July 13, 2018

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 Policy (the “Policy”) 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 Policy

While using the Site or the Services, Connect-i may collect and process a certain number of Personal Data that relate to you.

The Policy 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 Policy and agree to be bound by it and to comply with all applicable laws and regulations. You also acknowledge that you have read and understood the Terms of Use that apply to the Site and agree to be bound by them.

Connect-i may modify this Policy 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 Policy. In addition to the information contained in this Policy, 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 to this Policy 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 Policy.

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 use of the Services

When you use the Services, we may collect the following Personal Data:

  • • 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 service the following information will also be collected:
    •    - base URL of the Site
    •    - email address of the platform administrator
    •    - name of the Site
    •    - total number of users of the Site
    •    - for all users of the Site, username, ID and timezone (information also sent to Moxtra Inc)

c. Payment data

Connect-i does not process, nor does it have access to, any information provided in relation with the online payment of Services.

However, via the Site you transmit data relating to your means of payment, including by credit card (bank references, name of the owner of the account, card number, expiration date, etc.) (“Payment Data”).

Credit card payments are processed by the payment provider in compliance with the PCI-DSS norms.  We do not have access to the credit card numbers.  For all credit card payments, the payment service provider uses a secure payment system; this is an SSL secure payment.  This payment protocol standard is recognized throughout the world for the protection of data transmitted over the internet.  It is available on practically all browsers.  The Personal Data which you provide relating to your credit card (number, end of validity date, CVM etc.) are encrypted prior to the sending of your post to the payment server.

We do not register and we do not request banking data, credit card data or banking card data.  External service providers carry out credit card payments.  Regarding such data, the general conditions and the privacy policy of the payment operator are solely applicable. We do not act as a financial intermediary or as a payment institution for the transactions which take place via the Site, said transactions being processed by the payment service provider.

You agree that Connect-i shall process payments via external service providers and that you shall transmit to said external provider your Personal Data for the sole purpose of making the transaction. You expressly agree to send your Payment Data to the payment service provider, as well as send all information which the latter shall require from you.

You hereby expressly agree to comply with the general conditions of external service provider in charge of processing the payment, to pay it the commission provided therefore and to grant it all banking authorizations required to carry out the payment with your credit or banking card.

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

The following paragraphs describe the various purposes for which we collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.

a. Interaction and communication

We use your Personal Data in order to provide you with the Service, to interact with you, including by means of telephone, and to respond to your requests. Your Personal Data may also be used to for fraud detection purposes. By creating an account on the Site, you agree that we may process and use your Personal Data so that we may contact you, in particular by sending email containing general information. For this purpose, your Personal Data shall also be used in order to:

  • • 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

You consent that we use your Personal Data to send you information regarding our Services and any promotional offers and for electronic advertising purposes. Connect-i may use your Personal Data for its own commercial, promotional or marketing purposes. Connect-i always endeavors to send you advertising material tailored to your interests. Connect-i will however not monetize your Personal Data by transferring them to third parties.

Your Personal Data may also be used in in order to test your interest in the creation of new services, products or activities based on elements of your profile, your interests or your use of the Service. Your Personal Data may also be used in order to improve the services offered by Connect-i and to prepare anonymous statistics, including for big data purposes.

If you no longer wish to receive marketing communications or promotional offers, you can at any time unsubscribe from receiving marketing-related communications at any time, by following the instructions provided in each such communication or by sending an email to: info@opigno.org. You can also at any time adjust your privacy settings in your account profile by. Please note that, even though you opt out from receiving marketing communications, you may still receive administrative communications from us or notifications about your account activities (e.g. account confirmations, password changes, etc.), and/or other important announcements regarding the Site, the Privacy Policy or the Terms of use.

c. Personalization

You consent that we use of your Personal Data in order to analyze your preferences and your patterns, to personalize your experience on the Site, as well as to optimize the Site.  You consent also that we may also suggest to you content which is best suited to your interests.

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.

If you no longer wish to have your Personal Data used by Connect-i to provide you with a personalized experience, you can at any time adjust your privacy settings in your account.

d. Customer service

You consent that we use your Personal Data for customer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. technical issue, question/complaint, general question, etc.).

e. Social networks

You consent that we use your Personal Data when you interact with third party social networking features, such as to serve you with advertisements and engage with you on social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.

Certain features (called plugins) offered by various third party social media platform providers (for example Facebook, Linkedin, Twitter) are incorporated into our Site. These plugins allow you to share content available via social networks. If a plugin appears on the Site during a browsing session, an automatic link with the servers of said site is provided.  The data relating to your Site may be sent to this third-party provider.  If you are identified at the same time on the network of said third party provider, the visit to our Site may then be linked to the your network account (for example Facebook). Connect-i has no influence over this type of data transfer. Please consult the information relating to data protection by your social network regarding the purpose and the extent of the collection of your data, the subsequent management and use of your Personal Data by said provider, as well as your rights and setting options in order to protect your privacy.

When you authorize a third party social network (such as Facebook) to share information and data with us, we may receive any data which you publicly share on said social network as well as any data which forms part of your profile. This may consist of basic data relating to your account (e.g. your name, email address, gender, birthday, the town where you reside, your profile photograph, your user identifier, your list of friends, etc.) and all other information or activity which you have authorized the third-party network to share.

We also receive data relating to your profile when you use a function of the social network which is integrated into the Site (such as Facebook Connect) or when you interact with us via a social network.  In order to find out more about how we receive data regarding yourself from third party social networks or to cease sharing your data on said social networks, we invite you to read the conditions of use of the relevant social networks. You should at all time be aware of the terms of use and privacy policy that applies to the third party social network and are of its exclusive responsibility.

f. Services

We use your Personal Data to provide you with the Services you ordered.  

g. Internal research, analytic, security

In accordance with applicable laws, we use your Personal Data for other general business purposes, such as conducting internal marketing and demographic studies and measuring the effectiveness of advertising campaigns. We also use your Personal Data to ensure our 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

By using and/or registering on the Site, you acknowledge and agree that Personal Data you submit to Connect-i will be hosted by Connect-i or a third party of its choice for an indefinite period of time.

Your Personal Data will be stored in the European Economic Area (“EEA”), including Switzerland.

The storage as well as the processing of your Personal Data may require that your Personal Data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence, notably Switzerland. Where permitted by law, by accepting the terms of this Policy, you agree to such transferring, transmission, hosting, storing and/or processing. You also agree that such activities may take place to or in countries offering a similar level of protection than your country of residence or a lower level of protection than your country of residence, provided standard contractual clauses or binding corporate rules are implemented and you are provided with sufficient information as to the country with a lower level of protection to which your Personal Data are to be transferred.  

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 Policy.

Retention of your Personal Data

In accordance with applicable laws and the principle of proportionality, we will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements. Personal Data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.

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

In addition to the purposes specified above, you consent that Connect-i may collect information about your use of the Site through electronic communications protocols. Connect-i may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), referring Site and date and time. Collecting this automatic information helps us customize your experience as a user. It allows us to monitor and analyze use of the Site and to increase the Site's functionality and user-friendliness.

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

The Site uses "cookies" to collect information. Cookies are small piece of data that a website asks your browser to store on your computer or mobile device. Cookies contain an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

Cookies may be either "persistent" cookies or "session" cookies.

Sessions cookies will be erased when you close your browser, whereas “persistent” cookies will remain on your computer/device/web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date.

You understand and agree that the Site uses both session and persistent cookies on the Site.

The names of the cookies that we use on our website, and the purposes for which they are used, are set out in the table below.

Name

Type

Usage

Drupal.tableDrag.showWeight

Persistent

Used in order to store user interface preferences

SSESS[hash]

 

Note: the hash after SSESS will change each time the cookie is renewed

Session

This cookie is created when a user authenticates, in order to keep him logged in to the site and avoid that he has to constantly re-enter his username and password

__utma to __utmz

Persistent

These cookies are used by Google Analytics

_ga

Persistent

This cookie is used by Google Analytics

_gat

Persistent

This cookie is used by Google Analytics

has_js

Session

This cookie is used to check if the browser accepts JavaScript

ctools-collapsible-state

Session

Used in order to store user interface preferences

You consent that we use session cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users. We will use session cookies for identifying your language settings of your device, the promotional offers you subscribed to.

You can always control cookies by enabling your web browser to block cookies. However, if you block cookies you may not be able to use all portions of the Site or all functionality of the Services.

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 info@opigno.org 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 the 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 Policy. 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 Policy. 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 Policy. 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: info@opigno.org

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 Transfers

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 Policy followed by your submission of Personal Data represent your explicit agreement to that transfer.

Jurisdiction and Applicable Law

This Policy 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 Policy 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.

Contacting us and Complaints

We hope to be able to answer any questions or concerns you may have about your Personal Data. Should you have any questions about this Policy, please contact us at: info@opigno.org or Connect-i Sàrl, Le Trési 6, 1028 Préverenges, Switzerland.

You have the right to file a complaint if you feel your Personal Data has been mishandled or if we failed to meet your expectations. You are encouraged to contact us about any complaints or concerns but you are entitled to complain directly to the relevant supervisory authority.

Latest date of issue: July 13, 2018