PRIVACY AND COOKIES POLICY APPLICABLE TO WEBSITES AND SOCIAL MEDIA
Version dated June 1, 2024
1. PREAMBLE
This Privacy and Cookies Policy applicable to websites and social media (the “Privacy Policy”) describes how your information is processed in connection with the website <https://optimiso-group.com/> (the “Site” or “Website”) and with our pages available on social networks managed by troisdeuxun (“troisdeuxun”, “we”, “our”), whose registered office is located at Rue Louis-de-Savoie 47, 1110 Morges.
Please read this Privacy Policy carefully before using the Websites and our pages available on social networks. This Privacy Policy explains how information relating to an identified or identifiable person (“Personal Data”) is collected, used, and protected.
If you access our pages available on social networks, as well as other third-party websites from our Sites, the information you communicate will be subject to the privacy policy of the respective third party.
By browsing the Website, you acknowledge and accept the processing of your Personal Data as described in this Privacy Policy. If you do not accept that your Personal Data be processed in accordance with the terms of this Privacy Policy, please do not use the Websites or our pages available on social networks.
2. DATA CONTROLLER
Optimiso Group, located at Chemin JB Vandelle 8, 1290 Versoix Geneva, acts as the data controller for the processing of Personal Data collected via its websites and its dedicated social network pages.
3. GENERAL PRINCIPLES
3.1 Our websites and our pages available on social networks offer the following information and services:
(i) information related to our institution and its activities;
(ii) various means of contacting us;
(iii) the ability to create a user account;
(iv) links to third-party websites and the possibility to share content on social networks and other applications (such as via email).
3.2 This Privacy Policy does not apply to services offered offline.
4. PERSONAL DATA WE COLLECT AND THE PURPOSES OF COLLECTION
Sources of Collection
4.1. The Personal Data we collect through our websites and our pages available on social networks fall into two categories:
(i) Cookies (see Section B below);
(ii) Personal Data that you provide to us (see Section C below).
Cookies
What are Cookies and what information do they collect?
4.2. Cookies are files containing a small amount of data that are sent from a website to your browser and stored on your device (computer or mobile device). Other tracking technologies, such as beacons, tags, and scripts (“Similar Technologies”), may also be used to collect and track information and to improve and analyze our websites.
4.3. Through Cookies and Similar Technologies, we can collect Personal Data when you visit our websites or our pages available on social networks. We can specifically identify certain usage data when you browse or click on content.
4.4. The following information and Personal Data are collected through Cookies and Similar Technologies:
(i) the IP address of the device capable of connecting to the Internet and requesting the connection;
(ii) the date and time of connection;
(iii) location, if enabled on the device;
(iv) the resources you access on the websites;
(v) the name and URL of the consulted file;
(vi) the website/application from which the connection was made (referrer URL);
(vii) the browser you use and, if necessary, the operating system of your device capable of Internet access, as well as the name of your Internet service provider.
4.5. To control/limit the collection of this information, you can:
(i) if this functionality is available, configure your browser so that it refuses all Cookies and Similar Technologies or indicates when a Cookie or Similar Technology is used; or
(ii) delete Cookies and Similar Technologies and clean your browsing data directly from your browser settings.
If you do not accept certain Cookies or Similar Technologies, you may not be able to access certain features of our websites.
What purposes do we collect information through Cookies (purposes)?
4.6. We use Cookies and Similar Technologies that we collect to:
(i) allow access to our websites;
(ii) make certain features of our websites accessible and offer you additional functionalities;
(iii) improve the websites and our pages available on social networks;
(iv) ensure the security of the websites;
(v) create usage statistics of our websites to improve them.
Reasons for Processing
4.7. As for the Cookies and Similar Technologies necessary for the functioning and maintenance of our websites, the reason we justify the processing of your Personal Data is our predominant private interest in operating our sites and their functionalities.
4.8. As for Cookies and Similar Technologies used for statistical purposes related to our websites, the reason we justify the processing of your Personal Data is your consent, collected through the Cookie banner displayed on each of our sites.
Personal Data you provide to us
4.9. We collect Personal Data that you provide to us on a voluntary basis when, through our websites, you:
(i) fill out a form to contact us, such as the contact form or newsletter.
4.10. This Personal Data may include your name and surname, your email address, the Personal Data you choose to send us in the context of this account (such as your title, first and last name, postal address, telephone number, your email address, and your language preference).
What purposes do we collect these Personal Data (purposes)?
4.12. We use the Personal Data you provide us for the following purposes: (i) to allow you to participate in the interactive features of the websites when you wish;
Reasons for Processing
4.13. The reasons on which we justify the processing of your Personal Data are: your consent when you participate in the interactive features of the websites (for example, by registering for an event), a predominant private interest when we respond to your messages received through the contact form, you create an account.
5. PERSONAL DATA COLLECTED BY THIRD PARTIES (LINKS TO OTHER WEBSITES OR SOCIAL NETWORKS)
5.1. This Privacy Policy does not cover how your Personal Data is processed by third parties when we link to their websites. We encourage you to read the privacy policies of other websites you visit.
5.2. When you connect to a social network or another website, your browser directly connects to the server of the concerned service provider. Through this connection, the website receives the information that your browser accessed on the corresponding page of our websites or on our pages available on social networks. This information (including your IP address) is transmitted from your browser directly to the server of the service provider and stored there. If you interact with our pages available on social networks, for example by clicking the “Like” or “Share” icon, this information will also be transmitted directly to the server of the concerned social network provider and stored.
5.3. Please refer to the privacy policy of the relevant social network or website for any information related to the purpose and extent of the collection of Personal Data by the service provider, the subsequent processing and use of this Personal Data by the service provider, as well as the rights associated with it and the settings options to protect your Personal Data.
6. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
6.1. We may provide access to the Personal Data you have communicated to us through our websites or our pages available on social networks to certain independent contractors and affiliated companies to assist us in operating said websites or said pages. As of today, these contractors are:
(i) Website operation service provider <https://www.troisdeuxun.ch>: troisdeuxun Sàrl, located in Switzerland;
(ii) Website host <https://www.infomaniak.com/>: Infomaniak Group SA, located in Switzerland.
6.2. We take all necessary measures to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy and applicable legal rules. All our contractors are committed to protecting Personal Data using procedures similar to ours, unless otherwise specified in this Privacy Policy.
6.3. The purpose of sharing your Personal Data with the aforementioned third parties is to ensure our activity, as well as to maintain and continually seek to improve our websites and the services offered to our users. Thus, the justifying motive for this processing is our predominant private interests.
7. DISCLOSURE OF YOUR PERSONAL DATA TO AUTHORITIES
7.1. We may need to disclose your Personal Data (including your communications) if we believe it is necessary for security reasons, to investigate a potential offense or any other violation of this Privacy Policy and/or to prevent harm that could be caused to other users of our websites or our pages available on social networks. Therefore, we may need to disclose your Personal Data to investigate a complaint or dispute related to our websites or one of our pages available on a social network, respond to a complaint or dispute, or resolve them.
7.2. We may be required to disclose your Personal Data when the law requires it or when we believe in good faith that such disclosure is necessary to:
(i) investigate, prevent, or take action related to potential or actual illegal activities or to assist enforcement administrative authorities;
(ii) execute an agreement with you;
(iii) investigate and defend ourselves against any third-party claims or allegations;
(iv) protect the security and integrity of our websites or our pages available on social networks; or
(v) exercise and protect the rights and safety of our users, our employees, or others.
7.3. We attempt to notify users about third-party requests for their Personal Data when it seems appropriate from our perspective and when it appears technically feasible, subject to cases where the law or a decision by an authority prohibits us or when the request is urgent. We may challenge these requests when, at our sole discretion, we consider them too broadly formulated, vague, or unfounded, although we do not guarantee to challenge every request.
7.4. The purpose of sharing your Personal Data with the aforementioned authorities is to comply with a legal obligation to which we are subject.
8. NO DISCLOSURE OF YOUR PERSONAL DATA FOR COMMERCIAL PURPOSES
8.1. We do not sell your Personal Data to third parties. We do not share or make your Personal Data available to third parties, except as otherwise provided in this Privacy Policy.
9. CROSS-BORDER TRANSFER OF PERSONAL DATA
9.1. If, due to services provided by third parties, we are required to transfer your Personal Data to one of their databases outside the European Economic Area and/or Switzerland, potentially to a state that does not offer a level of personal data protection comparable to that in Switzerland or the European Economic Area, unless otherwise provided in this Privacy Policy, we commit to concluding an agreement with the third-party service provider to ensure an adequate level of protection of your Personal Data.
10. PROTECTION OF YOUR PERSONAL DATA AND NOTIFICATION OF A DATA BREACH
10.1. We commit to implementing all commercially reasonable means to prevent any exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (including administrative, physical, and technical) to manage cases of unauthorized disclosures or exposures of your Personal Data.
10.2. In the event of a confirmed or suspected Personal Data breach, we commit to
(i) making our best efforts to notify you without delay, when technically feasible, and
(ii) cooperating with you to investigate and resolve the breach, including, but not limited to, providing reasonable assistance in notifying affected third parties. We commit to giving you access, without delay and within the limits of a reasonable request, to our records relating to the breach of your Personal Data, provided that this does not give you access to records that would belong to other users or could compromise their security.
10.3. In the event of a confirmed or suspected Personal Data breach, we commit to notifying the relevant authority in accordance with applicable law.
11. MANAGEMENT OF YOUR PERSONAL DATA (YOUR RIGHTS)
11.1. Right to access, update, and delete Personal Data concerning you: Where possible, you can access, update, or request the deletion of your Personal Data by contacting us via the contact form, or by emailing us at: [email protected].
11.2. Right to rectification: You have the right to have your Personal Data rectified if it is inaccurate or incomplete.
11.3. Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.
11.4. Right to restrict processing: Within the limits of the law, you have the right to obtain a restriction on the processing of your Personal Data.
11.5. Right to data portability: You have the right to receive a copy of your Personal Data in a structured, commonly used, and machine-readable format.
11.6. Right to withdraw consent: Within the limits of the law, you have the right to withdraw your consent at any time when the processing of your Personal Data is based on it. However, it should be noted that such withdrawal: (i) does not affect the lawfulness of any processing carried out prior to this withdrawal based on your consent; and (ii) may result in you no longer being able to use certain features of the Websites or our pages on social networks.
11.7. Right to complain to an authority: You have the right to complain to any competent authority about the collection and use of your Personal Data.
11.8. We may ask you to prove your identity before responding to a request based on the aforementioned rights or otherwise related to your Personal Data.
12. RETENTION OF YOUR PERSONAL DATA
12.1. We retain the Personal Data you transmit to us as required for the access and use of our websites and our pages available on social networks, as well as the functionalities on them (such as our contact forms), and as necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve disputes, or to enforce the agreements we have entered into and our internal regulations.
12.2. The retention period for Cookies and Similar Technologies depends on their purpose and is always the same regardless of the person concerned.
12.3. We reserve the right to retain data in a depersonalized (i.e., anonymous) form after the deletion of your Personal Data.
13. SECURITY OF YOUR PERSONAL DATA
13.1. We place great importance on the security of your Personal Data. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable technical and organizational means to protect your Personal Data, we cannot guarantee its absolute security.
14. PERSONAL DATA RELATING TO CHILDREN
14.1. We do not provide services specifically targeted at children through our websites and do not proactively collect Personal Data related to them.
15. CHANGES TO THIS PRIVACY POLICY
15.1. We may modify this Privacy Policy at any time by posting a new version on this page or a deeper page without prior notice. In this case, you will be notified by a notification on the homepage of our websites. By continuing to access or use our websites or our pages available on social networks after the entry into force of this modification, you acknowledge and agree to the processing of your Personal Data in accordance with the revised Privacy Policy. If you do not accept these changes, please do not use our websites and our pages available on social networks.
15.2. We commit to always processing your Personal Data in accordance with the Privacy Policy in force at the time of the collection of such Data.
15.3. The new version of the Privacy Policy takes effect on the day of its publication, the date mentioned at the top of this Privacy Policy corresponding to the date of entry into force.
16. QUESTIONS?
16.1. Please do not hesitate to contact us via the contact form or by email at [email protected] if you have any questions related to this Privacy Policy.
16.2. You can also contact us by mail at the following address: Optimiso Group, Chemin JB Vandelle 8, 1290 Versoix Geneva.
