Data protection

Version from [2023-06-15]

In this data protection declaration, we, SLT Medical AG (hereinafter SLT, we or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; If necessary, other data protection declarations [or general terms and conditions, conditions of participation and similar documents] regulate specific matters. Personal data refers to all information that relates to a specific 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 data protection declaration and only provide us with their personal data if you are permitted to do so and if they do so Personal data is correct.

This data protection declaration is designed to meet 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. Responsible person / data protection officer / representative

Responsible for the data processing that we describe here is

SLT Medical AG

Obere Dorfstrasse 12-14

8873 Amden

Switzerland,

unless otherwise stated in individual cases. If you have any data protection concerns, you can let us know at the contact address above.

Our representative in the EEA according to Art. 27 GDPR (if necessary) is:

EuCo Medical GmbH

Meisenweg 5

75443 Ötisheim

Germany

2. Collection and processing of personal data

We primarily process the personal data that we receive from these and other people involved in our business relationships with our customers and other business partners or that we collect from their 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, authorities and other third parties (such as [credit reference agencies,] [address dealers]). . In addition to the data about you that you give 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 their professional functions and activities (so that we can, for example, conclude and process business with your employer with your help), information about you in correspondence and meetings with third parties, credit information (insofar as we conduct business with you personally), information about you that is available to us People from your environment (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-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 the media and the Internet about you (if this is indicated in the specific case). is, e.g. as part of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC -Address of the smartphone or computer, details of your

Device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location information).

3. Purposes of data processing and legal basis

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of sales via our online shop 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 from you and other persons, to the extent permitted and deemed appropriate to us, also for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

⎯ Offer and further development of 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);

⎯ Examination and optimization of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition;

⎯ Advertising and marketing (including the organization of events), as long as 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 and we will then put you on a blocking list from others advertising mail);

⎯ Market and opinion research, media monitoring;

⎯ Assertion of legal claims and defense in connection with legal disputes and official proceedings;

⎯ Prevention and investigation of crimes and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);

⎯ Warranties of our operations, especially IT, our websites, apps and other platforms;

⎯ Video surveillance to protect house rules and other measures for IT, building and system security and to protect our employees and other people and assets belonging to or entrusted to us (such as access controls, visitor lists, network and email scanners, telephone records);

⎯ Purchase and sale of business areas, 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 comply with legal and regulatory obligations as well as internal regulations of SLT.

If you have given us your consent to process your personal data for specific purposes (for example when you register to receive newsletters or carry out a background check), we will process your personal data within the framework and based on this consent, unless we have no other consent We have a legal basis and we need one. Consent given can be revoked at any time, but this has no effect on 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 stored on your computer or mobile device by the web browser you are using when you visit our website [or install an app]. This way, when you visit this website [or use our app] again, 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 are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information over a certain period of time (e.g. two years) ("permanent cookies "). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them early. Most browsers are preset to accept cookies. We use permanent cookies [so that you can save user settings (e.g. language, autologin), ][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 your needs (which also can happen on websites of other companies; however, they will not find out from us who you are, if we even know that ourselves, because they only see that the same user is on their website who was also on a specific page with us) ]. [Certain cookies are set by us, and some are also set 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.

By using our websites[, apps] and agreeing to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not want this, you must set your browser or email program accordingly[, or uninstall the app if this cannot be adjusted via the settings.]]

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties who may be located in any country in the world (in the case of Google Analytics it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as data processor (both “Google”), www.google.com), with which we can measure and evaluate the use of the website (not personal). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are shortened before being forwarded to the USA and therefore cannot be traced back. We have turned off 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 draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and share this data with Google -Accounts of these people can be linked. 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 data protection regulations. The service provider only tells us how our respective website works

is used (no information about you personally).

5. Data transfer and data transfer abroad

As part of our business activities and the purposes in accordance with Section 3, we also disclose this to third parties, to the extent permitted and deemed appropriate to us, either because they process it for us or because they want to use it for their own purposes . This particularly concerns the following positions:

⎯ Service providers from us (within SLT and externally, such as banks, insurance companies), including order 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 committees;

⎯ Acquirers or interested parties in acquiring business areas, companies or other parts of SLT;

⎯ other parties in potential or actual legal proceedings;

all common recipients.

These recipients are partly domestic, but can be anywhere on earth. In particular, you must expect the transfer of your data to all countries in which SLT is represented by group companies, branches or other offices as well as to other countries in Europe 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 contractually oblige the recipient to comply with the applicable data protection (for this purpose we use the revised standard contractual clauses of the European Commission, which can be found here: https://eur-lex.europa.eu/ eli/dec_impl/2021/914/oj? are available) unless it is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception provision. An exception may apply in particular in legal proceedings abroad, but also in cases of overriding public interests or if the execution of a contract requires such disclosure, if you have given your consent or if it concerns data that you have made generally accessible and the processing of which you have not objected to.

6. Duration of retention of personal data

We process and store your personal data for as long as it is necessary to fulfill our contractual and legal obligations or for other purposes pursued by the processing, i.e. for example for the duration of the entire business relationship (from initiation to processing until the termination of a contract) and beyond in accordance with the statutory retention and documentation obligations. It is possible that personal data will be stored for the period in which claims are asserted against our company

and to the extent that we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidentiary and documentation purposes). As soon as your personal data is no longer required for the purposes mentioned above, it will generally be deleted or anonymized as far as 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 precautions to protect your personal data from unauthorized access and misuse.

8. Obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a 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 to ensure data traffic (such as IP address) is not disclosed.

9. Profiling [and automated decision making]

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

In principle, we do not use fully automated decision-making (as regulated in Art. 22 GDPR) to establish and implement the business relationship or otherwise. If we use such procedures in individual cases, we will inform you separately, provided this is required by law and inform you about the associated rights.

10. Rights of the data subject

Within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular those for purposes of direct marketing, of direct advertising

carried out profiling and other legitimate interests in the processing as well as in the release of certain personal data for the purpose of transferring it to another location (so-called data portability). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (to the extent that we can rely on this) or you needed to assert claims. If you incur any costs, we will inform you in advance. We have already provided information about the possibility of revoking your consent in Section 3. Please note that exercising these rights may conflict with contractual agreements and this may have consequences such as early termination of the contract or cost consequences. We will inform you in advance if this is not already contractually stipulated.

The exercise of such rights usually requires that you provide clear proof of your identity (e.g. by providing a copy of your ID, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.

Every data subject also has the right to enforce their claims in court or to file a complaint with the responsible data protection authority. The responsible 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 current version published on our website applies. To the extent that the Privacy Policy is part of an agreement with you, in the event of an update, we will inform you of the change by email or other appropriate means.