Data protection: data privacy statement
We are delighted about your interest in our company. Data protection is of great importance to Sunrise UPC. With the following Data Privacy Statement, we inform you about which personal data we collect and process when using our website or as part of a contractual relationship.
Sunrise UPC has implemented numerous technological and organizational measures to ensure that the protection of the personal data processed by us is as seamless as possible, including:
- Sunrise UPC has been certified according to the international security standard ISO/IEC 27001 since September 2014. The ISO/IEC 27001 certification is an international standard that defines the high requirements placed on an Information Security Management System (ISMS). The ISMS implements security checks to ensure, for example, that personal data are properly protected;
- moreover, the ISO 27001 certification provides a model for the establishment, implementation, evaluation and improvement of comprehensive information security measures.
We do want to point out, however, that absolute protection cannot be guaranteed.
Furthermore, we also want to bring to your attention that you should also make efforts to protect yourself. This will help all of us in better dealing with risks related to your sensitive data. Please visit the following page for an overview of measures you can take to protect your data: www.melani.admin.ch.
With our Sunrise Code of Conduct, we furthermore specify guidelines on how Sunrise UPC employees should conduct themselves, particularly also related to the handling of your data.
Access to our website and the use of our online services
If you do not agree to our Data Privacy Statement (“Statement”), we recommend refraining from accessing any further content on the Sunrise UPC website.
Please note that the Statement can be updated at any time. We thus recommend regularly checking our website for any updates.
Please also note that the data privacy provisions of the current Sunrise general terms and conditions apply in addition to this Statement.
Which data are collected by us as a result of your use of our services and products?
We process personal data that you provide to us when concluding a contract and using our services and products as well as data that you enter into a registration page or when subscribing to a newsletter. When processing data, we ensure compliance with the applicable data protection requirements.
The personal data processed by us are
- Personal details
Personal details are made up of three essential components: contact details, contract details and billing details. Examples of personal details are your first and last name, address, gender, date of birth, phone number and e-mail address.
- Location data
Location data are created when your mobile phone connects to a radio cell or your router connects to the Internet. The location of a hotspot can additionally be identified through an IP address.
- Usage data (phone, Internet and TV)
Usage data are data on services and products that you use, such as numbers you’ve contact-ed using a telephony service, TV programs, data volume, IP addresses, subscriptions and devices (e.g., smartphone, Internet/TV Box, etc.), as well as information about the frequency, the time and date, and the duration of usage. We need these data to, among other things, bill the services you have used as well as remedy disruptions. As a telecommunications service provider, Sunrise UPC is obliged to uphold telecommunications secrecy and process data about telecommunications traffic as permitted and prescribed by law. Sunrise UPC processes data from telecommunications traffic in particular to establish connections, convey information and for billing. Sunrise UPC also processes location data from telecommunications traffic. Sunrise UPC does not record any voice content or messages such as SMS or MMS messages, Chat or Messenger conversations or e-mails produced between you and your communication partner through the use of telecommunication services, nor does it read these in any way. The same applies to data entrusted to us by you when using our e-mail services or data storage solutions.
Which data do we use to operate our apps?
We use your personal data to ensure that our apps function as expected. This concerns registration data as well as data about features you use within the app. To remedy faults and disruptions, we sometimes also have to use personal data; for example to find out when an app feature does not work (properly). During a system inspection, we keep our analyses as easy and short as possible and delete the data again after we no longer need them for remedying or improvement measures.
Within your personalized and protected “MySunrise” area, you have the option of managing your personal information as well as the data on the services you use. Here, the processing of certain personal data is necessary. For example, this includes
- Your first and last name
- Your home address and billing address
- Your e-mail addres
- Your date of birth
- Your My Sunrise password, as well as
- your desired correspondence language.
Which data are processed when making an online purchase?
If you purchase a product or procure a fee-based service through the Sunrise UPC Internet page, you must provide data such as your first and last name, address, and potentially other data, because we require these data to process the contract with you. If you choose to use an online payment option, such as a credit, when buying a product or fee-based service, payment takes place using the online payment system of the respective provider. Hereby, we are neither aware of your payment data, nor process them; we merely store information on your current and previous purchases and the contract you have concluded, such as the purchased products or procured services. Please note that when using online payment systems, the data privacy provisions of the respective provider of the online payment system additionally apply.
Which data are processed when subscribing to a newsletter?
Users of our website have the option of subscribing to newsletters on certain topics. With your subscription to our newsletter(s), you consent to our processing of your contact data for advertising measures such as sending e-mails of an advertising nature, invitations to events, and delivering customer-specific advertisement.
We are entitled to commission third parties with the technological processing of our advertising measures and to forward your data to third parties for this purpose. Your e-mail address will be used for advertising and marketing purposes until you revoke your consent. You can revoke your consent at any time and unsubscribe from newsletters for these topics by clicking on the unsubscribe link at the end of the respective newsletter.
Which data are processed when using the Sunrise UPC Chat or Messenger?
Sunrise UPC offers its customers the option of contacting Sunrise UPC through its website using the Chat/Messenger feature. We hereby collect and process personal data if you provide them to us for the purpose of using our service. The communication solution used for this is provided by our partner Clarabridge and the data is processed and stored in Belgium. Your data will of course be transmitted in encrypted form.
In any case, session data such as your IP address, the time and date of contacting us, and general chat data as well as information on chat content and uploaded files are stored. We additionally analyze the content of your chats (chat history) as well as all uploaded files to improve the quality of our service and/or better understand requests.
We have the right to provide the information specified above to our partners, who may be located within or outside of the European Union. We oblige our partners to comply with applicable regulations and only operate in line with our instructions and also oblige them to ensure the same guarantees and level of data protection as we ourselves ensure at Sunrise UPC.
Processing personal data in connection with prize competitions?
The processing of personal data is carried out in accordance with the applicable legal regulations. Without corresponding consent, the personal data collected for the implementation of the competition are used exclusively for the purpose of implementing the competition and to determine the winners and to align the prizes.
For what purposes do we use the collected data?
We are primarily concerned about ensuring that we can keep our contractual obligations towards you and ensuring that our services are operated trouble-free to the greatest possible extent using the various data and information available to us. In relation to the offers, we must be able to take into considerations restrictions as well as deviating payment conditions for credit reasons; this requires additional evaluations.
We process data for the following:
- to process and respond to the individual request you submit to Sunrise UPC,
- to verify the requirements for signing a contract,
- to meet contractual obligations,
- to evaluate your usage, order, and request customs,
- to safeguard our customer and user administration,
- to validate and update your datasets,
- to inform you about our services, products, and any promotions,
- to prevent illegitimate use of services (particularly to prevent instances of fraud when concluding a contract and during the contract duration)
- to publish directory files (like www.local.ch),
- to issue a bill and to potentially commission a collections agency to collect our claim in case of non-payment,
- to maintain, develop, and sustain the customer relationship with you,
- to individualize services or provide personalized content, for example by making evaluations of a demographic nature, of usage behavior, and of user interests,
- to carry out credit checks[HS1] with orders, as well as
- to offer any other features on the Sunrise UPC website in specific cases.
More information on credit checks
If you want to conclude a contract with us, we will first carry out a credit check. Hereby, we share your personal data with third parties such as Intrum AG. We also use any experiences and information we might have about your previous payment habits. This information is included in the credit evaluation. The credit check is a partially automated process that helps us decide whether or to which extent, and under which conditions, we can conclude the contract requested by you. We furthermore share data on any fraudulent behavior or contractually breaching behavior with the aforementioned third parties. This processing is lawful and in line with our legitimate interests as well as with the legitimate interests of any third parties involved in the contract conclusion.
How long are your data stored by Sunrise UPC?
We store personal data for as long as is necessary or required by law to achieve the purpose for which it was collected. Then they will be deleted or anonymized if necessary.
Location data are stored for the legally prescribed activities in accordance with the SPTA/Ordinance of SPTA, and then deleted. The usage data are also only stored for as long as we need them for our legitimate interests, and then deleted.
Which web analysis tools do we use?
We use web analysis tools to gain insights into the use of our web pages and to improve our Internet offer. These tools are usually provided by a third party. Generally, the information collected on the use of a website for this purpose is transmitted to the server of the third party by means of cookies. These servers may be located outside of Switzerland, depending on the provider.
You can prevent tracking via web analysis tools using the opt-out options specified in the Cookie list. You can additionally block the use of your data for marketing and analysis purposes in “MySunrise”.
Data processing related to the provision of service as well as innovation promotion
The available data offer various options of fine-tuning to the greatest extent on how we consult or contact you, or which offers we make to you, in line with your needs. After you have visited a shop, we might for example offer very specific and personal advice during a consultation, or show tips on our products or services based on your preferences. To be able to offer you all these services, we must in some instances also work together with advertising partners, to for example show product information via TV programs, mobile apps, or websites. As you might not have the same service requirements as other Sunrise UPC customers, there also exists the option of creating advertisements or offers tailored to specific regions, age groups, or also users.
As an “unlimited company”, we endeavor to always make further progress. That is why we also cooperate with selected third parties. Together, we try to develop new services, which can be offered to you either by us or by third parties. If the data we collect by performing our service are used and collected for analysis purposes, we will comply with the legal requirements. In particular, such data will be provided to third parties in anonymized form, meaning that no conclusions can be drawn about you as our customer.
We require your consent to carry out such data processing.
Are your data disclosed to third parties?
We will transfer your personal data if we are allowed to or required to under Swiss or European law. We cooperate particularly closely with some partners, for example in customer service (including Call Centers) or with IT service providers. We create detailed contractual specifications to ensure that these partners are allowed to process your personal data on our behalf.
If you make an emergency call from your smartphone, we pass on your location data to the responsible authority handling the emergency. We are furthermore obliged to in certain situations disclose your personal contract, connection, or location data to Swiss authorities. We will however only do so if we are legally obliged to. This might for example be the case if there is a judicial decision in criminal proceedings.
We may share your Personal Information with any parent company, subsidiaries (Liberty Global Group), or other companies under common control (collectively «Affiliates»). In such event, we will require our Affiliates to honor this Policy.
Are your data transferred to foreign countries?
In the course of the provision of its services, Sunrise UPC also relies on the products and services of manufacturers and suppliers in other countries which may, for the performance of their services – for instance the provision of customer services (including Call Centers) or maintenance services – access personal data or telecommunication data from abroad or process it at their location abroad.
In principle, your personal data are only stored within Switzerland or the European Union; particularly sensitive information is only stored in Switzerland. When working with processors who act on our behalf outside of the EU, we comply with the requirements of the Swiss Federal Data Protection and Information Commissioner, and if necessary taking into consideration the rules of the European Commission. Sunrise UPC hereby ensures that commissioned third parties are committed to data protection in a similar manner as Sunrise UPC itself.
Foreign suppliers and service providers may be located in the United States or other countries whose data protection legislation provides less protection than that afforded in Switzerland. In this case, we ensure suitable protection in accordance with Swiss legislation, for example by concluding what are known as “EU model clauses” with the recipients of this data. These clauses are a series of provisions introduced by the European Commission to afford suitable protection to personal data when it is transferred across borders.
What are your rights in relation to your personal data?
You have the right to receive written information about the processing of your personal data by us, generally free of charge. Send a written request for information and include a copy of your ID card or passport to the address listed below.
You furthermore have the right to request correction of your personal data if there are errors. You have the right to deletion of your personal data if we are not obliged or entitled to continued storage under applicable laws and regulations. Lastly, you have the right to revoke your consent or object to your consent to process personal data. You can do so either using the pages specified in this data privacy statement or by logging in to your “MySunrise” account and adjusting settings to consent to or revoke consent related to data use and processing.
Please feel free to contact us as follows if you have any questions or issues: