1. General information
Tea Association, a Swiss Association, located at Baarerstrasse 10, 6300 Zug, Switzerland, (the “Association”, “we”, or “us”) is the operator of any website published by us, including but not limited to tea.xyz (hereinafter the "Website”).
2. Controller for processing of your personal data
For any matters relating to data protection and the exercise of your rights stated herein, you may contact us in writing by email or letter at the following address:
You can also contact us for privacy concerns.
3. What personal data do we process?
We process various categories of personal data about you. The main categories of personal data are the following:
3.1 Technical data
When you visit our Websites and other online offerings, the hosting provider(s) of our Websites may automatically collect and store various information in server log files that your browser transmits to us. The following technical data may be recorded by us, as is usual with connections with a web server, without your intervention, and stored by us until automatic deletion after no later than six months:
- IP addresses;
- Terminal device; and
- Information about the operating system of your terminal device, the date, region and time of use, and the type of browser that you use to access our online offerings.
Any collection and processing of this technical data is for the purpose of enabling the use and functionality of our Websites, continuously ensuring system security and stability, optimising our Websites, showing you Websites customised for your region, and for internal statistical purposes. Furthermore, the collection of technical data may ensure the functionality and security of our offerings.
Technical data is not assigned to specific persons nor linked to data from other sources. Therefore, technical data in itself does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your identity) in relation to user accounts, registrations, access controls, or the performance of a contract.
Furthermore, IP addresses may be evaluated, together with other data, in the case of attacks on the network infrastructure or other unauthorised use or misuse of the Websites, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users.
In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device, for example as a cookie. Cookies are text files that are stored in a computer system via an Internet browser. More detailed information on cookies and how they work can be found at: http://www.allaboutcookies.org and in Section 4 below.
3.2 Registration data
Certain offerings and services, such as login areas of our Websites or the registration for our newsletter or for an event organised by us, can only be used with a user account or registration, which can happen directly with us or through our third-party service providers. In doing so, you may be required to provide us with certain personal data (for example username, password, first and last name, language, email address, phone number, company affiliation, company title, or payment information), and we may collect data about the use of the offering or service.
We generally keep registration data for 12 months from the date the use of the offering or service ceases.
3.3 Communication Data
When you are in contact with us via our Websites’ contact form or by email, letter, or other means of communication, we may collect the data exchanged between you and us, including your contact details and the metadata of the communication (for example the means, place, and time of communication and its content). If we have to determine your identity, for example in relation to a request for information relating to personal data or a request for press access, we may collect personal data to identify you.
We may use this data, which you give voluntarily, only in order to respond to your question or request in the best possible manner.
We generally keep this data for 12 months from the last exchange between you and us. This period may be longer where required for evidentiary purposes or to comply with legal or contractual requirements. Emails and written correspondence are generally kept for at least 10 years. Chats are generally stored for two years.
3.4 Master Data
Master data is the basic data we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes.
We process your master data if you are a customer or other business contact or work for one, or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and promotion, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of registration), from parties you work for, or from third parties such as contractual partners, associations, and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.).
We generally keep master data for 10 years from the last exchange between you and us or from the end of the contract. This period may be longer if required for evidentiary purposes or to comply with legal or contractual requirements. For contacts used only for marketing and promotion, the retention period is usually much shorter, usually no more than 2 years from the last contact between you and us.
Master data includes data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example from the media), or official documents (for example excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number, and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends, among other things, on the purpose of the processing activity.
3.5 Contract Data
This means personal data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as personal data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity between you and us or from the end of the contract. This period may be longer where necessary for evidentiary purposes or to comply with legal or contractual requirements.
3.6 Behavioral and preference data
We may try to tailor our services and offerings to you in order to improve your user experience. For this purpose, we may collect and process data about your behaviour and preferences. We may do so by evaluating information about your behaviour on our Websites, and we may supplement this with third-party information, including from public sources. Based on this data, we may, for example, determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by recording your behaviour (for example how you navigate our website).
Behavioural data is information about certain actions, such as your response to electronic communications (for example if and when you have opened an email) or your location, as well as your interaction with our Websites and social media pages. Preference data tells us what your choices are, which products or services might be of interest to you, or when and how likely you will respond to messages from us.
Behavioural and preference data may be analysed on a personally identifiable basis, but also on a non-identifiable basis (for example for market research or product development). Behavioural and preference data may also be combined with other data (for example, location data may be used for contact tracing as part of a health protection requirement).
We anonymise or delete this data when it is no longer relevant for the purposes pursued, which may be up to 2 years for service preferences. This period may be longer where necessary for evidentiary purposes or to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our Website in Section 4.
3.7 Other data
We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may obtain or create photos, videos, and sound recordings in which you may be identifiable (for example at events, with security cameras, etc.). We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.), who participates in events or campaigns (for example competitions), and who uses our infrastructure and systems and when.
The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for some security cameras, to a few weeks or months for contact tracing and visitor data, to several years or more for reports about events with images.
Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the Websites, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection requirements (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data, and registration data, as part of your contractual obligations under the relevant contract. When using our Websites, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.
As far as it is lawful we also collect data from public sources (for example debt collection registers, land registers, commercial registers, the media, or the internet including social media) or receive data from other companies, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).
4. Online tracking
We may use various techniques on our Websites that may allow us and third parties engaged by us to recognise you during your use of our Websites, and possibly to track you across several visits. This Section informs you about this.
In essence, we may wish to distinguish access by you (through your system) from access by other users, so that we may ensure the functionality of the Websites and carry out analysis and personalisation. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you in combination with registration data. However, even without registration data, the technologies we may use are designed in such a way that you may be recognised as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (i.e. cookies).
We may use these technologies and may allow certain third parties to do so as well. Depending on the purpose of these technologies, we may ask for consent before they are used. You can set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of third parties.
We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):
- Necessary cookies: Some cookies are necessary for the functioning of the Website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24 months.
In addition, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage. For example, we may transmit the e-mail addresses of our users and contractors to operators of advertising platforms (for example social media). If these persons are registered with them with the same e-mail address, the providers display our advertisement specifically to these persons. The providers do not receive personal e-mail addresses of persons who are not already known to them. In case of known e-mail addresses, however, they learn that these persons are in contact with us and the content they have accessed.
We may use the following services:
- Google Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service «Google Analytics» and acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both «Google»). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals option». Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here https://support. google. com/analytics/answer/6004245 and if you have a Google account, you can find more details about Google's processing here https://policies.google.com/technologies/partner-sites?hl=en.
6. For what purposes do we process your data?
We may process your data for the purposes explained below. Further information is set out in Sections 4 and 5 for online services. These purposes and their objectives represent our interests and potentially that of third parties. You can find further information on the legal basis of our processing in Section 7.
- We may process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 13) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data, master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance, and for follow-up inquiries.
- We may process data for the conclusion, administration, and performance of contractual relationships.
- We may process data for promotional or marketing purposes and relationship management, for example to send users or other contractual partners our newsletters. This may be done electronically in the form of emails, through other channels for which we have contact information from you, and also as part of marketing campaigns (for example events, contests, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time or refuse or withdraw consent to be contacted for promotional or marketing purposes. With your consent, we can target our promotional or marketing efforts on the internet more specifically to you (see Section 4).
- We may process your data for market research, to improve our services and operations, and for product development.
- We may process your data for security and access control purposes.
- We may process personal data to comply with laws, directives, and recommendations from authorities and internal regulations.
- We may process data for the purposes of our risk management and as part of our corporate governance, including business organisation and development.
- We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and training.
7. Legal Basis for Processing
Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, marketing mailings, personalised motion profiles, advertising management, or behaviour analysis on the Websites), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an email to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 4. Where you have a user account, you may also withdraw consent or contact us through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party’s legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 6 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognised as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets, and in managing and further developing the Association, including its operations, safely and efficiently.
Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defence of legal claims. In some cases, other legal bases may apply, which we will communicate to you separately as necessary.
8. What applies in case of profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you (profiling) based on your data (Section 4) for the purposes set out in Section 4 and 6, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioural and preference data, but also master data, contract data, and/or technical data relating to you in order to better understand you as a person with your various interests and other characteristics.
In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.
9. Other parties who have access to personal data we collect
In relation to our contracts, the Websites, our services, our legal obligations, or otherwise to protect our legitimate interests and the other purposes set out in Section 6, we may disclose your personal data to third parties, in particular to the following categories of recipients:
- Service Providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, security companies, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers).
- Contractual partners including customers: This refers to our customers (for example recipients of our products or services) and other contractual partners as this data disclosure arises from the contracts between us and our customers or other contractual partners. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard.
- Authorities: We may disclose personal data to agencies, courts, and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. These authorities act as separate controllers.
- Other persons: This includes other cases where interactions with third parties follows from the purposes set out in Section 6, for example service recipients, the media, and associations in which we participate or if you are included in one of our publications.
These categories of recipients may involve third parties and so your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).
We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if we are required to do so by law). Notwithstanding the foregoing, your data will continue to be subject to adequate data protection in Switzerland and the rest of Europe, even after disclosure. For disclosure to other countries, the provisions of Section 10 apply. If you do not wish certain data to be disclosed, please let us know so that we can review if and to what extent we can accommodate your concern (Section 2).
In addition, we enable certain third parties to collect personal data from you on our Website and at events organised by us (for example press photographers, providers of tools on our website, etc.). Where we have no control over these data collections, these third parties are sole controllers of the data they collect. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 4 for the Websites.
10. International transfer of personal data
As referred in Section 9, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in the United States, and in exceptional cases, in other countries in the world.
If a recipient is located in a country without adequate statutory data protection requirements, we require the recipient to undertake to comply with equivalent data protection safeguards. For this purpose, we use the revised European Commission’s standard contractual clauses which can be accessed here, unless the recipient is subject to a legally accepted set of rules to ensure data protection and we cannot rely on an exception. An exception may apply for example in the case of legal proceedings abroad, but also in cases of overriding public interest, 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.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
11. How long do we process your data?
We process your data for as long as our processing purposes, the legal retention periods, and our legitimate interests in documentation and retaining evidence require it or if storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 4. If there are no contrary legal or contractual obligations, we will delete or anonymise your data once the storage or processing period has expired as part of our usual processes.
12. Data security
We use appropriate technical and organisational security measures to protect your stored personal data against manipulation, partial or complete loss, and unauthorised access by third parties. Our security measures are continuously being improved in line with technical developments.
Please note that any data transmission on the Internet (e.g. communication by email) is generally not secure and we accept no liability for data transmitted to us via the Internet. Unfortunately, absolute protection is not technically possible.
This information does not apply to the websites of third parties and the corresponding links given on our Websites. The Association assumes no responsibility and liability for those.
13. Your Rights regarding your personal data
You have the right to object to the processing of your personal data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes, and for other legitimate interests in processing.
You have the following rights in relation to our data processing, depending on the applicable data protection law:
13.1 Right to request information
13.2 Right to access
You have the right to obtain from us free information about your personal data stored at any time and a copy of this information. Furthermore, you will have access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected directly from you, any available information as to their source; and
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
13.3 Right to rectification
13.4 Right to erasure (right to be forgotten)
You have the right to obtain from us the erasure of personal data concerning you as soon as possible, and we shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;
- The personal data has been unlawfully processed;
- The personal data must be erased for compliance with a legal obligation in accordance with the applicable law to which we are subject; and/or
- The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
13.5 Right to receive personal data in a commonly used electronic format
You have the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller.
13.6 Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and requests instead the restriction of their use instead;
- we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/or
- the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether our legitimate grounds override those of the data subject.
If any one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by us, you may at any time contact our responsible person. The responsible person will arrange the restriction of the processing.
13.7 Right to object
You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
We shall no longer process the personal data in the event of the objection, unless we can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defence of legal claims. In order to exercise the right to object, you may directly contact the responsible person.
13.8 Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision: (a) is not necessary for entering into, or the performance of, a contract between you and us; or (b) is not authorised by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (c) is not based on your explicit consent.
If the decision: (a) is necessary for entering into, or the performance of, a contract between you and the Association; or (b) it is based on your explicit consent, we shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.
13.9 Right to withdraw data protection consent
You have the right to withdraw your consent to processing of your personal data at any time where our processing is based on your consent. If you wish to exercise the right to withdraw the consent, you may at any time directly contact the responsible person as stated in Section 1.
13.10 Right to receive further information
The right to receive further information comprises:
- The right to receive, upon request, further information that is helpful for the exercise of these rights; and
- The right to express your point of view in case of automated individual decisions (Section 6) and to request that the decision be reviewed by a human.
If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing at our premises or, unless otherwise specified or agreed, by email; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).
You also have these rights in relation to other parties that cooperate with us as separate controllers; please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 9 and additional information in Section 4.
Please note that conditions, exceptions, or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.
15. More information about privacy regulations
For more information on applicable privacy regulations, you may refer to:
- EU General Data Protection Regulation
- Swiss Federal Act on Data Protection
- Swiss Ordinance to the Federal Act on Data Protection