Bryt GmbH
Chamerstrasse 56, 6300 Zug

Privacy Policy of BRYT GMBH

Version from November 13, 2023

In this privacy policy, we, BRYT GMBH [companies of the BRYT GMBH Group] (hereinafter [all collectively] BRYT GMBH, we, or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; other privacy policies [or general terms and conditions, conditions of participation, and similar documents] may regulate specific issues. Personal data is understood to mean all information that relates to an identified or identifiable person.

If you provide us with personal data of other people (e.g. family members, data of work colleagues), please ensure that these people are aware of this privacy policy and only provide us with their personal data if you are permitted to do so and if this personal data is correct.

This privacy policy is designed to comply with the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DSG"), and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.

1. Person responsible / data protection officer / representative

BRYT GMBH ([ BRYT GMBH, CHAMERSTRASSE 56, 6300 ZUG]) is responsible for the data processing described here [unless otherwise stated in individual cases]. If you have any data protection concerns, you can contact us at the following address: Bryt GmbH, Chamer Strasse 56, 6300 Zug [for all companies in the BRYT GMBH Group (please state which ones you are referring to, if possible)]: [ BRYT GMBH, CHAMERSTRASSE 56, 6300 ZUG AND INFO@BRYT.CH]

Our representative in the EEA according to Art. 27 GDPR (if necessary) is: [INFO@BRYT.CH].

2. Collection and processing of personal data

We primarily process the personal data that we receive from our customers and other business partners and other persons involved in the course of our business relationship with them, or that we collect from users when operating our websites, apps and other applications.

To the extent permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from other companies within the BRYT GMBH group, from authorities and other third parties (such as [credit agencies,] [address dealers]). In addition to the data you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (insofar as we conduct business with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) give us so that we can conclude or process contracts with you or with your involvement (e.g. references, your Bryt GmbH, Chamer Strasse 56, 6300 Zug for deliveries, powers of attorney, information on compliance with legal requirements such as the fight against money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours regarding the use or provision of services by you (e.g. payments made, purchases made)), information from Media and internet about you (as far as this is appropriate in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.), your Bryt GmbH, Chamer Strasse 56, 6300 Zug n and if applicable interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP- Bryt GmbH, Chamer Strasse 56, 6300 Zug , MAC- Bryt GmbH, Chamer Strasse 56, 6300 Zug of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location information).

3. Purposes of data processing and legal bases

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, particularly in the context of [TRADING CHAMPAGNE AND EVENTS] with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity.

In addition, we process personal data of you and other persons, where permitted and deemed appropriate, for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offering and further developing our offers, services and websites, apps and other platforms on which we are present;
• Communication with third parties and processing their inquiries (e.g. applications, media inquiries);
• Testing and optimising procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;
• Advertising and marketing (including organizing events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time; we will then place you on a blacklist to prevent further advertising mailings);
• Market and opinion research, media monitoring;
• Asserting legal claims and defending in connection with legal disputes and regulatory proceedings;
• Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
• Ensuring our operations, in particular IT, our websites, apps and other platforms;
• Video surveillance to protect house rules and other measures for IT, building and facility security and to protect our employees and other persons and assets belonging to us or entrusted to us (such as access controls, visitor lists, network and email scanners, telephone recordings);
• Purchase and sale of business units, companies or parts of companies and other corporate transactions and the associated transfer of personal data as well as measures for business management and, to the extent necessary to comply with legal and regulatory obligations as well as internal regulations of BRYT GMBH.

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or conduct a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and we require one. Consent given can be revoked at any time; however, this will not affect data processing that has already taken place.

4. Cookies / tracking and other technologies related to the use of our website

We typically use "cookies" and similar technologies on our websites [and apps] that can be used to identify your browser or device. A cookie is a small file that is sent to your computer or automatically saved on your computer or mobile device by the web browser you use when you visit our website [or install the app]. When you visit this website again [or use our app], we can recognize you, even if we don't know who you are. In addition to cookies that are only used during a session and deleted after your website visit ("session cookies"), cookies can also be used to store user preferences and other information for a specific period of time (e.g., two years) ("permanent cookies"). However, you can set your browser to reject cookies, save them only for a session, or otherwise delete them earlier. Most browsers are preset to accept cookies. We use permanent cookies [so that you can save user settings (e.g. language, auto login),][so that we can better understand how you use our offers and content,][and][so that we can show you offers and advertising tailored to you (which can also happen on other companies' websites; however, they will not learn who you are from us, if we even know that ourselves, because they only see that the same user is on their website who was on a certain page on ours)]. [Certain of the cookies are set by us, and others by contractual partners with whom we work.] If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.

[We sometimes, and where permitted, include visible and invisible image elements in our newsletters and other marketing emails. By retrieving these from our servers, we can determine whether and when you have opened the info@bryt.ch website. This allows us to measure and better understand how you use our offerings and tailor them to your needs. You can block this in your info@bryt.ch program; most are preset to do so.]

By using our websites [, apps] and agreeing to receive newsletters and other marketing emails, you consent to the use of these technologies. If you do not want this, you must configure your browser or your info@bryt.ch program accordingly [or uninstall the app if this cannot be adjusted via the settings.]]

If Google Analytics or other statistical services are used to which no personal data is transmitted (such as info@bryt.ch - Bryt GmbH, Chamerstrasse 56, 6300 Zug):

We occasionally use Google Analytics or similar services on our websites. This is a service provided by third parties that may be located in any country in the world (in the case of Google Analytics, this is Google Ireland (based in Ireland); Google Ireland relies on Google LLC (based in the USA) as a processor (both "Google"), www.google.com), with which we can measure and evaluate the use of the website (not in a personal way). For this purpose, permanent cookies set by the service provider are also used. We have configured the service so that the IP address of visitors in Europe is shortened by Google before being forwarded to the USA and thus cannot be traced back. We have deactivated the "Data sharing" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles, and link this data to these individuals' Google accounts. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its privacy policy. The service provider only informs us how our respective website is used (no information about you personally).

We also use plug-ins from social networks such as Facebook, Twitter, YouTube, Pinterest, or Instagram on our websites. You will be able to see this (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking), the operators of the respective social networks can register that you are on our website and where you are, and can use this information for their own purposes. Your personal data will then be processed under the responsibility of that operator in accordance with its privacy policy. We will not receive any information about you from them.

5. Data sharing and data transfer abroad

Within the scope of our business activities and for the purposes set out in Section 3, we also disclose personal data to third parties, where permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following entities:

• Our service providers (within the BRYT GMBH group and externally, such as banks, insurance companies), including contract processors (such as IT providers);
• dealers, suppliers, subcontractors and other business partners;
• Customers;
• domestic and foreign authorities, offices or courts;
• Media;
• Public, including visitors to websites and social media;
• Competitors, industry organizations, associations, organizations and other bodies;
• Purchasers or parties interested in acquiring business units, companies or other parts of the BRYT GMBH Group;
• other parties in potential or actual legal proceedings;
• Other companies of the BRYT GMBH group;

all common recipients.

Some of these recipients are located in Germany, but they may be located anywhere in the world. In particular, you must expect your data to be transferred to all countries in which the BRYT GMBH Group is represented by group companies, branches, or other offices ([LINK TO LIST]), as well as to other European countries and the USA where the service providers we use are located (such as [Microsoft], [SAP], [Amazon], [Salesforce.com]).

If a recipient is located in a country without adequate legal data protection, we will contractually oblige the recipient to comply with the applicable data protection regulations (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply, in particular, in legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires such disclosure, if you have consented, or if the data concerned has been made generally accessible by you and whose processing you have not objected to.

6. Duration of storage of personal data

We process and store your personal data as long as it is necessary to fulfill our contractual and legal obligations or for the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from initiation and processing to termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data will be retained for the period during which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require it (e.g. for evidential and documentation purposes). As soon as your personal data is no longer required for the purposes stated above, it will generally be deleted or anonymized wherever possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less apply.

7. Data security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as [issuing instructions] [, training] [, IT and network security solutions] [, access controls and restrictions] [, encryption of data media and transmissions] [, pseudonymization] [, controls].

8. Obligation to provide personal data

As part of our business relationship, you must provide the personal data necessary to establish and conduct a business relationship and fulfill the associated contractual obligations (you generally have no legal obligation to provide us with data). Without this data, we will generally not be able to enter into or process a contract with you (or the entity or person you represent). The website cannot be used if certain information required to secure data traffic (such as IP-Bryt GmbH, Chamer Strasse 56, 6300 Zug) is not disclosed.

9. Profiling [and automated decision-making]

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. We use evaluation tools that enable us to tailor communication and advertising to your needs, including market and opinion research.

[To establish and conduct the business relationship, or otherwise, we generally do not use fully automated decision-making (as regulated, for example, in Art. 22 GDPR). Should we use such procedures in individual cases, we will inform you separately, provided this is required by law, and inform you of your associated rights.]

10. Rights of the data subject

Within the scope of the data protection law applicable to you and to the extent provided therein (such as in the case of the GDPR), you have the right to information, rectification, erasure, the right to restriction of data processing and otherwise to object to our data processing, in particular that for the purposes of direct marketing, profiling carried out for direct advertising and other legitimate interests in processing, as well as to the release of certain personal data for the purpose of transferring it to another entity (so-called data portability). Please note, however, that we reserve the right to assert the legally prescribed restrictions, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this), or require it to assert claims. If costs are incurred for you, we will inform you in advance. We have already informed you about the possibility of revoking your consent in section 3. Please note that the exercise of these rights may conflict with contractual agreements and this may have consequences such as early termination of the contract or cost implications. We will inform you in advance if this is not already contractually agreed.

Exercising such rights generally requires that you provide clear proof of your identity (e.g., by providing a copy of your ID card where your identity is otherwise unclear or cannot be verified). To assert your rights, you can contact us at Bryt GmbH, Chamerstrasse 56, 6300 Zug, as stated in Section 1.

Furthermore, every data subject has the right to enforce their claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Changes

We may amend this Privacy Policy at any time without prior notice. The most current version published on our website applies. If this Privacy Policy is part of an agreement with you, we will notify you of any changes via info@bryt.ch or by other appropriate means.

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