Privacy Policy

Your privacy is important to ArrowResources AG and its affiliated companies (“ArrowResources”, “we”, “us” or “our”).  This Privacy Policy (the “Privacy Policy”) explains what Personal Data (as defined below) we collect, how we may use and manage it and the rights you have in relation to your Personal Data.  Before you provide us with any Personal Data or browse our websites, you should read through this Policy in full and make sure that you are comfortable with our privacy practices. 

For the purposes of applicable data protection and privacy laws, the data controller is ArrowResources AG, with company registration number CHE-158.017.998 whose address and contact information is set out below.

We reserve the right to make amendments to this Policy at any time without notice. It is your responsibility to check the ArrowResources website for any changes and before submitting any information to us.

1. What is Personal Data

Personal Data refers to any information that can be used to personally identify you. This may include, for example, your name, postal address, e-mail address, phone number, date of birth, job title, photographic identification, age or gender, communications with you (including notes from meetings) and financial and payment information.

 Personal information is only collected with your consent, and where it is reasonably necessary to comply with the law or if it is required to administer aspects of the relationship between you and us..

We collect Personal Data from a range of individuals in the context of our business activities, including:

• representatives of our suppliers, customers and other business contacts;
• contractors;
• users of our websites;
• individuals who contact us by any means;
• recording and retaining certain telephone conversations where we are required to do so to comply with our regulatory obligations; and
• job applicants.

2. How is Personal Data collected by us?

We obtain Personal Data:

• which you knowingly and voluntarily disclose to us, both online and offline, notably when you:
• visit our websites and / or complete one of our web forms;
• visit our premises;
• communicate with us via any means, including but not limited to telephone, email and through the use of social networking websites, third party apps or similar technologies.
• from third party sources, e.g. employers, authorised representatives, agents or third parties who are authorised to share Personal Data, as well as publicly available sources of information e.g. address validation software, telephone directories, as well as our agents or other third parties who have identified you as a potential purchaser of our products or services.

When you use our sites at https://www.arrowresources.com we collect certain standard information that is sent by your browser to the websites, e.g. your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses)

3. Why do we process Personal Data

We may collect your Personal Data for a range of different purposes as a prospective or existing customer or counterparty, including:

• to support our procurement and onboarding processes, including complying with our internal policies (particularly policies designed to prevent money laundering and sanctions violations);
• to provide our products and services to you, or to provide you with a quote or offer for our products and services;
• to communicate with you about a potential or existing engagement with ArrowResources;
• to answer your enquiries and provide any information or documents you ask for;
• to ensure that content from the websites is presented in the most effective manner for you and for your computer, including carrying out analytics in relation to the use of the websites;
• for administrative, planning, product or service development and delivery purposes;
• to comply with our legal and regulatory obligations, which may include the disclosure of certain information and/or recordings of telephone conversations to regulatory authorities;
• for other business-related purposes, including negotiating contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration; and
• to update our records and keep your contact details up to date.

If you choose not to provide your Personal Data to us, we may not be able to engage in a business relationship with you, either partly or at all.

4. The legal basis for our processing of your Personal Data

In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for us processing your Personal Data will typically be one of the following:

• your consent;
• the processing is necessary in connection with the performance of a contract that we have in place with you or other individuals;
• our, or our third parties’, legitimate business interests; or
• compliance with our legal obligations.

5. Where do we store Your Personal Data

The data that we collect from you may be transferred to, and stored in, a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By submitting your Personal Data, you agree to this potential transfer to a country other than your own.

Whenever we transfer Personal Data across borders, we will take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure that it is treated in accordance with this Privacy Policy.

You acknowledge and understand that the transmission of information via the internet is not completely secure.  Although we will take reasonable and appropriate steps to protect your Personal Data once we have received it, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk.  Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.

6. To whom do we disclose your Personal Data?

We may share your Personal Data with any of our affiliated entities.  However, these entities are required to maintain the confidentiality of your data and are restricted from using it for any purpose other than the purposes set out in this Privacy Policy.

We may disclose your Personal Data to third parties during the course of business, including:

• your authorised representatives (agents, consultants, intermediaries);
• financial institutions (for payment processing);
• government and regulatory authorities (where required or authorised by law);
• our service providers, such as information technology suppliers, contractors, debt collection agencies and our professional advisors, such as accountants, auditors and lawyers;
• to protect any intellectual property rights in any materials displayed on or otherwise available from our websites;
• to respond to a legal request or comply with a legal obligation; and
• to enforce the terms of use of our websites.

We may also disclose your Personal Data to third parties:

• In the event that we sell, merge or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
• If ArrowResources or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be transferred.
• We may decide to allow our website users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public.  Information that you provide in these areas may be read, collected, and used by others who access them.

We may also share non-Personal Data with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device.  Aggregation means that we combine the non-Personal Data of numerous people together so that the data does not relate to any one person.  De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.

7. International transfers of your Personal Data

The disclosures discussed above include transfers of Personal Data which is subject to Swiss, UK or European Economic Area data protection laws to countries outside Switzerland, the UK and the EEA.  ArrowResources is a global group of companies and we have affiliates and service providers, and relationships with counterparties and governmental authorities, in many countries.  This includes transfers to countries which are not regarded by the European Commission (or the equivalent authorities in other jurisdictions) as ensuring an adequate level of data protection, but we ask that these third parties hold, use and disclose your Personal Data in accordance with any applicable data protection laws. 

8. Data retention

We will keep your Personal Data for as long as we need to keep it for legal compliance or business purposes. Please contact info@arrowresources.com for more information about our record retention practices.

9. How you can access, correct or delete your Personal Data

We take reasonable steps to ensure the Personal Data we collect, use and disclose about you is correct, complete and relevant for the purposes for which we collect it.

Applicable data privacy laws give rights to individuals in respect of Personal Data that organisations hold about them. If you wish to:

• request a copy of the Personal Data that we hold about you; or
• request that we rectify, delete, or limit the processing of your Personal Data,

please submit your request to the contact address set out below.

In some circumstances, we may refuse to give you access to your Personal Data, or to comply with your other requests, in accordance with the Swiss Federal Act on Data Protection and other relevant laws.

To protect your Personal Data we will always confirm your identity with you before giving you access to any information or making any changes.

You can make any such request by contacting ArrowResources at the address given below. 

10. Third Party Websites

The websites may, from time to time, contain links to and from the websites of our partner networks and affiliates, or of other third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any Personal Data to these websites.

11. Cookies

This website uses Cookies and ArrowResources tracks information based on Cookies.  Please see our Cookies Policy here.

12. Contact information

If you have any questions, comments or complaints or would like further information about this Privacy Policy, how we deal with your Personal Data, or if you wish to exercise any of the above-mentioned rights, please contact us using the details below.  We will investigate your complaint and provide you with a formal response, usually within 30 days.  If the circumstances of your complaint are complex and we need additional information or time to provide you with a formal response, we will contact you to let you know.

ArrowResources AG

Hinterbergstrasse 16

6312 Steinhausen

Switzerland

Tel +41 41 544 57 60

info@arrowresources.com

If you are not satisfied with our response, then you may file a report with the Federal Data Protection and Information Commissioner at:

https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt.html or lodge a formal complaint with your local data protection authority.

Last updated 30 September 2023