By accessing our website, you are likely to provide us with data such as: your name and surname (physical person), business name (legal person), residence and home address or your postal address, your home office, your e-mail address, your profession and professional status (employee or self-employed), your function within your company, your age and gender, and the IP address from which you connected to the Internet.
These data and their processing are protected by the Swiss Federal Law on Data Protection of June 19, 1992 (LPD) and, to the extent applicable, by the new General Data Protection Regulation (GDPR)entered into force on May 25, 2018.
Data protection is a key concern for us. This privacy statement is intended to help you understand how we may use the data you provide to us as a user of our site.
2. LEGAL BASIS
Last update: 25th of May 2018
4. OUR SITE URL
Any information relating to an identified or identifiable natural person (data subject). In particular by reference to an identifier such as the name, the first name or the address, the email, the telephone number, etc.
CMS is the acronym for Content Management System. This is the system for managing the content displayed on a website.
Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
A cookie is a text file that the site you are visiting stores on the hard disk or in the browser memory of the computer that you use to access the internet. A cookie allows your computer to store various technical data allowing the general control of public access to a site (number of visits, duration of the visit, connection to other sites, etc.) or the customisation of the displayed pages for your next interactions with the same site (your account, the most visited pages, etc.)
Privacy Impact Assessment (PIA)
A PIA is a detailed study to establish the risk to privacy that a personal data processing could have on the privacy of the data subject should an incident occur.
Purpose of processing
The purpose of processing is the reason why the data is collected.
A plugin or plug-in is a computer program designed to add functionality to other software (called host software). For example, the buttons of social networks. Equivalent terms; "Plug-in", "Add in", "Add on".
Any natural person subject to a processing of personal data.
The controller is the natural person or legal person on whose behalf the treatment is carried out. It determines alone or jointly the purposes of the treatment.
The processor is any natural or legal person, public authority, service or other body that processes personal data on behalf of the controller. For example, a web host or an online service provider.
Tag or HTML tags are the basic elements of the HTML coding of a web page. They are invisible to the user (except by activating the display of the source code). They are interpreted by the browser for the composition of the page. They allow the formatting and structuring of content and some are specifically taken into account by the algorithms of search engines for setting the score of the page on a query and the return of results.
Any transaction or set of transactions involving personal data, whether or not performed using automated processes, including the collection, recording, organisation, retention, adaptation, modification extraction, consultation, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection and limitation, erasure or destruction.
6. PROCESSING YOUR DATA
We only process data that you choose to transmit to us and for which you explicitly consent to the treatment.
Through our website, you can fill out a contact form. The following personal data will be requested:
· Last name
· First Name
· Phone number
You have the opportunity to write a message related to your contact request. We recommend that you remain concise in your message and not provide us with any personal information.
You can also choose to receive our newsletter by ticking the option provided for this purpose. You will then receive a request for consent by email which will clearly indicate the purposes of processing your personal data that you can accept or refuse selectively.
If you have subscribed to our newsletter and do not wish to receive it anymore, you can unsubscribe by clicking on the "unsubscribe" link at the bottom of the newsletter. By doing so, you will receive an automatic confirmation of unsubscription and your data will be automatically deleted from the file provided for this purpose.
7. PURPOSES OF TREATMENT
We treat your data only in order to best meet your expectations. By collecting some of your personal data, two purposes stand out:
1. Operational purposes
· Respond to requests for contacts or information
· Establishment of an offer(s)
2. Marketing purposes
· Sending newsletters
· Sending commercial offers
8. DURATION OF CONSERVATION OF PERSONAL DATA
Your data is stored in our systems for the time necessary for the intended treatment. After processing, the data is archived and anonymized or destroyed.
9. TRANSFER OF YOUR DATA
To process your data, as well as for the maintenance and support of our IT systems, we use subcontractors (service providers) based in Switzerland and abroad.
When the servers of our subcontractors are located abroad we ensure that they are located in a state whose data protection legislation is equivalent to the FADP and the GDPR and that our subcontractors apply organizational and technical measures consistent with the FADP and the GDPR.
We draw your attention to the fact that the servers of our subcontractors, processors may be located in states whose legislation does not include data protection rules appropriate or equivalent to the LPD or the GDPR.
If this is the case, we ensure that our subcontractors, processors, provide data protection safeguards and that they apply equivalent or GDPR-compliant standards, regardless of the geolocation of their servers.
10. DATA PROTECTION MEASURES
We strive to maintain a high level of security in the collection, processing and retention of data by relying on organisational and technical measures and taking the necessary precautions regarding the nature of the personal data that you are likely to communicate to us and the risks presented by their treatment in order to preserve its security and prevent such that they are altered, damaged, destroyed or that unauthorised third parties have access to it.
11. COOKIES & PLUGINS
Our web site uses plugins and cookies that may automatically record information. Their use aims to make the use of the site more pleasant by improving its ergonomics from the data collected.
This data can also be used for statistical measurement, user behavior analysis and geolocation analysis, in order to personalize our commercial offer.
When you browse our site, the computer you use will interact with a server that provides all the requested resources by automatically saving each operation to a specific file in which the computer used is identified by its IP address. This is how the browser that you use gives us some standard data, including the browser used and its features, the operating system of the computer, tablet or smartphone used, third-party sites (Facebook, Linkedin etc.) from which you may have logged in as well as the dates and times of access to our site.
This data and in particular the IP address from which you logged in do not allow us to identify you by name.
Marketing analysis and targeting plugins
The provider will use this information for the purpose of evaluating your use of the site, compiling reports on website activity and providing other services relating to website activity and internet usage. The supplier is likely to communicate this data to third parties in case of legal obligation or when these third parties process these data for their own account, including in particular the publisher of the site.
Our site uses the following analytics and advertising services:
· Smartlook de Smartsupp.com, s.r.o
· Google Tag Manager de Google Inc.
· Google Maps de Google Inc.
Plugins of social networks
Our website uses social plugins ("plugins"). These plugins are marked with logos.
If you open a page of our website containing one of these plugins, your Internet browser then establishes a direct link with the servers of the social network concerned. The content of the plugin is directly transmitted by the social network concerned to your Internet browser and integrated into the web page by it.
Thanks to the inclusion of cookies on the pages of our site, the social network concerned is informed that you have consulted one or more pages of our website. If you are connected to a social network when you visit our site, it is able to attribute your visit to our site to your account at home. If you interact with plugins, eg. By clicking on the "Like" button or by entering a comment, the corresponding information is sent directly by your Internet browser to the social network and saved on their servers.
The following social plugins are installed on our site:
· Plus.google.com de Google Inc.
· Facebook.com de Facebook Inc.
· Linkedin.com de Linkedin Corporation
· Twitter.com de Twitter Inc.
12. MEANS YOU HAVE TO CONTROL YOUR TRACES
· You have the option to disable plugins and cookies via the console provided for this purpose. This is accessible through the cookies banner that appears on the bottom of the home page when you visit our website. To customise or disable plugins and cookies, select the "customise" button.
· Recent versions of the main browsers allow not only to oppose the registration of cookies but also to perform browsing sessions at the end of which all cookies installed during this session are automatically deleted regardless of their lifespan provided, thus providing better protection for traces.
13. YOUR RIGHTS
Right of information
You have the right to be informed about your personal data, including the nature of the data and the purpose of the processing.
Right to access data
You have the right to request access to your data at any time.
Right to rectify data
You have the right to request the correction or updating of your data.
Right to data erasure (Right to be forgotten)
Under the GDPR EU nationals can request the complete and definitive erasure of their data. In order to apply the measures that are most favorable to you, we extend this right to Swiss residents.
Right of limitation of data processing
You have the right to limit the processing of your data, particularly as regards the nature, purpose and duration of processing.
Right to portability of data (transmitted to a third party on your instruction)
Under the GDPR, EU nationals have the right to request that their data be passed on to third parties. In order to apply the measures that are most favorable to you, we extend this right to Swiss residents.
Right to oppose data processing
You have the right to oppose at any time the processing of your data.
Right not to be subject to an automated individual decision
You have the right not to be subject to a decision resulting exclusively from automated processing that has legal effects that affect you or affect you significantly. Profiling is expressly included.
14. EXERCISE YOUR RIGHTS & INFORMATION
You can exercise your rights or request information by contacting us via the email address email@example.com or by post to the address below. We will do what is necessary to answer you as soon as possible.
Data controller: xxxx
Address: Al Moudira Hotel
Luxor West Bank, Hager Al Dabbeya