Owner and Data Controller
Limited Liability Company «A Swiss Group AG»
4 Weinberglistrasse, CH-6005,
Lucerne
Switzerland
Owner contact email:
office@a-swiss.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties,
there are: email address; Usage Data; first name; last name; country; Tracker; various types of Data;
profession.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this
privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically
when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide
this Data may make it impossible for this Application to provide its services. In cases where this
Application specifically states that some Data is not mandatory, Users are free not to communicate this
Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party
services used
by this Application serves the purpose of providing the Service required by the User, in addition to any
other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this
Application and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification,
or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational
procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some
cases, the Data may be
accessible to certain types of persons in charge, involved with the operation of this Application
(administration, sales, marketing, legal, system administration) or external parties (such as
third-party technical service providers, mail carriers, hosting providers, IT companies, communications
agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties
may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the
Owner may be allowed to process Personal Data until the User objects to such processing (“opt-
out”), without having to rely on consent or any other of the following legal bases. This, however,
does not apply, whenever the processing of Personal Data is subject to European data protection law;
- Provision of Data is necessary for the performance of an agreement with the User and/or for any
pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which the Owner is subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of
official authority vested in the Owner;
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a
third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties
involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country
other than their own. To find out more about the place of processing of such transferred Data, Users can
check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the
European Union or to any international organization governed by public international law or set up by
two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard
their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this
document or inquire with the Owner using the information provided in the contact section.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and
the User shall be retained until such contract has been fully performed.
-
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as
long as needed to fulfill such purposes. Users may find specific information regarding the
legitimate interests pursued by the Owner within the relevant sections of this document or by
contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent
to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the
right to erasure, the right to rectification and the right to data portability cannot be enforced after
expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its
legal obligations, respond to enforcement requests, protect its rights and interests (or those of its
Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Platform services and hosting and Registration and authentication.
For specific information about the Personal Data used for each purpose, the User may refer to the
section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic
and can be used to keep track of User behavior.
Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland
Limited, depending on the location this Application is accessed from, (“Google”). Google
utilizes the Data collected to track and examine the use of this Application, to prepare
reports on its activities and share them with other Google services. Google may use the Data
collected to contextualize and personalize the ads of its own advertising network. Personal
Data processed: Cookies; Usage Data.
-
Platform services and hosting
These services have the purpose of hosting and running key components of this Application,
therefore allowing the provision of this Application from within a unified platform. Such
platforms provide a wide range of tools to the Owner – e.g. analytics, user registration,
commenting, database management, e-commerce, payment processing – that imply the collection
and handling of Personal Data. Some of these services work through geographically
distributed servers, making it difficult to determine the actual location where the Personal
Data are stored.
-
Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give
them access to dedicated services. Depending on what is described below, third parties may
provide registration and authentication services. In this case, this Application will be
able to access some Data, stored by these third-party
services, for registration or identification purposes. Some of the services listed below may
also collect Personal Data for targeting and profiling purposes; to find out more, please
refer to the description of each service.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may
learn more on how to generally opt out of interest-based advertising within the dedicated section of
the Cookie Policy.
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users
have the right to do the following:
-
Withdraw their consent at any time. Users have the right to withdraw consent where they
have previously given their consent to the processing of their Personal Data
-
Object to processing of their Data. Users have the right to object to the processing of
their
Data if the processing is carried out on a legal basis other than consent. Further details are
provided in the dedicated section below.
-
Access their Data. Users have the right to learn if Data is being processed by the
Owner,
obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data
undergoing processing.
-
Access their Data. Users have the right to learn if Data is being processed by the Owner,
obtain
disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing
processing.
-
Verify and seek rectification. Users have the right to verify the accuracy of their Data
and ask for it to be updated or corrected.
-
Restrict the processing of their Data. Users have the right, under certain circumstances,
to
restrict the processing of their Data. In this case, the Owner will not process their Data for
any purpose other than storing it.
-
Restrict the processing of their Data. Users have the right, under certain circumstances,
to
restrict the processing of their Data. In this case, the Owner will not process their Data for
any purpose other than storing it.
-
Have their Personal Data deleted or otherwise removed. Users have the right, under
certain circumstances, to obtain the erasure of their Data from the Owner.
-
Receive their Data and have it transferred to another controller. Users have the right to
receive their Data in a structured, commonly used and machine-readable format and, if
technically feasible, to have it transmitted to another controller without any hindrance. This
provision is applicable provided that the Data is processed by automated means and that the
processing is based on the User's consent, on a contract which the User is part of or on
pre-contractual obligations thereof.
-
Lodge a complaint. Users have the right to bring a claim before their competent data
protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested
in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to
such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes,
they can object to that processing at any time without providing any justification. To learn, whether
the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant
sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in
this document. These requests can be exercised free of charge and will be addressed by the Owner as
early as possible and always within one month.
Cookie Policy
This Application uses Trackers. To learn more, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Application or the related Services. The User
declares to be aware that the Owner may be required to reveal personal data upon request of public
authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User
with additional and contextual information concerning particular Services or the collection and
processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files
that record interaction with this Application (System logs) use other Personal Data (such as the IP
Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at
any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests. To determine whether any of the third-party
services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on
this page and possibly within this Application and/or - as far as technically and legally feasible -
sending a notice to Users via any contact information available to the Owner. It is strongly recommended
to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner
shall collect new consent from the User, where required.
Updated on December 20, 2022
