you to a significant extent ("automated individual decisions"). In these cases, we will inform you accordingly and take the measures required by the applicable law.
One example of an automated individual decision is the automatic non-acceptance of an accident. Simple if-then decisions are not included (for example where a computer accepts your Suva insurance coverage after checking your association with a company); only discretionary decisions are applicable (for example where no accident is recognised based on the claim report). We will inform you in each case where an automated decision give rise to negative legal effects concerning you or impacts on you to a similarly significant extent. If you do not agree with the result of such a decision, you will be able to discuss this with a human being, who will review the decision.
8 With whom do we share your data?
In relation to our contracts, the website, our services and products, our legal obligations or otherwise in protecting our legitimate interests and for the other purposes set out in Section 5, we may disclose your personal data to third parties, in particular to the following categories of recipients:
- Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers). This may include health data. For the service providers used for the website, see Section 13. Key service providers in the area of IT are Microsoft, IBM, Oracle, Google, Adcubum and SAP; a key service provider for debt collection is the company Crif; and a key service provider for security is Protectas.
To be able to deliver our products and services efficiently and focus on our core competencies, we procure services from third parties in various areas. These include, for example, IT services, information transmission, marketing, sales, communication or printing services, facility management, security and cleaning, services for organising and holding events and receptions, debt collection, credit agencies, address verification providers (for example to update address lists in case of relocations), fraud prevention measures and services from consulting companies, lawyers, banks, insurers and telecommunication companies. In each case, we disclose to these providers the data they require for their services, which may also concern you. These providers may also use such data for their own purposes, for example information about overdue claims and your payment history in case of credit information agencies or anonymised data to improve their services. In addition, we enter into contracts with these providers that include provisions to protect data, where such protection does not follow from the law. In some cases, our service providers may also process data on how their services are used and other data that is generated in the course of using their services as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing purposes). Service providers provide information about their independent data processing activities in their own privacy statements. More information on how Microsoft processes data can be found here
; for the use of Microsoft Teams in particular, see here .
- Contractual partners including customers: This refers to customers (e.g. insurees) and our other contractual partners as this data disclosure results from these contracts. For example, they receive registration data in relation to issued and redeemed vouchers, invitations, etc. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. This may include health data. These recipients also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners to send you or display advertising based on your data only with your consent (for online advertising, see Section 13). Our main cooperation partners are Google, Meta, TikTok and LinkedIn, and our online advertising partners are listed in Section 13.
If you act as an employee for a company with which we have concluded a contract, performance of this contract may require us to tell the company, for example, how you have used our service. Cooperation partners and advertising partners receive selected master data, contract data, behavioural data and preference data from us so that they can carry out non-personal analyses in their fields (for example about the number of our customers who have viewed their advertising) and, in addition, so that they can use data for advertising purposes (including targeting you). For example, advertising partners should be able to communicate with selected other customers of ours and send advertising to them.
- Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health data. These authorities process data about you that they have received from us under their own responsibility.
Examples are criminal investigations, police measures (for example health protection schemes, combating violence, etc.), regulatory requirements and investigations, judicial proceedings, reporting obligations and pre-court and out-of-court proceedings, as well as legal obligations to provide information and to cooperate. Data may also be disclosed if we wish to obtain information from public bodies, for example in order to justify a request for information or because we need to state whom we require information about (for example from a register).
- Other persons: This means other cases where interactions with third parties arise from the purposes set out in Section 5, for example service recipients, the media and associations in which we participate or if you are included in one of our publications.
Other recipients include, for example, delivery recipients or third-party payees specified by you, other third parties in relation to agency relationships (for example if we share your data with your lawyer or your bank) or persons involved in administrative or judicial proceedings. If we cooperate with the media and share materials with them (e.g. photos), this may also affect you depending on the circumstances. The same applies if we publish content (e.g. photos, interviews, quotes, etc.), for example on our website or in our other publications. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you, for example as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with competitors, industry organisations, associations and other bodies, data may be exchanged that also affects you.
All these categories of recipients may involve third parties, so your data may also be disclosed to them. We can restrict the processing by certain third parties (e.g. IT providers), but not by others (e.g. authorities, banks, etc.).
We reserve the right to make such disclosures even of confidential data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, unless we are required to do so by law).
In many cases, the disclosure of confidential data is necessary in order to perform contracts or provide other services. Likewise, non-disclosure agreements generally do not exclude such disclosures of data or disclosures to service providers. However, depending on the sensitivity of the data and on other circumstances, we will ensure that these third parties handle the data appropriately. We cannot comply with your objection to the disclosure of data where the disclosure in question is necessary for our activities.
In addition, we enable certain third parties to collect personal data from you on our website and at events organised by us (e.g. press photographers, providers of tools on our website, etc.). Where we have no control over this data collection, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 13 for the website.
9 Is your personal data disclosed abroad?
As explained in Section 8, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in Europe and, in exceptional cases, in any country in the world.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the European Commission’s revised standard contractual clauses, which can be accessed here
Many countries outside Switzerland or the EEA currently do not have laws that ensure an adequate level of data protection under the FADP or the GDPR. The contractual arrangements mentioned compensate for this weaker or lack of legal protection to some extent. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in individual cases, and we take further measures (e.g. pseudonymisation or anonymisation) to minimise them.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
10 How long do we process your data for?
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in terms of documentation and keeping evidence require it or for as long as storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 4, and for cookies in Section 13. If there are no contrary legal or contractual obligations, we will delete or anonymise your data once the storage or processing period has expired as part of our usual processes.
Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with this other data (for example in case of backups or document management systems).
11 How do we protect your data?
We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorised or unlawful processing, and to mitigate the risk of loss, accidental alteration, and unauthorised disclosure or access.
Technical and organisational security measures may include encryption and pseudonymisation of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering into confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by means of appropriate encryption. However, we can only secure areas under our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.
12 What are your rights?
Applicable data protection laws grant you the right to object to the processing of your data under some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether and what data we process from you;
- The right to have us correct data if it is inaccurate; – The right to request erasure of data;
- The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- The right to withdraw consent , where our processing is based on your consent;
- The right to receive, upon request, further information that is helpful in exercising these rights;
- The right to express your point of view in cases of automated individual decisions (Section 7) and to request that the decision be reviewed by a human.
If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, by e-mail or post; you will find our contact details in Section 3. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID document if identification is not possible otherwise).
You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 8 and additional information in Section 13.
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in full or in part (for example by redacting content that concerns third parties or our trade secrets).
If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 3) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here
13 Do we use online tracking and online advertising techniques?
We use various techniques on our website that allow us and third parties engaged by us to recognise you during your use of our website, and possibly to track you across several visits. This section provides information about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analyses and personalisation. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you based on a combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognised as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (a "cookie").
Cookies are individual codes (e.g. a serial number) that our server or a server belonging to our service providers or advertising partners transmits to your system when you connect to our website, and that your system (browser, mobile phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognised even if your identity is unknown.
Other technologies may be used to recognise you with some likelihood (i.e. distinguish you from other users), such as "fingerprinting". Fingerprinting combines your IP address, the browser you use, screen resolution, language settings and other information that your system tells every server, resulting in a more or less unique fingerprint. This makes it possible to do without cookies.
Whenever you access a server (for example when you use a website or an app, or because an e-mail includes a visible or invisible image), your visits can therefore be "tracked". If we integrate offers from an advertising partners or a provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in a particular case.
We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here
We distinguish between the following categories of cookies (including other comparable technologies such as fingerprinting):
- Necessary cookies Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only ("session cookies"). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (e.g. language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24 months.
. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.
In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage. For example, we may transmit the e-mail addresses of our users, customers and other persons to whom we wish to display advertisements to operators of advertising platforms (e.g. social media). If these persons are registered with them with the same e-mail address (which the advertising platforms determine by a matching process), the providers display our advertisements specifically to these persons. The providers do not receive personal e-mail addresses of persons who are not already known to them. In the case of known e-mail addresses, however, they learn that these persons are in contact with us and the content they have accessed.
We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), these providers can determine that you are using our website. If you have an account with that social media provider, it can assign this information to you and thereby track your use of online offers. These social media providers process this data as separate controllers.
We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):
- Google Analytics and Sitecore Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service "Google Analytics" and acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both "Google"). Google collects information about the behaviour of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before being forwarding to the United States, so they cannot be traced back. Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here
and if you have a Google account, you can find more details about Google's processing here .
Sitecore Analytics is also used to show the website to you in a personalised manner and to display appropriate offers to you.
- Tracking with fusedeck: The fusedeck tracking solution by Capture Media AG (hereinafter "Capture") is integrated into this website. Capture is a Swiss company based in Zurich that measures the use of this website on our behalf in the context of engagements and events. Tracking is anonymous, meaning that no connection can be made to identified or identifiable persons.
- Siteimprove Analytics: This website uses Siteimprove Analytics, a web analysis service provided by Siteimprove. Siteimprove Analytics uses "cookies" – text files that are stored on your computer or smartphone to help Suva analyse how visitors use the website. The information generated by the cookies regarding website usage is stored and processed by Siteimprove on servers in Denmark.
IP addresses are fully anonymised before recorded data becomes visible to Suva via Siteimprove Suite. It is not possible to reverse the anonymisation of the IP addresses, nor associate the IP addresses with the recorded data.
Suva can use this information to analyse user behaviour of its website visitors, create reports about this and improve the website experience for its visitors. Siteimprove will not pass on this information to third parties or use it for marketing or advertising purposes of any kind.
These cookies and pixels are necessary for Suva to be able to optimise the website, personalise advertising messages and offers, or generate statistics and market research relating to usage. Only anonymous data is recorded and processed using this technology on the website. You can still use the website without these cookies by deactivating cookies in your browser.
The majority of cookies used are deleted automatically after your visit. Other cookies are stored on your terminal device for longer, and used for purposes such as personalisation and retargeting. You can, however, delete these cookies at any time.
When you visit the Suva website, the cookie can be used to create a link between your browser and the server of the corresponding provider. This means that your visit to the website can be assigned to, for example, a user account with the corresponding social network. Suva has no knowledge of this data or its usage. You can find further information about this topic in the corresponding privacy policies of the respective social networks.
- InxMail: This website uses Inxmail to send newsletters. The provider is Inxmail GmbH, Wentzingerstr. 17, 79106 Freiburg, Germany. Inxmail is a service that can be used to organise and analyse newsletter distribution. The data you provide for the purpose of receiving the newsletter (e.g. e-mail address) is stored on Inxmail's servers in the EU. We also transfer the data required to send newsletters to existing customers (see Section 8.2) to Inxmail.
Inxmail uses this data to send and analyse the newsletter on our behalf. According to the information it provides, Inxmail uses this data to improve its own services, for example technical optimisation of the distribution and appearance of the newsletter, or for business purposes, to determine from which country the recipients originate. However, Inxmail does not use this data to send its own e-mails, nor does it pass the data on to third parties. You can find further information on data processing at Inxmail at www.inxmail.com/data-conditions
Please note that we analyse your user behaviour when sending the newsletter. The newsletter contains a "web beacon", a pixel-sized file that is accessed by an Inxmail GmbH server when the newsletter is opened. As part of this process, technical information such as data regarding your browser and system, your IP address and time of access are recorded. This information is used to make technical improvements to the service based on the technical data or the target groups and your reading behaviour.
Statistical data recording also includes determining whether the newsletters were opened, when they were opened, and which links were clicked. This information is not assigned to individual newsletter recipients and is only processed anonymously. The analysis serves to determine the reading habits of our users and adapt our content to them.
There are cases where the newsletter recipients will be taken to an Inxmail webpage. For example, our newsletters contain a link via which newsletter recipients can access the newsletter online (for example if they have issues viewing it in their e-mail application).
You can cancel your newsletter subscription at any time by revoking your consent. You will find a cancellation link at the end of every newsletter. This revokes your consent both for receiving the newsletter from Inxmail and for the statistical analysis.
14 What data do we process on our social network pages?
We may operate pages and other online presences ("fan pages", "channels", "profiles", etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 4 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyse your use of our online presences and combine this data with other data they hold about you (for example about your behaviour and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalise advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.
We receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences or are active on them (for example publish content, submit comments). These platforms also collect technical data, registration data, communication data, behavioural data and preference data from you or about you, among other things (see Section 4 about these terms). These platforms usually perform statistical analyses of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, "like", forward, etc.) and combine this data with other information about you (for example information about your age and your gender and other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use this data and profiles to display to you our or other advertisements and other personalised content on the platform and to manage the behaviour of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can control the analysis that these platforms generate regarding the use of our online presence to some extent.
For further information on the processing of the platform operators, please refer to the privacy information for the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects' rights, and how you can exercise them or obtain further information. We currently use the following platforms:
- LinkedIn insight tag: This website uses the "LinkedIn insight tag", an analysis and tracking tool by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The LinkedIn insight tag enables the collection of data about the visitors to this website, including the URL, referrer URL, IP address, device and browser properties, timestamp and page views. This data is encrypted and then anonymised within seven days, and the anonymised data is deleted within 90 days.
LinkedIn does not share any personal data with the owner of this website, but rather provides summarised reports about the website target group and the display performance.
LinkedIn also offers retargeting for website visitors, meaning that the owner of this website can use this data to display targeted advertising outside of its website without the member being identified.
The purpose of the data collection is to analyse visits to our website and campaign results and therefore provide you with interesting information.
LinkedIn members can manage the use of their personal data for advertising purposes in their account settings.
- Meta: On Facebook we operate the page www.facebook.com/suvaschweiz
. The controller for operating the platform for users from Europe is Facebook Ireland Ltd., Dublin, Ireland. Its privacy notice is available at www.facebook.com/policy . Some of your data will be transferred to the United States. You can object to advertising here: www.facebook.com/settings?tab=ads . With regard to the data collected and processed when visiting our site for "page insights", we are joint controllers with Facebook Ireland Ltd., Dublin, Ireland. As part of page insights, statistics are created about the actions visitors perform on our site (comment on posts, share content, etc.). This is explained at www.facebook.com/legal/terms/information_about_page_insights_data . It helps us understand how our page is used and how to improve it. We only receive anonymous, aggregated data. We have agreed our data protection responsibilities according to the information on www.facebook.com/legal/terms/page_controller_addendum .
- Planyo: A plugin of the Planyo tool is integrated into the Suva website. This is operated by Xtreeme Sagl, Via Cantonale, 6633 Lavertezzo, Switzerland. If you visit our website and book a construction course, a direct connection will be established via the plugin between your browser and the Planyo server. In this process, Planyo receives the information that you visited our website from your IP address. In this case, your personal data (such as your name, address, email address, etc.) is only transferred if you have entered it yourself voluntarily. This data is stored on the server of the Planyo tool. You can find more information about data processing by the Planyo server at: www.planyo.ch/privacy.php
- Unblu: For questions related to customer service, the website uses the services of the provider Unblu, Centralbahnplatz 10, 4051 Basel, Switzerland, which in turn works with Aspectra AG, Weberstrasse 4, 8004 Zurich, Switzerland for the cloud solution. On contacting Suva, only the data you enter voluntarily will be transferred to and processed by Unblu. However, personal data such as salary information is not transferred to Unblu in this process. You can find more details about Unblu’s data protection practices at: https://www.unblu.com/en/privacy-policy/
and https://vimeo.com/privacy .
15 Can we update this Privacy Notice?
This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.
Last updated: August 2023