This Privacy Policy describes the ways in which Oculis Holding AG (“Oculis”, “we” or “us”) having its registered office at Oculis Holding AG, Bahnhofstrasse 7, 6300 Zug, Switzerland collects and processes information about you that identifies you directly or indirectly (“Personal Information”), either alone or in combination with other information made available to us, through your interactions with us via our website www.oculis.com (the “Services”).
Oculis is responsible for the processing of your Personal Information as it decides why and how it is processed, thereby acting as the “Data Controller” of such Personal Information. This Privacy Policy covers how we respect your privacy rights with respect to the processing of your Personal Information in relation to the Services and/or for the purposes described in this Privacy Policy.
This Privacy Policy is intended for individuals interacting with the Services. Wherever required, we will also present you with specific privacy policies for the purposes of activities not covered under this Privacy Policy including but not limited to recruitment, employment, or third party management.
Do take note that if you access any third-party link or website from our Services, you may need to refer to the privacy policies of such third parties. Oculis does not endorse and is not responsible for the information or privacy practices of websites or services owned by third parties.
By continuing using the Services, you agree to this Privacy Policy. We consider the protection of your Personal Information and privacy to be a very important matter. As such, we invite you to carefully read this Privacy Policy.
If you have any questions in relation to the processing of your Personal Information or this Privacy Policy, please refer to our Contact us section below.
How do we deal with Personal Information from individuals under the age of 13?
Our Services are not directed at children. We do not knowingly collect any Personal Information about children under the age of 13 on our website or for the purposes mentioned in this Privacy Policy. If Personal Information about children has been mistakenly provided to us and you would like to request that such Personal Information be removed, please refer to our Contact us section.
What Personal Information do we process and for which purposes?
Our Services do not require any form of registration or sign-up to access the Services. However, depending on how you interact with us, we may collect and process Personal Information that directly identifies you such as your name, contact details and email address. We may also collect certain Personal Information that does not directly identify you, but which makes identification possible through the combination of other information or identifiers such as your company name and position. If you submit Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
For inquiries via our contact form, you must provide your name, e-mail address, and your message. We process and save the Personal Information provided in the contact request or via e-mail to process and answer your request and to get in touch with you.
The legal bases for processing your Personal Information are to perform our obligations under any contract with you, or for our legitimate interests.
We may use your Personal Information for our business purposes, including audits, monitoring and prevention of fraud, infringement.
Also, we may use your Personal Information:
- if we are required to do so because of an applicable law, requests from public and government authorities (including court order, subpoena, or governmental regulation), even outside your country of residence;
- if we need to enforce our terms and conditions;
- when we believe in good faith that the use of Personal Information is necessary to protect legal rights, the security or integrity of this website;
- to protect your safety or the safety of others;
- as part of any criminal or other legal investigation or proceeding in your country or in other countries; or
- to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction.
We do not collect sensitive Personal Information. You are requested to not disclose your sensitive Personal Information to us unless we specifically ask for it (e.g., national identification card numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual).
When and to whom do we disclose your Personal Information?
We may share your Personal Information with other Oculis subsidiaries and affiliates worldwide to exchange information and maintain databases in different countries. We also may transfer Personal Information to third parties who act on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, evaluating the usefulness of our Services, data management, or technical support.
We will not sell, share, or otherwise transfer your Personal Information to third parties other than those indicated in this Privacy Policy.
In the course of our activities and for the same purposes as those listed in this Privacy Policy, your Personal Information can be accessed by, or transferred to the following categories of recipients on a need to know basis to achieve such purposes:
- our personnel (including personnel, departments or other companies of the Oculis group);
- our independent agents or brokers (if any);
- our other suppliers and service providers that provide services and products to us; and
- our IT systems providers, cloud service providers, database providers and consultants.
These third parties have contracted with us to only use Personal Information for the agreed upon purpose, and not to sell Personal Information to third parties, and not to disclose it to third parties except as may be permitted by us, as required by law, or as stated in this Privacy Policy.
Also, we may disclose your Personal Information to a third party if we are required to do so because of an applicable law, requests from public and government authorities (including court order, subpoena, or governmental regulation), even outside your country of residence; if we need to enforce our terms and conditions; when we believe in good faith that the disclosure is necessary to protect legal rights, the security or integrity of this website; to protect your safety or the safety of others; as part of any criminal or other legal investigation or proceeding in your country or in other countries; or to third parties, advisors, and other entities to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction.
Your Personal Information may also be processed, accessed, or stored in countries outside Switzerland. Such countries may offer a different level of protection of Personal Information. If we transfer your Personal Information to external companies in other jurisdictions, we will make sure to protect your Personal Information by applying the level of protection required under applicable data privacy laws by implementing adequate technical and organisational measures. In the event that your Personal Information is transferred to a service provider based in a third country (countries outside the European Union that do not have a level of data protection comparable to the data protection law of the European Union, as determined by a competent data protection authority) and processed there, Oculis ensures the protection of your Personal Information by means of Standard Contractual Clauses or EU Model Clauses or another method in accordance with applicable law. Should these Standard Contractual Clauses in the future be declared null and void and/or be revised by the European Commission, we will adopt other applicable and/or approved instruments to provide for appropriate safeguards required for the third country transfers and enter into such agreed instruments in a written and legally binding form.
How long do we keep your Personal Information?
We keep your Personal Information for as long as you use the Services. We may also keep your Personal Information for a reasonable period following the fulfilment of our Services or termination of your relationship with us or discontinuation of your use of our Services, unless a longer retention period is required or permitted by law.
How do we protect your Personal Information?
We have implemented appropriate technical and organisational measures designed to provide an adequate level of security and confidentiality to your Personal Information. The purpose of these measures is to protect Personal Information against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
What are your rights and how can you exercise them?
Whenever we process Personal Information, we take reasonable steps to keep your Personal Information accurate and up-to-date for the purposes for which they were collected. We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law:
- the right to be informed about what Personal Information we have about you and how we process your Personal Information;
- the right to access your Personal Information as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
- the right to request the erasure of your Personal Information or the restriction thereof to specific categories of processing;
- the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal;
- the right to object, in whole or in part, to the processing of your Personal Information;
- the right to request a data portability, i.e. that the Personal Information you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hindrance from us and subject to your confidentiality obligations; and
- the right to object to automated decision making including profiling resulting in a significant or legal effect, i.e. you can request an human intervention in any automated decision making process related to processing of your data resulting in a significant or legal effect, and where such processing is not based on your consent, authorised by law or necessary for the performance of a contract. However, we don’t currently make decisions using automated processes only that result in significant or legal effects on individual.
If you have a question or want to exercise the above rights, you may send an email to our Data Protection Officer at privacy@oculis.com or a letter to Oculis at the address described in the Contact us section below. If you have a complaint about how your Personal Information is being processed, you also have the right to contact the Data Protection Authority in your country.
How frequently do we update this Privacy Policy?
We keep our Privacy Policy under regular review and update it as and when required. The last version of this Privacy Policy was last updated on March 3, 2023.
Contact us
If you wish to contact us regarding how we use your Personal Information or you wish to exercise your data privacy rights, please email us at privacy@oculis.com or write us to the following address:
Oculis Holding AG
Data Protection Officer
Bahnhofstrasse 7
6300 Zug
Switzerland