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Our Data Protection Policy

1. Data protection principles

Lyftonomie Sàrl is committed to processing data in accordance with its responsibilities under the GDPR and the Swiss Federal Act on Data Protection (FADP).

Article 5 of the GDPR requires that personal data shall be:

  • processed lawfully, fairly and in a transparent manner in relation to individuals;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

In addition, Article 4 of Swiss Privacy Law requires that:

  • Personal data may only be processed lawfully.
  • Its processing must be carried out in good faith and must be proportionate.
  • Personal data may only be processed for the purpose indicated at the time of collection, that is evident from the circumstances, or that is provided for by law.
  • The collection of personal data and in particular the purpose of its processing must be evident to the data subject.
  • If the consent of the data subject is required for the processing of personal data, such consent is valid only if given voluntarily on the provision of adequate information. Additionally, consent must be given expressly in the case of processing of sensitive personal data or personality profiles.

2. General provisions

  1. This policy applies to all personal data processed by Lyftonomie.
  2. This policy shall be reviewed at least annually

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, Lyftonomie shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.

4. Lawful purposes

  1. All data processed by Lyftonomie must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
  2. Lyftonomie shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Lyftonomie’s systems.

5. Data minimisation

  1. Lyftonomie shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. Lyftonomie will not communicate personal data to third parties except whereby it is necessary for the execution of its services, such as for payment processing or shipping.
  3. Lyftonomie will not sell personal data to third parties

6. Accuracy

  1. Lyftonomie shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
  3. Lyftonomie cannot be held liable for inaccuracies resulting from its systems being compromised

7. Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, Lyftonomie shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

  1. Lyftonomie shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. Appropriate back-up and disaster recovery solutions shall be in place.

9. Rights

  1. Individuals have a right of access(Art. GDPR 15), a right to rectification of incorrect data (Art. GDPR 16), a right to erasure (Art. GDPR 17), a right to the restriction of processing (Art. GDPR 18), and a right to data portability (Art. GDPR 20).
  2. You also have an individual right to objectto processing and a right to object to the use of your data for direct marketing purposes (Art. GDPR 21).
  3. You may also withdraw your consentto the processing of your personal data at any time, if we are processing your personal data on the basis of your consent (Art. GDPR 7). This withdrawal will apply only for the future.
  4. Finally, you are entitled to lodge a complaintwith the relevant authority responsible for the protection of personal data (Art. GDPR 77).

10. Provision of personal data

You need to provide us personal data if you wish to purchase a subscription or any product provided by Lyftonomie, this in order for us to meet our contractual and legal obligations. Without this data we cannot enter into a contract with you.

11. Cookies

We use cookies, pixels, and other technologies (collectively, « cookies ») to recognise your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:

  • Keeping track of your shopping basket.
  • Conducting research and diagnostics to improve our content, products, and services.
  • Preventing fraudulent activity.
  • Improving security.
  • Ensuring you are displayed content relevant to your geographic location and language.
  • Delivering content, including ads, relevant to your interests on third-party sites.
  • This allows us to measure and analyse the performance of our services.

Cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you might not be able to recover unsaved orders from your basket.

Approved third parties may also set cookies when you interact with Lyftonomie’s website. Third parties include search engines, providers of measurement and analytics services and social media networks.

You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

12. Your points of contact

Should you have any questions you can contact us on: privacy@lyftonomie.com

 

Last Reviewed: 16.07.2018