Swiss-U.S. Data Privacy Framework Statement
Last Updated: November 11, 2024
 
Your data is safe with us. SFS complies with the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SFS has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The following U.S. entities or U.S. subsidiaries of the organisation also adhere to the principles of the Swiss-U.S. DPF as ‘other covered entities’:
 

• Triangle Fastener Corporation
• Truelove & Maclean, Inc.
• Tegra Medical LLC

 
Categories of individuals about whom we process personal data and Categories of personal data processed 
We process personal data from or about the following categories of individuals and corresponding types of personal data:

• Users of the SFS Website: The personal data we collect and process generally includes details such as usage information, IP address, website activities, user ID, and browser information.
• Individuals associated with SFS group company, employees, vendors, or business contacts: This includes those we interact with or seek to establish relationships with, as well as individuals who communicate with SFS or subscribe to its newsletters or other materials. The personal data typically collected includes your name, job title, position, employer, email address, other business contact details (e.g., business card information), and similar relationship-related information.
• Independent contractors providing services to or on behalf of SFS: The personal data collected and processed includes information necessary for the engagement, such as your name, address, job title, position, email address, bank account information, tax and social security details, and any background check-related data.

 
Purposes and Legal Basis for the Processing:
We process Personal Data for the following purposes:

• Managing and maintaining client relationships, including communication with existing and potential clients;
• Processing personal data of employees and prospective personnel in connection with employment and recruitment processes;
• analyzing and improving the SFS websites;
• our own statistical purposes in order to improve our online presence and our products and services,
• fulfilment of legal and regulatory obligations within the scope of our business activities;
• engaging individuals as contractors;
• generally operating SFS’s business; and
• in connection with an actual or proposed merger, sale or other organizational change of SFS.

For Swiss Individuals, the legal basis for such processing is that:

• In many cases, SFS's legitimate interest in conducting its business, which is not overridden by your interests or fundamental rights;
• In some cases, the necessity of performing a contract with you or taking pre-contractual steps at your request;
• Compliance with legal obligations, including those related to data protection and record-keeping;
• Your voluntary consent, where required.

Sharing of Personal Data - Recipients
We may share selected personal data about you with the following parties or in the following circumstances.

• SFS group company: We may share personal data with SFS group company that require access to personal data for business purposes related to processing any application, request, inquiry, event, project, or other activity consistent with the business of SFS.
• Third Party Service Providers: We may share personal data about you with third parties who perform services for us or on our behalf, for the limited purpose of carrying out such services. This includes, without limitation, third parties that assist in managing our organization, support with the processing of business operations, hosting or administering the SFS websites or other systems, sending communications on our behalf, maintaining or analyzing our data, or in otherwise providing services to us. These third parties are required to provide the same level of protection as stipulated by the Swiss-U.S. Data Privacy Framework.
• Corporate Change: We reserve the right to disclose and transfer personal data about you in connection with a merger, consolidation, restructuring, financing, sale of substantially all assets, or other organizational change of SFS.
• Legal Requirements and Law Enforcement: We may disclose personal data about you to governmental authorities or a court when we believe in good faith that the law requires it; at the request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our agreements or policies and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of SFS, its users, or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
• Consent: We may also share personal data about you in accordance with any express consent you or your authorized agent give us which is specific to the purposes of the processing which you will be informed about at the time we request such consent. You do not have to give such consent. If you do give consent, you may withdraw it at any time by contacting us (see “Contacts” section below), however, please be aware that such withdrawal will not affect the lawfulness of personal data collected and processed prior to the date of your withdrawal of consent.

Choice
If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, SFS will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to us as specified in the "Contacts" section below.
Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered "Sensitive Information." SFS will not use Sensitive Personal for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless SFS has received your affirmative and explicit consent (opt-in).
 
Disclosures of Personal Data
In some circumstances, SFS may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In these cases, we follow all applicable legal and regulatory guidelines.
 
Accountability for Third-Party Transfers
SFS is responsible for ensuring that any third-party service provider involved in processing personal information complies with the Swiss-U.S. Data Privacy Framework. Should a third party fail to comply with the required privacy protection standards, SFS may be liable if such non-compliance results in damages.
 
Your Rights
You have the right to access your personal information, correct it if inaccurate, or request its deletion if processed unlawfully. To exercise these rights, or if you have any concerns regarding our handling of your personal data under the Swiss-U.S. Data Privacy Framework, please contact our Data Protection Officer at dataprotection@sfs.com or via the following form Notification to the Data Protection Office.

Contacts
In compliance with the Swiss-U.S. DPF, SFS commits to resolve DPF Principles-related complaints about our collection and use of your personal information. Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the Swiss-U.S. DPF should first contact (see below) at: dataprotection@sfs.com or via the following form Notification to the Data Protection Office.

SFS Group USA, Inc.
1045 Spring Street
Wyomissing, PA 19610

You can also contact our Swiss company:
SFS Group AG
Rosenbergsaustrasse 8
CH-9435 Heerbrugg

In compliance with the Swiss-U.S. DPF, SFS commits to cooperate and comply respectively with the advice of the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the Swiss-U.S. DPF.

Please note that if your complaint is not resolved through other dispute resolution procedures, under limited circumstances, you may be entitled to invoke binding arbitration.

Authorized statutory body
SFS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
 
Modifications to this Policy
This Privacy Policy may be updated or amended in line with the Swiss-U.S. Data Privacy Framework requirements. In the event of any conflict between this Notice and the Swiss-U.S. Data Privacy Framework Principles, the latter will prevail.
For more information about the Swiss-U.S. Data Privacy Framework and to view SFS’s certification, please visit www.dataprivacyframework.gov.

This Privacy Policy applies in combination with the Data Privacy Policy of SFS, which can be accessed at https://us.sfs.com/privacy-policy.