Trans Adriatic Pipeline AG (hereinafter “TAP” or “we” or “us” or “the Company”) is the responsible party for the processing of personal data collected through the website www.tap-ag.com (hereinafter the “Website”) as per the applicable data protection laws, in particular the Swiss Data Protection Act (DPA) and – if applicable to your personal data - the European General Data Protection Regulation (GDPR). We have our registered domicile at Lindenstrasse 2, 6340 Baar, Switzerland. For any inquiries regarding our use of your personal data you may contact us by letter, phone (+41 41 747 3400), fax (+41 41 747 3401) or e-mail us at DPO@tap-ag.com.
2.GENERAL INFORMATION ON HOW WE PROCESS YOUR PERSONAL DATA
We only process your personal data if this is necessary in the course of our activities, such as if the processing is necessary to provide a functional website, to provide you with our contents and information on our activities or to address a relevant request or application submitted by you. The processing of personal data only takes place after we have obtained your prior consent or when the processing of your personal data is permitted by law.
Your data is protected against unauthorized access according to appropriate technology standards and through a role and authorization concept.
2.2.Legal Basis for Processing
We process your data on a certain legal basis, as described below. If a basis on which we process your personal information is no longer relevant then we shall cease processing your data. If the basis changes and if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. We set out the relevant legal basis for each processing activity in the relevant sections below.
2.3.Duration of Processing
The duration of processing depends on the specific processing activity. As a general rule, we only store your personal data for as long as necessary to serve the purpose of the processing and we delete personal data as soon as such purpose ceases to apply. The applicable retention periods for the specific processing activities are set out below.
Furthermore, personal data may be stored if this has been provided for by the applicable law (for example for book keeping or mandatory archiving purposes). The data will also be deleted if a storage period prescribed by the applicable law expires, unless there is a need for further storage of the data.
3.WEBSITE ACCESS AND LOGFILES
3.1.Automated Data Processing
Every time you visit our website, our system automatically collects data and information about the computer system you used to access our website.
The following data is collected:
- Browserinformation (type and version)
- Operating system
- Your internet service provider
- Your IP address
- Date and time of access
- Websites from which your system reaches our website
- Websites accessed by the user's system via our website
- The data is also stored in the log files of our system. This data is not stored together with any of your other personal data that you may submit voluntarily in other sections of the website as described below.
3.2.Legal basis of processing
The processing of data collected when visiting our website is performed on the basis of our legitimate interest to provide and maintain a well-functioning and user-friendly website which includes information about the TAP project.
3.3.Purpose of Processing
The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
3.4.Duration of Processing
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, deletion occurs after 28 days at the latest.
- search terms
- frequency of page hits
- use of website functions
The data collected in this way is pseudonymised by technical means. Therefore, it is no longer possible to assign the data to you. The data will not be stored together with any of your other personal data which you may submit voluntarily in other sections of the website as described below.
4.2.Legal basis of processing
The processing of your data for the cookies usage takes place on the basis of your consent as well as on the basis of our Company’s legitimate interest to provide and maintain a well-functioning and user-friendly website which includes information about the TAP project.
4.3.Purpose of processing
The data used for cookies are collected in order to provide a complete well-functioning and user-friendly website.
4.4.Duration of processing
5.MEDIA RELEASE SUBSCRIPTION
We process your personal data when you subscribe to receive media releases from us. When registering for media releases, the data from the input mask is transmitted to us. You are asked to enter the following data when registering for our media releases:
- First name
- Last name
- Email address
We use this data to provide you with our media releases.
In addition, the following data is collected upon registration:
- Date and time of registration
5.1.Legal basis of the processing
The processing of your data for the subscription and receipt of the media release is performed on the basis of your consent as well as our legitimate interests in keeping our contacts up to date on news relating to our company. In the course of the registration process, your consent is obtained for the processing of the data and reference is made to this Privacy Notice. The data will be used exclusively for sending media releases.
You may withdraw your consent for the abovementioned data processing at any time. You can cancel your subscription to the media releases at any time. For this purpose, there is a corresponding unsubscribe link in every media release. Upon cancellation of your subscription we will delete your personal data and cease to send you media releases.
5.2.Purpose of processing
The collection of this personal data as part of the registration process serves to keep files of people interested in our newsfeed and updating them relevantly as well as to prevent misuse of the services or the e-mail address used. Some of the optional information, if inserted is useful to us for certain urgent situations or to understand your background regarding your relationship with us.
5.3. Duration of processing
Your data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. Your e-mail address, name and company name will therefore be stored for as long as your subscription to the media release is active.
Any personal data inserted in our electronic recruiting platform (hereinafter the “e-Recruiting Tool”) and the Applicant Account created are being processed according to the law. The submission of any further personal information, other than what is required in the mandatory fields, is voluntary. You are responsible for the accuracy of your data.
The electronic recruiting platform is run by TAP AG as the operator. The data will be stored in a data centre located in SAP data-centre in St. Leon-Rot, Germany. The data centre is hosted by SuccessFactors, a service provider of TAP AG.
The following data is collected during the registration process:
- Your IP address
- Date and time of upload
- Manually filled data as per profile requirement – such as name, age, work experience, education, qualification details, skills
6.1. Legal basis of the processing
When using the e-Recruiting Tool, you agree to our processing the data for the processing of your application. Legal basis for the processing is your consent as well as the potential necessity of the performance of a contract or the performance of the necessary steps prior to entering into a contract. In the course of the application submission process, your consent is obtained for the processing of the data and reference is made to this Privacy Notice. You may delete your Applicant Account or rescind your application in full or in part at any time. By doing so we will delete your personal data and will withdraw your application and data from the ongoing recruiting process.
6.2.Purpose of the processing
Your data inserted in the system will be processed in order to address and evaluate your application to our company. Data inserted in the system outside of the context of a direct application for a position will be kept online in our files for the potential situation that a position suitable to your skills and competencies emerges on the basis of your data that was submitted and thus general interest expressed in a position within TAP. All your data will be collected, stored and used by TAP AG for the purpose of handling your application or generally your data submission as an expression of your interest in current or future employment with TAP AG.
6.3. Duration of processing
We will store the data transmitted via the e-Recruiting Tool for as long as your Applicant Account is active but will be deleted automatically upon one year from the latest change date to your Applicant Account.
Any personal data, such as a valid e-mail address and any personal data relevant to your specific grievance which you insert to the system when submitting a grievance notification with TAP using our grievance notification tool (hereinafter “Grievance Tool”) and filling in the relevant grievance form online, are used only in connection with the processing of your grievance notification and are processed according to the law. Except for the e-mail address when uploading the grievance notification, grievances may be submitted anonymously.
The following data is collected during the registration process:
- Your IP address
- Date and time of upload
- Description of a grievance or request submitted by the online tool user, which may include names, addresses, gender, age, profession, ownership and generally details of certain events and dates provided by the person who submits the online grievance form to TAP.
7.1.Legal basis of the processing
When using the Grievance Tool, you consent to the processing of your submitted data by our company. In the course of the grievance submission process, your consent is obtained for the processing of the data and reference is made to this Privacy Notice. Additionally, we have an obligation to establish and maintain local independent grievance redress mechanisms based on the social and cultural institutions of the people affected by the project in order to solve grievances and address complaints timely, impartially and in a transparent manner on the basis of relevant host government agreements signed with project’s hosting countries and ratified with relevant laws. You may revoke your grievance at any time, in which case we will delete your data and cease with the investigation and potential resolution of your request/grievance.
7.2.Purpose of the processing
Processing of the submitted personal data is taking place in order to attempt the addressing and potentially solving of the submitted grievance.
7.3.Duration of processing
We will store the data transmitted via the Grievance Tool for as long as this is necessary for the investigation into your grievance and for storage and background information purposes until the end of the Construction phase of the TAP project.
Additionally, by clicking the box you are consenting to the delivery by us of your personal data to any third parties necessary for the processing according to the designated purpose for addressing and possibly resolving the grievance.
You may contact us via the e-mail addresses and phone/fax numbers published on our website. In this case any personal data transmitted in your e-mail will be processed accordingly in line with applicable law. Your personal data will not be forwarded to any third party without your prior consent.
8.1.Legal basis of processing
Legal basis for the processing is your consent as well as the potential necessity of the performance of a contract or the performance of the necessary steps prior to entering into a contract and processing in connection with a contractual obligation. You may ask for your data to be deleted at any time.
8.2.Purpose of the processing
The processing of the personal data serves the purpose of establishing and maintaining contact. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
8.3.Duration of processing
We will delete your personal data as soon as they are no longer required for such purpose. You may ask us at any time by e-mail or letter to no longer use such personal data and request their deletion.
9.TRANSFER TO THIRD PARTIES
We may transfer or disclose the personal data we collect to our third-party service providers such as our website operator. When we transfer personal data, we do so for the purposes described above under “Purpose of the processing” in each applicable section.
It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.
Your data may be delivered and processed in third countries from time to time. This can be in countries, which provide adequate protection on the basis of respective adequacy decisions of the European Commission, such as Switzerland. In any other case, we use safeguards with respect to your personal data such as data protection clauses in our contracts with data processors to ensure that processing activities in third countries are compliant with the strict requirements of Swiss law and the GDPR.
You acknowledge hereby that:
You have been informed that you have the right to withdraw your consent at any time, as well as the consequences of such a withdrawal.
Moreover, you have been informed regarding the following rights, as established and under the conditions prescribed in the General Data Protection Regulation (EU 679/2016) and the national legislation in force. More precisely:
- you have the right of access to your personal data collected, stored and processed by us.
- you have the right to request the rectification of inaccurate or outdated personal data concerning yourself and the completion of incomplete data concerning yourself.
- you have the right to request the erasure of personal data concerning yourself from our archives, if their processing is not essential for the purposes for which they have been collected.
- you have the right to request the restriction of processing your data in case you contest their accuracy.
- you have the right to receive personal data concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format.
- for the cases that the processing of your data is based on our legitimate interest to perform an activity, as described in the separate sections above, you have the right to object to the processing on grounds relevant to your case.
Exercising the above rights requires the submission, without any cost, of a written application to us to the address provided below or by using the email DPO@tap-ag.com
If there is any issue or question regarding the above, you can address us by letter (Lindenstrasse 2, 6340 Baar, Switzerland), phone (+41 41 747 3400), fax (+41 41 747 3401) or e-mail at DPO@tap-ag.com.
In case of exercising one of the abovementioned rights, the Company will take any possible measure in order to investigate the request and address this right within thirty (30) days starting from the receipt of the relevant application, notifying you in written form on the satisfaction of your request or the reasons which prevent its exercise. You will also be notified in case the handling of your request requires more than the abovementioned thirty (30) days. We will process your request as long as you provide us with verification of your identity along with your request.
Trans Adriatic Pipeline AG Privacy Notice 25.05.2018