Data Protection Policy.
We attach great importance to the protection of personal data. How personal data is processed by using the website wickipartners.ch resp. wickipartners.com is described hereinafter.
This Data Protection Policy describes the collection and further processing of personal data by Wicki Partners Ltd. unless the activities covered by this policy are governed by other data protection policies, are evident from the circumstances, or are governed by applicable laws The term personal data shall include all information relating to an identified or identifiable person.
1 Data Controller
The Data Controller in accordance with the Swiss Data Protection Regulations of the website wickipartners.ch and wickipartners.com (hereinafter "Website") shall be Wicki Partners Ltd., Stockerstrasse 44, CH-8002 Zurich, Switzerland ("WPA").
2 Processing of personal data
WPA collects and processes personal data of (together "Customers"):
users of the Website (i.e. visitors, account holders etc.);
recipients of WPA newsletters.
The personal data of Customers is generally collected directly by WPA while using the Website. Personal data can also be collected indirectly through third-party processors (e.g., social media, credit checks etc.).
In particular, the following categories of personal data are processed by WPA (together "Customer Data"):
Personal data including but not limited to company name, salutation, first and last name, address, telephone number, email address;
Data in connection with communication, including but not limited to information relating to newsletter and other communication channels, communication preferences, correspondence and communication with WPA (including records of the communication);
Data concerning the use of the Website including but not limited to the IP address and other user identification (e.g. user name of social media, MAC address of devices, cookies, beacons, etc.), date and time of Website visits, visited sites and contents, and referring websites.
Any access to the Website is logged, therefore WPA collects any data regarding the usage and customer journey of and through the Website which cannot be deactivated by the user of the Website.
3 Purpose of processing and legal grounds
3.1 Purpose of data processing
In particular, but not limited to, and in accordance with the applicable law, WPA may process personal Data for the following Purposes (together the "Purpose of Data Processing"):
In connection with communication, advertisement and marketing (including newsletters and mailings);
management of the users of the Website and other activities, operation, maintaining and developing the Website (including the provision of functions which require identifiers or other personal data) and additional IT systems and identity verifications;
compliance with legal and regulatory requirements, including the internal rules of WPA, enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities;
for other lawful purposes where such processing was evident from the circumstances or indicated at the time of the collection.
3.2 Legal grounds of Data processing
WPA uses the personal data for the Purpose of Data Processing based on the following legal grounds:
performance of contracts;
compliance with legal obligations of WPA;
consent of Customer (can be withdrawn at any time);
legitimate interests of WPA, including but not limited to
purchase and rendering of services;
advertising and marketing activities;
efficient and effective improvement of existing services and development of new products and services;
maintenance and security, efficiency of business and development, the Website and IT systems;
reasonable corporate governance and development;
prevention of fraud, offences and crimes as well as related investigations, handling of claims and actions against WPA, legal proceedings, cooperation with public authorities, legal actions.
4 Transfer and Disclosure of Data
In accordance with applicable data protection laws, WPA may transfer personal data, to the following categories of commissioned data processors (together "Commissioned Data Processors"):
suppliers and other business partners;
local, national and foreign authorities;
acquirers or parties interested in acquiring business units, companies or other parts of WPA;
other parties in potential or actual legal proceedings.
WPA may disclose personal data to Commissioned Data Processors and to any country worldwide, including namely all countries in which WPA is represented by Group companies, affiliates or other offices and representatives as well as to countries in which service providers of WPA process their data. If data is disclosed to countries without an adequate protection, WPA shall ensure such (e.g. by EU standard clauses, binding corporate rules, EU-U.S. and/or the Swiss-U.S. Privacy Shield Framework).
5 Data Retention
In general, WPA retains personal data for no longer than it is necessary for the purposes for which the personal data are processed. Notwithstanding the general principle, WPA may process personal data for longer periods subject to the following rules and obligations: WPA retains personal data as long as WPA (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements). Deviating rules are reserved with respect to anonymization or pseudonymization of personal data subject to applicable law.
6 Cookies, Tracking and Social Plug-Ins
WPA uses session cookies that are automatically deleted when the Website is closed and that enable the server to establish a stable connection to the user (e.g. for not losing the content of the shopping cart) while the user is using the Website. WPA also uses permanent cookies that are only deleted after a per Website specified time.
Permanent cookies are used to remember the preferences of the user on the Website and remain on the user's device even after the browser is closed or the device is restarted. WPA uses these cookies to analyze user behavior and to determine visit patterns so that the Website functionality can be improved for all users.
Cookies do not cause any damage and do not contain any viruses. If the user nevertheless does not wish cookies to be set, browser settings can be changed that cookies are only created or generally rejected with the consent of the user.
Please note, however, that if cookies are not allowed or rejected on the Website, some functionalities may be restricted or unavailable.
WPA is entitled to install a code in transactional emails, newsletters and other marketing emails to determine whether the recipient has opened an email or downloaded images contained in the email. However, the recipient can block this application in his or her email program. In any case, the recipient agrees to the use of this technology by receiving newsletters and other marketing e-mails.
6.2 Analytic Tools (Google Tag Manager and Google Analytics)
7 Rights of the customers, visitors and partners
Any affected individual may request information from WPA if data concerning them is being processed. In addition, any affected individual has the right to request the correction, deletion or restriction of its own personal data as well as to object to the processing of its own personal data per se. Should the processing of personal data be based on consent, the affected individual may withdraw such consent at any time. If an account is deleted, all related data and information will be deleted entirely, including any and all pictures.
Request shall be submitted to: Wicki Partners Ltd., Stockerstrasse 44, CH-8002 Zurich, firstname.lastname@example.org.
WPA reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.
In the event that WPA makes an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect him or her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with WPA and to request a reconsideration of the decision or to request the prior evaluation by WPA. In such case, the affected individual may no longer be able to use certain automated products and services. The individual will be informed thereof subsequently or separately in advance.
Any affected individual may also raise a complaint with the competent data protection authority, which in the case of a WPA is the Federal Data Protection and Information Commissioner in Switzerland (https://www.edoeb.admin.ch/edoeb/en/home.html) or the respective data protection authority in the user's country of residence.
8 Changes to this Data Protection Policy
WPA reserves the right to amend this Data Privacy Notice at any time and without prior notice or announcement. The latest version posted on the Website shall be applicable.
Version v1 (06-2019)