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Art. 1 Preamble and acceptance
Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time, provided that such withdrawal :
- does not call into question the lawfulness of any processing carried out prior to such withdrawal and based on your consent;
- may result in you no longer being able to make use of certain features of the Website or our social network pages.
Art. 2 Data Controller
If you have any questions, please do not hesitate to contact us via the Contact Form available on the Website. We will be happy to answer them.
Art. 3 General Principles
Our Website and social network pages contain the following information and enable us to provide the following services:
- (i) information relating to our company and the services offered by it,
- (ii) online sales of our products,
- (iii) different ways of getting in touch with us (contact form, subscription to our newsletter, etc.),
- (iv) links to other websites and other pages on social networks.
Art. 4 Personnal data that we collect and the purposes for which it is collected
A. SOURCES OF COLLECTION
The Personal Data that we collect through our Website and our pages available on social networks can be divided into two categories:
- (i) Cookies (infra B.)
- (ii) Personal Data that you transmit to us (infra C.),
What are Cookies and what information do they collect?
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 analyse our Website.
- (i) the IP address of the device that can connect to the Internet and request the connection,
- (ii) the date and time of the connection
- (iii) the location, if enabled on the device
- (iv) the resources you access on the Website,
- (v) the name and URL of the file accessed,
- (vi) the website/application from which the connection was made (referring URL),
- (vii) the browser you are using and, if necessary, the operating system of your Internet-enabled device, as well as the name of your service provider.
In order to control/limit the collection of this information, you can :
- (i) if this feature is available, configure your browser to refuse all Cookies and similar Technologies or to indicate when a Cookie or similar Technology is being used,
- (ii) deleting Cookies and similar Technologies and cleaning 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 Website.
List of Cookies and Similar Technologies that we use :
For what purpose do we collect information using Cookies (Purpose)?
- (i) enable access to our Website,
- (ii) to make certain features of our Website accessible and to provide you with additional functionality,
- (iv) store information about your preferences, enabling us to customise our Website in accordance with your personal interests,
- (v) speed up your searches,
- (vi) ensure the security of the Website,
- (vii) anonymously collect statistical information about the use of the Website, in particular to measure the audience and usage patterns.
>li>(iii) improve the Website and our pages available on social networks,
Reason for processing
With regard to Cookies and similar Technologies for the operation, maintenance and security of our Website, the reason for which we justify the processing of your Personal Data is article 13 al. 1 LPD, which authorises us to process Personal Data when such processing is necessary for the purposes of our legitimate interests.
With regard to Cookies and similar Technologies for statistical, analytical or marketing purposes in connection with our Website, the reason for which we justify the processing of your Personal Data is article 13 al. 1 and 2 LPD, which authorises us to process Personal Data. This processing is based on the consent of the owner of the Personal Data.
C. PERSONAL DATA THAT YOU COMMUNICATE TO US
What Personal Data do you communicate to us?
We collect Personal Data that you provide to us on a voluntary basis, when, through our Website, you :
- (i) fill in a form enabling you to contact us (contact form, subscription to our newsletter, etc.),
- (ii) place an order on our online shop.
This Personal Data may concern your first and last name, title, telephone number, email address, postal address, delivery address, birthday, shopping basket.
For what purpose do we collect these Personal Data (Purpose)?
We use the Personal Data that you provide to us for the following purposes:
- (i) to enable you to participate in the interactive features of the Website when you wish to do so,
- (ii) to provide the service you want and for which you have provided us with the Personal Data.
Reason for processing
The ground on which we justify the processing of your Personal Data is article 13 al. 1 LPD, which authorises us to process Personal Data when the person concerned has given his consent to the processing of his Personal Data.
Art. 5 Personal data collected by third parties (links to other websites or social media)
Our Website and our pages available on social networks may contain links that take you to social networks such as Instagram, Facebook, YouTube and LinkedIn (the “Social Network“), as well as to other websites, in order to enable you to access the content available on these platforms. When you access the Social Network or another website through our Website or any of our pages available on a social network, it is the responsibility of the relevant service provider to comply with applicable data protection requirements.
When you establish a connection to a Social Network or Website, your browser connects directly to the server of the relevant Service Provider. Through this connection, the Social Network or Website receives the information that your browser has accessed on the relevant page of our Website or on our page available through a social network, even if you do not have an account with the Social Network or if you are not logged in to the Social Network. This information (including your IP address) is transmitted from your browser directly to the service provider’s server and stored there. If you are logged in to your account with the relevant Social Network, Social Network may immediately link your visit to our Website or social network page to your account. If you interact with our Website or social network page, for example by clicking on the “Like” or “Share” icon, this information will also be transmitted directly to the Social Network service provider’s server and stored there.
Art. 6 Disclosure of your personal data to this parties
We may provide access to the Personal Data that you have provided to us through our Website or our social networking pages to certain independent contractors and affiliated companies to assist us in the operation of the Website or social networking pages. To date, these contractors are as follows:
- (i)Fournisseur de service IT: Superhuit Sàrl, Rue Mercerie 1, CH-1003 Lausanne
- (ii)Hébergeur des données informatiques : Infomankiak Network SA, CH-1127 Genève
The purpose of sharing your Personal Data with the aforementioned third parties is to ensure our business, as well as to maintain and seek to constantly improve our Website and the services offered to our users. The grounds on which we justify the processing of your Personal Data is article 13 al. 1 and 2 LPD, which authorises us to process Personal Data when such processing is necessary for the purposes of our legitimate interests.
Art. 7 Communication of your personal data to the authorities
We may be required to disclose your Personal Information when required to do so by law or when we have a good faith belief that such disclosure is necessary to :
- (i) investigate, prevent or take action in relation to potential or actual illegal activities or to assist administrative enforcement authorities,
- (ii) to execute an agreement between us and you,
- (iii) to investigate and defend against a complaint or allegation from third parties,
- (iv) protect the security and integrity of our Website or our social networking pages, or
- (v) exercise and protect the rights and safety of our users, employees or others.
We attempt to notify users of third party requests for their Personal Data when we believe it is appropriate and technically feasible to do so, except where we are prohibited from doing so by law or an order of authority or where the request is urgent. We may challenge such requests when, in our sole discretion, we consider that the request is formulated too broadly, is too vague or is unfounded, but we do not guarantee to challenge any request.
The purpose of sharing your Personal Data with the aforementioned authorities is to meet our obligation under article 13 al. 1 LPD, which authorises us to process Personal Data when such processing is necessary to comply with a legal obligation to which we are subject.
Art. 8 No communication of your personal data for commercial purposes
Art. 9 Cross-border disclosure of personal data
Art. 10 Protection fo your personal data and notification of a data breach
We undertake to use 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 measures) to deal with unauthorised disclosure or exposure of your Personal Data.
In the event of an actual or suspected breach of Personal Data, we will (i) use our best efforts to notify you promptly, where technically feasible, and (ii) cooperate with you to investigate and resolve the breach, including, but not limited to, providing you with reasonable assistance in notifying affected third parties. We undertake to provide you with access, without delay and upon reasonable request, to our records relating to the breach of your Personal Data, provided, however, that this does not give you access to records that belong to other users or that could compromise their security.
In the event of an actual or suspected breach of Personal Data, we undertake to notify the relevant authority under applicable law.
Art. 11 Management of your personal data (your rights)
Right to access, update and delete your Personal Data: To the extent possible, you may access, update or request the deletion of your Personal Data by contacting us through the Contact Form.
Right of rectification: You have the right to obtain the rectification of your Personal Data if it is inaccurate or incomplete.
Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.
Right to limit the processing : Within the limits of the law, you have the right to obtain a limitation of the processing of your Personal Data.
Right to portability of Personal Data: You have the right to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format.
Right to Withdrawal of 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 relies on it.
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.
We may ask you to prove your identity before responding to a request based on the above rights or otherwise related to your Personal Data.
Art. 12 Retention of your personal data
We retain the Personal Data you provide to us to the extent required to access and use our Website and our social network pages and the features on them (such as our contact or newsletter registration forms), as well as to the extent required to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce agreements we have entered into and our internal regulations.
The length of time we retain Cookies depends on their purpose and is always the same regardless of who the Personal Data relates to.
We reserve the right to store the data in a depersonalised (i.e. anonymous) form after deletion of your Personal Data.
Art. 13 Security of your personal data
We attach great importance to the security of your Personal Data. However, no method of communication over the Internet or method of electronic storage guarantees 100% security. Therefore, although we strive to use commercially acceptable technical and organisational means to protect your Personal Data, we cannot guarantee its absolute security.
Art. 14 Personal data relating to children
We do not provide services specifically targeted at children and we do not proactively collect Personal Information from children.
Art. 16 Miscellaneous
Art. 17 Questions?
You may also contact us by post at Lavey Product SA, c/o Les Bains de Lavey S.A, Route des Bains 48, 1892 Lavey-les-Bains.
Version of February 8th, 2021