XY SA and its controlled companies (hereinafter “XY”) understands that your privacy is important to you and that you care about how your Personal Data is used. XY respect and value the privacy of everyone who visits this website, www.xy.net (hereinafter “Site”), and will only collect and use Personal Data in ways that are described here, and in a way that is consistent with XY obligations and your rights under the law.
Definitions and interpretation
In this Policy the following terms shall have the following meanings:
|"Cookie"||means a small text file placed on your computer or device by the Site when you visit certain parts of the Site and/or when you use certain features of the Site.|
|"Personal Data"||is defined by the “GDPR” (General Data Protection Regulation - EU Regulation 2016/679) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.|
Information about the owner
The Site is owned and operated by XY SA, a Swiss based company.
Registered address: Bahnhofstrasse 88, Zurich.
Data Protection Officer: Lorenzo Fabrizio Maccarrone (firstname.lastname@example.org).
What does this policy cover?
What is Personal Data?
Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What are my rights?
Under the GDPR, you have the following rights, which XY will always work to uphold:
- The right to access the Personal Data XY holds about you.
- The right to have your Personal Data rectified if any of your Personal Data held by XY is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask XY to delete or otherwise dispose of any of your Personal Data that XY has. Please contact XY using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your Personal Data.
- The right to object to XY using your Personal Data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided Personal Data to XY directly, XY is using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask XY for a copy of that Personal Data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about XY use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What data does XY collect?
Depending upon your use of the Site, XY may collect some or all of the following personal and non-Personal Data:
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on the Site, and the site you exit to.
How does XY use my Personal Data?
Under the GDPR, XY must always have a lawful basis for using Personal Data. This may be because the data is necessary for the performance of a contract with you, because you have consented to the use of your Personal Data, or because it is in XY legitimate business interests to use it. Your Personal Data may be used for one or more of the following purposes:
- Providing and managing your access to the Site;
- Personalising and tailoring your experience on the Site;
- Improving the user experience and the Site in general.
Third Parties whose content appears on the Site may use third-party Cookies, as detailed below. Please note that XY does not control the activities of such third parties, nor the data that they collect and use themselves, and XY advises you to check the privacy policies of any such third parties.
XY uses the following automated systems for carrying out certain kinds of automated decision-making and profiling. If at any point you wish to query any action that XY takes on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact XY to find out more.
- The following automated decision-making method(s) may be used:
- Language selection based on browser language.
- The following automated profiling may take place:
How long will you keep my Personal Data?
XY will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for a maximum of 5 years.
How and where do you store or transfer my Personal Data?
XY may store or transfer some or all of your Personal Data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that XY will take additional steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the EEA and under the GDPR as follows.
XY shares your data within the group of companies of which XY is a part. Where this involves the transfer of Personal Data outside the EEA, XY group ensures that Personal Data is protected by requiring all companies within the group to follow the same rules with respect to Personal Data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
The security of your Personal Data is essential to XY, and to protect your data, XY takes a number of important measures, including the following: Encryption, DLP, Firewall, Network Segmentation, Intrusion detection systems, …
Do you share my Personal Data?
XY may share your Personal Data with other companies in XY group for special projects. This includes subsidiaries and sister companies.
XY may sometimes contract with the following third parties to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your Personal Data that XY holds: Google Analytics, located in the US.
If any of your Personal Data is required by a third party, as described above, XY will take steps to ensure that your Personal Data is handled safely, securely, and in accordance with your rights, XY obligations, and the third party’s obligations under the law.
If any Personal Data is transferred outside of the EEA, XY will take suitable steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the Switzerland and under the GDPR.
In some limited circumstances, XY may be legally required to share certain Personal Data, which might include yours, if XY is involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Can I withhold information?
How can I access my Personal Data?
If you want to know what Personal Data XY has about you, you can ask XY for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover XY’s administrative costs in responding.
XY will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, XY aims to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date XY receives your request. You will be kept fully informed of the progress.
The Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling XY to better understand how the Site is used. This, in turn, enables XY to improve the Site.
The analytics services used by the Site use the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||Third||Google Analytics||Used to distinguish users.|
|_gid||Third||Google Analytics||Used to distinguish users.|
|_gat||Third||Google Analytics||Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_
|AMP_TOKEN||Third||Google Analytics||Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.|
||Third||Google Analytics||Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out.|
In addition to the controls that XY provides, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How do I contact you?
To contact XY about anything to do with your Personal Data and data protection, including to make a subject access request, please use the following details:
- email@example.com (Data Protection Officer)
- Bahnhofstrasse 88, 8001 Zurich, Switzerland
- Phone: +41 (0)91 261 4500
XY may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if XY changes its business in a way that affects Personal Data protection.