Privacy
Policy _

English is not an official language of the Swiss Confederation. This translation is provided for information purposes only and has no legal force. 

 

Fondation La Source attaches great importance to privacy protection, and in particular to data protection. Fondation La Source therefore strives to treat all data captured with the utmost care and complies with the provisions of Swiss legislation on the protection of personal data.

This document also informs you of your personal data protection rights with regard to the processing carried out by Fondation La Source. 
User data is collected when users visit our website and interact with the services and features we offer.

This declaration was drawn up in accordance with the provisions of the Federal Act on Data Protection ("FADP”) of 25 September 2020, the Data Protection Ordinance (“DPO”) of 31 August 2022 and is inspired, by way of good practice, by the principles enshrined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Data Controller 

The data controller is 
Fondation La Source, Avenue Vinet 30, 1004 Lausanne, Switzerland

Host

The host of this website is
Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Les Acacias, Switzerland

 

 1.    Collection of Your Personal Data

We obtain your personal data when you visit and browse www.lasource.ch and its sub-sites. 

How?	In what context?
The data you provide to us	Contact: for example, to ask us a question or when you request information about a product/service (first name, last name, email, phone). Events: when you register for one of our events (e.g. seminars for healthcare professionals, patients and other clients as well as the public) and you send us your contact details so that we can contact you (first name, last name, email, telephone number). As part of a job search: for example, when you create your account on our platform, emploi.lasource.ch, and submit your application file to us, we collect and process the corresponding data for the purposes of reviewing your profile, conducting the procedure and, in the event of recruitment, preparing and drawing up the contract. The processing of data in the context of an employment relationship is the subject of a separate data protection declaration. When using the Doctors’ Area: for doctors and medical offices only, when you request an account or log in to the platform. We process the data disclosed as part of this registration.
Data from third parties, including information about your use of www.lasource.ch and its sub-sites	We collect basic information about your connection to our website that you provide to us, including when you: -    create an account -    browse the site and  -    consult our web pages This includes the IP address, the type of device, the operating system, the type of browser, the region, the date and time of connection, as well as information relating to the visitor’s behaviour (pages visited, duration). We use Google Analytics to collect this information, but it is only processed in a way that does not personally identify individuals.

2.    Use of Your Personal Data

The personal information collected by Fondation La Source is treated strictly confidentially.

We process your personal data for the following purposes:

ON WHAT BASIS ?	PURPOSES
When we have your consent	- We place cookies or other tracers in accordance with our cookie policy. - Sometimes, with your consent, we will use your personal data for the purposes described at the time of collection. - Fondation La Source via the Clinic, uses the professional data of doctors and their practices to transmit information on the day-to-day operation of the company (do invitations to events fall under the concept of day-to-day operation?)
When processing is necessary for compliance with a legal obligation	- This includes disclosure of information to law enforcement agencies, in exercising legal rights, or for regulatory purposes.
When necessary for purposes in the legitimate interests of Fondation La Source and when its interests take precedence over your data protection rights	- We monitor user accounts in order to prevent, investigate and/or report any fraud, security incidents or criminal action in accordance with applicable laws. - We use the information you provide to investigate complaints or claims you submit to us regarding www.lasource.ch or our services. - We analyse the use of www.lasource.ch and use your information to help us improve, analyse and protect our content, products and services. - We use the information you provide to customise the services we provide on the platform. - We protect the rights of the Fondation La Source. This includes, in particular, any use for legal, compliance, audit, investigative or regulatory purposes (including disclosure of such data in connection with legal proceedings or litigation).

3.    Data Transfer/Retention Period

In principle, your personal data is not transmitted to third parties, unless a legal obligation requires you to do so.

In any case, the Fondation La Source and any data processors who might process or access your personal data will do so from Switzerland or the EEA.

In the event that the data is processed outside Switzerland or the EEA, and in accordance with the FADP, DPO and EU Regulation 2018/1725, Fondation La Source will ensure beforehand that an adequate level of protection of individuals’ fundamental right to data protection is provided, in particular by adopting the European Commission’s Standard Contractual Clauses.

We may share your personal data with affiliated entities of Fondation La Source located in Switzerland for the purposes of administration and customer management.

Data will be kept for as long as is necessary to fulfil the purposes for which it was collected and for a maximum of 12 months, unless the law requires us to keep it for a longer period. It will then be destroyed or anonymised.

Data Processors

1.    Hosting

Data Processor	Type of Task Performed	Country of Destination	Information on Security and Confidentiality	Guarantees for Transfer outside Switzerland
Infomaniak	Hosting the domain name and website	CH	https://www.infomaniak.com/en/legal/general-terms-and-conditions	N/A

 

 

 

 

 

 

 

2.    Analytics

Data Processor	Type of Task Performed	Country of Destination	Information on Security and Confidentiality	Guarantees for Transfer outside Switzerland
Axeptio	Consent Manager	UE	https://client.axept.io/content/624d5e22e4776e1f019014e2/contracts/635fcc3ee67894a8d892f2b1/0.1.2.pdf	DPA, adequate country
Google Analytics	Analytical Platform	Global	Only anonymised data is transmitted https://policies.google.com/privacy/frameworks	Standard contractual clauses

 

 

 

 

 

3.    Sales/ Support

Data Processor	Type of Task Performed	Country of Destination	Information on Security and Confidentiality	Guarantees for Transfer outside Switzerland
Click dimensions	Marketing automation solution	Global	https://clickdimensions.com/about/privacy-policy/	Standard contractual clauses
reCAPTCHA	Used for the prevention of Fondation La Source form spam submission	Global	https://policies.google.com/privacy https://policies.google.com/terms	Standard contractual clauses
Microsoft Dynamics 365	Customer Management Tool (CRM)	Global	https://privacy.microsoft.com/fr-fr/privacystatement	Standard contractual clauses
Antistatique	Management of the website lasource.ch and its sub-sites	CH	https://antistatique.net/protection-des-donnees	N/A
SQLI	Management of the “Doctors Area” platform	CH	https://www.sqli.com/ch-en/personal-data-protection-policy	N/A
Adequasys	Job platform	CH	https://adequasys.com/fr/mentions-legales/	N/A

4.    Data Security 

We take appropriate security measures (both organisational and technological) to protect your information from unauthorised access, alteration, disclosure or destruction.

5.    Correction of Your Personal Data

We attach great importance to the accuracy of the data we hold about you.

You can at any time: 

• Request access to, the modification and deletion of your personal data,
• You can also limit the processing of your personal data,
• If at any time we have asked for your consent, you can withdraw it at any moment.
• You can ask to receive your personal data in a structured and machine-readable format (portability).
• You may object to processing in certain situations.

In any case, you can submit a request to us by email at dpo@lasource.ch or by mail at the following address: 
Fondation La Source, for the attention of: Data Protection Officer, Avenue Vinet 30, 1004 Lausanne, Switzerland.

However, these rights may be limited in certain situations. If this is the case, the reason for this exception appearing in the FADP, the DPO or the GDPR will be provided to you. This applies in particular when we are able to prove that we are legally obliged to process your data, or when this data infringes the rights of a third party, including our rights, or when you ask us to delete data that we are legally obliged to retain, or when retaining it is in our legitimate interests.  

6.    Use of Cookies (see cookie management policy)

We use cookies to make access to lasource.ch and its sub-sites more convenient and to offer you the best possible experience. 
 
What Is a Cookie? 

A cookie is a small file stored by a server on a user’s terminal (computer, phone, etc.) and associated with a web domain (i.e. in the majority of cases, with all pages of the same website). This file is automatically referenced during subsequent contacts with the same domain. 

The purpose of these files is to identify you faster on your next visit and to customise certain aspects of the website, such as language, to improve your user experience. 
Fondation La Source uses various categories of cookies to improve the interactivity of the website and its services on the website lasource.ch or one of its sub-sites. These cookies may be deployed by both Fondation La Source and third-party technical service providers, with the aim of optimising your user experience and offering advanced functionalities. 
  
What Cookies and Similar Technologies Do We Use?
  

• Strictly necessary cookies: Strictly necessary cookies are essential to use the website and its functionalities. They are therefore deposited without your consent. These cookies ensure, for example, that you can navigate from page to page without the information entered in a form or the products placed in a basket disappearing. 
• Preferences cookies: Preference cookies enable a website to remember information that modifies the way the website behaves or is displayed, such as your preferred language or the region in which you are located. 
• Statistical cookies: Statistical cookies help website owners, by collecting and communicating information anonymously, to understand how visitors interact with the websites. 
• Marketing cookies: Marketing cookies are used to track visitors across websites. The goal is to display ads that are relevant and interesting to the individual user and therefore more valuable to third-party publishers and advertisers. 

For more details, we recommend that you consult the cookie management policy that we have drawn up and which is an essential part of our website privacy policy, demonstrating our commitment to the protection of your personal information.

7.    Data Protection Officer 

Fondation La Source, to which the Clinique de La Source and its affiliated entities belong, has appointed a Data Protection Officer and has made a declaration to the Federal Data Protection and Information Commissioner (FDPIC) in accordance with Art. 10, para. 3, let. d LPD

Their email address: dpo@lasource.ch

8.    Right to Lodge a Complaint

You also have the right to notify the Federal Data Protection and Information Commissioner (FDPIC)  – Feldeggweg 1 – CH-3003 Bren of any complaint relating to the way Fondation La Source collects and processes your data. 

9.    Amendment

Fondation La Source may amend this Data Protection Statement at any time. Please consult it regularly.