Data protection according to EU General Data Protection Regulation (GDPR)

1. Introduction

To ensure the best possible transparency and security for you as a user of our website, our data protection declaration is based on the EU General Data Protection Regulation (GDPR) of May 25, 2018. This data protection declaration is intended to explain to you in a transparent and clear manner how we process your personal data when you visit our website at https://www.swisssteel-group.com. However, should you have any question regarding data protection, please do not hesitate to contact our data protection officer at dpo(at)swisssteel-group.com

2. Data Controller

The controller for the processing of your personal data within the meaning of Art. 4 para. 7 GDPR is:

SWISS STEEL Holding AG

Landenbergstrasse 11

CH-6005 Luzern

Switzerland ("SWISS STEEL Holding AG")

3. Data Protection Officer

SWISS STEEL Holding AG has appointed a data protection officer in accordance with Art. 37 GDPR. You can contact the data protection officer of SWISS STEEL Holding AG at the following address: dpo(at)swisssteel-group.com

4. Your rights under data protection law

You have the following rights towards SWISS STEEL Holding AG according to the applicable data protection law with regard to personal data concerning you.

Right to information: Free of charge you can request information from SWISS STEEL Holding AG at any time as to whether and which personal data SWISS STEEL Holding AG has stored about you.

The right to information does not exist, or only to a limited extent, if and to the extent that information requiring confidentiality would be disclosed by the information, e.g. information that is subject to professional secrecy.

Right to correction: If your personal data stored at SWISS STEEL Holding AG is incorrect or incomplete, you have the right to request SWISS STEEL Holding AG to correct this data at any time.

Right of deletion: You have the right to request SWISS STEEL Holding AG to delete your personal data if and to the extent that the respective data is no longer required for the purposes for which these were collected, or if the processing is based on your consent, you have revoked your consent. In this case SWISS STEEL Holding AG must stop processing your personal data and remove it from its IT systems and databases.

There is no right of deletion if

• the data must not be deleted due to a legal obligation, or must be processed due to a legal obligation;
• the data processing is necessary to assert, exercise or defend legal claims.

Right to restrict processing: You have the right to request SWISS STEEL Holding AG to restrict the processing of your personal data.

Right to data portability: You have the right to receive from SWISS STEEL Holding AG the data provided by you in a structured, current and machine-readable format and the right that this data is transferred to another controller. This right exists only, if

• you have provided us with the data on the basis of your consent or on the basis of a contract concluded with you,
• and processing is carried out using automated methods.

Right of objection to processing: If SWISS STEEL Holding AG processes your data on the basis of Art. 6 para. 1 lit. e) or f) GDPR, you can object to the processing at any time.

All rights described above can be asserted against SWISS STEEL Holding AG if you address your concrete request to the following address: dpo(at)swisssteel-group.com

5. Right to appeal to a data protection supervisory authority

You have the right to appeal to a data protection supervisory authority under Art. 77 of the GDPR, if you believe that the processing of your personal data violates data protection law.

6. Use of profiling

Unless expressly stated otherwise in this data protection declaration, SWISS STEEL Holding AG does not use so-called "profiling". Profiling describes a fully automated data processing that aims to evaluate a person (e.g. in relation to their personal preferences) or to analyze or predict its behavior.

7. Processing your data in log files

When you visit our website, we collect the data that is technically necessary to display this website to you. The following personal data is automatically transmitted from your browser to our server (so-called log files):

• IP address
• Date and time of your request/access to the website (app)
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (information as to which specific page you called up)
• Access status/http status code
• Amount of data transferred in each case
• Website from which the requirements come
• Browser (information about the browser you are using)
• Operating system and its interface (operating system of the computer you are using to access the website)
• Language and version of the browser software

This personal data is processed on the basis of Art. 6 para. 1 lit. f) GDPR. The website cannot be accessed and offered to users without the use of this data. It is therefore a legitimate interest to make it technically possible to access and use the website.

These data will be received by PlusServer GmbH, Hohenzollernring 72, 50672 Köln, Germany, who hosts this website, and by SWISS STEEL Holding AG and will be processed exclusively in the territory of the European Union. The information in the log files is stored for 60 days and then deleted.

8. Mailing list for media releases and newsletters

If you register for the mailing list for media releases at SWISS STEEL Holding AG or our newsletters and give us your consent, we store and process the contact data provided there for the purpose of sending the news you have subscribed to. The legal basis for data processing is Art. 6 para. 1 a) GDPR.

The consent text for the media releases was:

"Yes, I agree that SWISS STEEL Holding AG sends me the media releases I have ordered by e-mail and processes my personal data for this purpose. I can unsubscribe from the media releases at any time and free of charge at ir(at)swisssteel-group.com".

The consent text for the newsletter was:

"Yes, I agree that SWISS STEEL Holding AG sends me the newsletters I have ordered by e-mail and processes my personal data for this purpose. I can unsubscribe from the newsletters at any time and free of charge at ir(at)swisssteel-group.com".

You can cancel the media release mailings and newsletters at any time with effect for the future and revoke your consent with it. You will find the link to unsubscribe from the media releases mailings and newsletters in every e-mail providing you with the media release or newsletter. As soon as you revoke your consent, we delete your data, as far as this is not contrary to legal storage obligations.

The subscription of media releases and newsletters is at your sole discretion and not a prerequisite for the use of the website. Please note, however, that we cannot send you any media releases or newsletters if you have not given us your consent or if you withdraw your consent.

9. Contact forms

We offer a contact form on our website so that you can contact us with questions about SWISS STEEL Holding AG, our website and other inquiries. You can also contact us by e-mail.

When you contact us via the contact form or by e-mail, the data you provide (in particular your e-mail address, your first and last name and the text of your enquiry as well as any other information you may have provided in the contact form or by e-mail) will be stored by us in order to process your enquiry and answer your questions.

Your data will be processed for this purpose on the basis of Art. 6 para. 1 f) GDPR. If you make inquiries to us, it is in your own and our interest that we process your contact data in order to be able to process your request. The use of the contact form is completely at your discretion and not a prerequisite for the use of the website. Note that we cannot process your request if you do not provide us with the contact data requested in the contact form.

We will delete the data of your inquiry/contact as soon as they are no longer necessary for processing your inquiry. Only if there are legal storage obligations, the data may be stored for longer and then deleted.

10. Use of cookies

We use so-called cookies on our website. Cookies are small text files with configuration information that are sent from our web servers to your browser when you visit our website and are stored on your computer for later retrieval.

Cookies allow our website to retrieve or store information from your browser. This can be information about you, your settings or your device. They are usually used to ensure that the website functions as expected. As a rule, this information does not identify you directly. But they can offer you a more personalized web experience. SWISS STEEL Holding AG uses two different types of cookies:

1. Session cookies (transient cookies)

We use so-called session cookies (also called temporary or transient cookies). The session cookies are stored exclusively for the duration of your use of our website. The session cookies used by us serve exclusively to identify you as long as you are logged on to our website. The session cookies are deleted at the end of each session. The session cookies are not used in any other way.

These cookies are necessary for the function of our website and cannot be deactivated in our systems. Typically, these cookies are only set in response to actions you take in order to service requests, such as setting your privacy preferences, logging in, or filling out forms. You can set your browser to block these cookies or to notify you about these cookies. However, some areas of the website may not work.

These session cookies are used on the basis of Art. 6 para. 1 lit. f) GDPR. Without the use of these cookies, it is technically impossible for you to access and use the website. However, we have described how you can delete these cookies in section 11.

2. Persistent cookies (Google Analytics)

We also use third-party cookies from Google Inc. "("Google") called Google Analytics. Google Analytics uses cookies which are stored on the user's computer and which enable an analysis of your use of the website. This allows us to optimize our website for users, for example by learning which pages are particularly interesting, which pages need better information, from which source users come, how long users are on our site.

The information generated by the cookie about the use of this website by users is usually transferred to a Google server in the USA and stored there. IP anonymization has been activated on this website so that the IP addresses of users of Google within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area are previously reduced.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. We would therefore like to point out that data processing within the framework of Google Analytics may also take place outside the scope of EU law.

On behalf of the operator of this website, Google will use this information to evaluate the use of the website by the users, to compile reports on the website activities and to provide the website operator with further services associated with the use of the website and the Internet. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. Please note that your consent to the use of Google Analytics is completely at your discretion. The granting of consent is not a prerequisite for the use of our website.

SWISS STEEL Holding AG has set the storage period for cookies at Google Analytics to the shortest period of 14 months.  After this period has expired, data is automatically deleted.

SWISS STEEL Holding AG has concluded a contract on Google Analytics. Google Analytics is only used by us with your prior consent, which you can revoke at any time with effect for the future (see Section 11).

11. Consent and deletion or revocation with regard to cookies

This section explains how you can control the use of cookies and revoke your consent to use Google Analytics.

1. Google Analytics

We only use Google Analytics with your express consent. The legal basis for this is Art. 6 para. 1 a) GDPR. You can revoke this consent at any time.

The consent text was:

"Yes, I agree until revoked that this website stores Google Analytics cookies on my device and processes my personal data to the extent explained in the data protection declaration. It also describes how I can make use of my right of withdrawal. Consent is voluntary and not a condition of use of this website".

There are two ways to revoke this consent. This means that Google does not collect any data generated by the cookie and relating to your use of the website (including your IP address).

• You can either download and install the browser plugin available under the following link. The current link is: http://tools.google.com/dlpage/gaoptout?hl=en
• Alternatively, you can revoke your consent to the placement of cookies by Google Analytics by proceeding as follows: delete the history and all cookies in the settings of your web browser, reload our page in your browser afterwards. In the selection window of the cookie settings, select: Do not use Google Analytics.

2. Session Cookies

Session cookies, which are absolutely necessary for the function of our website, are also used without your consent. However, if you do not wish to use session cookies, you can control the use of cookies yourself via your browser settings. By disabling cookies, you will not be able to use some parts of the website.

12. Links to Google Maps, Youtube and LinkedIn

On our websites we offer you the possibility to visit contents of SWISS STEEL Holding AG in social networks (Youtube and LinkedIn) and to plan routes via Google Maps. Our website only integrates these services as external links. Processing of your data by these companies therefore only takes place when you click on the integrated graphics. You will then be redirected to the page of the respective provider. If you do not want the mentioned providers to receive your data, please do not click on the graphics.

Luzern, Switzerland, October 05, 2020