# Privacy policy

*This is a translation. The French version is legally binding.*

## 1. Introduction

### 1.1. Who are we?

**VNV SA** is a company incorporated under Swiss law with its registered office at Allée des Défricheurs 4, 2300 La Chaux-de-Fonds, Switzerland. **VNV SA** is entered in the Commercial Register under number CHE-151.659.612.

**VNV SA** is active in particular in the development and operation of software applications, in application hosting and, more generally, in IT consulting.

This privacy statement concerns **VNV SA** only.

**VNV SA** can be contacted at the following email address for any question or complaint relating to this privacy statement: privacy@vnv.ch.

In this privacy statement, we inform you about how we process data. We explain which data we process when you access our digital presence, whether on this website or on other websites.

We attach the utmost importance to protecting your privacy and your personality rights. Accordingly, we process your personal data in accordance with the law.

### 1.2. Scope of this privacy policy

This privacy policy applies to **VNV SA** and to its clients and users.

### 1.3. Personal data?

In the course of our activities, we collect, store, share and/or process personal data. Under the applicable data protection law, we are considered the controller of the personal data that we collect, store and process.

In this privacy statement, the term “personal data” means information that relates to you and allows us to identify you, either directly or when we combine it with other information that we may hold. Your personal data may include, in particular, your name, your contact details and information on when you accessed our data centre.

### 1.4. Addressees

This privacy policy is addressed, among others, to the clients of **VNV SA**, to the users of **VNV SA** products and to applicants for positions at **VNV SA**.

### 2. Data collection

We respect your right to privacy and endeavour to protect your personal data in accordance with the applicable data protection legislation and, more specifically, with the General Data Protection Regulation (GDPR) of the European Union and the Swiss Federal Act on Data Protection (FADP).

In this privacy statement, we set out the means by which we collect your data, how and for what purposes we may use your personal data, and to whom we may disclose it.

In addition, this privacy statement contains important information about your rights in relation to the processing of your personal data.

### 2.1. About whom do we collect data?

In the course of our services, we may collect personal data about the following persons:

- Visitors accessing our data centre;
- Client contacts;
- Contacts at suppliers and service providers;
- Prospects who may be interested in our services or who show such an interest;
- Job applicants;
- Visitors to our website.

### 2.2.  What data do we collect?

We may collect information about you in various ways.

#### 2.2.1.  Directly from you

- Details (in particular: surname; first name) of visitors, which we collect from you, for example when you access our data centre;
- Your contact details, which you provide to us in the context of a contractual business relationship;
- Personal information (in particular: CV, letter of recommendation, cover letter; employment reference) that you provide to us as a job applicant;
- Personal information that you provide to us by filling in a form on the website;
- Personal information that you provide to us at a professional or business event.

#### 2.2.2. Indirectly from you

- Your personal information that our client provides to us, for example under a contract;
- Your personal information that our supplier or service provider provides to us;
- Your contact details collected by third parties, for example to update our database.

#### 2.2.3. Data collection and recording

- Information that we obtain from your use of our website, for example through our servers’ access logs or the audience measurement tool described in section 8.
- Our web servers automatically collect and record every access in a temporary log file. User-specific data (such as the identification data of the browser used, the operating system of the computer used, the amount of data transferred, the IP address, and the date and time of access) and technical data (such as the name and URL of the referring web page, the date and time of access to the website via a link and the search term in the case of access via a search engine) are recorded and evaluated anonymously. In other words, the data collected is not linked to any identified person.
- The tools used to collect data include, in particular, the website access logs, the application access logs and the Matomo audience measurement tool, configured without cookies.
- The general purpose of the automatic data collection is to compile statistics that enable us to improve our services and their quality. For further details on the automatic collection of data, please refer to section 3 below.
- The automatically collected data mentioned above is not used for any purposes other than those described in this section, unless you have also expressly consented to the processing of your data for other purposes in connection with the use of certain services, or we are legally required to do so.

## 3. Purposes for which data is used

### 3.1. Client contacts

| **Personal data** | **Purposes** |
| --- | --- |
| Your contact details: ; – Surname, first name and company ; – Business email address ; – Business telephone number ; – Business mobile number ; – Personal mobile number | To administer and manage our relationship, including invoicing and debt collection. To ensure the performance of our contractual services, including their configuration and implementation, and for any other operational purpose. To keep the information in our systems up to date. For VNV’s own marketing purposes only. To handle any complaints. To establish, defend and exercise our rights. |

### 3.2. Contacts at suppliers and service providers

| **Personal data** | **Purposes** |
| --- | --- |
| Your contact details: ; – Name and company ; – Business email address ; – Business telephone number ; – Mobile number ; – Personal telephone number | To administer and manage our relationship, including the payment of invoices. To ensure the performance of our contractual services, including day-to-day operational tasks. To keep the contact information in our systems up to date. To handle any complaints. To establish, defend and exercise our rights. |

### 3.3. Prospects

| **Personal data** | **Purposes** |
| --- | --- |
| Your contact details: ; – Name and company ; – Business email address ; – Business telephone number ; – Mobile number | For VNV’s own marketing purposes only. |
| Personal information relating to the company, including participation in business or marketing events or webinars | To meet the business needs of potential clients whom we will contact in the future. |

### 3.4. Job applicants

| **Personal data** | **Purposes** |
| --- | --- |
| Your contact details: ; – Surname and first name ; – Postal address ; – Email address ; – Mobile number ; – Landline number | Basic information used during the recruitment process and then, where applicable, in the event of an employment contract validly concluded with VNV SA. |
| Your curriculum vitae and your cover letter | For use in our recruitment process and then, where applicable, in the event of an employment contract validly concluded with VNV SA. |
| Your assessment and any other information, where applicable | For use in our recruitment process and then, where applicable, in the event of an employment contract validly concluded with VNV SA. To handle any complaints. To establish, defend and exercise our rights. |

### 3.5. Visitors to our website

| **Personal data** | **Purposes** |
| --- | --- |
| The data you enter in the contact form: ; – Name ; – Email address ; – Message | To respond to your enquiry. |
| Browsing data: ; – Anonymised IP address ; – Pages viewed ; – Browser and device type | To compile anonymous visitor statistics and improve our website, without cookies or profiling. |

### 3.6. Legal bases for these processing activities

- For the processing of visitors’ data for security purposes, we rely on our legitimate interest and on their express acceptance. Legitimate interest means, in particular, improving our services and their quality, marketing and offering future services.
- For the processing of the personal data of contacts at our clients, suppliers and service providers, we rely on the performance of a contract with the client, supplier or service provider who provided the contact details, and on our legitimate interest in using those contact details.
- For the processing of the personal data of our client contacts for marketing purposes, we rely on our legitimate interest.
- For the processing of the personal data of our job applicants, we rely on consent, given by an affirmative action when the applicants submit this information to **VNV SA**.
- For the processing of the personal data of visitors to our website:
  - For the contact form, we rely on consent, given by an affirmative action when the visitor submits the form.
  - For audience measurement with Matomo, we rely on our legitimate interest in compiling visitor statistics and improving our website. This measurement works without cookies and involves no profiling.
  - For Google Tag Manager and Google Analytics (section 8), we rely on your consent, given through the Biskoui consent banner and revocable at any time.
- For the processing of prospects’ personal data for marketing purposes, we usually rely on our legitimate interest, unless local legislation requires us to obtain specific consent.
- By legitimate interest, we mean, without limitation, all the purposes set out in the tables in sections 3.1 to 3.6 above.

## 4. Sharing your data

In the situations listed above, we may share your personal data with third parties (for example, with clients, by providing them with information from the data centre access register).

We may share the personal data we collect within our group of companies to the extent necessary. It may therefore be passed on to employees of the group (internal). We may also call on third parties to assist us in our business operations (external).

We only share personal data with third parties who ensure that appropriate security measures are in place, so that the processing activities meet the requirements of the GDPR and the FADP and the protection of your individual rights is guaranteed. Where applicable, we must ensure that data processing agreements are concluded with third parties, describing the purpose, protection and security of your data.

The parties with whom we may share your personal data, as indicated above, may be located in countries outside the European Economic Area (EEA), and these countries may offer a lower level of data protection than EEA member states.

In that case, appropriate measures must be taken to ensure adequate protection of your personal data in accordance with the GDPR and the FADP. More specifically, transfers of personal data outside Switzerland and the EEA are based on an adequacy decision (for example the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework) or on the standard contractual clauses recognised by the European Commission and the Federal Data Protection and Information Commissioner (FDPIC).

Your personal data and/or profiles will not be rented or sold to third parties without your prior explicit consent.

## 5. Data retention period

Your personal data will not be stored for longer than necessary for the purposes of the processing (listed in section 3).

We will only store personal data for longer if the law requires us to do so or if it is necessary to defend our interests in legal proceedings (for example in a dispute, administrative proceedings or criminal proceedings).

### 5.1. Clients, suppliers and service providers

| **Personal data** | **Retention period** |
| --- | --- |
| Your contact details: ; – Name and company ; – Business email address ; – Business telephone number ; – Mobile number ; – Personal telephone number | Generally 10 years, for administrative and tax reasons. |

### 5.2. Prospects

| **Personal data** | **Retention period** |
| --- | --- |
| Your contact details: ; – Name and company ; – Business email address ; – Business telephone number ; – Mobile number | 4 weeks after withdrawal of your consent. |

### 5.3. Job applicants

| **Personal data** | **Retention period** |
| --- | --- |
| All information, including name, postal address, email address, telephone numbers, curriculum vitae, cover letter, employment reference(s) and assessment(s) | If the applicant is not hired, 2 years. If the applicant is hired, up to 5 years after the end of their employment contract. |

### 5.4. Visitors to our website

| **Personal data** | **Retention period** |
| --- | --- |
| The data entered in the contact form: ; – Name ; – Email address ; – Message | 4 weeks after withdrawal of your consent. |

## 6. Protection of your personal data

**VNV SA** uses appropriate technical and operational security measures to protect as effectively as possible the personal data that we hold in our systems, whether located on our premises or on the servers of a designated third party. We protect your personal data against manipulation, partial or total loss and unauthorised access by third parties.

We implement the administrative, technical and organisational measures necessary to ensure a level of security appropriate to the specific risks we have identified. We protect your personal data against destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data transmitted, stored or processed. In particular, we have taken the following measures:

- Valid physical access, based on the authorisations in force;
- Access to networks and systems restricted to staff with access rights;
- Users with unique passwords (password management ensuring their quality);
- Event logs recording user activity in data processing systems;
- Two-factor authentication for access to our systems;
- Firewalls and intrusion prevention systems;
- Encryption in transit and at rest, applied where necessary;
- Mandatory training for all employees in the Information Systems Security Policy (ISSP), the GDPR, the FADP and security.

We also make sure that your personal data is accurate and up to date. We therefore ask you to inform us of any change to your personal data (such as a change in your contact details).

In the event of a security breach, **VNV SA** undertakes to inform the clients affected by the breach immediately upon its discovery by **VNV SA**. Among other things, VNV SA would keep clients informed of the steps taken, immediately communicate when the breach occurred and inform the client of the data potentially affected.

## 7. Your rights and how to exercise them

### 7.1. Rectification, blocking and erasure/withdrawal of consent

Under the Swiss Federal Act on Data Protection, you may exercise the following rights over the data we hold about you:

- You may request general information about the recording of your personal data
- You may request access to the personal data we hold about you;
- You may correct or delete inaccurate personal data, and complete incomplete personal data;
- You may request the erasure of your personal data;
- You may object to the processing of your personal data or obtain the restriction of the processing of your personal data (including with regard to the processing of your personal data for direct marketing purposes);
- You may request the transfer of your personal data to another controller, or receive it in a format that allows such a transfer (“right to data portability”);
- You may object to any decision concerning you that is taken solely by a computer or based solely on any other automated processing (including profiling);
- You may lodge a complaint about the use of your personal data with a supervisory authority.

In addition, in accordance with Art. 26 FADP, we may refuse or restrict the disclosure of the information requested, or defer it, if a law in the formal sense so provides or if overriding interests of a third party so require.

### 7.2. Contact information

For any question, suggestion or request relating to the processing of your personal data, you may submit a specific request by post or by email:

- Postal address:

**VNV SA**

Allée des Défricheurs 4  
2300 La Chaux-de-Fonds  
Switzerland

Email address: [privacy@vnv.ch](mailto:privacy@vnv.ch)

## 8. Use of cookies and other technologies

Our website does not use any social media plug-ins. The fonts, the map, the images and our own scripts are served from our own servers.

On your first visit, a consent banner (Biskoui) lets you accept or refuse the third-party cookies and tools described below. Until you have given your consent, none of these tools is loaded; the banner only stores your choice.

Links to external websites, for example LinkedIn or Google Maps, do not load any content until you click on them. When you follow one of these links, the privacy policy of the external website concerned applies.

### 8.1. Audience measurement

To compile visitor statistics, we use the Matomo audience measurement tool, configured without cookies. Your IP address is anonymised. The data collected is used exclusively to compile aggregated statistics and is not passed on to third parties.

With your consent, we also use Google Tag Manager and Google Analytics, services of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC (United States). These services place cookies and send browsing data (in particular your IP address, the pages viewed, and the browser and device type) to Google, including to the United States; this transfer relies on the Data Privacy Framework or on standard contractual clauses (see section 4). You may withdraw your consent at any time (see section 8.3).

### 8.2. Contact form

The anti-spam check of the contact form (ALTCHA) is computed in your browser, without cookies and without using any third-party service. The data you enter in the form is sent to **VNV SA** by email and retained in accordance with section 5.4 above.

### 8.3. Managing cookies

You may change or withdraw your consent at any time by reopening the settings of the Biskoui consent banner. All major web browsers also allow you to manage and delete the cookies installed on your computer or mobile device.

You will find further information on the use of cookies on the following website: [www.allaboutcookies.org](https://www.allaboutcookies.org/).

## 9. Changes to our privacy statement

From time to time, we may need to change our privacy statement, for example as a result of technological developments or changes in legal provisions. **VNV SA** therefore reserves the right to amend this privacy statement at any time, with effect from a later date.

We encourage you to consult our website regularly, where you will find the most recent version of this privacy statement. You may also ask us to send you a copy of the most recent version of this privacy statement.

This privacy statement was last updated in: **October 2026**.

## 10. Applicable law and place of jurisdiction

To the extent permitted by law, all legal relationships between **VNV SA**, its clients and its users are governed by Swiss law.

Should any clause of this privacy statement prove to be void or unenforceable, in whole or in part, the remaining clauses shall remain valid.

The exclusive place of jurisdiction for any dispute arising from this privacy statement is La Chaux-de-Fonds, Canton of Neuchâtel.

**VNV SA**  
Allée des Défricheurs 4  
2300 La Chaux-de-Fonds  
SWITZERLAND  
[info@vnv.ch](mailto:info@vnv.ch)