Valuart SAGL (hereinafter: “Valuart”)
Registered seat: Via delle Scuole, 3 | 6900 | Paradiso (Switzerland)
Websites: valuart.com and hadem.xyz
The contact details of the data protection officer of Valuart: firstname.lastname@example.org.
1. Personal data which is processed
● E-mail address and username.
● Name and surname
● Information about disputes/complaints.
Further data which may be processed through technological tools:
● Log files: IP addresses, browser type, type of device, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
● Pixel Tag: we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are very small graphic images with a unique identifier that are used to track online movements of Web users. Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
● Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our service. This includes third party analytics services, that we engage to help analyze how users use the Service. The information received from Analytics services is solely used to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at the address given above.
2. Purpose of the data processing
● The primary objective of the data processing is for Valuart to be able to provide you an efficient Service.
● We may use the contact details to notify you for security, fraud protection or support and maintenance updates.
● Customer support data is collected on a case-by-case basis and stored for the purpose of resolving disputes and service quality issues.
● If you have consented to it, we may send you our newsletter to keep you updated on the development of Valuart and the Services and marketing material subject to the conditions established below.
● In case you lodge a complaint through the Platforms or otherwise, we process the latter and run an investigation.
3. Legal Basis for the data processing
● Personal data is processed in order to provide the Service contracted with us. We collect and process the personal data submitted in the course of the use of our Service.
● Personal data may be also processed on the ground of legitimate interest, for example in investigating and detecting fraudulent behaviour.
● The legal basis for the data processing related to marketing purposes is the consent explicitly provided for by the passenger via the Platforms.
4. Recipients of the personal data
● Any processing of personal data by any third party will occur under the same conditions as established in this Privacy Notice.
5. Data processors, Security and Access
● We may use the platforms of our contractual partners to investigate and to respond to relevant complaints.
● Any personal data collected in the course of providing the services is transferred to and stored in the data center of Infomaniak, which is located in the territory of Switzerland.
● Only the authorized employees of Valuart, and the authorized employees of contractual partners, can access personal data, to the extent necessary to comply with requests of the users in connection with the Services.
● Geolocation data is processed in anonymised form.
● For research and scientific purposes, the data is used in unidentified form (anonymized).
6. Access, correction and restriction
● You can access and update your personal data via the Platforms.
● You can request information related to your personal data, in which case we will provide information in connection with the categories of personal data concerned, the purposes of the processing, the period for which the personal data is stored, your rights related to data processing and your rights to lodge a complaint with the supervisory Authority in charge (hereinafter: “Authority”).
● You are entitled to request the restriction of the processing of your personal data according to Article 18 of GDPR, also where we no longer need your personal data for the purpose of processing, but they are required by you for the establishment, exercise or defence of legal claims.
7. Retention of personal data
● Your personal data will be stored by Valuart as long as you have an active account. If your account is closed, personal data will be deleted (according to the policies set out in this section), unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
● In the event that there are suspicions of criminal offence, fraud or false information having been provided, the data will be stored for 10 years in order to hinder the renewed registration of the person who acted unlawfully.
● In case of payment disputes, personal data will be retained until the dispute has been resolved or until the statute of limitation of the claim has elapsed (in principle for 5 years).
● You should also bear in mind that any request to delete your personal data is handled by Valuart and possible only if your account is also deleted. As a result of that you will not be able to use our Services.
● We respond to any request to delete personal data submitted by e-mail within a month and will specify the period of data deletion.
● In case we are required to store personal data pursuant to a legal obligation, we will not be able to comply with your request for deletion.
● We will respond to any request for transfer of personal data submitted by e-mail within a month and specify when the data transfer will take place. After we have verified the customer in question, we will provide you with your personal data.
10. Direct marketing and sweepstakes
● We will only use your e-mail address to send direct marketing messages if you have given us the permission to do so via our Platforms.
● If you no longer wish to receive direct marketing messages, please click the “Unsubscribe” link in the footer of our e-mail or change the settings related to direct marketing in the Platforms.
● We may direct to you marketing campaigns that contain gifts, sweepstakes and other marketing or promotional materials of our partners; however, we do not transfer your personal data to the latter.
11. Dispute resolution and remedies
● Disputes relating to the processing of personal data are resolved through customer support (email@example.com) or by contacting Valuart’s Data Protection Officer (firstname.lastname@example.org).
● In case you believe that the data processing is unlawful, you are entitled to start the procedure before the competent National Authority. For users resident in the European Union, you can find the list and contacts of EU National Data Protection Authorities here.