Privacy Policy

Introduction

4SD Foundation respects the privacy of our users. This Privacy Policy explains how 4SD Foundation collects, uses, discloses, and safeguards information about you that is provided to 4SD Foundation by you or through automated interactions, for example when you visit the 4SD Foundation owned website nutritiondialogues.org (“Site”).

This policy sets out how 4SD Foundation will protect and process your personal data. When it comes to data protection, we primarily adhere to the legal requirements of Swiss data protection law, in particular the Federal Act on Data Protection (FADP), as well as the EU General Data Protection Regulation (GDPR), which may be applicable in individual cases. Please read this Privacy Policy carefully.

Please note that the following information may be reviewed and amended from time to time. Therefore, we recommend regularly checking this Privacy Policy for any updates.

I. Data Controller

1. For purposes of compliance with the law, the entity that is collecting your data and is the data controller is 4SD Foundation, with registered address at Chemin de Balexert 7-9, 1219 Geneva, Switzerland.

2. If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy officer by sending an email to the following address at [email protected] at any time.

3. You can reach our EU data protection representative at: [email protected].

4. You have the right to make a complaint at any time to the supervisory authority of your country of residence, however, 4SD Foundation would appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

II. Collecting personal data

5. Personal data submitted on the Site will be used for the purposes specified in this Privacy Policy or in relevant parts of the Site.

6. 4SD Foundation may collect personal data from and about you which may be through:

  • Direct interaction where you give 4SD Foundation your personal data by filling in contact forms, setting up an account with us, register on our Site, register for our newsletter, using the functions available on our Site and/or by corresponding with us by post, e-mail or otherwise.
  • Automated technologies or interactions where you interact with our Site, 4SD Foundation may collect information about your equipment, browsing actions and patterns. 4SD Foundation collect this personal data by using cookies and other similar technologies and only in accordance with our cookies policy and applicable law.

7. For handling contact requests by the contact form on the Site, we use a WordPress plugin provided by WP Engine, Inc., a Delaware corporation located at 504 Lavaca St., Ste. 1000, Austin, Texas 78701. Information about data processing by third parties and any transfers abroad can be found in Section IV, XI and XII of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

8. If you register for our e-mail newsletter (e.g. when opening or within your customer account), the following data will be collected. Mandatory data is marked with an asterisk (*) in the registration form:

  • E-mail address
  • Name

In order to avoid misuse and to ensure that the owner of an e-mail address has actually given their consent, we use a double opt-in procedure for registration. After sending the registration form, you will receive an e-mail from us containing a confirmation link. In order to definitely register for the newsletter, you must click on this link. If you do not click on the confirmation link within the specified period, your data will be deleted again and our newsletter will not be sent to this address.

By registering, you consent to the processing of your data in order to receive messages from us about our organisation and our work and related matters. These messages may also include invitations to participate in events, to provide feedback, or to rate our services.
Your consent constitutes the legal basis for data processing within the meaning of Article 6(1)(a) of the GDPR. We will use your data to email you until you revoke your consent. Revocation is possible at any time, in particular via the unsubscribe link in all our newsletter emails.

III. Data Security

9. Your personal data is processed with the appropriate security measures as required by applicable data protection law including measures to prevent disclosure, modification or other unauthorized use or access to your personal data. Our employees and the service companies mandated by us are obliged to maintain confidentiality and uphold data protection. Furthermore, these persons are only granted access to personal data to the extent necessary for the performance of their tasks. Our security measures are periodically adapted in line with technological developments. However, the transmission of information via the Internet and electronic means of communication always involves certain security risks and we cannot, therefore, provide any absolute guarantee for the security of information transmitted in this way.

IV. Purposes of processing

10. 4SD Foundation may use your personal data to:

  • administer the Site;
  • improve your browsing experience by personalising the Site;
  • enable your use of the services available on the Site;
  • send you general (non-marketing) communications;
  • send you email notifications which you have specifically requested;
  • send you communication relating to the Nutrition Dialogues Programme which 4SD Foundation think may be of relevance to you;
  • conduct research into the impact of the Nutrition Dialogues Programme;
  • generate quantitative data that will feature in publicly available reports to adhere to and demonstrate the diversity and inclusion of people in Nutrition Dialogues Programme. These will not specifically identify you;
  • provide third parties with statistical information about you – but this information will not be used to identify any individual user;
  • deal with enquiries and complaints made by or about you relating to the Site;
  • promote Convenors of the Nutrition Dialogues Programme where you made this information available when identifying yourself, or on someone else’s behalf, as a Convenor;
  • enable emails, containing contact form contents from other registered users, to an email address provided by you for this purpose;
  • where you submit personal data for publication on the Site.

11. 4SD Foundation uses your personal data for the above purposes and may rely on the below legal basis:

  • performance of a contract with you;
  • where it is necessary for 4SD Foundation’s legitimate interest and such interest is not overridden by the interests of your fundamental rights and freedoms under data protection law;
  • where processing is necessary to comply with a legal obligation of 4SD Foundation; and where required, with your consent.

12. 4SD Foundation will only use your personal data for purposes for which it is collected, unless 4SD Foundation reasonably consider that it needs to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purposes is compatible with the original purpose, please contact 4SD Foundation using the contact details set out above.

V. Processing of personal data of children

13. The Site is not intended for children under 12-years old and 4SD Foundation does not knowingly collect personal data relating to children beyond information provided by young people aged 12 – 18 during registration as a member of the Site. When registering, they are specifically informed about the risks of engaging with the internet and they must confirm that they have received this information. In addition, they must confirm that they have guidance and support from a parent/guardian to convene a Stakeholder Dialogue or Children’s Workshop and have consent from a parent/guardian.

VI. Disclosure of your personal data

14. Apart from set out in this Privacy Policy, 4SD Foundation will not sell, rent or share your personal data with third party organisations.

15. 4SD Foundation may share your personal data with the external third parties set out below for the purposes set out in the above clause.

  • Service providers acting as processors based in the EU or internationally who provide IT and system administration services. 4SD uses WordPress software for the Site, hosted on Linode, part of Akamai Technologies International AG, Grafenauweg 8, Zug CH-6300, Switzerland.
  • Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU or internationally who provide consultancy, banking, legal, insurance and accounting services.
  • Partners of the Programme, where 4SD Foundation has a legal basis to do so.
  • Regulators and/or other authorities who require reporting of processing activities in certain circumstances such as tax reporting.
  • Third parties to whom 4SD Foundation may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
  • In the event you refuse to provide your personal data and/or object to 4SD Foundation processing your personal data under the terms of this Privacy Policy, you may not be able to participate fully in the Nutrition Dialogues Programme as 4SD Foundation will not be able to send required information to you. This will make it difficult for you to contribute to the Nutrition Dialogues Programme.

VII. Retention period

17. Your personal data is processed and stored for the time required by the purposes for which it was collected. 4SD Foundation intends to keep Nutrition Dialogues Programme active for at least 5 years from the date it becomes active (30 July 2024). Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the 4SD Foundation and you will be retained until the performance of this contract is completed, unless otherwise required by law.
  • Personal data collected for purposes related to the legitimate interest of 4SD Foundation will be retained until the satisfaction of this interest. You can obtain further information regarding the legitimate interest pursued by 4SD Foundation in the relevant sections of this document or by contacting 4SD Foundation.
  • 4SD Foundation may be obliged to store personal data for a longer period in compliance with a legal obligation or by order of an authority.
  • At the end of the retention period, personal data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

VIII. Data subject’s rights

18. Under certain circumstance, you have rights under data protection laws in relation to your personal data that is processed by 4SD Foundation

19. In particular, you have the right to:

  • Withdraw consent at any time: Where 4SD Foundation processes your personal data on the basis of consent, you can withdraw consent to the processing of your personal data at any time.
  • Object to processing: You can object to the processing of your personal data when it takes place on a legal basis other than consent.
  • Request access to your personal data: You have the right to obtain information on the data processed by 4SD Foundation, on certain aspects of the processing and to receive a copy of the data processed, this is commonly referred to as a ‘data subject access request’.
  • Verify and request correction: You can verify the accuracy of your personal data and request its updating or correction.
  • Request restriction: When certain conditions are met, you can request the limitation of the processing of your personal data.
  • Request erasure: When certain conditions are met, you can ask 4SD Foundation to delete or remove personal data where there is no good reason for 4SD Foundation to continue to process your personal data. 4SD Foundation may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request a transfer of your personal data: In some circumstances, where you have provided personal data to us, you have the right to receive your personal data in a structured format, commonly used and readable by an automatic device and its transfer to another controller.

IX. How to exercise the rights

20. To exercise the rights, you can send a request to 4SD Foundation’s contact details indicated in this document. 4SD Foundation will ask for information to verify your identity before fulfilling your request.

X. Cookie Policy

21. The Site, like most websites, uses “cookies” to help personalise your online experiences. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. Among other things, cookies help to make your visit to our website easier, more pleasant and more meaningful. We use cookies for various purposes that are necessary, i.e. “technically required”, for your use of the website.

22. The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in providing a user-friendly and up-to-date Website.

23. Most internet browsers automatically accept cookies. However, when accessing our Site, we ask you for your consent to the cookies we use that are not technically necessary. You can use the corresponding buttons in the cookie banner to define your desired settings. Details of the services and data processing associated with the individual cookies can be found within the cookie banner.

24. You may also be able to configure your browser so that no cookies are stored on your computer or so that a message always appears when you receive a new cookie.

Deactivating cookies may mean that you cannot use all the functions of our website.

XI. Analytics

25. For the purpose of customising and continuously optimising our Site, we use the web analytics services listed below. In this context, pseudonymised usage profiles are created, and cookies are used. The information generated by the cookie regarding your use of our Site is usually transmitted to a server of the service provider, where it is stored and processed, together with the Log File Data. This may also result in a transfer to servers abroad, e.g., the USA.

26. The Site may use the web analytics service Google Analytics from Google Ireland Limited (Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland) or Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (“Google Analytics”) to analyse use. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on your computers. The information generated relating to the Site is used to create reports about the use of the Site. Google will store this information.

27. The data described about the use of the Site may be transmitted to the servers of Google LLC. in the USA for the processing purposes explained. The IP address is shortened by activating IP anonymisation (“anonymizeIP”) on the Site before transmission. Users can prevent the collection of the data generated by the cookie and related to their Site use (including the IP address) and its transmission to and processing by Google and revoke their consent by refusing or deactivating the cookies concerned on the cookie banner or in the settings of their web browser (see section IX on this subject) or by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

XII. Data storage and transfer

28. Your information will be stored on computers located within the European Union.

29. Where 4SD Foundation transfers your personal data outside the EEA or Switzerland, 4SD Foundation will ensure an essentially equivalent degree of protection is afforded to your personal data by ensuring that at least one of the following safeguards is implemented (only with any supplementary measures deemed necessary by 4SD Foundation):

  • Transfers to a country with an adequate level of protection for personal data as established by the European Commission, the Annex to the Ordinance to the FADP or the Swiss Federal Data Protection and Information Commissioner;
  • Where 4SD Foundation use certain service providers, 4SD Foundation may use specific contracts approved by the European Commission which give personal data the same protections as within the EEA; and
  • Any other transfer mechanism specified and required under applicable data protection law.

XIII. Information on Data Transfers to the USA

30. Some of the third-party service providers mentioned in this Privacy Policy are based in the USA. For the sake of completeness, we would like to inform users residing or based in Switzerland or the EU that certain third-party service providers mentioned in this privacy statement are located in the USA. It is important to note that there are surveillance measures by US authorities in place that generally allow for the storage of all personal data of individuals whose data has been transmitted from Switzerland or the EU to the United States. This occurs without differentiation, limitation, or exception based on the purpose for which the data is being collected and without an objective criterion that would restrict US authorities’ access to the data and its subsequent use to specific, strictly limited purposes that can justify the interference associated with accessing and using the data. Furthermore, we would like to point out that affected individuals from Switzerland or the EU do not have legal remedies or effective judicial protection against general access rights of US authorities, which would allow them to access the data concerning them and to rectify or delete it. We explicitly highlight this legal and factual situation to enable you to make an informed decision regarding your consent or opposition to the use of your data.

31. For users residing in Switzerland or a member state of the EU, 4SD Foundation also want to inform you that, from the perspective of the European Union and Switzerland, the United States does not provide an adequate level of data protection, among other reasons, as explained in this paragraph. In cases where we have mentioned in this privacy statement that data recipients (such as Google) are located in the United States, 4SD Foundation will ensure through the choice of companies certified under the Privacy Framework agreement or through contractual arrangements with these companies and, if necessary, additional appropriate safeguards, that your data is adequately protected at our third-party service providers.

XIV. Third party websites

32. The Site contains links to other websites. 4SD Foundation is not responsible for the privacy policies or practices of third-party websites and you should check the third parties privacy policies where applicable.

XV. Changes to this Privacy Policy

33. 4SD Foundation reserves the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

34. It is important that the personal data 4SD Foundation hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.