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1. General Information

1.1. Objective and Responsibility

  1. This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as “online service” or “website”). Details on these processing activities can be found in section 2.
  2. Details on data processing for the purpose of carrying out our business processes are described in section 3.
  3. The online service is provided by  Brisen Group Holding Ltd. (140, Archiepiskopou Makariou III Office 101B, 3021, Limassol, Cyprus) – hereinafter referred to as “BDG”, “provider”, “we” or “us” – who is also legally responsible under the data protection law.
  4. Please contact us if you have any questions or require additional information: enquiries@brisengroup.com
  5. Our online service is hosted by Infomaniak Network AG (Rue Eugène Marziano 25, 1227 Les Acacias (GE), Switzerland). The server location is Switzerland.
  6. The term “user” encompasses all customers, interested people, employees and visitors of our online service.

1.2. Legal Bases

In principle, we collect and process personal data based on the following legal grounds:

  • Consent in accordance with article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
  • Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to article 6 paragraph 1 lit. b GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
  • Processing to fulfil a legal obligation in accordance with article 6 paragraph 1 lit. c GDPR, meaning that e.g. the processing of data is required by law or other provisions.
  • Processing in order to protect legitimate interests in accordance with article 6 paragraph 1 lit. f GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.

The specific legal bases for the individual processing operations are presented in the following sections.

1.3. Data Subject Rights

  1. You have the following rights with regards to the processing of your data through us:
  • The right to lodge a complaint with a supervisory authority in accordance with article 13 paragraph 2 lit. d GDPR and article 14 paragraph 2 lit. e GDPR.
  • Right of access in accordance with article 15 GDPR
  • Right to rectification in accordance with article 16 GDPR
  • Right to erasure (‘right to be forgotten’) in accordance with article 17 GDPR
  • Right to restriction of processing in accordance with article 18 GDPR
  • Right to data portability in accordance with article 20 GDPR
  • Right to objection in accordance with article 21 GDPR

Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.

  1. Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

The data protection supervisory authority responsible for us is Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus (Homepage: http://www.dataprotection.gov.cy)

1.4. Data Erasure and Duration of Storage

The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.

1.5. Security of Processing

  1. We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
  2. These security measures include in particular the encrypted transfer of data between your browser and our server.

1.6. Transfer of Data to Third Parties, Subcontractors and Third Party Providers

  1. A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
  2. If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
  3. If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.

2. Processing activities within the scope of our online service

2.1. Collection of Information on the Use of the Online Service

  1. When using our online-service, information may be transferred automatically from the browser of the user to us; this information includes the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
  2. The processing of this information is based on legitimate interests in accordance with Article 6 paragraph (1) lit. f GDPR (e.g. optimisation of the online service) as well as to ensure the security of the processing in accordance with Article 5 paragraph (1) lit. f GDPR (e.g. for the defence and clarification of cyber attacks).
  3. This information will be automatically deleted latest 30 days after the termination of the connection, unless any other retention periods require otherwise.
  4. The collection of the data and the storage of the data in log files is essential for the provision of the online service. Therefore users are not entitled to the options of erasure, objection or correction.

2.2. Information about Google services

  1. We use various services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland on our website.

For more information on the individual concrete services of Google that we use on this website, please refer to the further privacy policy.

  1. Through the integration of Google services, Google may collect information (including personal data) and process it. It cannot be ruled out that Google also transmits the information to a server in a third country.

The transmission to the USA depends on the function in which personal data is transmitted. As the responsible party, we ourselves may transfer data to Google in the USA for further use.

Google is registered in the data privacy framework (DPF). Furthermore, Google has committed to comply with the standard contractual clauses for the transfer of personal data to third countries (Standard Contractual Clauses – SCC).

More information about the Standard Contractual Clauses is available at

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractuals-clauses-scc_de

and at

https://policies.google.com/privacy/frameworks?hl=de

  1. We ourselves cannot influence which data Google actually collects and processes. However, Google states that, in principle, the following information (including personal data) may be processed, among others:
  • Log data (in particular the IP address)
  • Location-related information
  • Unique application numbers
  • Cookies and similar technologies

Information on the types of cookies used by Google can be found at https://policies.google.com/technologies/types.

  1. If you are logged into your Google account, Google may add the processed information to your account depending on your account settings and treat it as personal data.
  2. Google states the following about this, among other things:

“If you are not signed into a Google Account, we store the data we collect with unique identifiers associated with the browser, app, or device you are using. This allows us to ensure, for example, that your language settings are maintained across all browser sessions.

If you are logged into a Google account, we also collect data that we store in your Google account and consider to be personal data.” (https://privacy.google.com/take-control.html)

  1. You can prevent this data from being added directly by logging out of your Google account or also by making the appropriate account settings in your Google account. Furthermore, you can change your cookie settings (e.g. delete cookies, block cookies, etc.). 
  2. You can find more detailed information in the privacy notices of Google, which you can access here: https://www.google.com/policies/privacy/
  3. You can find notes on Google’s privacy settings at https://privacy.google.com/take-control.html.

2.3. Google Analytics

  1. We use Google Analytics, a web analytics service of Google Ireland Limited (Gordon House Barclays Dublin Ireland – hereinafter “Google”), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Art. 6 para. 1 lit. a. GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by the users is transmitted to a Google server in the USA and processed there.
  2. Google acts on our behalf within the framework of order processing in accordance with Article 28 GDPR. We have concluded a data protection agreement with Google that contains the EU standard data protection clauses. 
  3. In addition, we have concluded a shared responsibility agreement pursuant to Article 26 GDPR with Google for the use of Google’s measurement services (see https://support.google.com/analytics/answer/9012600). Within this framework, we have agreed with Google to be responsible for the fulfillment of information obligations and for ensuring data subject rights in accordance with Chapter 3 of the GDPR, as well as for the security of processing and reporting/notification obligations. (Articles 32 to 34 of the GDPR). Google will use the information to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and internet use. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
  4. We use Google Analytics to display the ads placed within advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “remarketing audiences”, or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users and do not have a harassing effect.
  5. We use Google Analytics with IP anonymization enabled.
  6. Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you during future website visits. Users can prevent the storage of cookies by setting their browser software accordingly.
  7. The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.
  8. For more information on data usage by Google, settings and revocation options, please visit Google’s websites:

https://policies.google.com/technologies/partner-sites?hl=en (“HOW GOOGLE USES INFORMATION FROM SITES OR APPS THAT USE OUR SERVICES “).

https://policies.google.com/technologies/ads?hl=en (“How Google uses cookies in advertising “)

https://adssettings.google.com/authenticated (“Manage information Google uses to serve ads to you”).

2.4. Google Tag Manager

  1. We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
  2. Through the Google Tag Manager, we can integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or “triggers” the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. In doing so, it cannot be ruled out that Google also transmits the information to a server in a third country.
  3. In particular, the following personal data is processed by the Google Tag Manager:
  • Online identifiers (including cookie identifiers).
  • IP address
  1. In addition, you can find more detailed information about the Google Tag Manager on the websites https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/ 

as well as at

https://www.google.com/intl/de/policies/privacy/index.html (section “Data we receive based on your use of our services”).

  1. Furthermore, we have concluded an order processing contract with Google for the use of the Google Tag Manager (Art. 28 GDPR). Google processes the data on our behalf in order to trigger the stored tags and display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
  2. If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains for all affected tracking tags that are integrated by the Google Tag Manager.
  3. By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services. Legal Basis of the usage of Google Tag Manager is Art. 6 Para. 1 lit. f GDPR (legitimate interests).
  4. The legal basis for the processing of personal data described here as part of the measurement process is consent expressly granted by you in accordance with Art. 6 Para. 1 lit. a GDPR.
  5. The legal basis for the processing of those data that are processed in the context of obtaining consent is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. We have a legitimate interest in being able to prove that you have given your consent to the measurement procedure (Art. 7 (1) GDPR).

2.5. Typekit fonts from Adobe

  1. We integrate the fonts (“Typekit fonts”) of the provider Adobe, whereby the users’ data is used solely for the purpose of displaying the fonts in the users’ browser. 
  2. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration
  3. Service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland
  4. Legal basis: Legitimate interests (Art. 6 para. 1 lit. f GDPR)
  5. Privacy policy: https://www.adobe.com/de/privacy.html
  6. Data Privacy Framework (DPF): https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000TNo9AAG&status=Active.tbd

2.6. Cloudflare

  1. Our online offer uses services from “Cloudflare” (provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA). Cloudflare operates a content delivery network (CDN) and provides protection functions for the website (web application firewall).
  2. The data transfer between your browser and our servers flows through Cloudflare’s infrastructure and is analysed there to prevent attacks. Cloudflare uses cookies to enable you to access our website.
  3. The use of Cloudflare is in the interest of a secure use of our online offer and the defence against harmful attacks from the outside. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.
  4. For further information, please refer to the Cloudflare privacy policy: https://www.cloudflare.com/de-de/privacypolicy/

2.7. Consent Management

  1. This website uses Cookiebot’s cookie consent technology to obtain your consent to the storage of certain cookies on your end device and to document this in accordance with data protection regulations. The provider of this technology is Cybot A/S (Havnegade 39, 1058 Copenhagen, Denmark, website: https://www.cookiebot.com/) – hereinafter referred to as “Cookiebot”.
  2. When you visit our website, the following personal data is transferred to Cookiebot
  • Your consent(s) or the withdrawal of your consent(s)
  • Your IP address
  • Information about your browser
  • Information about your end device
  • Time of your visit to the website
  1. Furthermore, Cookiebot stores a cookie in your browser in order to be able to assign the consents given or their revocation to you. The data collected in this way is stored until you ask us to delete it, delete the Cookiebot cookie yourself or the purpose for data storage no longer applies. Mandatory statutory retention obligations remain unaffected.
  2. Cookiebot is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 sentence 1 lit. c GDPR.
  3. Cookiebot establishes connections to the domains cookiebot.eu and usercentrics.eu.

2.8. DoubleClick

  1. Doubleclick by Google is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’).
  2. Doubleclick by Google uses cookies to serve ads relevant to you. Your browser is assigned a pseudonymous identification number (ID) to check which ads have been displayed in your browser and which ads have been called. The cookies do not contain any personal information. The use of DoubleClick cookies only allows Google and its partner websites to serve ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. Under no circumstances will Google match your data with other data collected by Google.
  3. With your consent in accordance with Article 6 (1) (a) GDPR to the use of Youtube, Doubleclick is automatically reloaded. You consent to the processing of data about you by Google in the manner and for the purposes set out above. By using our website, you consent to the processing of data about you by Google and the manner of data processing described above as well as the named purpose. 
  4. You can prevent the storage of cookies by selecting the appropriate settings in your browser software. You can also prevent Google from collecting the data generated by the cookies and relating to your use of the websites and from processing this data by Google by downloading and installing the browser plug-in available under the following link under the item ‘Extension for DoubleClick deactivation’.
  5. For more information about DoubleClick by Google and privacy, please visit: https://policies.google.com/technologies/ads?hl=en

3. Processing for the purpose of carrying out our business processes

3.1. Contact Form and Contacting via E-Mail

  1. When contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for processing the inquiry and its handling.
  2. Any other use of the data will only take place based on the given consent from the user.
  3. The users’ data will be stored in our Customer Relationship Management System (‘CRM System’) or a comparable software/database. The legal retention periods for business letters apply.

3.2. Links to other websites

  1. While using some of our services, you will be automatically redirected to other websites.
  2. Please note that this privacy policy does not apply there. The privacy policy of the linked website may differ significantly from this one.

4. Cookie Policy

4.1. General Information

  1. Cookies are information transmitted by our web server or third-party web servers to the users’ web browsers where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
  2. In the case that users do not want that cookies are stored on their computer, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.

4.2. Cookie overview, objection options

  1. You can find an up-to-date overview of the cookies and services used on this website in our consent management platform (see section 2.7 “Consent Management”).
  2. You can also manage your individual consents and preferences there.

5. Changes to the Data Privacy Policy

  1. We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
  2. If users’ consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
  3. Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.


Version: September, 2024