RoomPriceGenie's Privacy Policy

1. Introduction

We recognize the importance of your privacy and of transparency in our processing of your personal data.

At RoomPriceGenie AG (we, our or RoomPriceGenie), we recognize the importance of your privacy and of transparency in our processing of your personal data. This privacy notice (Privacy Notice) informs you on the personal data we collect and process in connection with the provision of our solution accessible at https://roompricegenie.com/ (the Solution) and/or the services provided through the Solution (together with the Solution, our Services).

By accessing and using our Services, you expressly acknowledge that we may collect and process your personal data in accordance with this Privacy Notice.

This Privacy Notice is incorporated into and forms an integral part of our terms of use for the Solution (ToU). All capitalized terms not defined in this document have the meaning given to them in the ToU.

 

2. Summary

The following is a brief summary of (but not a replacement for) this Privacy Notice:

  • RoomPriceGenie AG is responsible for the processing, as controller, of your personal data. This Privacy Notice, however, only applies to our activities, and not to those of third-party providers (even if we link to their services or contents) (see section 3);
  • As part of our operation of the Services, we may collect personal data which is provided to us by you, your Organization, third parties, or which we collect automatically when you interact with the Services (see section 4);
  • We process such personal data in compliance with Swiss law and other laws applicable to us, mainly for the purpose of providing our Services and to operate the Solution, in accordance with the contract between us and your Organization. We act as a processor for your Organization, or in some cases, as a controller for our legitimate business operations related to providing those Services. We may also process your personal data to communicate with you, send you our newsletter, analyze and improve the use of our Services, comply with our legal obligations, and for the other legitimate purposes indicated in this Privacy Notice (see section 7, as well as sections 5 and 6);
  • This Privacy Notice does not address how your Organization collects and uses your personal data or how we process your data when we act as processor for your Organization. You must refer to your Organization’s privacy policy for information about its processing activities (see section 8);
  • Your personal data is stored in Switzerland and/or in the E.U. We do not share it with third parties or transfer it abroad unless this is both necessary for the operation of our Services and permitted by applicable laws. This may for instance be the case when we use service providers or must interact with third parties to conduct our professional activities. However, some information on the Solution is available publicly or to other users, worldwide (see sections 8 and 10);
  • We do not store your personal data for longer than necessary for us to fulfill the purposes set out in this Privacy Notice (see section 11);
  • We apply security measures and strive to protect your personal data. However, no IT infrastructure is completely secure, and we cannot guarantee that ours is (see section 12);
  • You may contact us ([email protected]) to exercise your rights pertaining to your personal data (see sections 14 and 15).

 

3. Who is responsible for the processing of your personal data?

RoomPriceGenie AG, Sumpfstrasse 18, 6312 Steinhausen, Switzerland, is responsible for the processing, as controller, of your personal data. You will find our contact details below in Section 13.

This Privacy Notice only applies to processing undertaken by or on behalf of us. Whilst we may provide links to third party websites, contents, or services, we are not responsible for their policies in relation to personal data. In such circumstances, the collection and use of your personal data are governed by the privacy policy of those third-party providers, which you should carefully review to learn more about their personal data processing practices.

As further detailed in this Privacy Notice, we may process your personal data in connection with the professional Services we provide to your employer, respectively the organization to which you are affiliated in any other way (each an Organization). This Privacy Notice does not govern how your Organization process your personal data through the Services. You must refer to your Organization’s policies.

Please see section 8 below for additional information in this respect.

 

4. How we collect your personal data

We collect the personal data that you or your Organization provide to us.

We collect the personal data that you or our customers provide to us when using our Services, for example when you use our App, communicate with us, when you create and/or manage your account, through web forms you fill, or when you subscribe to our newsletter.

You are only authorized to provide us with personal data related to you directly, unless you obtain the prior consent of the other individual about whom you want to share information.

Some information is mandatory, and some is optional.

It is mandatory that you complete the data fields identified by an asterisk. If one or more mandatory data fields are not completed, we will not be able to provide access to our Services. You are not required to complete the optional data fields in order to access our Services. These fields may be completed at any time through your account settings.

Some information about you may also be provided to us directly by our users

Even if you are not a user of our Services, we may collect certain information about you if this is provided to us by one of our users. Such information may include your property details and other information that may be given to us, such as your name.

Certain personal data are also collected in an automated manner.

We also automatically collect personal data, including by means of tools, web forms, cookies, and other active elements, as further described in this Privacy Notice.

You may define certain authorizations relating to the automatic collection of your personal data when you configure your device or your internet browser according to available functionalities. You may also define certain settings for the automated collection of your personal data through the cookies setting plugin available on the Solution. For more detailed information, please see the cookie section below (section 13).

 

5. How we process your personal data

We process your personal data by automated means for the purposes indicated in this Privacy Notice and in accordance with applicable law.

We process your personal data in compliance with applicable law, in particular Swiss data protection laws and, to the extent they apply to us, other data protection legislations, such as the EU General Data Protection Regulation (GDPR) or its equivalent in the United Kingdom, using computers or computer tools, in line with the purposes set out in this Privacy Notice.

We do not process your personal data to create a profile about you (profiling).

We also do not make decisions exclusively based on an automated processing which have legal effects on the data subjects or affect them significantly (automated individual decision).

We may combine your personal data with other information (aggregate) or erase any information that allows us to identify you (anonymize), so that it is no longer considered personal data under applicable data protection law, in which case this Privacy Notice will no longer apply and we may use such data for purposes not contemplated by this Privacy Notice (e.g. for benchmarking or analytics purposes, or to develop and market new services). You may object to the anonymization or aggregation of your personal data for this purpose at any time (see section 14 below for additional information on your rights).

We take the technical and organizational appropriate security measures to prevent unauthorized access, disclosure, modification, alteration, or destruction of your personal data, as specified in Section 12 below.

 

6. On which legal ground do we process your personal data

We process your personal data only if we have a valid legal ground to do so.

We will only process your personal data if we have a valid legal ground for doing so. Unless we must process your personal data as controller for one of the reasons listed below, we will process your personal data as data processor for the provision of our Services to our customers (see section 8)

Depending on the processing activity carried out, we will therefore only process your personal data if:

  • The processing is necessary to fulfil our contractual obligations to you or to take pre-contractual steps at your request (Contractual Necessity);
    • This is the case when processing your personal data is strictly required to provide you with the Services, as further specified in section 7 below. When the GDPR applies, Contractual Necessity is based on Article 6(1)(b) GDPR;
  • The processing is necessary for the fulfilment of our legitimate interests, and only to the extent that your interests or fundamental rights and freedoms do not require us to refrain from processing (Legitimate Interest);
    • Our Legitimate Interests include in particular (i) ensuring that our Services are provided in an efficient and secure way (e.g. through internal analysis of the Services’ stability and security, updates and troubleshooting, as well as support services); (ii) improving and developing the Services (including monitoring the use of our Services, and for statistical purposes); (iii) benefiting from cost-effective services (e.g. we may opt to use certain services offered by suppliers rather than undertaking the activity ourselves); and (iv) achieving our corporate goals. When the GDPR applies, Legitimate Interest is based on Article 6(1)(f) GDPR;
  • We have obtained your prior consent in a clear and unambiguous manner (Consent);
    • When the GDPR applies, Consent is based on Article 6(1)(a) GDPR;
  • The processing is necessary to comply with our legal or regulatory obligations (Legal Obligation);
    • Finally, we will process your personal data if we are required by law to do so, as further specified in section 7 below. When the GDPR applies, Legal Obligation is based on Article 6(1)(c) GDPR.

If you are not a customer or user of our Services, but your personal data is provided to us by our users, we will process your personal data as data processor for the providing of our Services to our users. In this case, our processing of your personal data is governed by a contract between us and the relevant users. This Privacy Notice does not address how our users uses your personal data. Please refer to the user who has provided us with your data and contact it directly for any inquiry relating to the use of your personal data by it.

 

7. Purposes for which we process your personal data

We process your personal data for legitimate and clearly identified purposes:

Your personal data is collected and processed for the purpose of operating the Services and for the other legitimate purposes explicitly specified below, only to the extent relevant to achieve these purposes, and is not further processed in a manner that is incompatible with them.

We process your personal data for the following purposes:

To operate the Solution and provide the related Services.

If you are a user of the Solution, we mainly process your personal data to provide the Solution and the Services, based on our Contractual Necessity to do so, including for creating and maintaining a user account, interacting with you and other users, providing you with the requested information and Services, making the Services available on the Solution, as well as for customer and user management purposes.

If you are not a user, we will process your personal data if it is provided to us by one of our users, for instance due to your position in an organization to which a user is affiliated (Organization). In this case, we process your personal data for the purpose of providing the Solution and the Services to your Organization, based on a contract between us and your Organization. This Privacy Notice does not govern how your Organization processes your personal data or how we process your data for the account of your Organization (e.g. to carry out the analysis requested by your Organization). Please refer to your Organization’s policies and contact your Organization directly for any inquiry relating to the use of your personal data by it.

In addition to the personal data which you or your Organization provide when logging-in to your account or interacting with the Solution, we automatically collect technical information about your interactions with the Solution, such as IP address, the content that was accessed, date and time of access, information about your web browser, your preferences, or other information related to your interaction with the Solution, including your navigation details on the Solution. We process this data [to establish a connection with your device over the internet, to identify you when you use the Solution, control the use of the Solution and manage its stability and security, based on our Legitimate Interest to do so.

Your account information is retained for as long as your account is active. If you suppress your user account, your account information can be deleted on request.

To contact you and respond to your queries.

You have the option of contacting us via the Solution, by email, telephone, or post. In this context, we process the data which you provide to us (including your contact information and the subject-matter of the request). This data is used for the purpose of providing you with the requested information and services, based on our Contractual Necessity.

The retention period depends on the reason for your request and its context.

To send you our newsletter and other advertising information.

If you subscribe to our newsletter, we will collect your contact details (name and email address) and use it to provide you with our newsletter, based on your Consent. You may unsubscribe from the newsletter service at any time, in which case your contact details will be deleted.

We also process the time of registration and your opt-in confirmation based on our Legal Obligation to demonstrate compliance. We also analyze your use of our newsletter, e.g. whether you have opened it or clicked on certain links, and process this data to optimize and improve our newsletter, based on our Legitimate Interest.

We use the third-party services of Hubspot to provide our newsletter service, which will have access to your login data in order to provide you with the service. The privacy policy of Hubspot is applicable in connection with this, which you will find here.

Independently from your subscription to our newsletter, we may also contact you by email to inform you about our activities if you have previously subscribed for the use of our Services, if you have not objected to the corresponding use of your email address. You can object to the use of your email address for this purpose at any time by contacting us (see contact detail in section 15). The legal basis for the corresponding processing of your data is our Legitimate Interest to advertise certain activities relating to our previous interactions with you.

For internal analysis and statistical purposes in order to improve our Services.

Unless you object to such processing, we may process your personal data, in particular data relating to your use of our Services and your habits and preferences (e.g. the content you accessed, date and time of access and your preferences), for internal analysis and statistical purposes, in order to better understand the needs of our users, to optimize their experience, and in general to improve the ergonomics and functionality of our Services. You may object to such processing activities at any time (see section 14 below for additional information on your rights).

You will find additional information in section 13 in relation to the use of cookies for this purpose, including on the duration for which data collected this way are stored. Data collected by other means is deleted or anonymized at the latest one year after its collection.

To provide you with targeted information or advertisements based on the content you published and your interactions with the Solution.

Provided we have collected your valid Consent, we use as part of our operation of the Solution the services of third parties, such as Hubspot, Appcues (RoomPriceGenie App only) or Google Analytics, which may place cookies on your device in order to provide you with personalized advertisements based on your interaction with the Solution. The privacy policies of those providers are applicable in relation to their activities. You may withdraw your consent at any time (see section 14 below for additional information on your rights).

You will find additional information in section 13 in relation to the use of cookies for this purpose, including on the duration for which data collected this way are stored, and the link to the privacy policies of those external service providers.

To comply with our other Legal Obligations or for other Legitimate Interests.

We may further process your personal data if we have a Legal Obligation to do so or for other Legitimate Interests. This will for instance be the case if we need to disclose certain information to public authorities or retain such information for tax or accounting purposes, or for the establishment, exercise or defense of legal claims.

The personal data that we process for this purpose are those that we collected for one of the purposes indicated elsewhere in this section 7. We retain the personal data for the duration of the legal obligation imposed on us.
If we have obtained your consent.

In addition to the above, we may process your personal data if we have obtained your prior unambiguous consent for specific purposes. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

 

8. Our Operations with Your Organization

If you are an end user of a Service we provide to your Organization, or if we process for any other reason your personal data on behalf of your Organization (for instance, if you are not a user, but your personal data is provided to us by your Organization), please read the following:

  • In the situations described above, our processing of your personal data is governed by a contract between us and your Organization. We will process your personal data as data processor for the providing of our Services to your Organization which is our customer, or in some cases, as a controller for our legitimate business operations related to providing those Services, as detailed in this Privacy Notice.
  • This Privacy Notice does not address how your Organization collects and uses your personal data or how we process your data when we act as processor for your Organization. Please refer to your Organization’s privacy policy for information about its processing activities.
  • Some information about you may be provided to us directly by your Organization. If this is the case, it is your Organization which is responsible for ensuring that your personal data is collected and transferred to us in accordance with all privacy and data protection laws of all relevant jurisdictions, based on an appropriate legal ground.
  • If you would like to make any requests or queries regarding our processing of your personal data on behalf of your Organization, please contact your Organization directly. For example, if you wish to request to access, correct, amend, or delete inaccurate personal data that was originally transmitted by your Organization, please direct your query to your Organization. If we are requested by your Organization to remove your personal data, we will respond to such request in a timely manner upon verification and in accordance with applicable law (for example, 30 days under Swiss law or the GDPR).
  • If you have questions about our legitimate business operations in connection with providing Services to your Organization, please contact us as described in section 15.

 

9. The circumstances in which we share your personal data with third parties

We may share your personal data with third parties if this is necessary for the operation of our Services, if there is a legal obligation or permission to do so, or if there is another valid reason to do so.

We may share your personal data with third parties in connection with the operation of the Services and with subcontractors such as IT service providers, cloud service providers, database providers, automated marketing solutions providers and consultants, including Amazon Web Services (Server hosting), Hubspot (CRM), Google Analyics, Chargbee (Payment), Stripe (Payment), Appcues (In-app Walk-throughs) and the integrated Property Management System or Channel Manager.

We may share your personal data with your Organization to enable it to manage the Services

If you use a Service provided by an Organization you are affiliated with, we share certain data, such as interaction data and diagnostic data to enable your Organization to manage the Services.

Some information is accessible to other users or the public

Your personal data may also be made available to other users of the Services or to third parties to the extent necessary for the proper operation and provision of the Services, for example for the purpose of enabling users to interact.

We may also disclose your personal data to third parties where we have a legal obligation to do so or a legitimate interest in doing so.

We may also disclose your personal data where we have a legitimate interest in doing so, for example (i) to respond to a request from a judicial authority or in accordance with a legal obligation; (ii) to bring or defend against a claim or lawsuit; or (iii) in the context of restructuring, if we transfer our assets to another company.

 

10. International Transfers

Your personal data is stored in Germany but may in certain circumstances be disclosed in other countries.

We store your personal data on servers located in Switzerland and/or the European Union.

In principle, we do not transfer your personal data to other countries or make it available there. However, in certain circumstances, in particular in connection with the operations of our subcontractors, your personal data may be made available to recipients located abroad (analytics companies based in the US such as AWS, Google Analytics, Hubspot, Strip, Chargebee and Appcues, as well as the location/country of your Property Management System or Channel Manager provider). In such cases, we will ensure that suitable safeguards are in place, in accordance with applicable data protection laws, for instance by relying on standard contractual clauses adopted by the European Commission.

Moreover, the information accessible to the public or to other users on the Solution may be accessed worldwide.

If you transmit information and data to us, you are expressly deemed to consent to such data transfers. You may request additional information in this regard and obtain a copy of the relevant safeguards upon request by sending a request to the contact address indicated in section 15 below.

 

11. How long do we store your personal data?

Your personal data will not be stored longer than necessary.

We will erase or anonymize personal data as soon as it is no longer necessary for us to fulfil the purposes set out in section 7 of this Privacy Notice. This period varies, depending on the type of data concerned and the applicable legal requirements. More information on each type of processing can be found in section 7 above.

Your account information is retained for as long as your account is active. If you suppress your user account, your account information can be deleted upon request.

In view of the legal obligations incumbent upon us, certain information relating in particular to the contractual relationship must be retained for at least 10 years.

 

12. Security

We maintain physical, technical and procedural safeguards to keep secure your personal data.

We are committed to the security of your personal data, and have in place physical, administrative and technical measures designed to keep secure your personal data and to prevent unauthorized access to it. We restrict access to your personal data to those persons who need to know it for the purpose described in this Privacy Notice. In addition, we use standard security protocols and mechanisms to exchange the transmission of sensitive data.

Although we take appropriate steps to protect your personal data, no IT infrastructure is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.

The internet is a global environment. As a result, by sending information to us electronically, such data may be transferred internationally over the internet depending upon your location. Internet is not a secure environment and this Privacy Notice applies to our use of your personal data once it is under our control only. Given the inherent nature of the internet, all internet transmissions are done at your own risk.

If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication (including by posting a notice on the Solution).

 

13. How we use cookies or other analytical tools

We use Cookies, other analytical tools and similar technologies in connection with the Solution.

We use various types of cookies, other analytical tools, or similar technologies (collectively, Cookies) in connection with our Solution, some of which are capable of automatically processing data on your electronic device and/or of transferring personal data about you to us or third parties.

These technologies are generally used to monitor and analyze your interactions with the Solution and/or to enable us to improve the Solution and its functionalities, including customizing the Solution and related services, depending on your interactions. We may also use Cookies to measure and monitor the traffic and use of the Solution and its performance.

Cookies are generally divided in four categories:

A. Essential Cookies. Some cookies are placed on your electronic devices to make the Solution capable of being used, by providing basic features such as page browsing and accessing secure areas. The Solution cannot function properly without this type of Cookies.

B. Functionality Cookies. Some Cookies enable the Solution to remember choices persons make, for example, username, and language or text size. These cookies are known as “functionality cookies” and help to improve a person’s experience of the Solution by providing a more personalized service.

C. Advertising Cookies. These cookies are used to better understand user interests and to display more relevant advertisements.

D. Analytics/productivity Cookies. Analytics/productivity Cookies, such as those linked to Google Analytics, help understand how users interact with the Solution by anonymously collecting and reporting information.

Our use of cookies may vary depending on the section or functionalities of the Solution you access, but we generally use the following:

Name Owner Purpose / Decription Duration and expiry Type
HubSpotutk
Track visitors Identity. Passed to HubSpot on form submission and when used deduplicating contacts
12 months
Analytics
_hssc
Used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp.
30 mins
Functionality
__hssrc
Whenever HubSpot changes the session cookie, this cookie is also set. HubSpot sets it to the value “1”, and uses it to determine if the user has restarted their browser. If this cookie does not exist when HubSpot manages cookies, they assume it is a new session.
Session
Functionality
__hs_testcookie
Used to test whether the visitor has support for cookies enabled
Session
Necessary
hsPagesViewedThisSession
Used to keep track of page views in a session.
Session
Necessary
_gcl_au
Used by Google Analytics to understand user interaction with the Solution. https://policies.google.com/privacy
90 days
Analytics
_ga
Used to compute visitor, session, campaign data and to keep track of the use of the Solution for Solution analysis reporting. It stores a number generated randomly to identify unique visitors https://policies.google.com/privacy
1 year
Analytics
_gid
Used to store information about the use of a website by visitors and creates an analytical report on the functioning of the website. It stores the number of visitors, their source and the page visited in pseudonymized form. https://policies.google.com/privacy
1 day
Analytics
_gat_UA-126103277-1
Attribute Cookie. Contains the unique identification number of the account or website to which it relates. This is a variant of the gat_cookie which is used to limit the amount of data stored by Google on high traffic websites. https://policies.google.com/privacy
1 minute
Analytics
_fbp, fbclid
Tracks users coming from facebook or facebook ads, to understand how they interact with the website, and to build target audiences for advertisements in Linkedin.
180 days
Analytics
li_at
Tracks users coming from Linkedin or Linkedin ads, to understand how they interact with the website, and to build target audiences for advertisements in Linkedin (for full list see here: https://www.linkedin.com/legal/l/cookie-table).
1 year
Analytics
_cef
Helps to detect ad fraud from google and facebook ads
Session
Analytics

Cookies in the RoomPriceGenie App (not on the website):

Name Owner Purpose / Decription Duration and expiry Type
HubSpotutk
Track visitors Identity. Passed to HubSpot on form submission and when used deduplicating contacts
12 months
Analytics
_hssc
Used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp.
30 mins
Functionality
__hssrc
Whenever HubSpot changes the session cookie, this cookie is also set. HubSpot sets it to the value “1”, and uses it to determine if the user has restarted their browser. If this cookie does not exist when HubSpot manages cookies, they assume it is a new session.
Session
Functionality
__hs_testcookie
Used to test whether the visitor has support for cookies enabled
Session
Necessary
hsPagesViewedThisSession
Used to keep track of page views in a session.
Session
Necessary
hsfirstvisit
This cookie used to keep track of a user's first visit
10 years
Necessary
_gcl_au
Used by Google Analytics to understand user interaction with the Solution. https://policies.google.com/privacy
90 days
Analytics
_ga
Used to compute visitor, session, campaign data and to keep track of the use of the Solution for Solution analysis reporting. It stores a number generated randomly to identify unique visitors https://policies.google.com/privacy
1 year
Analytics
_gid
Used to store information about the use of a website by visitors and creates an analytical report on the functioning of the website. It stores the number of visitors, their source and the page visited in pseudonymized form. https://policies.google.com/privacy
1 day
Analytics
_gat_UA-126103277-1
Attribute Cookie. Contains the unique identification number of the account or website to which it relates. This is a variant of the gat_cookie which is used to limit the amount of data stored by Google on high traffic websites. https://policies.google.com/privacy
1 minute
Analytics
Google Tag Manager
Analytical/ Performance cookie (link to privacy notice: https://privacy.microsoft.com/en-us/privacystatement)
-
-
AppCues
Used to provide onboarding in-app walk-throughs. Tracks walk-through behavior (e.g. clicking “Skip”)
90 days
Necessary
Amplitude
Used to track button clicks and user flows to optimize the app
1 year
Analytics

You can manage Cookies through the settings of your web browser and/or electronic device

If you do not want Cookies to be stored on your electronic device, you can configure your internet browser or electronic device to refuse and/or restrict them. However, some Cookies are essential to the functioning of the Solution and may operate differently if you refuse or completely restrict Cookies.

For more information, please visit the website http://www.allaboutcookies.org. You can also see the help section of your internet browser or electronic device for more specific instructions on how to manage Cookies.


14. Your rights with regard to the processing of your personal data

You have the right to access your personal data we process and may request in particular that they be removed, updated, or rectified.

If you are using a Service provided by your Organization, you should direct your privacy inquiries relating to our use of your personal data on behalf of your Organization, including any requests to exercise your data protection rights, directly to your Organization’s contact person.

In other cases, you may contact us directly to exercise your rights. Unless otherwise provided by law, you have the right to know whether we are processing your personal data, to know the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be supplemented, updated, rectified, or erased. You also have the right to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law, and you have the right to object to any processing of personal data for legitimate reasons. However, if you are not user, you should direct your privacy inquiries relating to the use of your personal data by your Organization, including any requests to exercise your data protection rights, directly to your Organization.

By accessing your user account, you can review, update, correct or delete the personal data available within your user account.

If you request us to delete your personal data from our systems, we will do so unless we need to retain your data for legal or other legitimate reasons. Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request.

Where we rely on your consent to process your personal data, we will seek your freely given and specific consent by providing you with informed and unambiguous indications relating to your personal data. You may revoke at any time such consent (without such withdrawal affecting the lawfulness of processing made prior to).

The above does not restrict any other rights you might have pursuant to applicable data protection legislation under certain circumstances. In particular, if the GDPR applies to the processing of your personal data the GDPR grants you certain rights as a data subject if the respective requirements are met:

  • Right of access (Art. 15 GDPR) – you have the right to access and ask us for copies of your personal data.
  • Right to rectification (Art. 16 GDPR) – you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Right to erasure (Art. 17 GDPR) – you have the right to ask us to erase your personal data in certain circumstances.
  • Right to restriction of processing (Art. 18 GDPR) – you have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • Right to data portability (Art. 20 GDPR) – you have the right to ask that we transfer in a structured, commonly used and machine-readable format the personal data you gave us to another organization, or to you, in certain circumstances.
  • Right to object to processing (Art. 21 GDPR) – you have the right to object to the processing of your personal data, which is based on our Legitimate Interests, in certain circumstances. In such case, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defense of legal claims.

 

As a rule, you are not required to pay any charge for exercising your rights and we will respond to your request within one month.

You will find further details of your rights in sections 5 and 7 of this Privacy Notice in connection with each processing activity we perform. If you want to exercise any of your rights, or want additional information about them, please contact us using the contact detailed listed below (see section 15).

You have the right to lodge a complaint with the competent authority.

If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in addition to the rights described above.

Although this is not required, we recommend that you contact us first, as we might be able to respond to your request directly.


15. Contact Us

If you believe your personal data has been used in a way that is not consistent with this Privacy Notice, or if you have any questions or queries regarding the collection or processing of your personal data, please contact us at contact.


16. Updates to this Privacy Notice

This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you (including by email and/or via the Solution, e.g. banners, pop-ups or other notification mechanisms). If you do not agree to the changes made, you must stop accessing and/or using the impacted Services.

Last updated: January 2022.