PRIVACY POLICY

Last Updated: 28 October 2022

This Privacy Policy describes how we – Palmira Wireless AG – collect, use, process, store, and share your personal information.

We may modify this Privacy Policy at any time, in response to changes in applicable law or as we implement new technology, offer new licensing programs, services, or applications, or otherwise change our privacy practices. Changes to this Privacy Policy will become effective when posted on this page. Your continued use of our website or hosted services (including data rooms for accessing documents), participation in our licensing programs, or communication with us shall constitute your acceptance of all such changes.

Personal Information We Collect

We collect and process the following types of information:

basic personal information (such as your name, company you work for, and job title);
contact information (such as your personal and/or work telephone numbers, email addresses, and postal addresses);
professional or employment related information (such as career history, educational background, links to your professional profiles);
identification or background information provided by you or collected as part of any licensing program, inquiry, or employment process (such as identity document details, insurance numbers, etc.);
financial information (such as bank account or payment-related information);
technical information (such as when you access our secure hosted document data rooms, including server visit logs and content accessed); and
any other information relating to you which you may provide to us.

How We Collect Information

We collect information from you in the ordinary course of business, including:

when you use our website (palmira-wireless.com) or when you use our technology tools or linked services, including access to our file storage databases or hosted data rooms;
when you inquire about, negotiate terms and conditions, or participate in our licensing program;
when you provide or request information or interact directly with us (for example engaging directly with any of our staff, filling in any inquiry forms on our website, registering to access any of our file storage databases (such as a hosted data room or digital document platform), or contacting us by telephone, email, mail, fax, or otherwise);
when you apply for a job; and
from third parties (such as employment agencies or recruiters) and from publicly available sources (including social media, company websites, or registries of commerce).

How We Use Information

We create, hold, and use personal information:

to operate and manage our business, including sending you information about our patent portfolio and licensing programs, contacting you about potential infringements of our intellectual property rights, doing research, negotiating, executing, and managing a settlement and/or license agreement, managing our relationship with you, and processing and responding to your inquiries, requests, or other communications;
to manage and develop our recruitment, employment, and service provider activities, including assessing employee or service provider qualifications; and
to fulfill and comply with our legal, regulatory, and risk management obligations, including establishing, exercising, or defending legal claims.

In carrying out these activities, we combine data we collect from different contexts or obtain from various sources to make informed business decisions.

How We Store Personal Information

We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, accidental loss, disclosure, alteration, or destruction, consistent with applicable data protection laws.

Your personal information will be retained and securely stored on servers based in Switzerland, while some of our hosted data room servers are based in Germany.

How We Share Personal Information

We may share your personal information with trusted third parties in accordance with contractual arrangements in place with them, including:

our professional advisers, including our lawyers, auditors, accountants, financing advisors, and technology experts;
vendors to whom we outsource support services such as data room and case management services, word processing, translation, photocopying, and document review; and
our IT service providers.

Such third parties are required to safeguard personal data in accordance with our contractual obligations and applicable data protection legislation.

Where necessary, or for the reasons set out in this Privacy Policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies, and law enforcement agencies. Finally, while it is unlikely, we may be required to disclose your information to other third parties if we are under obligation to do so to comply with legal or regulatory requirements, or an enforceable official or court order.

In short, we share your personal information to manage and execute employment, license, or settlement negotiations and agreements with you. We also share data with vendors working on our behalf, when required by law or to respond to legal processes, and to protect the rights and property of Palmira and its licensees.

Transfer of Your Personal Information Outside of Switzerland

Some recipients of personal information, as described in Section 5 above, are located in Switzerland and others in the European Union and the US.

If we transmit data to the countries that have not been deemed to provide an adequate level of protection according to the lists of countries published by the Swiss Federal Data Protection and Information Commissioner, we ensure necessary safeguards by applying standard contractual clauses which provide for appropriate protection of data.

We may also transfer data to such countries on the basis of the following exemptions provided for by law: consent is given by data subject; the transfer is necessary for the conclusion or performance of the contract; there is an overriding public interest; it is necessary to establish, exercise or defend legal claims; it is necessary for the vital interest of data subject or other persons; the transfer involves publicly accessible data.

Cookies & Technical Information

Our website (www.palmira-wireless.com) does not use cookies.

When you visit our website, our hosting provider, Hostpoint AG, automatically collects and stores certain technical data (log data), such as the IP address and operating system of the user’s device as well as the browser’s date and time of access. Hostpoint AG processes such data based on a contract with us exclusively on our behalf in order to check and ensure the security and availability of our website. Hostpoint AG and its servers are located in Switzerland.

When you log into any data room or hosted service we offer (such as through FileCloud or NetFiles), the vendor also automatically collects and stores certain technical data (log data), such as the IP address and operating system of the user’s device as well as the browser’s date and time of access in order to provide us user reports. These vendors use servers located in Switzerland and/or Germany.

Your Data Protection Rights

Under personal data protection laws, you have a number of rights regarding your personal information. You are entitled to request details of the information we hold about you and how we process it, as well as information necessary to enable you to exercise your rights and ensure a transparent processing of your personal information. You may also have a right in accordance with applicable data protection laws to have your information rectified or deleted, to restrict or object to our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organization. You also have the right to withdraw your consent for us to process your personal data.

Please note that even after you have asked us to delete your information or chosen to withdraw your consent for us to process it, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

How to Contact Us

If you want to make a request under Section 8 above, want further information, or have any questions or complaints about this Privacy Policy or our privacy practices, please contact us at:

Palmira Wireless AG, Baarerstrasse 79, 6300 Zug, Switzerland (info@palmira-wireless.com)

If you are unhappy with how your inquiry has been handled, you may lodge a complaint with the Swiss data protection supervisory authority:

Federal Data Protection and Information Commissioner FDPIC, Feldeggweg 1, 3003 Bern, Switzerland (Tel.: +41 (0)58 462 43 95)