Our Privacy Notice
We will only process your Personal Data in accordance with applicable data protection and privacy laws. For the purposes of UK and EU data protection legislation, the data controller is Swissly sàrl Productions located at The Lausanne Guide, Avenue du Temple 19B, 1012 Lausanne.
Table of Contents
Information We Automatically Collect
Categories of Information
We and our third-party service providers (including any third-party content, advertising, and analytics providers) automatically collect certain information from your device or web browser when you interact with the Services to help us understand how our users use the Services and to target advertising to you (which we will refer to in this Privacy Notice collectively as “Usage Data”). For example, each time you visit the Services we and our third-party service providers automatically collect your location, IP address, mobile device identifier or other unique identifier, browser and computer type, Internet service provider used, clickstream information, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on the Services. We may contract with third parties to collect this information on our behalf for analytics purposes. These include companies such as Google.
Purposes For This Information
We and our third-party service providers use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.
We use tracking technologies, such as cookies.
Cookies and Local Storage
Our Services use the following types of cookies for the purposes set out below:
What types of cookies do we use ?
Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket and checkout securely.
Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit etc. These data help us understand and analyze how well the website performs and where it needs improvement.
Marketing: Our website displays advertisements. These cookies are used to personalize the advertisements that we show to you so that they are meaningful to you. These cookies also help us keep track of the efficiency of these ad campaigns.
The information stored in these cookies may also be used by the third-party ad providers to show you ads on other websites on the browser as well.
Functional: These are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing contents on the website on social media platforms.
Preferences: These cookies help us store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.
Information You Choose To Submit
You can visit the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual (which we will refer to in this Privacy Notice collectively as “Personal Data”). If, however, you wish to register to become a member of the Services, you are required to provide certain Personal Data (for example, your name and email address), and you must also provide a username and password. We use your Personal Data to fulfil your requests for products and services, to improve our Services, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Privacy Notice.
We refer collectively to all information we collect that is not Personal Data, including Usage Data, demographic data and de-identified Personal Data, as “Non-Personal Data”. If we combine Non-Personal Data with Personal Data, we will treat the combined information as Personal Data under this Privacy Notice.
Personal Data, Non-Personal Data, and User Submissions are referred to in this Privacy Notice collectively as “User Information.”
You may choose to enter contests, competitions, participate in surveys, subscribe to newsletters, comment articles, use message boards, chat rooms, reader photo upload areas, reader ratings and reviews, save articles or other content on our Sites, reader-created content upload areas, contact us and customer support areas. These Interactive Areas may require that you provide Personal Data corresponding with the activities. You understand and agree that the Interactive Areas are voluntary and that your providing Personal Data for those activities will be collected and used by us to identify and communicate with you. In certain circumstances, we may share that Personal Information with sponsors, advertisers, affiliates or other partners. If you have questions about a specific Interactive Area, please contact us and reference that specific Interactive Area.
In addition, you are required to provide certain Personal Data when you submit a job application and supporting materials. Where you submit a job application on behalf of another person, you confirm that you have made that person aware of how we collect, use and share their Personal Data, the reason you have provided it, how they can contact us, the terms of this Privacy Notice and related policies and that they have consented to such collection, use and sharing. You can also choose to submit or we may collect additional information about yourself, such as demographic information (for example your gender, birth date, or postal code) and information about your preferences and interests. Failure to provide any required Personal Data will prevent us from being able to provide the Services you request (e.g., member registration or submission of job application) or otherwise inhibit our ability to provide the Services.
Here are examples of User Information we may collect:
- 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 other information for authentication and account access.
- Demographic Data. We collect demographic information including your age, gender, and country.
- Content. We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use.
- Survey Data. We may also survey visitors about various topics, including events and experiences, media consumption preferences and how we can improve our Sites and services. Response to our surveys is entirely voluntary.
- Public Postings. We collect information when you submit something to be displayed on our Sites. Any communication you submit or that may be posted to a publicly viewable area of our Sites, such as a comment on an article or a review, is a public communication and may be viewed by the general public. Therefore, you acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to such areas via our Sites, whether or not your submission includes personal information. These submissions would include newsletter sign-ups and any area of our site that requires a login or registration prior to use. If at any time you display your personal information in any communication submitted to such areas, other individuals may collect and use your personal information. We are not responsible for, nor can we guarantee the protection of, any personal information you disclose in a communication submitted to such areas for posting or contained in an email or other communication submitted to us for such posting, and thus, you acknowledge that if you disclose personal information in any such material, you do so at your own risk.
Information We Receive From Other Sources
We supplement the information we collect with outside records in order to learn more about our users, to better tailor the content and offers we show you, and for other purposes. We receive this information about you from public sources or third parties, including without limitation consumer data resellers, social networks, and advertisers. We combine the information we receive from those other sources with information we collect through the Services. In those cases, we will apply this Privacy Notice to the combined information.
We use the information we collect, including Personal Data and Usage Data:
- To enable you to use our Services, to create an account or profile, to process information you provide via our Services (including verifying that your email address is active and valid) and to process your transactions.
- To provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys and processing survey responses.
- To provide you with information, products, or services that you have requested.
- For internal business purposes, such as to improve our Services and content.
- To administer and process contests, promotions, conferences and special events (collectively “Events”). Information collected through our Sites in conjunction with such Events is also used for marketing additional products, services and events by us and/or by our advertisers, sponsors, and marketing partners. Please see the rules of each individual Event and any applicable privacy policies for those Events for additional information on the choices you may exercise with respect to the use of your personal information collected in connection with that Event. To the extent there is a conflict between this Privacy Notice and the rules or policies applicable to an Event, the rules and policies associated with the Event shall govern.
- To comply with regulatory and legal obligations;.
- For purposes as disclosed at the time you provide your information and as further described in this Privacy Notice.
Social Network and Platform Integration
Our Information Sharing Practice
We share Non-Personal Data, including Usage Data, de-identified Personal Data and aggregated user statistics, with third parties in our discretion. Information collected via the Sites is shared among our affiliates. For example, we may share your information for customer support, marketing, and technical operations. We share User Information, including Personal Data, as otherwise described in this Policy, and under the following circumstances.
From time to time, we enter into relationships with third parties who provide services to us (for example, analytics and research companies, advertisers and ad agencies, data management and storage services, credit card processing services, merchandise sales facilitators, sweepstakes or contest prize fulfillment). We share your information with third parties for the purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Sites) and in connection with tailoring advertisements, measuring and improving our Sites and advertising effectiveness, and other enabling enhancements. We share aggregate information about our visitors with our advertisers, sponsors, and promotional partners, such as how many persons visited a particular page or activity, the average age of our visitors on the Site(s) or page(s), or the likes and dislikes of our visitors, but this information is not specific to any individual visitor. We obtain geographic information such as zip code clustering from other sources, but this aggregate information will not reveal the precise location of a specific visitor. We also obtain other demographic information from third parties to improve our products and services, for marketing purposes or to display more relevant advertising. In those circumstances, we disclose User Information so that such service providers perform those services. These service providers are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data. And our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which enable collection and sharing of your information (including Personal Data) with Google for further use. For specific information on Google usage and how to control it, please see How Google uses data when you use our partners’ sites or apps and Google’s Privacy Notice.
Our Events and promotions may be jointly managed, sponsored or offered by third parties. If you voluntarily choose to enter or attend an Event, we may share your information with third parties as set forth in the official rules that govern the Event as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a contest or sweepstakes Event, you agree to the official rules that govern that Event, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. Some events may be managed wholly by a third party and will be governed by any rules or terms they provide for that event and it is your responsibility to review and comply with those terms.
Third-Party Direct Marketing
Third Party Features
We offer our content on social networks such as a Facebook, Twitter, and Instagram. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Notice. Also, if you publicly reference our Sites on a third party service (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Service.
Change of Control
In the event we go through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of our assets, including, without limitation, during the course of any due diligence process), your Personal Data will likely be among the assets transferred. By providing your Personal Data, you agree that we can transfer such information in those circumstances without your further consent. Should such a business transition occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Notice with respect to your Personal Data. If your Personal Data would be used contrary to this Privacy Notice, we will request that you receive prior notice.
Other Disclosure Scenarios
We reserve the right, and you hereby expressly authorize us, to share User Information: (i) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (ii) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (iii) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (iv) to protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the general public; and (v) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Notice).
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third-party. We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data will include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name or other personal identifiers) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.
If you identify any User Information as public, you are authorizing us to share such information publicly. For example, you can elect to make certain of your User Submissions (such as your alias, bio, email or photos) publicly available. Also, there are areas of the Services (for example, message boards, discussion rooms, and other online forums) in which you are able to post information that automatically will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone can access, use, and disclose any information that you post to those areas.
You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to identify you in our database.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.
We may offer discounted prices to consumers who sign up to be on our mailing lists or join our loyalty programs. Such programs will have additional terms that require your review and agreement. Please review those terms for the details of those programs, how to withdraw or cancel, or to assert your rights specific to those programs.
We generally do not treat consumers differently. However, in certain circumstances, discounted prices will require you to be on our mailing list or a member of our loyalty program. In such circumstances, we may offer a price difference because the price is reasonably related to the value of your data. The value of your data will be explained in the terms of such incentivized programs.
We use other companies under agreements with us to serve third-party advertisements when you visit and use the Services. These companies collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one. In addition, we share with these third parties any personal information you voluntarily provide, such as an email address, in response to an advertisement or sponsored content link.
In order to serve offers and advertisements that may be of interest to our users, we display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected.
Choice/Opt-Out From Communications
We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third-party partners, users may elect to modify their preferences by following the “Communications Preferences” and/or “Unsubscribe” link provided in an email or communication received. You may also be able to change your preferences by updating your profile or account, depending on which of our Services you are using. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third-party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to the Services, service announcements, notices of changes to this Privacy Notice or other Services policies, and to contact you regarding any goods or services you have ordered.
Retaining, Modifying and Deleting Your Personal Data
You may request access to the information you have provided to us. If you wish to make a request, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us please log into your account to make the changes. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law, for necessary operational reasons, or to maintain uniform business practices.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such promotion). We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
EU Data Subject Rights
If you are a resident of the European Economic Area (EEA), you have the right to: (a) request access to your Personal Data and rectification of inaccurate Personal Data; (b) request erasure of your Personal Data; (c) request restrictions on the processing of your Personal Data; (d) object to processing your Personal Data; and/or (e) the right to data portability (collectively, “EU Requests”).
We can only process EU Requests from a user whose identity has been verified. To verify your identity, please provide your email address or [URL] when you make an EU Request. For more information about how to get access to Personal Data and for exercising your rights, you can submit a request by contacting us through email@example.com. You also have the right to lodge a complaint with a supervisory authority. To view additional information about behavioral advertising and manage your preferences, you can do so by visiting: http://www.youronlinechoices.eu/.
We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below.
The Services contain links to other websites that we do not control, and the Services contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third-party. We may also integrate with third parties who will interact with you under their terms of service. One such third party is YouTube. We use YouTube API Services and by using the Sites or Services, you agree to be bound by the YouTube Terms of Service located here.
The Services are intended for a general audience and are not intended for and should not be used by children under the age of 13. We do not knowingly collect information from children under the age of 16 and we do not target the Services to children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive Personal Data as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive Personal Data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Notice. If you do not consent to our processing and use of such sensitive Personal Data, you must not submit such content to our Services.
We update this Privacy Notice from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Data by posting a notice on relevant areas of the Services. We will also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Notice will be effective immediately upon the posting of the revised Privacy Notice unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Notice (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.
If you have any questions about this Privacy Notice, please feel free to contact us by email at: firstname.lastname@example.org