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Privacy Policy

1 General and scope of application

Thank you for visiting the SUISA website and for your interest in our services. We attach great importance to the protection of your personal data and we assume the responsibility for processing such data in compliance with applicable law.

This Privacy Policy informs you how SUISA processes and protects the personal data of its customers or of the visitors to its website for example; it also provides more specific information about tracking technologies such as cookies and tags.

In our relationship with customers, the Privacy Policies in the customer forms and information documentation, as well as the provisions of Article 51(2) of the Copyright Act apply. In our relationships with principals, associate members and members of SUISA, Article 6.3 of the General Terms and Conditions for Rights Administration apply. Certain online services offered by SUISA may be subject to special terms and conditions of use. In case of discrepancies, the aforementioned documents and the provisions of the Copyright Act take precedence over this Privacy Policy.

2 The Controller

The Controller responsible for processing your personal data and who determines the purpose and the means of processing personal data is:

SUISA, the Swiss Cooperative Society for Music Authors and Publishers (hereafter referred to as "SUISA" or "we")

Bellariastrasse 82

8038 Zurich

3 Processing categories

SUISA only collects and processes personal data that is publicly accessible, or which has been communicated to it or entered directly by you as user, principal, customer, supplier, collective rights management organisation or member, provider of services, visitor, employee or applicant (e.g. in the context of inquiries, membership or licence applications, works registrations, orders, website visits, communications with SUISA or in connection with the use of online services).

The personal data (to the extent permitted by law) is the following:

  • identification data (e.g. name, date of birth, address, nationality), contact particulars (e.g. phone numbers, email addresses), and family-related information (e.g. civil status, particulars about family members and relatives such as names of spouse and children);
  • relevant information about professional qualifications (e.g. education, professional experience, work references);
  • tax residence;
  • contract-related information (e.g. relating to fulfillment and enforcement of contractual claims);
  • account and payment particulars;
  • access data relating to our website or website applications as well as IP addresses, website usage data and other use-related information.

We sometimes collect personal data from public registers in countries in which you entertain relations with us.

SUISA processes especially sensitive personal data on the basis of your explicit consent, if processing is necessary for the purpose of legal claims, if there is a legal basis for such processing, or if you have made the personal data to be processed generally accessible.

3.1 Personal data relating to authors or publishers

SUISA hosts the international database for authors and publishers. An author is the natural person who creates a new work. As related to music, an author is someone who composes, arranges or writes the lyrics of musical work. As a rule, lyrics and compositions of musical works are automatically protected by copyright as personal creations of the mind from the time they are created (i.e. when a song is rehearsed for the first time or when lyrics and melodies are written down). The publisher of a musical work is like the manager of the work. Authors (composers, lyricists, arrangers) transfer the exploitation rights in their works to a publisher who exploits the works commercially.  The publisher accompanies the entire progress of a work including its marketing.

As a cooperative society, SUISA manages in trust the copyrights of composers, lyricists, and publishers by collecting licence fees and remitting them to the entitled parties as royalties. This applies to all non-dramatic compositions and lyrics. Dramatic musical works are musical works with a plot portrayed by persons playing set roles and which rely on music to the point where they cannot generally be used without it. 

When you register with SUISA as an author or a publisher, we record the following data:

  • identification and contact data;
  • IPI number.

We use such data to confirm your identity and manage our relationship, including to communicate with you and facilitate your use of our services to members. After registration, SUISA collects additional data (for example account particulars) for the purpose of providing the relevant services.

Such processing is justified by the direct connection with the conclusion or the performance of a contract and with the business relationship, as well as for the purpose of fulfilling SUISA’s statutory obligations.

3.2 Personal data when customers register (online or offline)

For the provision of services to customers (users of works), personal data is collected, generally by means of ad hoc forms.

SUISA collects the following personal data from customers (users of works) in particular:

  • identification and contact data;
  • account and payment particulars.

The processing of such data is directly connected with the conclusion or the performance of a contract, due fulfillment of statutory obligations, or the processing is in SUISA’s overriding interest.

3.3 Personal data of applicants in the recruitment process

If you apply to SUISA for a job, we will record the data provided by you, namely:

  • identification and contact data;
  • information about your professional qualifications.

These are processed as part of your application. If the recruitment process does not lead to your employment, your personal data is deleted.

The processing of such data is justified by the direct connection with the possible conclusion or execution of an employment contract.

3.4  Personal data of employees

If you take a job with SUISA, your personal data is recorded in our personnel files. In this context, we process personal data collected for recruitment purposes (see point 3.3), and also collect family data and payment particulars.

SUISA processes such personal information in direct connection with the conclusion of an employment contract and in fulfillment of its statutory obligations as an employer.

3.5 Personal data of service providers who offer or deliver services to SUISA

In this context, we process such personal data as are necessary for the procurement of services. This includes, for example, the personal data of providers of logistical, postage and shipping, marketing, translation and consulting services.

The justification for processing such data is the direct connection with the conclusion or performance of a contract or the safeguarding of SUISA’s overriding interests.

3.6 Personal data of website visitors

When you visit SUISA’s website, your browser communicates certain information to SUISA which is automatically recorded on our server, notably:

  • IP address;
  • date and time of access;
  • retrieved data, selected pages and/or links, volume of data moved;
  • success of your access, top-level domain;
  • your browser and operating system.

SUISA processes these personal data to guarantee security and for statistical purposes. The personal data are anonymously evaluated.

The justification for processing such data resides in SUISA’s overriding interests.

SUISA is active on the Facebook, Instagram, LinkedIn and YouTube platforms and offers you a user-friendly means of keeping abreast of its latest news on the different social media.

3.6.1 Use of cookies / analysis of user behaviour

SUISA's website uses cookies. Cookies are small text files that are saved locally on the cache of the internet browser on the website visitor's computer, smartphone or tablet. The cookies used on our website collect the following data:

  • IP address;
  • surfing behaviour (referring website, time spent, click behaviour);
  • device information (device used and browser).

We use this information to evaluate your use of our website, to compile reports on web activities for the site host, and to perform other services associated with website and internet use. Cookies enable your browser to be recognized and your user settings to be stored (e.g. password, language) for example.

As a rule, the use of cookies may be blocked by activating the relevant settings in your browser. If you opt out or deactivate necessary technical cookies, however, this may restrict the availability of the functions of SUISA’s website or the member area. All recorded cookies may be deleted through the settings on your computer’s browser.

The justification for processing such data resides in SUISA’s overriding interests.

3.6.2 Matomo

With the help of Matomo, we collect and evaluate data about user behaviour on our website.  This enables us to see which pages were called up, when and from which geographical region. Moreover, we can record various log files (e.g. IP address, referrer, browsers and operating systems) and determine which actions visitors perform on our website (e.g. clicks, logins etc.).

IP anonymisation

We use IP anonymisation in our Matomo analyses. This involves removing the last components of your IP address before analysis so that it can no longer be unequivocally attributed to you.

Hosting

We host Matomo exclusively on our own servers so that all analytical data remain with us and are not passed on elsewhere.

3.6.3 Google reCATPCHA

In a few rare cases we use the “reCAPTCHA” service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, on our website to be able to determine whether forms on our website are duly filled in by natural persons or are filled in unlawfully by automated software or mechanical processing.

For this purpose, the following data is communicated to Google Inc.:

  • Referrer URL (address of the page from which the user accesses our site);
  • IP address;
  • Information about the operating system;
  • cookies;
  • mouse and keyboard behaviour;
  • date and language settings;
  • all Javascript objects;
  • screen resolution.

We use reCAPTCHA to prevent website functions from being misused by spam, mechanical processing or by any other means. This data processing is justified by our overriding interests within the meaning of Article 13(1) FADP.

For more about reCAPTCHA, see https://developers.google.com/recaptcha/

For an overview of how Google uses personal data, see https://policies.google.com/privacy?hl=en-US#whycollect

If you do not wish data about your user behaviour to be disclosed to Google Inc, you should log out of Google and delete all Google cookies before visiting our website. To have data with Google removed, contact Google support at https://support.google.com/?hl=en-GB&tid=231560237376&sjid=9332844766203533172-EU.

The justification for processing such data resides in SUISA’s overriding interests.

3.6.4 Meta Pixel

SUISA’s website uses Meta Pixel of the social network Facebook (Meta Platforms Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are an EU resident, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). 

For further information, visit: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0 

Thanks to Meta Pixel, visitors to SUISA's website can be designated to an advertising target group for Facebook ads.  Accordingly, we use Meta Pixel to display Facebook ads posted by SUISA only to "Custom Audiences" of Facebook users who have shown an interest in SUISA's website or who meet certain criteria (e.g. interest in topics or products identified through the websites they visit) and which we transmit to Facebook.  Meta Pixel also helps us in our efforts to ensure that SUISA Facebook ads correspond to users’ potential interests and are not irritating. Moreover, Meta Pixel helps us track the effectiveness of Facebook ads for statistical and market research purposes by showing us whether users were redirected to SUISA’s website after clicking on a Facebook ad ("conversion").

Meta Pixel is directly incorporated when you access SUISA’s website and may save a cookie on your device. If you subsequently log in to Facebook, or visit Facebook while you are logged in, the visit to SUISA’s website will be recorded in your profile. The data collected about you is anonymous and does not allow SUISA to infer your identity. However, the data is stored and processed by Facebook and it is possible to connect it with the relevant user profile, thus enabling Facebook to track your visits to SUISA's website.  The data can therefore be used by Facebook for market research purposes and advertising will be served to you on this basis.

The justification for processing such data resides in SUISA’s overriding interests.

4 Disclosure of personal data

SUISA passes on personal data to third parties where necessary for the performance of its duties, or if the data subject has expressly consented to such disclosure, or if it is obliged to disclose such data by law or by a judicial or official order.

Moreover, SUISA may communicate the collected data to sister societies in Switzerland and abroad that process such data in the same way and to the same extent: List of regions where data can be shared  

In so doing, data may reach countries which do not offer the assurance of adequate data protection comparable with Switzerland’s. The recipients of the data are contractually bound to process the data only to the same extent that SUISA is allowed to do so, and to safeguard the security of the data.

5 Data security and data storage

SUISA implements state-of-the-art security measures and takes the appropriate organisational precautions to protect your personal data against unauthorised, accidental or unlawful destruction, alteration or disclosure, and against unauthorised, accidental or unlawful loss, misuse or access, and against any other unlawful processing whatsoever.

Communication through SUISA's website and member area is only partially encrypted; communication by email is basically unencrypted so your security and privacy are not guaranteed. SUISA declines any liability for all and any damages incurred by you as user or by any third party in connection with communications made through SUISA's website, the member area or by email. SUISA recommends that you avoid sending confidential information over the internet.

All electronic messages sent to or by SUISA are automatically and unalterably archived to secure their evidential value. Stored data is protected by the appropriate technological and organisational precautions, and may only be accessed in justified cases in line with applicable laws and regulations, and by specific persons in defined functions.

Personal data are stored in Switzerland in accordance with legal requirements, notably the obligation to preserve business records and accounting vouchers. SUISA stores personal data for the duration of the statutory retention period and as long as is necessary for processing purposes. Thereafter, personal data are deleted or destroyed.

6 Rights of the data subject

6.1 Rights of the data subject

You are entitled to demand information about your personal data. If you assert your right to information, response must be given within 30 days.

You are also entitled to demand that incorrect or incomplete personal data be rectified and that you be informed about such rectification.  Under certain circumstances, you may demand that personal data be deleted or that processing be restricted. You are also entitled to demand the delivery or transfer of your personal data in a conventional electronic format.

If the processing of personal data is based on your consent, you may revoke such consent for any future processing. Past processing activities based on your consent do not become unlawful when your consent is revoked.

If you have access to SUISA’s website member area and can call up, enter or change data and information about yourself and your works, you may check and if necessary rectify your own personal data.

Before giving information, rectifying or erasing personal data, or revoking consent, SUISA reserves the right to ask the applicant for identification and a written request.

Kindly address any applications and inquiries concerning data protection to SUISA's legal department: legalservices@suisa.ch

6.2 Right of appeal to the regulatory authority

You have the right to file a complaint with the independent Federal Data Protection and Information Commissioner (FDPIC) against any processing of personal data in violation of statutory data protection rules.

7 Amendment of Privacy Policy

This Privacy Policy comes into effect on 1 September 2023. SUISA reserves the right to amend this Privacy Policy at any time. The latest valid version is published on SUISA’s website.