Privacy policy

Version: 30 August 2023


This privacy notice provides visitors of this website with information on the collection of personal data, and how and for what purposes it is processed when you access our website, subscribe to one of our online services, use our apps or in other interactions with us (e.g. also offline under a business relationship, processing contact data, recruitment and job application process, etc.).

Protecting your privacy is important to Axpo and as an international company we use your personal data in compliance with the applicable data protection laws.

Topic overview

  • Axpo Holding AG, Parkstrasse 23, CH - 5401 Baden is the data controller and responsible for data processing under this privacy notice. Axpo Group consists of various companies, which can be found in the current financial report for Axpo Holding AG. Where Axpo Holding AG itself is not responsible for the processing of your data and where "Axpo", "we" or "us" is mentioned below, we refer to the relevant company of the Axpo Group which is responsible for the processing of your data.

If you have additional questions about this privacy notice, the processing of your personal data, and/or exercising your rights in this context, please contact us (e-mail: dataprotection@axpo.com).

Our data protection officer looks forward to hearing from you and addressing your concerns. For security reasons, Axpo may implement appropriate measures to verify your identity.

EEA and UK residents can also contact the following data protection representatives in the EEA and in UK:

  • EEA: Axpo Italia S.p.A., operative office Via XII Ottobre 1, 16121 Genova GE, Italy; e-mail: privacy.it@axpo.com
  • UK: Axpo UK Limited, 38 Threadneedle Street, London EC2R 8AY, United Kingdom; e-mail: privacy.uk@axpo.com

When visiting this website, using our online services or apps, submitting a job application and in other instances, your personal data is collected, stored and processed by us. This includes, in particular, the following personal data and takes place in the following situations for the purposes listed below:

2.1. Visiting our website

2.1.1. Log data

When visiting our website technical data is collected. This data includes your IP address, or the IP address of your Internet service provider, the homepage (website from which you accessed our website), the browser type, the operating system and platform, the pages visited under www.axpo.com, as well as the time and date of access (referred to as "connection data"). Data is automatically stored in log files over a time period of 6 months.

We process this connection data in order to optimise our website, namely to analyse how visitors use this website. Data is also analysed for statistical purposes as well as for internal measures related to security and quality improvement.

2.1.2. Cookies

This website also uses cookies to track website usage. Cookies are small data files that a web portal leaves on your computer, tablet, or smart phone when you visit the site. By using cookies, the website can “remember” certain inputs and settings (e.g. login, language, font size and other preferences) over a certain period of time, and you do not have to re-enter these parameters when returning to the site or navigating the portal. We use cookies on our website to analyse website usage. On our website, we use cookies to record your participation in a survey on the usefulness of content (so you are not asked again by the pop-up window), or your decision to (or not to) use all or part of the cookies on this portal. Some of the videos embedded on our web pages also use cookies to generate anonymous statistics on the previously visited pages and videos selected.

The information collected with the help of cookies is not used to identify you, and cookies are only used for the purposes described in this privacy policy. It is not absolutely necessary to accept cookies in order to use the website, but it makes Internet surfing easier. You can change the cookie settings at any time during your visit to our site via our cookie management tool. You can block or delete cookies in your web browser. You can consult: aboutcookies.org for further information.

You can delete all the cookies on your computer and set most browsers so that they will not accept cookies. However, you may then have to manually adjust certain settings each time you access a particular web page, which may result in the impairment of some functions.

 

2.1.3. Social plug-ins

This website contains social plug-ins, such as the Facebook "Like" button. When the website is accessed, these plug-ins automatically transfer your data (IP address, date and time of the visit, etc.) to the respective provider of such plug-in (e.g. Facebook’s “like”-button) irrespective of whether you clicked the button or are a member of this social network. These third-party providers apply their own privacy policies and we invite you to consult them for further information:

Solution

Provider

Address

Links

Twitter

Twitter Inc.

Twitter International Company

Data Protection Officer

One Cumberland Place, Fenian Street

Dublin 2, D02 AX07 IRELAND

Privacy policy

Facebook

Facebook Inc.

Facebook Ireland Ltd.

4 Grand Canal Square,

Grand Canal Harbour

Dublin 2 IRELAND

Privacy policy

YouTube

YouTube LLC.

Google Ireland Limited

Gordon House,

Barrow Street

Dublin 4, IRELAND

Privacy policy

Linkedin

LinkedIn Inc.

LinkedIn Ireland Unlimited Company

Legal Dept.

Wilton Plaza

Wilton Place,

Dublin 2, IRELAND

Privacy policy

Xing

XING SE

Dammtorstraße 30, 20354 Hamburg, Germany

Privacy policy

2.1.4. Web analysis, tracking and marketing automation

Web analysis tools are used for the anonymous analysis of user data (connection data) to identify trends and enhance our online offering. As a result, data is not only processed by Axpo, but also by the providers of these tools on Axpo's behalf. The providers use this information to analyse your use of the website, to generate reports on website activities, and to provide additional services in connection with the website and Internet usage. By means of tracking and marketing automation tools, your contact data, that you proactively provided via the contact form for newsletters or media releases to identify yourself, can be transferred automatically to our contact database. The providers may also transmit this information to third parties insofar as this is legally prescribed or when third parties process this data on behalf of the providers. The IP address transmitted from your browser is not combined with other data of the respective providers (see terms below).

 

Solution

Purpose

Provider

Address

Links

Google Analytics

Website analysis

Google Inc.

Google Ireland Limited

Gordon House,

Barrow Street

Dublin 4, IRELAND

https://policies.google.com/privacy

Adobe Analytics

Website-Analyse

Adobe Inc.

Adobe Systems Software Ireland Limited

4-6 Riverwalk,

Citywest Business Park,

Dublin 24, IRELAND

https://docs.adobe.com/content/help/en/analytics/admin/data-governance/an-gdpr-overview.html

Pardot

Tracking, Marketing Automation

Salesfor-ce.com, Inc.

Worldwide Head-quarters, The Landmark at One Market, Suite 300, San Fran-cisco, CA 94105, USA

https://www.salesforce.com/eu/gdpr/pardot/

 

2.1.5. Third-party website links

This website may contain third-party contents or links to other websites that have been made available solely to enhance user-friendliness and provide information. Please note that this privacy policy does not apply to third-party contents or websites. The contents or websites of third-parties - including third-party websites that are linked to the Axpo website or display these in frames (displayed in frames on this website) - are outside our sphere of influence. Axpo is not liable for the correctness, completeness or legality of the contents and links contained on such websites, nor for any offers, services or similar. You are responsible for the use of such contents or websites.

2.1.6. Use of online services or apps

When registering for online offerings or apps, filling out surveys, using apps or other interactions on our website, you transmit information about yourself to us, e.g. name, address, email address (“content data”). If you use one of our online offerings or apps we process your personal data so that we can provide you with the respective service and do so to your satisfaction.

If you subscribe to a newsletter your personal data is used to process newsletter delivery. By subscribing you agree to the delivery of an electronic newsletter. You can unsubscribe and withdraw permission at any time via the respective link in the newsletter.

2.2. Processing contact data

When we establish business relationships with suppliers, customers and partners, we process, analyse and store the personal data of their employees and assistants to initiate and process contracts, for planning purposes, for accounting purposes and other purposes in connection with the contract. Depending on the field of activity we are also obligated to audit the respective company and its employees, e.g. through vetting. In this case, we collect and process additional data, if necessary from third-party providers. We can also process this data to improve our customer orientation, customer satisfaction or customer relations (Customer/Supplier Relationship Management).

2.3. Data privacy in recruitment and job application processes

Persons in charge of processing - as a rule this is the company that has posted the position and/or receives the applications - process the personal data of job applicants to carry out the recruitment process. Processing can also take place by electronic means. In particular, this is the case when an applicant provides the respective job application documents electronically, for example via email to the responsible individual. We process the personal data that you make available to us in the application in order to carry out the respective recruitment process in so far as this is necessary to review your application file in connection with the vacant position, and upon successful recruitment to prepare the employment contract.

Depending on the purpose we process data based on various legal bases. In particular, we can process personal data when this is necessary:

(a)              to fulfil a contract with you; for example, to provide you with our online services or apps in accordance with our terms of use or to process your job application (pre-contractual measure)

(b)             to pursue our legitimate interests (see examples here below);

(c)              based on valid consent that has not been revoked; for example for the use of cookies on this website or our marketing activities;

(d)             to comply with legal obligations to which we may be subject, for example to respond to a request for disclosure of data received from a competent authority.

Legitimate interests are for example:

(a)              our customer support and business relations (e.g. contact, communication with our business partners);

(b)             advertising and marketing activities;

(c)              opportunities to become better acquainted with the users of our website and online services;

(d)             improvement and development of our products and services (e.g. IT security in connection with the use of our website, improvement of our online services offering);

(e)             intra-group management involving data exchanges with other group companies.

As a rule there is no obligation to disclose personal data to us. However, we must collect and process the personal data necessary to initiate and process an employment relationship with you or a company that you work for. In addition, processing of log data and certain other technical data when using the website is unavoidable for the proper functioning of the website. In communication with us, we must at least process the personal data that you transmit to us or that we transmit to you.

 

Purpose of processing

Data categories

Legal basis for processing

Optimisation, analysis, statistics and security related to the use of website

Contact data

Log data

Connection data

Cookies

Social plug-ins

Consent

Legitimate interest in improving website quality, security and customer satisfaction

Newsletter management

Contact data

Consent

Provision of online services or apps

Contact data

Log data

Connection data

Cookies

Consent

Legitimate interest in improving online services quality, security and customer satisfaction

Business relationships and contracts with suppliers, customers, partners

Contact data

Contract performance

Recruitment and job applications

Contact data

Job application data

Consent

Contract performance

 

You have the following rights under applicable law in connection with the processing of your personal data:

Right to information: You may review this Privacy Policy at any time from any page of our website and take a copy.

Access right: You have the right at any time to request, free of charge, information about the personal data we process about you. You may also request a copy of your personal data processed by us. In some cases, this right may be limited or excluded, in particular in case of doubt as to identity or when it is necessary to protect other persons.

Right to rectification: You have the right to request the correction of inaccurate or incomplete personal data.

Right to erasure: You have the right to request the erasure of your personal data when it is no longer required for the intended purposes, for example, when they are processed on the basis of your consent and you have withdrawn that consent, or when an objection against processing has been filed, or when the personal data was illegally processed.

Right to restriction of processing: Under certain conditions you have the right to request the restricted processing of your personal data, for example, when you dispute the accuracy of your personal data.

Right to data portability: You have the right to receive your personal data provided to us in a structured, commonly-used, machine-readable format in so far as the actual data processing took place with your consent or was required to fulfil a contract and the processing took place by means of automatic procedures.

Right to withdraw consent: Where the legal basis for processing your data is consent, you have the right to withdraw any formerly given consent for data processing at any time. Withdrawal of consent is only applicable to the future. Processing activities that occurred in the past and took place with your consent are excluded from the right to withdraw consent and remain legal.

Right to object to processing: You have the right to object to processing at any time for reasons related to your particular situation. In particular, a right to object to processing exists for data processing in connection with direct advertising (e.g. newsletters) without the need to give any reason.

To exercise these rights please contact the Data Protection Officer (email: dataprotection@axpo.com).

Right to appeal: You have a right to appeal to the responsible supervisory authority if you are of the opinion that your rights were violated through certain data processing.

We may disclose personal data that we process for purposes described in this privacy policy within the Axpo Group and to other Axpo subsidiaries. Disclosure takes place exclusively for the purpose of intra-company management (e.g. accounting, centralised customer management, etc.).

Your personal data is only shared with third parties outside of Axpo Group to the extent necessary to provide our services, where that third party is a service provider acting on our behalf and at our direction, including hosting or maintaining our databases, software and website, customer relationship management and marketing activities These companies have a contractual obligation to Axpo (e.g. by contract) to comply with the valid laws and our privacy policy when processing your personal data. In addition, Axpo only discloses your data to third parties if and in so far as this is necessary according to applicable law and supported by court orders, or required by regulation.

The Axpo Group produces, trades and sells energy in Switzerland, countries in Europe, Singapore and the USA.

In the context of our business activities and in line with the purposes of the data processing set out in Section 2 above, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned: 

  •  our service providers (within the Axpo Group or externally, such as e.g. banks, insurances), including processors (such as e.g. IT providers);
  • dealers, suppliers, subcontractors and other business partners;
  • clients;
  • domestic and foreign authorities or courts;
  • the media;
  • the public, including users of our websites and social media;
  • competitors, industry organizations, associations, organizations and other bodies;
  • acquirers or parties interested in the acquisition of business divisions, companies or other parts of the Axpo Group;
  • other parties in possible or pending legal proceedings;
  • affiliates of the Axpo Group;

together “Recipients”.

Certain Recipients may be within Switzerland but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which the Axpo Group is represented by affiliates, branches or other offices as well as to other countries in Europe and the USA where our service providers are located (such as Microsoft, SAP, Amazon, Salesforce). See also annual report of Axpo Holding AG [link to report] [CGO1] for the location of the Group Companies.

If a Recipient is located in a country without adequate statutory data protection, we require the Recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the Recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

We retain your personal data in compliance with applicable laws as long as needed for the purposes described in this privacy policy or as long as required by applicable retention requirements. For example: we keep your choice (acceptance or refusal) concerning cookies for a period of 6 months.

If a job application process is successful, the data provided in this context may be retained for the purpose of processing the employment relationship in compliance with legal provisions, and, if required, to conclude the employment contract. If no employment contract is concluded with the applicant, the application documents are automatically deleted 6 months after notification of the rejection decision, in so far as no other justifiable interests contrary to erasure exist on the part of the data controller.

We take adequate technical and organisational measures to protect your personal data. Your personal data is only accessible to individuals who require it for the purposes and tasks described in this privacy policy (e.g. HR staff, IT system administrators). These persons are all obliged to handle personal data confidentially and solely in accordance with valid data protection regulations. Data transmission to us takes place in unencrypted form and by means of an open, cross-border network that is accessible to anyone. However, Axpo has implemented security measures to protect data against unauthorised access and to ensure website authenticity, data integrity, and the confidentiality of data transmitted over the group-internal network (Intranet). Nevertheless, zero risk does not exist because of the risks inherent in the use of the Internet, the loss of transmitted data, viewing by non-authorized third parties cannot be ruled out. Consequently, this can result in your data being disclosed or modified, including in countries without an adequate data protection level. 

This privacy policy may be amended from time to time to reflect legal, regulatory, technical, economic or other developments at Axpo's discretion and without prior notice. When we make significant changes, we will notify you in advance by any appropriate means. The latest version of the privacy policy accessible here applies at the time when your personal data is processed.

Last updated: 30.08.2023