We, Alternative Distribution Financing Ltd., are committed to the protection of personal data we collect and process, with rigorous policies, controls, and compliance oversight to ensure that data is held and used appropriately. In the context of its activities, Alternative Distribution Financing Ltd. may need to process personal data and to disclose personal data to affiliates and selected third party services providers or business partners or third-party experts and advisors, as explained in this document.
This notice is designed to provide information on which data Alternative Distribution Financing Ltd. collects and processes and for which purpose data is being collected/processed.
Alternative Distribution Financing Ltd. reserves the right, at its discretion, to change, modify, and/or remove sections from this data privacy notice at any time. If it makes any material changes to this data privacy notice, it will notify by means of a notice on the website https://www.gscf-adf.com or by any other means deemed appropriate.
1. Which data do we collect and process?
Alternative Distribution Financing Ltd. may collect and process the following data:
- Name and surname of individuals;
- Postal address of individuals;
- Email address of individuals;
- Telephone number of individuals;
- Recruitment related information;
- User statistics on ADF’s websites and web-based servicing platforms;
- Other personal information relating to identified and identifiable individuals (e.g. nationality, gender, date of birth, passport, etc.)
2. For what purposes do we process data?
Alternative Distribution Financing Ltd. may use personal data for the following purposes:
- performing contracts;
- responding to requests for information;
- coordinating the administration of the client relationship with Alternative Distribution Financing Ltd. and client interactions with affiliates of Alternative Distribution Financing Ltd. (“Affiliates“);
- making available products and services offered by us or by other Affiliates;
- complying with a legal or regulatory duty to disclose personal data (for example if required to do so by a court or a government authority, or to prevent a fraud or another crime);
- enforcing the terms of its agreements;
- enhancing user experience.
We process personal data only to the extent required for the performance of our contracts, or in accordance with our legitimate interests in responding to enquiries or otherwise improving our relationship with our counterparties (including offering new or modified products or services) or enforcing our rights or defending ourselves in legal proceedings, or as required by a legal or regulatory or judicial obligation imposed on us.
Retaining personal information
We keep the information provided to us for as long as necessary to fulfil the purposes for which we process it according to this data privacy notice or for as long as we have a statutory obligation to retain it.
3. Who we share personal data with?
Alternative Distribution Financing Ltd. may disclose the data to other Affiliates for the purposes described in this notice. Affiliates may themselves process such data to perform their services. In particular, we may disclose personal data to our parent company:
- Global Supply Chain Finance AG
No data will be sold, traded or rented to others for their own purposes. However, Alternative Distribution Financing Ltd. may share personal data with selected external parties including:
- service providers, if any, used by Alternative Distribution Financing Ltd. or its Affiliates;
- business partners of Alternative Distribution Financing Ltd. or its Affiliates;
- third party experts and advisers including legal counsels, tax advisers or auditors;
- governmental or judicial bodies or agencies, regulatory and tax authorities to comply with legal and regulatory obligations.
Alternative Distribution Financing Ltd. is committed to protecting privacy and keeping personal data secure. It will therefore take all reasonable steps to ensure the personal data received is kept securely by the Affiliates and third parties and is not subject to unauthorised access or disclosure.
Transferring information outside of Europe
The information received by Alternative Distribution Financing Ltd. may be transferred to, and stored at, countries outside of the European Union (“EU”) and Switzerland. For example, we may share information with other Affiliates or business partners outside the EU. These countries may not have similar data protection laws to Switzerland or the EU. If we transfer personal data information outside of the EU in this way, we will take steps with the aim of ensuring that privacy rights continue to be protected as outlined in this data privacy notice.
4. What are the rights as a data subject?
At any time, a data subject has the right to:
- request us to stop processing his/her data. This may mean that we are no longer able to provide services or continuing the contractual relationship in relation to which the personal data were provided;
- obtain a copy of his/her personal data being processed;
- request any corrections or adjustments to the processed data or any rectifications or erasure of (incorrect) data;
- request the restriction of the processing of the personal data in accordance with applicable privacy legislation. This may mean that we are no longer able to provide the services or continuing the contractual relationship in relation to which the personal data were provided;
- contact the Federal Data Protection and Information Commissioner (“Eidgenössischen Datenschutz- und Öffentlichkeitsbeauftragten [EDÖB]”) and/or any other public authority responsible for data protection in Switzerland, if Alternative Distribution Financing Ltd. does not comply with applicable privacy legislation.
Such rights can be exercised by addressing a written request to:
Alternative Distribution Financing Ltd.
Att. Head Legal