Privacy Policy

1. Purpose and scope

beqom understands that the services provided to you or performed on your behalf involve a great deal of trust on your part. We take this trust very seriously, and make it our highest priority to ensure the security and confidentiality of the personal data provided to us. Please read the following policy to learn about our privacy practices. By downloading or using the beqom web sites (the "Site") or benefiting from the services available from the Site, you are accepting the practices described herein.

beqom provides this Global Privacy Policy to describe our procedures regarding the collection, use and disclosure of personal data we collect or receive from the visitors of the Site.

2. Definitions

Personal data "(Personal Data") within this policy refers to any information relating to an identified or identifiable natural person in the meaning of:

For data subjects residing within the territory of the European Economic Area (EEA), the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;

For data subjects residing in Switzerland, the Swiss Federal Act on Data Protection and related ordinances;

For data subjects residing in the United Kingdom, the UK Data Protection Act 2018 and the UK GDPR (GDPR as it forms part of the law of England, Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018)

3. Collection and Use of Personal Data

3.1. Data Collection

3.1.1. Purpose

We collect Personal Data about you to provide you the services and improve the Site features and content, to administer your user account and to enable you to enjoy our services and easily navigate the Site.

When you register through the Site to become a user, when you create or edit your user account and use a service, we will ask you for Personal Data. We may collect the Personal Data that you provide as part of registration and the administration and personalization of your user account, or Personal Data that you provide us by using the services.

3.1.2. Extent

beqom may collect the following Personal Data:

Contact information, such as name, physical address, telephone number(s), email address, and company;

Transactional information, including information about the services you purchase or download or about which you make an inquiry;

User preferences, such as services requirements, areas of industry interest, newsletters, community choices and other information you select in the customer profile when registering on the Site or indicated by your use of the Site.

We may supplement the information you provide with information received from third parties.

3.2. Data Use

beqom uses Personal Data for the purpose of offering the services. The data transmitted to beqom by you may be hosted by beqom or a third party of its choice, as part of the services.

We use your Personal Data for the following general purposes:

To fulfill your requests for services;

To personalize promotional offers and content you see, in particular based upon your activity and your transaction history with the Site;

To improve the services;

To conduct research and compile statistics on usage patterns;

To provide anonymous aggregate reporting for internal and external partners;

To manage your user account;

To communicate with you in general;

To respond to your questions and comments;

To notify you about promotional offers and services that may be of interest to you;

To send you the beqom's newsletter;

To prevent potentially prohibited or illegal activities;

To enforce the Terms of Use of the Site;

And as otherwise described to you at the point of collection;

To comply with legal requirements related to Personal Data protection.

3.3. Legal Requirements

beqom may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.

3.4. Subcontractors

Your Personal Data may be transferred, accessed and stored as necessary for the uses stated in Section 3.2 and 3.3 above. While beqom may share your personal information with agents and contractors to perform the functions listed in Sections 3.2 and 3.3, including order fulfilment and website management, we require that such agents and contractors treat your Personal Data, and limit its use, in accordance with the standards specified in this policy.

4. Electronic Communications Protocols and Cookies

4.1. In General

In addition to the information specified above, beqom may collect information about your use of the Site through electronic communications protocols and cookies. As is true when you visit most websites, beqom may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address, referring website and date and time. Collecting this automatic information helps us customize your experience as a user. It allows us to monitor and analyze the use of the Site and services and to increase the Site's functionality and user-friendliness.

Like many other websites, beqom also uses cookies, embedded URLs and embedded pixels to capture additional information. Cookies are small data files, which are transferred to a computer's hard disk in order to memorize information like registration IDs and passwords. We further utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users. We will utilize cookies for identifying your language settings of your device, the promotional offers you subscribed to in and/or session cookies. Session cookies are, unlike persistent cookies, deleted from your computer when you log off from the Site and then close your browser. Please note that you can always choose not to receive a cookie file by enabling your Web browser to refuse cookies or to prompt you before accepting a cookie. However, if you refuse cookies, you may not be able to use all portions of the Site or all functionality of the services.

We may re-associate the information provided by the technologies directly above with Personal Data.

4.2. First-Party and Third-Party Cookies

4.2.1 First-Party Cookies

beqom’s website has first-party cookies and allows third parties to place cookies on your device. The difference between a first-party cookie and a third-party cookie relates to who places the cookie on your device. First-party cookies are cookies that are specific to the website that created them. These cookies enable beqom to operate an efficient service and to track patterns of user behavior to beqom’s website.

4.2.2 First-Party Cookies

Third-party cookies are placed on your device by a third party (i.e., not by beqom). While beqom allows third parties to access beqom’s website to place a third-party cookie on your device, beqom does not retain control over the information supplied by such cookies, nor does beqom retain access to this information. This information is controlled wholly by that third party according to the respective privacy policy of the third party. Details on third-party cookies are stated in the below table.

5. Security Control

beqom is committed to the security of your Personal Data, and has in place technical and organizational measures designed to prevent unauthorized access to that information. These measures, which are aligned with the highest standards in the industry, govern all areas of security applicable to Services and apply to all beqom employees.

In addition, beqom uses standard security protocols and mechanisms to exchange the transmission of sensitive data. When you enter sensitive information on our site, we encrypt it using secure socket layer (SSL) technology.

Where your Personal Data information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, beqom will promptly notify you of the breach by email, fax, or mail.

6. International Transfer

By using the Site, you acknowledge and agree that Personal Data you submit to beqom will be hosted by beqom or a third party of its choice for an indefinite period of time.

You hereby agree that your Personal Data may be transferred outside EEA countries, the United Kingdom or Switzerland - and maintained on - computers located outside the EEA territory, the United Kingdom or Switzerland, where privacy laws may not be as protective as those in your jurisdiction.

Your consent to this Privacy Policy followed by your submission of Personal Data represents your explicit agreement to such transfer.

To the extent cross border transfer to third countries not benefiting from an adequacy decision is concerned, refer to section 10 hereunder.

7. Information Sharing and Disclosure

We may share aggregated information that does not include Personal Data and we may otherwise disclose non-identifying information with third parties for analysis and other purposes. Any aggregated information shared in these contexts will not contain Personal Data.

Under certain circumstances, beqom may be required to disclose Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements. beqom may disclose Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency, or in the good faith belief that such action is necessary:

To comply with a legal obligation,

To protect or defend our rights, interests or property or that of third parties,

To prevent or investigate possible wrongdoing in connection with the Site or our services,

To act in urgent circumstances to protect the personal safety of users of the Site, our services or the public.

Where disclosure relates to your Personal Data, we will communicate to you any request for disclosure by public authorities (including those received for national security or law enforcement reasons) unless beqom is prohibited by law to do so.

8. Right to Access, Correct or Delete your Personal Data

You may, at any time, request access to your Personal Data collected by beqom, request that inaccurate information be corrected, or that the collected Personal Data be erased. You can also ask us to stop using all or some of your Personal Data (for example, if we have no legal right to keep using it) or to limit our use of it (including, for example, if the information about you is inaccurate). Any such request must be sent in writing to:

beqom SA, Rue de la Colombière 28, 1260 Nyon, Switzerland, or

[security.officer@beqom.com].

beqom has appointed a Chief Privacy Officer. To exercise the above rights, you may send a request by email to:

[security.officer@beqom.com],

with a copy of your identity card or passport for identification purposes. We will respond in compliance with applicable law.

If you are not satisfied with how beqom processes your Personal Data, please let us know and we will investigate your concern.

In addition, you have the right to make a complaint to the competent data protection authority.

9. How to Delete your User Account

If you would like us to delete your Personal Data in our system, please let us know by e-mail at [security.officer@beqom.com] and we will attempt to accommodate your request if we do not have any legal obligation to retain the record.

Please note that any information that we have collected may remain in back-up storage for some period of time after your deletion request, as well as any content that you have posted transmitted to a third-party. This may be the case even though no Personal Data about your user account remains in our active users’ databases.

You acknowledge that the use of the Internet is not safe and that there are certain inherent risks to your Personal Data. beqom shall make reasonable efforts to protect your Personal Data but it cannot guarantee or warrant that data you provide to beqom is safe and protected from unauthorized third-party access.

10. Transfer outside EEA or jurisdictions without EC adequacy decision

beqom have entered into EU standard contractual clauses as approved by the EU Commission, respectively the standard contractual clauses for the transborder outsourcing of personal data processing approved by the Swiss Federal Data Protection and Information Commissioner, the standard contractual clauses approved by the UK Information Commissioner’s Office, or reliance on a recognized certification mechanism prior to such transfer to ensure the required level of protection for the transferred Personal Data.

11. Data Controller and EU-UK Representatives

The data controller in the meaning of the legislation referred to in section 2 is beqom SA, a company incorporated under Swiss law, with a registered office at Rue de la Colombière 28, 1260 Nyon, Switzerland, registered under No. CHE-114.718.819.

The data controller has appointed the following beqom SA representatives:

in the EU, beqom France, with offices at 203 Rue de Bercy, 75012 Paris, France, registered under No. 441.403.508 at R.C.S. Paris

in the UK, beqom UK Limited, with offices at 8 St Thomas Street, London SE1 9RS, Company No. 07006587.

12. Acceptance of the Policy

beqom reserves the right to amend this policy as beqom deems necessary or desirable without prior notification to you. Users will be informed of the new Privacy Policy, but it is your responsibility to verify regularly this policy to be informed of any changes. Your continued use of the services after any such changes or after explicitly accepting the new Privacy Policy upon using the Site and/or the services shall constitute your consent to such changes.

beqom uses a third-party service provider (Hubspot) to perform analysis of visits to its website and to provide its marketing services. Hubspot anonymously tracks visitor activities and, when visitors subscribe to marketing services, Hubspot combines this information with contact information collected through beqom forms using cookies.

13. Contacting us

beqom has appointed a Chief Privacy Officer. If you believe your Personal Data has been used in a way that is not consistent with this policy, or if you have further questions related to this policy, please contact us at:

[security.officer@beqom.com].

14. Validity and document management

The current version of this document is effective as of the last update set out in the Change History.

The owner of this document is the Head of Legal, who checks and, if necessary, updates the document at least once a year.

15. Change history