Revision: August 2020
Connect-i understands that the collection of Personal Data involves a great deal of trust on your part. We take this trust very seriously and make it our highest priority to ensure the security and confidentiality of the Personal Data you provide us with.
This is why we implemented privacy by design and privacy by default standards and undertake to store your Personal Data in a secured way as well as to process your Personal Data with all appropriate care and attention in accordance with the Federal Data Protection Act (RS 235.1), the Ordinance on the Federal Data Protection Act (RS 235.11). Data which is deemed to be personal consists of all the information relating to a person who is either identified or identifiable (“Personal Data”).
Capitalized terms not defined in this Privacy Policy have the meanings set forth in the Terms of Service.
Please read this Privacy Notice (the “Privacy Notice”) carefully to understand our policies and practices regarding your Personal Data and how we will treat and process them.
By using and/or registering on the Site, you accept the practices described below:
Acceptance of the Privacy Notice
While using the Site or the Services, Connect-i may collect and process a certain number of Personal Data that relate to you.
The Privacy Notice shall apply to any use of the Site or use of the Services, whatever the method or medium used. It details the conditions at which, we may collect, keep, use and save information that relates to you, as well as the choices that you have in relation to the collection, utilization and disclosure of your Personal Data.
By using the Site or the Services, you acknowledge that you have read and understood this Privacy Notice.
Connect-i may modify this Privacy Notice from time to time and will post the most current version on the Site. You will be notified by email and you will be asked to consent to these modifications before they become applicable.
Purpose of the collection
Connect-i uses Personal Data mainly for the purpose of improving the user experience and the Site and targeting the Services to your needs.
The main reason why we collect Personal Data about you is :
- to improve the Site features and content, to administer your user account;
- to identify your needs and target the Services;
- to enable you to enjoy and easily navigate the Site and benefit from the Services;
- for specific purposes stated below.
The Personal Data will be freely provided by you to Connect-i or collected automatically while using the Site, in accordance with this Privacy Notice. In addition to the information contained in this Privacy Notice, the Site may provide users with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
We may supplement information you provide with information received from third parties.
Personal Data transmitted to Connect-i by you may be hosted by Connect-i or a third party of its choice subject to the same privacy obligations.
Type of Personal Data collected
Your consent followed by your submission of Personal Data represent your agreement to the collection, processing and storage of Personal Data by Connect-i as described in this Privacy Notice.
a. Registration data
When you register through the Site or in any other way interact with us (including by email), you may be asked to communicate a number of information, including without limitation, your personal contact details:
- Title;
- first name;
- last name;
- address;
- zip code;
- city;
- country;
- email address;
- phone number;
- language preference;
- profile picture and;
- password.
When you order Services via the Site, we will collect, process and store your Personal Data.
We may collect the Personal Data that you provide as part of registration and personalization of your user account.
If you only create an account without ordering or using the Services, we will not collect Personal Data listed below.
b. Data relating to the provision of the Services
When you use the Services, we may collect the following Personal Data for the purpose of executing the contract with you:
- contact information, such as first name, last name, company, address, country, email address;
- site registration credentials, such as login and password;
- computer information, such as IP address, operating system, type of device, browser, login dates;
- user preferences, such as areas of interest, newsletters, community choices and other information you select in the user profile when registering on the Site or indicated by your use of the Site;
- usage interaction information, such as scrolling, clicks, and mouse-overs, and methods used to browse away from the Site;
- expressed preferences, such as communications and language settings;
- communications, such as emails and messages with Connect-i;
- when you use the Site on a mobile device, we automatically collect information on the type of device you use, operating system version, and the device identifier.
In case you use collaborative workspace or live meeting services proposed by Moxtra Inc., the following information will be collected and transferred to this third party society based on your consent:
- base URL of the website;
c. Payment data
Your credit card transaction is made at your sole risk. Connect-i shall in no way or manner be held liable for any delay in the banking authorization relating to your banking card or of any damage or loss which may arise in relation with the transaction made via the Site.
Use of your Personal Data
a. Interaction and communication
- create an account;
- manage your account;
- communicate with you including by email and by telephone;
- send you our newsletter (provided you subscribed to it);
- fulfill your requests for Services;
- provide and improve the Site and/or the Services;
- conduct research and compile statistics on usage patterns;
- provide anonymous aggregate reporting for internal and external partners;
- manage your user account;
- respond to your questions and comments;
- notify you about promotional offers and Services (provided you have agreed with such use of your Personal Data);
- prevent potentially prohibited or illegal activities;
- enforce the Terms of Services;
- ensure the security of the Site;
- access to third party services if you connect your account with such third party services;
- comply with legal requirements;
- as otherwise described to you at the point of collection.
b. Marketing
c. Personalization
We use your Personal Data for the following personalized features:
- to analyze your preferences and consumption habits;
- to anticipate your needs based on our analysis of your profile;
- to improve and personalize your experience on our Site;
- to ensure that content from our Site is optimized for you and for your computer or device; and
- to allow you to participate in interactive features, when you choose to do so.
d. Customer service
e. Social networks
f. Services
We use your Personal Data to provide you with the Services you ordered
g. Internal research, analytic, security
h. Legal reasons or merger/acquisition
In the event that Connect-i or its assets are acquired by, or merged with, another company including through bankruptcy, we may share your Personal Data with any of our legal successors. We may also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of the Platform.
Public profile
By registering on the Site, you accept that Personal Data such as your profile picture and username will be published and displayed on the Site and be publicly available. The Company shall not be responsible for any reproduction, use or referencing (by search engines) of your Personal Data made publicly available on the Site. You shall not collect, web scrap or use in any way for your own profit information made publicly available on profiles, unless you are expressly entitled to do so by Connect-i.
Storage of your Personal Data and international Transfers
Your Personal Data will be stored in the European Economic Area (“EEA”), including Switzerland.
Your submission of Personal Data and your explicit consent to such international transfer represent your agreement to such international transfers and hosting abroad as specified above in accordance with the terms of this Privacy Notice.
Retention of your Personal Data
When you delete your account, your Personal Data will be kept for a period of 12 (twelve) months in order to comply with legal requirements.
Electronic Communications Protocols
You consent that Connect-i may re-associate the information provided by the technologies described above with your Personal Data.
System Logs and Maintenance
For operation and maintenance purposes, you consent that Connect-i and any third party services may collect files that record interaction with the Site (system logs) or use for this purpose other Personal Data (such as IP Address).
Cookies and similar technology
Cookies may be either "persistent" cookies or "session" cookies.
You understand and agree that the Site uses both session and persistent cookies on the Site.
You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
Google Analytics
The Site (to the exclusion of cloud services available on the Site) uses Google Analytics, an Internet site analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies which are text files placed on your computer to help to analyse the use made of the Site by its users. The data generated by the cookies concerning your use of the Site (including your IP address) will be forwarded to, and stored by, Google on servers located outside of Switzerland. Google will use this information to evaluate your use of the Site, compile reports on site activity for its publisher and provide other services relating to the activity of the Site and the use of the internet. Google may release these data to third parties if there is a legal obligation to do so or when the third parties process these data for the account of Google including, in particular, the publisher of this Platform. Google will not cross-reference your IP address with any other data held by Google.
You may deactivate the use of cookies by selecting appropriate parameters on your web browser. However, deactivation of this kind might prevent the use of certain functions of this site. By using this Site, you specifically consent to the processing of your Personal Data by Google under the conditions and for the purposes described above.
Security of your Personal Data
The security of your Personal Data is very important to us. Connect-i processes your Personal Data in a proper manner and shall take appropriate technical and organizational measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Personal Data.
The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Connect-i, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of the Site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by Connect-i. The updated list of these parties may be requested from the Data Controller at any time.
You shall be solely responsible to keep your password and other information relating to your account confidential and not allow any third party to access and use your account.
In the event that your Personal Data is unduly accessed, or is reasonably believed to have been unduly accessed, by an unauthorized person and applicable law requires notification, Connect-i shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, the Company shall communicate this breach to you without undue delay.
YOU HOWEVER ACKNOWLEDGE THAT THE USE OF THE INTERNET IS NOT SAFE AND THAT THERE ARE CERTAIN INHERENT RISKS TO YOUR PERSONAL DATA. CONNECT-I SHALL MAKE REASONABLE EFFORTS TO PROTECT YOUR PERSONAL DATA BUT IT CANNOT GUARANTEE OR WARRANT THAT PERSONAL DATA YOU PROVIDE TO CONNECT-I IS SAFE AND PROTECTED FROM UNAUTHORIZED THIRD PARTY ACCESS AND THEFT AND, THEREFORE, WAIVES ALL LIABILITY IN THIS RESPECT. IN NO EVENT, SHALL CONNECT-I BE HELD LIABLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS, VIRUSES OR SECURITY MEASURES CONTAINED ON THE SITE.
Access to your Personal Data and information rights
You have the right to request access to or information about the Personal Data related to you which are processed by Connect-i.
Where provided by law, you, your successors, representatives and/or proxies may (i) request deletion, correction or revision of your Personal Data; (ii) oppose the data processing; (iii) limit the use and disclosure of your Personal Data; and (iv) revoke consent to any of our data processing activities, if we are relying on your consent and do not have another legal basis to continue processing your data.
These rights can be exercised by writing to us at: Connect-i Sàrl, Le Trési 6, 1028 Préverenges, Switzerland, or by sending us an email at the following address [email protected] attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, we may charge you a reasonable request fee according to applicable laws.
We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.
Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request. This may be the case even though no Personal Data about your user account remains in our active users’ databases. Please note that Personal Data posted on third party services, such as social networks, are not located on our servers and will, therefore, not be deleted from the internet by Connect-i.
Portability of your Personal Data
You also have the right to receive your Personal Data, which you have provided Connect-i with, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Connect-i.
This right can be exercised by writing to us at: Connect-i Sàrl, Le Trési 6, 1028 Préverenges, Switzerland, attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, we may charge you a reasonable request fee according to applicable laws.
We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.
Privacy by design and by default
Connect-i will, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of Swiss law and, where applicable, the standards of GDPR and protect your rights.
Connect-i will implement appropriate technical and organizational measures for ensuring that, by default, only Personal Data which are necessary for each specific purpose of the processing are processed. This obligation applies to the amount of your Personal Data we collect, the extent of their processing, the period of storage and their accessibility. These measures will ensure that by default your Personal Data are not made accessible without your intervention to an indefinite number of third parties.
Data controller
The data controller of the file is Connect-i Sàrl (CHE-114.078.026), Le Trési 6, 1028 Préverenges, Switzerland.
Links
If any part of the Site contains links to third party’s sites or pages, those third party’s sites or pages do not operate under this Privacy Notice. If you choose to visit third party Sites or pages, you will be directed to these third party's sites or pages. We do not exercise control over third party Sites and therefore recommend you to examine the privacy statements posted on these other Sites or pages to understand their procedures for collecting, using, and disclosing Personal Data. We reject any liability relating to the privacy policy in force on said third party’s site, the collection and use of your Personal Data by the latter and relating to the contents of said sites (whether the links are hypertext links or deep-links).
Third party disclosure
Your Personal Data may be accessed and stored as necessary for the uses stated above in accordance with this Privacy Notice. While Connect-i may share your Personal Data with agents and contractors in order to perform the functions listed above, including hosting services and Site management, we require that they treat your Personal Data, and limit their use, in accordance with the standards specified in this Privacy Notice. Connect-i may transfer your Personal Data to a third party for hosting or processing purposes only.
Connect-i may transfer and share your Personal Data with other companies of the group Connect-i, as well as with our suppliers.
When you use the Site, you submit information to Connect-i that we store in order to offer you personalized features.
In any case where cross-border transfer is done, we ensure that an adequate protection is guaranteed for Personal Data to be transferred outside of Switzerland and the EEA. In some specific cases when this level of protection is not guaranteed, we will obtain your prior consent or establish with the recipient of Personal Data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting us.
Unless otherwise stated, the third parties who receive data from Connect-i are prohibited to use this Personal Data beyond what is necessary to provide the service to you, directly or by participating to our activities.
For compliance, please contact: [email protected]
Compliance with Laws and Law Enforcement
Connect-i may share your Personal Data to relevant third parties, in particular if we are requested to do so to comply with a court order or law enforcement authorities request, or if we find it necessary, as determined in our sole discretion, to investigate, prevent or take action regarding illegal activities, to defend our interest, in case of violations of the Terms of Services or as otherwise required or permitted by law.
Business Transfer
Connect-i may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy or insolvency event. Your consent to this Privacy Notice followed by your submission of Personal Data represent your explicit agreement to that transfer.
Jurisdiction and Applicable Law
This Privacy Notice and all matters arising out of or relating to it shall be governed by the substantive laws of Switzerland, without regards to principle of conflicts of laws thereof.
Any controversy, claim or dispute between a user and Connect-i arising out of or relating to this Privacy Notice shall be subject to the exclusive jurisdiction to the ordinary courts of the seat of Connect-i without prejudice to an appeal to the Swiss Federal Court.