Last updated [October 18, 2018]
Thank you for choosing to be part of our community at Deon Digital AG (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Information collected from other Sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook, LinkedIn and Twitter), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
How do we use your information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “Your Privacy Rights” below).
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To post testimonials. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites.
To protect our Sites. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
Will your information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We only share and disclose your information in the following situations:
Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
With your Consent. We may disclose your personal information for any other purpose with your consent.
Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly distributed outside the Sites in perpetuity.
Is your information transferred internationally?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Switzerland. If you are accessing our Sites from outside Switzerland, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “Disclosure of Your Information” above) in other countries.
Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
What is our stance on third-party websites?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
Do we collect information from minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
What are your privacy rights?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
access your personal data and certain other supplementary information that this Privacy Notice is already designed to address;
require us to correct any mistakes in your information which we hold;
require the deletion of personal data concerning you in certain situations;
receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
effects concerning you or similarly significantly affecting you;
object in certain other situations to our continued processing of your personal data; and
otherwise restrict our processing of your personal data in certain circumstances.
If you would like to exercise any of these rights, please:
contact us using our contact details below;
provide us with enough information to identify you;
provide us with proof of your identity and address; and
indicate to which information your request relates.
We hope that we can resolve any query or concern you raise about the use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union or European Economic Area state where you work, normally live or where any alleged infringement of data protection laws occurred. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
You may at any time review or change the information in your account or terminate your account by:
Logging into your account settings and updating your account
Contacting us using the contact information provided below
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by contacting us using the contact information provided below.
Do we make updates to this policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
How can you contact us about this policy?
If you have questions or comments about this policy, email us at email@example.com or by post to:
Deon Digital AG