Privacy Policy

Adresta

You can view, save and print the most recent version of the Adresta privacy policy ("Privacy Policy") at www.adresta.ch/en/privacy

1. Applicability

We are committed to protecting your privacy. Bucherer AG takes the protection of not only your personal but the safety and security of all data that flows through our website www.adresta.ch/ (“Website”) and end-user application of Bucherer AG ("App" and together with the Website "Platform") serious. As part of this effort, we process personal data and information ("Personal Data") in accordance with the Swiss Data Protection Law and, where applicable, with the European General Data Protection Regulation (“GDPR”). This Privacy Policy applies to the Platform, but does not apply to any third party websites that may be linked to our Website or App, which will be governed by their own privacy policies. California Consumer Privacy Act (CCPA): We are not in the business of selling Personal Data. We do not sell any collected Personal Data. Personal Data that is collected by us as a result of your visiting of our Platform or using our product and services in any form, is only processed for that purpose or any other purpose that you consent to us. As a con-sumer, you have extensive rights under the CCPA. We have described these below for you. Contact us under the contact details provided below if you have any questions or concerns.

2. Controller

Bucherer AG (Data Privacy, Langensandstrasse 27, 6005 Luzern, data-privacy@bucherer.com is controller ("Controller" and "Bucherer") in the sense of article 4 para. 7 GDPR.

3. General Information

The terms “We”, “Us” and ”Our” mean Bucherer. The terms “You” and “Your” refer to you, as a user or visitor of Our Platform provided services. The term Personal Data refers to all information relating to an identified or identifiable natural person (hereinafter referred to as "Data Subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics ex-pressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person, as set out in article 4 para. 1 GDPR. In addition, personal data subject to the Swiss Federal Act on Data Protection ("FADP") comprises data of le-gal persons. We treat all Personal Data confidentially.

4. Collection of Data

You may give Us information about You by submitting information on Our Platform or by corresponding with Us by phone, e-mail or otherwise. This includes information You provide when You register to use the Platform, subscribe to the Platform services, par-ticipate in discussion boards or other social media functions on the Platform, and when You report a problem relating to the Platform. The information You give Us may include your name, address, e-mail address, phone number, personal description or photograph. Any processing of Your Personal Data is based on a legal basis which is indicated below. By visiting the Platform, You agree to the collection and use of information in accordance with this Privacy Policy. We will not collect any Personal Data unless it is voluntarily provided by You or it is au-tomatically collected by visiting the Platform (technical data such as Internet browser, op-erating system, date or time of the Platform access as well as the referrer URL, IP ad-dress and host name of the accessing computer). We process only product-related data on the blockchain. Access to Personal Data is limited to those employees of Us who need to know this data. The persons concerned are obliged to maintain confidentially and to comply with the ap-plicable data protection laws and regulations.

5. Collection of Data by the App

The server, the App is communicating with, stores information in so-called log files au-tomatically. This applies to information automatically transmitted by the App, as follows: type of mobile device, operating system in use, technical information about the device in use, date and time of the request. This happens based on article 6 para. 1 lit. b GDPR, that regulates the lawfulness of processing when it is necessary for the performance of a contract or in order to take steps prior to entering into a contract.

6. Purpose of processing and legal basis

Any processing of data requires a legal basis. If the processing is necessary for the per-formance of a contract to which the Data Subject is a party, or for the implementation of pre-contractual measures taken at the request of the Data Subject, the processing may be based on article 6 para. 1 lit. b GDPR. If the processing is necessary to safeguard the legitimate interests of the Controller or a third party, provided that the interests or fundamental rights and freedoms of the Data Subject, which require the protection of Personal Data, do not prevail, it can be based on article 6 para. 1 lit. f GDPR.

We process Your Personal Data for the following purposes:

to fulfil Our obligation to make the services available to You in accordance with the service conditions concluded between You and Us; the legal basis for data pro-cessing is article 6 para. 1 lit. b GDPR;
to inform You about changes to Our services; the legal basis for data processing is article 6 para. 1 lit. b GDPR;
to ensure that the content of the Platform is presented on Your computer as effi-ciently as possible; the legal basis for data processing is article 6 para. 1 lit. b or f GDPR;
in order to enable You to participate in test and trial offers of Our services; the legal basis for data processing is article 6 para. 1 lit. b GDPR;
to inform You about parts of the services which We believe to be of interest to You if You have given Your consent; the legal basis for data processing is article 6 para. 1 lit. a GDPR; and
as part of Our efforts to offer You the greatest possible security when using the Platform; the legal basis for data processing is article 6 para. 1 lit. f GDPR.

We also process data that cannot be assigned to any person. These are data that do not personally identify You, including anonymous information and aggregated data. This in-formation helps Us to better understand how Our visitors use the services, to analyse demographics, interests and behaviours of Our visitors, to improve the services, to pro-vide customized services and information to visitors, and similar purposes.

7. Feedback

If You contact Us to provide feedback, register a complaint, or ask a question, We will record any Personal Data and other content that You provide in Your communication so that We can effectively respond to Your communication. We reserve the right to use this information in any manner permitted by law, to respond to Your communication. The pro-cessing of Your Personal Data for feedback processing is based on article 6 para. 1 lit. f GDPR.

8. Activity

When You use the services, We receive and store certain information which may include Your Personal Data, regarding Your use of the services. Examples include IP addresses, browser types, domain names, and other statistical data regarding Your use of the ser-vices. We may use this data in a way that does not disclose any of Your personally identi-fiable information, including, but not limited to, for purposes of developing new product and service offerings.

9. Cookies

We may send cookies to Your computer in order to uniquely identify Your browser and improve the quality of Our service. The term “cookies” refers to small text files that are stored permanently or temporarily on Your computer when You visit the Platform. Their main function is to analyse how the Platform is used, both for statistical evaluation and to help continually improve the Platform. Furthermore, the data collected by cookies is used to learn about Your preferences and to ensure that the Platform is provided without er-rors. Cookies do not cause any damage to Your computer and do not contain viruses. We may use both session cookies (which expire once You close Your browser) and per-sistent cookies (which stay on Your computer until You delete them). You can set Your browser to partly or completely deactivate cookies at any time. However, the complete deactivation of cookies can lead to the fact that You cannot use all functions of the Plat-form. You can find further information on this in the browser instructions. The use of cookies is based on article 6 para. 1 lit. f GDPR.

10. Web analysis services

In order to record the use of the Platform statistically and to evaluate it for the purpose of optimisation, We use web analysis services of third parties (tracking tools) to whom Personal Data may also be transferred in the course of using these services. In addition, We use social plug-ins from various providers (Facebook, LinkedIn, Twitter and Insta-gram) on the Platform. This can be accompanied by a data collection of the respective providers. For the purpose of the continuous optimisation of the pages and the design of the Plat-form, We use Matomo Analytics ("Matomo"). Matomo is a free and open source web ana-lytics application, that runs on a PHP/MySQL webserver. It tracks online visits to one or more websites and displays reports on these visits for analysis. Matomo can be operated in the cloud of the provider as well as on its own server (On-Premise). We operate Ma-tomo on Our host provider Hosttech. Due to the option of self-hosting and customization possibilities, Matomo is often also used to bypass user-side ad and tracking blockers. The open-source tool enables precise analyses of overall performance and user behav-iour. Each customer journey is recorded 1:1, so that the movement data of each visitor can be viewed down to the person level. Individual customer tracking can also be imple-mented, allowing every interaction of a visitor to be tracked. Matomo uses also cookies, which enables an analysis of the use of the Platform. Matomo is set up so that IP-addresses are only stored anonymously. Matomo will use this information for the pur-pose of evaluating Your use of the Platform, compiling reports on Platform activity and providing further services relating to Platform activity and Internet usage. Matomo may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Matomo's behalf. Under no circumstances will Matomo merge Your IP address with any other data held by Matomo. You may refuse the use of cookies by selecting the appropriate settings on its browser. By doing so, You may not be able to use the full functionality of the Platform. By using the Platform, You agree to the processing of the data collected about it by Matomo in the manner and for the purpose described above.

If You do not want to allow Matomo Analytics in principle, You can deactivate it. For more information on the privacy practices of Matomo or data protection in connection with Ma-tomo Analytics, You can visit the Matomo privacy policy (https://matomo.org/privacy-policy/). Facebook is a social network of the American company Facebook, Inc. (1601 S. Califor-nia Ave, Palo Alto, CA 94304, USA). LinkedIn is a social network of the LinkedIn Corpo-ration (2029 Stierlin Court, Mountain View, CA 94043, USA). Twitter is a microblogging and social networking service provided by the American company Twitter, Inc. based in San Francisco, California, on which users can post, like and interact with messages. In-stagram is an advertising-financed online service for sharing photos and videos, which belongs to the American company Facebook, Inc. If You access the Platform, Your browser establishes a direct connection to the servers of the aforementioned providers and loads the respective button from there. The information that the respective Platform has been called up is transmitted to the respective provider. If You are a registered user of the service in question, the provider can also assign the Platform access to the corre-sponding profile and may collect further data. Further information on data collection and processing can be found in the privacy policies of the respective providers, which are available at www.facebook.com/, www.ch.linkedin.com/, www.twitter.com/ and www.instagram.com/.

11. Disclosure of Personal Data

We may disclose Your Personal Data for the following purposes:

a) Legal obligation We may disclose Your Personal Data in response to a request for information if We be-lieve such disclosure is in accordance with any applicable law, regulation or legal pro-cess, or as otherwise required by any applicable law, rule or regulation. The legal basis for processing to fulfil a legal obligation is article 6 para. 1 lit. c GDPR.
b) Violation of terms of services
We may disclose Your Personal Data if We believe Your actions are in violation of Our terms of service and Privacy Policy, or to protect the rights, property and safety of Us or others. In this case, the transfer is based on article 6 para. 1 lit. f GDPR.
c) Disclosure within the company
If necessary, We transmit Personal Data to other parts of the company, e.g. for billing purposes. In this case, the transfer is based on article 6 para. 1 lit. f GDPR.

12. Disclosure of Personal Data to third parties

Under no circumstances will We rent, sell or otherwise share Personal Data to third par-ties, except with your consent, the disclosure is necessary to assert, exercise or defend legal claims, a legal obligation exists or it is legally permissible and necessary for the ex-ecution of contractual relationships with You. Your rights regarding the transmission and processing of its Personal Data to third parties in accordance with the applicable data protection laws and regulations will be respected. A transfer of Personal Data will take place in relation to the web analysis services as listed above. A transfer of Personal Data to third parties will take place e.g. by transmitting the credit card data to the processing bank institutes or payment service providers for the purpose of debiting the purchase price. We process our payments trough Stripe, Inc. (to learn more about their Privacy Policy please visit https://stripe.com/privacy). Furthermore, a transfer of Personal Data will take place in relation to the web analysis services as listed above. We built Our App with the Expo tools, services and React. For more information about this Software, please refer to https://expo.io/ and to https://expo.io/privacy/ for their privacy policy.

13. Links

Our Platform and services may contain links to third party websites to which We have no affiliation. This Privacy Policy does not extend to any external links. Except as set forth herein, We do not share Your Personal Data with those third parties, and are not re-sponsible for and accept no liability for their privacy practices. We suggest You to read the privacy policies on all such third party websites.

14. Security

We take commercially reasonable steps to protect Your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use up to date TLS-encryption that Your systems support when transmitting data via Our systems. However, a complete protection of data against access by third parties is not possible. We cannot guarantee that all Internet or e-mail transmission is fully secure or free of errors. We also use suitable technical and organisational security measures to protect Your Personal Da-ta against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments. Nevertheless, We cannot guarantee their abso-lute security and We therefore cannot be held liable for intercepted information sent via the Internet or for third parties using revoked, stolen, forged, or otherwise insecure cer-tificates. You should therefore take special care in deciding which information You send Us by e-mail and keep this in mind by disclosing any Personal Data to Us or to any other party via Internet.

15. Retention Period

We store Your Personal Data for as long as it is necessary for the respective purpose for which it was collected, in particular to fulfil contractual and legal obligations, such as statutory retention periods, or until You revoke Your consent in the processing of Per-sonal Data. We may in any event retain and use such Personal Data as necessary to maintain accurate accounting, financial and other operational records, resolve disputes, and enforce the rights connected to the use of the Platform. The Personal Data will be deleted at the latest within one month after the respective purpose no longer applies.

16. Your Rights

You are entitled to extensive rights which You can assert against Us based on article 15 to 21 GDPR. Upon request, We will inform You in writing, in accordance with the appli-cable statutory provisions, which Personal Data We have stored about You. You may re-quest information about the origin, transfer, purpose of collection and use, the planned storage period and the type of processing of the Personal Data. Furthermore, at Your request, We will correct, complete, amend, delete or restrict the processing and storage of the Personal Data at any time, unless the processing is justified by Our legitimate in-terests, necessary to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims. For this purpose and/or to obtain further information, please contact Us at data-privacy@bucherer.com. You have the right to receive the Personal Data We hold about You in a structured, common, machine-readable format and free of charge. Upon request, We will transfer Your Personal Data to another controller. If You wish to exercise any of the rights men-tioned in this section or if You have any questions about the processing of Your Person-al Data, please contact Us at the e-mail address data-privacy@bucherer.com. We are obliged to verify Your identity in such requests. Inquiries can therefore only be processed if a suitable proof of Your identity (copy of identity card or similar) is en-closed. If the processing of the Personal Data is carried out on the basis of the consent pursu-ant to article 6 para. 1 lit. a GDPR, You have the right to object such consent at any time. The data processing’s legality up to the time of objection stays untouched. Should the processing of Your Personal Data be based on article 6 para. 1 lit. e or f GDPR, You have the right to object, on grounds relating to Your particular situation, at any time to processing of Your Personal Data, including profiling based on those provisions. The re-spective legal basis for a processing of data is explained in this Privacy Policy. If You ob-ject, We will no longer process Your Personal Data, except we can prove reasons of compelling worth of protection, outweighing Your interests, rights and freedom or the processing is necessary for the establishment, exercise or defence of legal claims (arti-cle 21 para. 1 GDPR). Should Your Personal Data be processed for direct marketing purposes, You have the right to object at any time to the processing of Your Personal Data for such marketing. If You object, We will no longer process Your Personal Data for direct marketing (article 21 para. 2 GDPR). Furthermore, You have the opportunity to file a complaint with the competent data pro-tection supervisory authority and to revoke consent to data processing based on article 77 GDPR. In Switzerland, the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html) is responsible for such complaints.

17. Existence of an Automatic Decision-Making Process

As a responsible company, We refrain from automatic decision-making or profiling.

18. Conditions and Changes to this Privacy Policy

This is Our currently valid Privacy Policy. We are free to change this Privacy Policy from time to time. The new version will always be posted on the Website or App and will re-place all previous versions. The changes will be effective immediately for new visitors and users of Our services and will become effective for existing users through contin-ued use of the services after the effective date of the posted change. If You do not want to approve the changes to Our use of Your Personal Data, You have to notify Us before such changes take effect that You want to deactivate Your account with Us. Please note that You are always responsible for keeping Your Personal Data up to date and providing Us with Your current contact information.

Bucherer AG, August 2023, Version 1.2

End of the Privacy Policy. Last revision: 08.08.2023

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PRIVACY POLICY