PRIVACY POLICY.

As of: October 2025

As part of our business activities and on our website (www.sicilia.de; hereinafter referred to as the "Website"), we collect and process personal data, particularly data about our customers, suppliers, business partners, related persons, users of our website, visitors to our premises, participants in events, recipients of newsletters, employees, job applicants, professional and other associations, as well as other entities or their respective contact persons and employees (hereinafter also referred to as "you").

In this privacy policy, we would like to inform you about the aforementioned data processing activities.

If you disclose data about other persons to us, we assume that you are authorized to do so, that the data is accurate, and that you have ensured these persons have been informed about the disclosure.

1. Controller Responsible for Processing Your Personal Data and a Contact Person

The following companies belong to the SIDAG Group:

– SIDAG Aktiengesellschaft, Weinmoosstrasse 7-9, CH-8583 Sulgen, Switzerland, CHE-105.774.871;
– SICILIA Citrussäfte GmbH, Wittestrasse 30K, D-13509 Berlin, Germany, USt-IdNr.: DE450780460.

Since the SIDAG Group consists of different companies, the company which will be responsible for processing your personal data may vary. The company of the SIDAG Group with which you correspond or do business, or which has referred you to this privacy policy in the context of an enquiry, a contract or other correspondence is responsible for processing your personal data under this privacy policy.

Depending on the data processing, the companies of the SIDAG Group may each individually or jointly be the data controller or may also assume the role of data processor.

The contact person for any queries you may have regarding data protection is, irrespective of which company of the SIDAG Group is responsible for the processing of your personal data in each individual case:

SIDAG Aktiengesellschaft
Weinmoosstrasse 7–9
CH-8583 Sulgen
Switzerland

E-Mail: info@sicilia-ch.com
Tel.: +41 71 644 99 88

EU data protection representative according to Art. 27 of the EU General Data Protection Regulation ("GDPR") is:

SICILIA Citrussäfte GmbH
Wittestrasse 30K
D-13509 Berlin
Germany

For data protection matters, please contact us in writing or by email using the above contact details, unless otherwise specified or agreed.

2. Sources from Which We Collect Personal Data

Primarily, we process the personal data that you provide to us yourself (e.g., in the course of your business relationship or communication with us) or that we collect from your device when you visit our website. Except in individual cases (e.g., legal obligations), of which we will inform you, you are not required to provide us with your data. However, please note that in order to use our services and products, you must provide us with certain data. Likewise, the use of our website is not possible without some data processing.

In addition, for the purposes outlined in Section 3, we may also collect personal data from third parties within the scope permitted by law, in particular:

– publicly available sources such as commercial registers, debt collection registers, media, publications, or the Internet (including social media);

– your employer or client with whom we have a business relationship or otherwise deal (e.g., for reference checks during recruitment processes);

– persons acting on your behalf;

– authorities; as well as

– other third parties such as credit agencies, address brokers, associations, contractual partners, or web analytics services.

3. Purposes for Which We Process Your Personal Data ans Data Categories

When you use our products and services, visit our website, or otherwise interact with us, we collect and process your personal data for the following purposes:

– Communication with you and, in particular, with the third parties mentioned in Section 2 via email, telephone (including video conferences), mail, or other means (e.g., to respond to inquiries, provide advice, or for contract initiation and/or execution). This also includes sending our customers, contractual partners, and other interested parties information about events, company news, seasonal greetings, or similar. Such communication may take the form of newsletters, other regular contacts (electronically or by mail), through our website, or via our social media channels. You may refuse or withdraw your consent to such communication at any time. For this purpose, we process, in particular, the content of communication, your contact details, and communication metadata.

– Initiation and conclusion of contracts with you or with third parties. For this purpose, we may in particular process your name, contact details, powers of attorney, declarations of consent, information about third parties (e.g., contact persons), contract details, creditworthiness data, as well as any other data you provide to us or that we collect from the sources listed in Section 2 (e.g., commercial registers, credit agencies, or the internet).

– Management and performance of contracts with our customers, employees, and other contractual partners (e.g., suppliers, service providers, project partners), in order to provide and enforce contractual services. This includes data processing for contract administration, bookkeeping, and – within the permitted scope – public communication. For this, we process data that we received or collected during contract initiation and conclusion, as well as data we generate in the performance of our contractual services or collect from public sources or other third parties as described in Section 2. This includes conversation and consultation records, notes, internal and external correspondence, contract documents, documents we create or receive, other business-related information, invoices, and financial and payment information.

– Operation of our website, in particular to ensure its secure and stable functioning, for which we collect technical data and also use cookies and similar technologies (see Section 9 for more details).

– Improvement of our services, in particular our website, social media channels, and other offerings, for which we collect data on your behavior and preferences. For example, we may analyze how you navigate our website, interact with our other online offerings such as social media profiles, or how you use and evaluate our services.

– Registration, where required to use specific offerings and services (e.g., newsletters), for which we process the personal data provided during registration. Registration may take place directly with us or via external service providers (see especially Section 9).

– Ensuring security (including access controls), to guarantee the adequate security of our IT (including the website) and other infrastructure (e.g., buildings), to combat and prevent criminal and fraudulent activities, and to continuously improve security. This includes monitoring and controlling access to our IT systems and physical premises, analyzing and testing our IT systems, performing system and error checks, and creating backups. In addition, for documentation and security purposes (preventively and for incident investigation), we may also maintain logs and access records (e.g., visitor lists).

– Compliance with regulatory requirements such as laws (e.g., anti-money laundering regulations, tax obligations, or professional duties), self-regulation, industry standards, directives, recommendations from authorities, and internal policies. In addition to master and behavioral data as well as financial data, we also collect any other data that we deem necessary or useful for fulfilling our obligations.

– Risk management and prudent corporate governance, which includes protection against criminal activities, business organization (e.g., resource planning), and business development (e.g., purchase or sale of business units or companies). For this purpose, we process in particular master, contract, and registration data, as well as technical, behavioral, and communication data.

– Recruitment of employees, to review applications, conduct recruitment processes, and, in the event of a successful application, prepare and conclude an employment contract. This includes, in addition to your contact details and information from related communication, personal data you provide to us during the application process as well as data we collect from third parties (e.g., professional background, education and training, references (with your consent), criminal record extracts, and data from public sources such as social media, media, and the internet).

– Reporting, which includes, in particular, the disclosure of business-related data to other companies within the SIDAG Group;

– Assertion of legal claims and defence in connection with legal disputes and official proceedings domestic and abroad, including clarification of the prospects of litigation and other legal, economic and other issues. For this purpose, we process, in particular contract data, invoices, financial and payment information, communication data and other business-related information.

– Other purposes, in particular for training and educational purposes, administrative purposes (e.g., accounting), or the organization of events. We may also process personal data for the planning, execution, and follow-up of events, such as participant lists, content of presentations and discussions, as well as images and audio/video recordings taken during such events. Finally, safeguarding other legitimate interests also falls within the scope of other purposes, which cannot be exhaustively listed here.

4. Disclosure of Your Personal Data

In connection with the purposes described in Section 3, it may be necessary for us to disclose your personal data, in particular to the following categories of recipients. Where required, we will obtain your consent:

– Service providers: We work with service providers who process personal data about you on our behalf or jointly with us, or who receive data about you from us under their own responsibility (e.g., IT and hosting providers, marketing communication agencies, banks, insurers, trustees, tax advisors, credit agencies, debt collection companies, business information services, address verification providers, and the third parties mentioned in Section 9 who collect data about you via our website).

– Customers and other contractual partners: This refers to customers and other contractual partners to whom we may transfer your data under a contract (e.g., because you work for a contractual partner or they provide services for you). This category also includes entities with whom we cooperate. These recipients generally process the data under their own responsibility.

– Authorities and courts: We may disclose personal data to offices, courts, and other authorities in Switzerland and abroad if we are authorized or legally obliged to do so, or if it appears necessary to protect our legitimate interests, or those of our customers or third parties. Such authorities process the data about you under their own responsibility.

– Other parties: This refers to other situations where the involvement of third parties arises from the purposes set out in Section 3, such as delivery recipients or payment beneficiaries specified by you, or other third parties. If we cooperate with media outlets and provide them with materials (e.g., photos), this may also affect you. In the course of corporate development, we may sell or acquire businesses, business units, assets, or companies, or enter into partnerships, which may also involve the disclosure of data (including your data, e.g., as a customer, supplier, or their representative) to parties involved in such transactions. In the context of communication with competitors, industry organizations, associations, and other bodies, data relating to you may also be exchanged.

The categories of recipients mentioned above may in turn involve other third parties, making your personal data accessible to them as well. While we can restrict processing by certain third parties (e.g., IT providers), we cannot do so for others (e.g., authorities, banks, etc.).

In addition, we enable certain third parties to collect personal data about you on our website and at events under their own responsibility (e.g., providers of tools integrated into our website). These third parties are solely responsible for the relevant data processing, unless we are substantially involved. Please therefore contact these third parties directly with any concerns or to exercise your data protection rights (see Section 8). For information on activities on our website, see Sections 9 and 10.

5. Data Transfers Abroad

We primarily process and store personal data in Switzerland and the European Economic Area (EEA). Depending on the case – for example, through subcontractors of our service providers – your personal data may, however, be processed in any country worldwide. Likewise, in the course of our activities for clients, your personal data may be transferred to any country worldwide.

If a recipient is located in a country without adequate legal data protection, we contractually obligate them to comply with an appropriate level of data protection – for example, by agreeing to the EU Standard Contractual Clauses (available at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?) with the necessary supplements for Switzerland – unless they are already subject to a legally recognized framework ensuring data protection, or unless we can rely on an exception.

Exceptions may apply in particular where there are overriding public interests, where disclosure is necessary for the performance of a contract in your interest, where you have given your consent, or where obtaining consent within a reasonable timeframe is not possible and disclosure is necessary to protect your life or physical integrity or that of a third party, or where the data in question has been made generally accessible by you and you have not objected to its processing. We may also rely on the exception for data from a legally prescribed register (e.g., commercial register) to which we have been granted lawful access.

6. Data Security

We take appropriate security measures to maintain the confidentiality, integrity, and availability of your personal data, to protect it against unauthorized or unlawful processing, and to safeguard it from the risks of loss, accidental alteration, unintended disclosure, or unauthorized access.

In the course of order processing and business relationships, we use external IT service providers and cloud providers with servers located in Switzerland.

Please note that the communication methods and technologies we use (e.g., email, video conferences) cannot guarantee complete protection of transmitted messages or content against data security risks. In particular, we cannot rule out that third parties may gain access to data transmitted via these channels and collect or use it for their own purposes. If you communicate with us via these channels without reservation and do not expressly object to such communication with effect for the future, we assume that you consent to communication via the respective channels.

7. Duration of Retention of Personal Data

We process your data for as long as necessary to fulfill our processing purposes, comply with statutory retention periods, and safeguard our legitimate interests in processing for documentation and evidence purposes, or for as long as storage is technically required (e.g., in the case of backups or document management systems). Unless legal or contractual obligations or technical reasons prevent it, we generally delete or anonymize your data after the retention or processing period has expired, in accordance with our standard procedures and in compliance with applicable legal requirements.

8. Your Rights

Applicable data protection law grants you various rights in connection with the processing of your personal data, including the right to request information about the processing of your personal data, the right to correction of inaccurate personal data or deletion of personal data, the right to object to data processing, as well as the right to request the release of certain personal data in a commonly used electronic format or its transfer to another controller. You may also withdraw consent you have given for the processing of your personal data at any time with effect for the future (this applies in particular to newsletter distribution and other direct marketing). These rights are subject to conditions, limitations, or exceptions (e.g., to protect the rights of third parties or trade secrets). Accordingly, we reserve the right to redact copies for data protection reasons or to transmit them only in part.

If you have questions regarding your rights or their exercise, or if you disagree with how we handle your rights or data protection, please contact us in writing or, unless otherwise indicated or agreed, by email; our contact details can be found in Section 1 above. Exercising your rights usually requires you to clearly prove your identity (e.g. by providing a copy of your ID if your identity is otherwise unclear or cannot be verified).

Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority may vary depending on your place of residence or the location where the alleged violation of applicable data protection law takes place. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/en).

9. Data We Process in Connection with Our Website and Any Newsletter Distribution

Log files and cookies: In connection with our electronic services, in particular our website and any newsletter distribution, we use technologies that store data (in particular technical data such as the IP address of your device, browser type and version, operating system used, referrer URL, hostname of the accessing computer, and the time of the server request) by means of logging, as well as other technologies such as cookies. These enable us and third parties engaged by us to recognize you when you use our services, record your behavior, and identify preferences. Cookies are small files transmitted between your system and the server that make it possible to recognize a specific device or browser. Essentially, they allow us to distinguish your visits (via your system) from those of other users so that we can ensure the functionality of the website, as well as perform analysis and personalization. Cookies help make your visit to our website easier, more pleasant, and more useful in many ways.

We do not intend to draw conclusions about your identity from the technical data we collect or from cookies. However, personal data that we or third-party providers engaged by us store about you – particularly if you have a user account with us or with these providers – may be linked to technical data or to information stored in or derived from cookies, and may thereby be associated with you as a person. In addition, we reserve the right to review this data retroactively if we become aware of concrete indications of unlawful use.

Most of the cookies we use are so-called "session cookies." They are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser the next time you visit.

You can configure your browser to notify you when cookies are set and to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to enable automatic deletion of cookies when closing the browser. Further information can be found in your browser’s help menu (usually under “privacy”). Please note that disabling cookies may mean you are unable to use all the functions of our website.

Links to third-party websites: Our website contains links. By clicking on the respective hyperlink, you will be redirected to the respective provider’s profile, and the privacy policy of that provider will apply (see Section 10 for further information). To use the functions of the respective network, you may need to log into your user account for that network.

When you open a link, a direct connection is established between your browser and the server of the relevant network. The network thereby receives the information that you have visited our website with your IP address and have accessed the link. If you are also logged into your account on the relevant network, the content of our site can be linked with your profile on the network, allowing the network to directly associate your visit to our website with your user account. To prevent this, you must log out of your account before clicking the respective link. If you log into the network after clicking the link, the association will occur in any case.

In addition, we use our own tools as well as services of third-party providers (which may themselves use cookies) on our website, in particular to improve the functionality or content of our website and to compile statistics. We use tools and services from the following third-party providers:

Some of the third-party providers we use are located outside Switzerland. For information on data disclosure abroad, please see Section 5.

10. Legal Grounds for Data Processing

We process your personal data for the above purposes in accordance with the applicable data protection regulations.

We base the processing of your personal data for the purposes mentioned in Section 3, depending on the situation, in particular on the following legal grounds:

– as described in Section 3, it is necessary for the initiation and conclusion of contracts and for their management, performance, and enforcement (Art. 6(1)(b) GDPR);

– it is necessary for the purposes of legitimate interests pursued by us or by third parties as described in Section 3, namely for communication with you or third parties, to operate our website, to improve our electronic offerings and for registration for certain services and offerings, for security purposes, for compliance with Swiss and foreign law and internal regulations, for our risk management and corporate governance, and for other purposes such as training and education, administration, evidence and quality assurance, organization, execution, and follow-up of events, and to safeguard other legitimate interests (Art. 6(1)(f) GDPR);

– it is legally required or permitted on the basis of our mandate or status under the laws of Switzerland, the EEA or an EEA member state (Art. 6(1)(c) GDPR), or it is necessary to protect your vital interests or those of another natural person (Art. 6(1)(d) GDPR);

– you have separately consented to the processing, e.g., by means of a corresponding declaration (Art. 6(1)(a) and Art. 9(2)(a) GDPR).

If you are located in the EEA, you also have the right to lodge a complaint with the data protection supervisory authority of your country. A list of the supervisory authorities in the EEA is available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

11. Changes to This Privacy Policy

This Privacy Policy does not form part of a contract with you. We may review and amend it at any time. The version published on this website is the most current version.