Privacy Policy

1. SCOPE

The following Privacy Policy applies to Koa Switzerland AG, a Swiss corporation domiciled at Giesshübelstrasse 40, 8045 Zurich (hereinafter referred to as Koa or we/us). Koa is committed to responsibly handling your personal information. This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information, and certain rights you may have relating to such use. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please feel free to reach out to us using the details set forth at the end of this Privacy Policy. We reserve the right to change or modify any of the terms and conditions contained in this Privacy Policy, at any time and at our sole discretion. To the extent permitted by law, any changes or modification will be effective immediately upon posting of the revisions on our website(s) without further notice. Last revision: March 2022.

2. COLLECTION & STORAGE OF PERSONAL INFORMATION

Personal information is data that can be used to identify you or that we can otherwise link to you (the Personal Information). The use of our website is usually possible without providing any Personal Information. Except for cookies (see below), we only collect certain Personal Information that you voluntarily provide to us, for example when you communicate with us via email or other channels, when you sign up for or ask us to send you newsletters or other marketing materials. The Personal Information we collect includes, but is not limited to, your name, e-mail address, phone number, location, language preference and business affiliations.

When processing your Personal Information for the purposes described herein, we rely on your consent to this Privacy Policy, our legitimate interests in maintaining business relationships and communicating with you and/or our performance of any contract or another ground for lawful processing of your Personal Information under the applicable laws and regulations.

3. USE OF PERSONAL INFORMATION

We use your Personal Information to offer you our products and services as well as for communication purposes, including sending you newsletters, invitations to events, promotions, and to maintain our list of contacts.

A transfer of your Personal Information to third parties for purposes other than those listed below does not take place. We only pass on your data to third parties if:

  • You have given your express consent to this;
  • this is necessary for the performance of contractual relationships with you;
  • there is a legal obligation to pass it on;
  • disclosure is required for asserting, exercising or defending legal claims and there is no reason to assume that you have a predominantly legitimate interest in not disclosing your data.

In these cases, however, the amount of data transmitted is limited to the minimum required. Our Privacy Policy is consistent with applicable data protection laws (including the Swiss Data Protection Act, “FADP” and, where applicable, the EU General Data Protection Regulation, “GDPR”).

4. NEWSLETTER

Subscription:
You may register for our newsletter on our website by providing us with your e-mail address. The newsletter will keep you updated on our latest news, products and customers.
When registering for our newsletter, you give us your consent to receive the newsletter on a regular basis and that we collect and store the following information: your e-mail address as well as your language used when registering for the newsletter. We use this information only for the purpose of sending you our newsletters.

Unsubscribe:
If you wish to unsubscribe from our newsletter, you can do so at any time by clicking on the “unsubscribe” link at the bottom of any newsletter that you receive. If you decide not to receive our newsletters, we may still send you business related communications.

Newsletter tracking:
The newsletters contain so-called “web beacons”, which are retrieved from an external server when the email is opened. This call will initially collect technical information, such as details about your browser and operating system, as well as your IP address and the time of retrieval. In addition, based on your e-mail address, we can track whether and when you opened a newsletter and which links were clicked. The analysis of this information helps us to identify the reading habits of our users and to adapt our content to you or to send out different content based on the interests of our users.

5. COOKIES

Cookies are small text files that are downloaded to your device by visiting our website or opening our marketing related emails. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number. Cookies (including third-party cookies such as tracking technologies provided by Google Analytics) are in particular used to ensure and improve the functionality of the website or for general marketing purposes by providing information on interaction of unique browser-device pairs with the website (such as number of sessions, pageviews, clicks and ecommerce interactions and time spent), statistical information on interaction with the website (including referrals thereto, popularity of certain content, accessing visitors’ languages, demographics, browser and device types and similar information), or statistical information on interaction with our marketing emails (such as if they have been opened or forwarded or links have been clicked on).

Third-party service providers such as Google may track your use of our website, combine this information with information from other websites you have visited (and which they also track) and use such combined information for their own purposes. If you have registered with the respective service providers, they may be able to identify you. In these instances, their processing of your Personal Information will be governed by their privacy policies.

Most internet browsers are initially set up to automatically accept cookies. You may change your browser settings to delete and block cookies. By continuing to use our website without changing your settings (or using the add-on, as applicable) you consent to our and our third-party service providers’ use of cookies. If you would like more information about cookies, we can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.

6. SOCIAL MEDIA PLATFORMS

We are also present on various social media platforms such as Facebook, Instagram, LinkedIn, Twitter and Youtube. On these social media pages, we publish and share various content with regards to our news, products, and customers.

When using third party social media platforms to communicate with us, kindly note that the operators of these social media platforms are considered as data controllers for any data shared and as such their respective privacy policy applies.

7. INTEGRATION OF THIRD-PARTY SERVICES

Google Analytics & Hotjar
Our website uses Google Analytics, a service by Google Inc., as well as Hotjar, a service by Hotjar Ltd., for the analysis of accesses to websites which allows us to improve our website over time. Both Google Analytics and Hotjar use cookies (see above) to allow us to analyse your use of our website. You may refuse the use of cookies by selecting the appropriate settings on your browser.

HubSpot
For the handling of customer data, contact forms and newsletter subscriptions, we use the HubSpot marketing automation software of the company Hubspot Inc. Hubspot provides an integrated software solution by which we cover different aspects of our digital marketing, sales and customer relation management. Similar to Google Analytics and Hotjar, Hubspot also uses cookies to allow us to analyse your use of our website. You may refuse the use of cookies by selecting the appropriate settings on your browser.

Personal Information is stored in our Hubspot marketing automation tool for newsletter subscribers as long as your newsletter subscription is active and for customers as long as you request us to delete your Personal Information pursuant to your rights under section 9.

Our Data Processing Agreement with HubSpot includes the Standard Contractual Clauses (SCC) as approved by the European Commission in 2021 to ensure any data is safely transferred to Hubspot.

8. YOUR DATA RIGHTS

You have the right to know what Personal Information we process about you and may request a copy. You are also entitled to have incorrect or incomplete Personal Information about you corrected or completed and you may ask us to delete your Personal Information. You can also object to certain Personal Information about you being processed and request that processing be limited. Please note that the limitation or deletion of your Personal Information may mean that we will be unable to provide the services and information described above. You also have the right to receive your Personal Information in a machine-readable format and have the information transferred to another party responsible for data processing.

9. DURATION OF DATA STORAGE

Personal Information will be stored by us as long as necessary for the performance of our services to you or the contractual relationship we have entered into, or you have not exercised your right to cancellation or your right to transfer data to another company.

10. PROTECTION OF YOUR PERSONAL INFORMATION

We restrict the use and access to your Personal Information to those who have an absolute need-to-know to provide you with our services or access to our website and/or to communicate with you. We maintain appropriate technical, physical, and organisational measures to help protect your Personal Information from unauthorised access, disclosure, modification, loss or destruction in accordance with applicable data protection and security laws.

11. DATA PROTECTION FOR FARMER DATA

In 2022, our affiliate Koa Impact Ghana Ltd., a company incorporated in Ghana (hereinafter referred to as Koa Impact Ghana), has launched a block-chain based traceability platform which lets customers and consumers transparently trace all payments made directly to smallholder farmers for the extraction of the so far discarded cocoa pulp found in our products.

As part of its operations, Koa Impact Ghana has been collecting personal data on all cocoa farmers it contractually engages with and is a registered data controller under the Ghana Data Protection Act. The personal data of the cocoa farmers is used for production planning and for the execution of payments via mobile money providers. All smallholder farmers have given their consent on the processing of their personal data and benefit of same data rights as you pursuant to section 9.

For the traceability platform, Koa Impact Ghana cooperates with the German based company seedtrace GmbH, which acts as a data processor under the Ghana Data Protection Act and supports Koa Impact Ghana on processing a limited set of farmer data for the traceability platform. While farmer data are anonymised to a certain degree, Koa Impact Ghana takes a conservative approach and treats such data as personal data under the Ghana Data Protection Act. This approach means that all smallholder farmers have provided their consent that such data can be shared on the traceability platform and they may also elect to request at any time a deletion of the personal data on the traceability platform.

For the avoidance of doubt, Koa Switzerland AG is neither a data controller nor a data processor with regards to the personal data of the cocoa farmers used on the traceability platform. Information on the cocoa farmers and the related payments to these farmers are displayed on a separate website hosted by seedtrace GmbH.

12. CONTACT US

Should you have any questions or concerns relating to this Privacy Policy or the processing of Personal Information we hold about you, please contact us on hello@koa-impact.com.