Valid from 19.02.2019
The purpose of this privacy statement is to explain to you what personal data Mr Mohamed Ayachi Ajroudi (hereinafter referred to as “we”) collects about you, for what purposes and how this data is processed and, if applicable, to whom they are transmitted. It also tells you what your rights are under current data protection law and how you can exercise these rights.
When you provide us with other people’s personal data (for example that of your family members), please ensure that these people are aware of this privacy statement and only disclose their personal data to us if you are authorized to do so and if these data are correct.
1 What happens to your data?
1.1 WHAT ARE PERSONAL DATA AND WHAT DOES “DATA PROCESSING” MEAN?
Data protection applies whenever personal data is processed. When we process data that is not personal, data protection does not apply.
Personal data is all information about you and which identifies you – directly or using other sources of information reasonably likely to be used for this. We are for example in the presence of this type of personal data when we record the following information: name, first name, postal address, e-mail address, date of birth, telephone number or other data concerning you that you transmit to us, especially in the context of a user account or a request. Information which does not allow you to be identified (for example statistics concerning the number of users of our website), i.e. anonymous data, is not personal data.
The processing includes any form of management of your personal data, in particular the entry, collection, anonymization, recording, management, use, transmission or deletion of your personal data.
1.2 WHAT PERSONAL DATA DO WE PROCESS?
We collect about you all the personal data that you communicate to us via our online forms, our applications or our other digital channels. We also collect personal data that you communicate to us in another way in the context of the use of our offers (for example during correspondence or other communications exchanged with you, in particular by telephone or e-mail) . We also collect data transmitted as part of your use of our websites, applications and other digital channels, as well as that of related companies and third-party companies.
In particular, we collect the following personal data:
Basic data (name, address, telephone, e-mail address, date of birth, gender, means of payment, information relating to the account that you may have with us, etc.);
Data about how you use our websites, applications and other digital channels and the services we offer;
Data concerning you which are necessary, or useful, for the treatment of the various services and which we receive either directly from you (for example information on the services for which we establish a price comparison or which we need to obtain an offer, data relating to payment), either via our related companies, or from other companies with which we collaborate (for example an offer concerning you and which we send you); in all these cases, it is not public data.
To the extent permitted by law, we also obtain certain data from publicly available sources (e.g. press, Internet) or receive this data from our affiliated companies, administrative departments or other third parties. In addition to the data concerning you that you provide to us directly, the categories of personal data that we receive from third parties about you include in particular information from public registers, information related to your professional functions and activities, information about you. concerning information mentioned in correspondence and in interviews with third parties, information concerning you as persons around you (family, advisers, legal representatives, etc.
This data can be combined, even if it concerns several visits and different contacts, for example in the case where a user name, an e-mail address or the identification of a device makes it possible to recognize you.
1.3 WHY IS THE DATA PROCESSED AND ON WHAT LEGAL BASIS?
We use the personal data that we collect in the first place in order to allow you to use our services and to process the related contracts concluded with you, but also in order to allow you to use our websites, applications and our other digital channels as part of our legitimate interest in providing an attractive offer and in order to fulfill our legal obligations, in Switzerland and abroad. The other people about whom you send us personal data are obviously also concerned.
we collect your personal data via online forms or via applications. We process this data in particular in order to respond to and execute your request as well as to administer and manage the customer relationship established with you (e.g. in the event of a change of address).
In addition, we process your personal data, as well as that of other people, within the limits authorized by law and to the extent that we deem appropriate, and this also for the following purposes for which we (and sometimes third parties) a legitimate interest consistent with these same purposes:
Propose and develop our offers, our services, our websites, our applications and other platforms on which we are present;
Communicate with third parties and process their requests (for example applications, requests from the media);
Control and optimize the needs analysis procedures for the purpose of a direct approach to the clientele as well as collect personal data from sources accessible to the public for commercial prospecting purposes;
Carry out advertising and marketing activities (including organizing events) insofar as you have not objected to the use of your data (when we send you advertising as a customer, you have the possibility of opposing it at any time; we will then put you on a blocking list allowing you to stop other advertising mailings);
Carrying out market studies and opinion polls, carrying out media monitoring;
Preventing criminal offenses and other reprehensible behavior and helping to elucidate it (for example, carrying out internal investigations or analyzing data with a view to combating fraud);
Ensure our operation, in particular concerning IT, our websites, our applications and other platforms;
Carry out surveillance operations to ensure the right of domicile and take any other measure relating to the security of data processing, buildings and installations as well as the protection of our employees or other persons and goods that belong to us or that have been entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone records);
Purchase and sell areas of activity, companies or parts of companies and other transactions under company law, as well as, within the framework of these operations, transmit personal data ;
Adopt measures for the conduct of operational activities and measures to ensure compliance with legal and regulatory obligations as well as internal regulations of our company.
When you have consented to the processing of your personal data for certain purposes (for example by registering to receive newsletters), we process your personal data in the context of and on the basis of this consent, to the extent that we have not other legal basis and that we are required to have such a basis. A given consent can be revoked at any time, this however having no effect on the data processing already carried out.
1.4 DIRECT MARKETING AND PROFILING
If you have consented to our use of your email address or other electronic means of communication for advertising purposes, we or our affiliated companies will periodically send you newsletters and other promotional information through the relevant channels in order to let you know about other offers and services. If you register, we may also use your personal data, including how you use our websites, applications and other digital channels, to personalize our advertising measures. Profiling is also carried out as part of product development and the optimization of our offer. This is done as part of our legitimate interest in improving the effectiveness of direct marketing,
Once you have subscribed to our services or have created an account, and you are one of our customers, we can then send you information on our current topics to your e-mail address and via other electronic means of communication, without the need for separate consent.
You can object at any time to the sending of such newsletters and advertising communications as well as to any processing, for this purpose, of your e-mail address and other electronic means of communication in the newsletter concerned: to unsubscribe , you can click on the link at the end of the newsletter or follow the instructions given at the end of the communication.
If you do not want this advertising communication to be personalized, you can also oppose it at any time (see figure 6).
1.5 TRANSMISSION OF PERSONAL DATA TO THIRD PARTIES AND ABROAD
In the course of our commercial activities and for the purposes set out in section 1.3, we also communicate, within the limits authorized by law and to the extent that seems appropriate, personal data to third parties, either because they process it for us, either because they want to use them for their own purposes. These include in particular the following entities:
Service providers appointed by us), including external service providers (for example IT providers);
Subcontractors and other business partners;
Service providers (e.g. insurance, banks, commercial enterprises);
Other companies, which may process them for the purposes indicated in section 1.3 or for their own purposes (in accordance with their specific privacy statement);
hereinafter collectively referred to as “recipients”. Some of these recipients are located in Switzerland, some may however be present in any other place in the world. In particular, you should expect your data to be transmitted to other European countries and to the United States, where there are service providers we use (eg Microsoft). When we transmit data in a country that does not have appropriate data protection legislation, we ensure, in accordance with the law, an adequate level of protection by the conclusion of suitable contracts (in particular on the basis of standard clauses of protection of data adopted by the European Commission, which can be consulted, or we rely on the exceptions provided by law, namely consent, performance of the contract, establishment, exercise or implementation of legal rights, overriding public interest, published personal data or because data processing is necessary in order to protect the integrity of the persons concerned. You can obtain a copy of the contractual guarantees mentioned above at any time at the address indicated in number 6, provided that they are not available by clicking on the link indicated above. However, for reasons inherent in the law governing data protection or for reasons of confidentiality, we reserve the right to hide certain passages on the copies or to provide only extracts. personal data published or because data processing is necessary in order to protect the integrity of the data subjects. You can obtain a copy of the contractual guarantees mentioned above at any time at the address indicated in number 6, provided that they are not available by clicking on the link indicated above. However, for reasons inherent in the law governing data protection or for reasons of confidentiality, we reserve the right to hide certain passages on the copies or to provide only extracts. personal data published or because data processing is necessary in order to protect the integrity of the data subjects. You can obtain a copy of the contractual guarantees mentioned above at any time at the address indicated in number 6, provided that they are not available by clicking on the link indicated above. However, for reasons inherent in the law governing data protection or for reasons of confidentiality, we reserve the right to hide certain passages on the copies or to provide only extracts. as long as they are not available by clicking on the link indicated above. However, for reasons inherent in the law governing data protection or for reasons of confidentiality, we reserve the right to hide certain passages on the copies or to provide only extracts. as long as they are not available by clicking on the link indicated above. However, for reasons inherent in the law governing data protection or for reasons of confidentiality, we reserve the right to hide certain passages on the copies or to provide only extracts.
Your data will not be transferred, transmitted or sold to third parties, except to the extent necessary for one of our services or when you have consented.
1.6 HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We process and store your personal data as long as necessary for the performance of our contractual and legal obligations or for the purposes pursued by the processing, that is to say in particular for the duration of the commercial relationship (first contacts, execution and termination of the contract) and ‘beyond, in accordance with the obligations of conservation and documentation provided for by law. As such, it is possible that personal data may be kept during the period during which rights are possibly invoked against our company, or to the extent that we are legally required to do so, or if legitimate commercial interests warrant it. require (eg for evidence and documentation). As soon as your personal data is no longer necessary for the aforementioned purposes, they will be systematically and as far as possible, deleted or anonymized. Generally speaking, shorter retention periods of twelve months or less apply to operational data (e.g. system logs, histories).,
1.7 DO YOU HAVE THE OBLIGATION TO TRANSMIT PERSONAL DATA TO US?
You have the option of using some of our websites, applications and other digital channels without having to register. Within the framework of our commercial relationship, you are required to transmit to us the personal data necessary for the registration and implementation of the commercial relationship as well as for the execution of the contractual obligations relating thereto (as a general rule , you have no legal obligation regarding the provision of data). Without this data, we are generally unable to conclude a contract with you (or with the entity or person you represent) or to process a mandate from you.
Likewise, the website cannot be used if certain information intended to ensure data transfer (eg IP address) is not communicated. Whether this data is still considered personal data is another matter.
1.8 COOKIES / TRACERS AND OTHER TECHNOLOGIES RELATED TO THE USE OF OUR WEBSITES
2. What data is collected?
When you contact us, data is collected from us and from third parties on our websites and in our applications by various technologies. We generally assign this data to that which we have already collected (e.g. user account), namely:
Usage data transmitted or collected automatically (e.g. date and time of use, previous page and page viewed, IP address, data relating to the browser used, identification of devices, temporary location, insofar as this information is shared , etc.); and
Interactive data, insofar as they are accessible without installing additional software on the computer (e.g. mouse movements and clicks, keyboard keys used on the website);
We collect and process this data in order to continually improve our products and services and to adapt them to your needs, identify trends, produce and analyze statistics on the use of our digital offers. This data is also used to provide you with a quality user experience. You have the option at any time to prevent the processing of non-personal data. For information on how to do this, please refer to figure 2.3 .
2.2 What technologies do we use and why?
Our websites generally use “cookies” and similar techniques to identify your browser or device. A cookie is a small file that is sent to your computer or that is automatically stored on your computer or on your mobile device by the web browser that you use when you visit our website. If you visit this website again, we will be able to recognize you even if we do not know who you are. In addition to cookies which are only used during a session and which are deleted after your visit to the website (“session cookies”), cookies can also be used to store for a specific period (eg two years ) user settings and other information (“permanent cookies”). You can however configure your browser so that it rejects cookies, only saves them for a single session or otherwise deletes them in advance. The settings of most browsers are predefined to accept cookies. We use permanent cookies in order to better understand how you use our offers and our content and in order to be able to display offers and advertisements tailored to your needs.
On our website, in our applications and on other digital channels, we sometimes use third-party elements and services that provide us with usage statistics that serve to display third-party advertising or allow the user access social networks and other third-party offers. These third parties are in particular Facebook , Twitter , Google (YouTube), NetMetrix and Optimizely. These third-party services, which can be located in any country in the world (in the case of Google, this is Google LLC in the United States, www.google.com), allow us to measure and evaluate (non-personal) use of the website. Permanent cookies, set up by the service provider, are also used for this purpose. The provider does not receive any personal data from us (and does not keep any IP address), it can however track your use of the website, cross-check this information with data from other websites that you have visited and which are also monitored by the provider, and use this information for their own purposes (for example monitoring advertising). Insofar as you have registered yourself with the service provider, the latter also knows you. The processing of your personal data by the service provider is then the responsibility of the latter, in accordance with its data protection provisions. The service provider simply informs us of the use of the website concerned belonging to us (and does not provide information concerning you personally).
In addition, we also use plug-ins associated with social networks such as Facebook, Twitter, YouTube, Pinterest or Instagram on our websites. When this is the case, these plug-ins are easily identifiable by the user (typically by the use of the corresponding symbols). The operators of the social networks concerned may register that you are on our website as well as where you are and may use this information for their own purposes. The processing of your personal data will then be the responsibility of this operator, in accordance with its data protection provisions. We do not receive any information about you from them.
To protect your privacy, we take into account the browser settings indicating that tracking is not desired and only work with third parties who also respect these settings (more information on this for Internet Explorer , Firefox , Chrome , Safari ). However, when you click on the link of an advertisement or other third-party offer, you leave our sphere of influence, and we are not able to control the data collected as a result. On this point, you must refer to the conditions of the third parties concerned.
3. What are your rights regarding your personal data?
Within the framework of the legislation in force on data protection and according to the extent which is envisaged there (for example in the case of the GDPR and, in part, also of the LPD), you have the right to obtain information (i.e. in particular the right to know free of charge whether we collect personal data about you and, if so, what data it is), the right to rectify your personal data (if personal data that we process are false), the right to the deletion of your personal data (if we have to delete the data stored with us), the right to limit the processing of your personal data and the right to object to their processing (by example if you want us to stop processing your data, in particular for direct marketing purposes),and the right to obtain certain personal data in order to transmit it to another entity (“data portability”).
However, please note that we reserve the right to invoke, for our part, the restrictions provided by law, for example when we are under an obligation to store or process certain data, when we have a preponderant interest (in to the extent that we can invoke it) or when necessary to exercise our rights. You will be informed in advance when fees apply.
Information has been provided regarding your ability to revoke your consent.
Please note, however, that the exercise of these rights may conflict with contractual agreements and that this may have consequences, for example the early termination of the contract or costs. In this case, we will inform you in advance when no contractual provision exists on this subject.
The exercise of such rights normally requires that you provide proof of your identity (eg by presenting a copy of your identity document when you cannot be authenticated or your identity cannot be verified by any other means) . To exercise your rights, you can contact us at the address indicated in number 6.
In addition, any data subject can assert their rights through the courts or lodge a complaint with the competent data protection authority.
4. Data security
We operate data networks and systems which meet the usual technical standards. We take appropriate technical and organizational measures to conscientiously protect your data against the risk of loss, destruction, falsification, manipulation or unauthorized access, in particular in the form of directives, training, IT solutions and related network security, access controls and restrictions, transmission encryption and other controls. However, the Internet is an open network accessible to all. Consequently, neither we nor our providers guarantee the confidentiality of data during their transfer via the Internet, as well as anonymity when using our websites, our applications and our other digital channels.
5. Who can you contact? Who is responsible ?
The processing of data as described in this declaration is the responsibility of Mr. Mohamed Ayachi Ajroudi.
6. Legal basis
This privacy statement is based on the EU General Data Protection Regulation (GDPR). Although the GDPR is a legal text of the European Union, it is important to us. Federal data protection law (LPD) is strongly influenced by European law, and companies located outside the European Union or the EEA are required to comply with the GDPR in certain circumstances.
7. Modification of this privacy statement
We are authorized to modify this declaration at any time and without prior notice. The current version, published on our website, cancels the previous ones. If the privacy statement is part of an agreement established with you, we will notify you of its modification in the event of an update, by e-mail or by any other appropriate means.