SwissPerio Privacy and cookie policy
IMPORTANT INFORMATION AND WHO WE ARE
Welcome to the privacy policy of SwissPerio Education. SwissPerio is committed to protecting and respecting your privacy.
This privacy policy will inform you as to how we look after your personal data (regardless of how we obtain such personal data) and tell you about your privacy rights and how the law protects you. It also provides you with information regarding our use of cookies. This policy describes our general practice and procedure for collecting, using and disclosing information about our customers, those of our commercial partners and visitors to our website (Individuals).
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- COOKIES
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on:
- how SwissPerio collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to, purchase a product or service, take part in a course, contact us or lregister to become a partner, fill in the ‘Contact Us’ section of the website, give us feedback or submit comments on a Case Study;
- how SwissPerio collects and processes data provided to us in the provision of our services to the persons or companies who engage SwissPerio (our ‘Customers’); and
- how SwissPerio collects and processes data relating to other persons or companies having a business relationship with SwissPerio.
This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it and regarding cookies. If you have not already read our Terms of Website Use, please do so at www.swissperio.com/terms-and-conditions
Controller
SwissPerio Limited is the controller and responsible for your personal data (collectively referred to as „we“, „us“ or „our“ in this privacy notice).
If you have any questions about this privacy policy, please contact us using the details set our below:
Contact details, our full details are:
SwissPerio Education
Burgstockstrasse 15
9050 Appenzell
Switzerland
Changes to the privacy notice and your duty to inform us of changes
We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform you and, if appropriate, seek your consent if we intend to materially change the way in which we use your data. We recommend that you consult this privacy policy regularly for updates.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, we encourage you to read the privacy notice of every website you visit.
2. INFORMATION WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that per-son can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes physical address, email address, fax number and telephone numbers.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your job role, industry, your purchases, your feedback, your survey responses and other feedback provided by you relating to your use of the SwissPerio services.
- Usage Data includes information about how you use our website and the features you interact with on our website, our products and our services and information you submit to us in relation to any support issues.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your interactions with our marketing communications and your communication preferences.
- Transaction Data includes details about payments to and from SwissPerio and other details of products and services you have purchased from SwissPerio.
- Financial Data including bank account and/or payment card details if activarted are stored on third parties like Stripe or PayPal.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. COOKIES
We may collect Technical Data about your computer for system administration and statistical analysis. This is statistical data about our users‘ browsing actions and patterns, and does not identify any individual.
Strictly necessary cookies.
These are cookies that are required for the operation of this website. They include, for example, cookies that enable you to log into secure areas of our website, submit comments to our blog or use submission forms
Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies.
These are used to recognise you when you return to our website. This enables us to personalise our content for you to remember your preferences (for example, your choice of language or region).
Targeting cookies.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
THE COOKIES OUR SITE USES
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Function |
|---|---|
| _ga and _gid | Google Analytics – Used to distinguish users and sessions |
| _gat | Google Analytics – Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_. |
| wordpress_ | WordPress cookie for a logged in user |
| wordpress_logged_in_ and wordpress_test_ | WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your indivi-dual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. |
| wordpress_test_cookie | WordPress test cookie |
| wp-settings- | WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. |
| wp-settings-time- | WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin inter-face, and possibly also the main site interface. |
| woocommerce_cart_hash and woocommerce_items_in_cart | contain information about the cart as a whole and helps WooCommerce know when the cart data changes. |
| wp_woocommerce_session_ | contains a unique code for each customer so that it knows where to find the cart data in the database for each customer. No personal information is stored within these cookies. |
| wfwaf-authcookie-(hash) | This cookie is used by the Wordfence firewall to perform a capability check of the current user before WordPress has been loaded. |
| VISITOR_INFO1_LIVE | YouTube Bandwidth Measurement |
| PREF | Registers a unique ID used by Google to keep statistics about how the visitor uses YouTube videos on various websites. |
| YSC | Registers a unique ID to keep track of the YouTube videos that the user has seen. |
| GPS | Registers a unique ID on mobile devices to enable tracking based on geographic GPS location. |
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
BLOCKING COOKIES
You may block cookies by activating settings on your browser which allow you to refuse the setting of some or all cookies. If you do so choose to block all cookies (including essential cookies) you may not be able to access all or some parts of our website.
Most cookies we use are known as session cookies. These cookies will expire whenever you close your browser or shut down your computer, and such cookies need not be blocked. Other cookies used for specific purpose will expire when that purpose is no longer required.
You can find out more about blocking cookies in specific browsers at https://www.aboutcookies.org/.
4. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact, Marketing and Communication, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create a trial account on our website;
- request marketing to be sent to you;
- download materials, ebooks, videos etc;
- watch demonstrations;
- enter an online course, competition or survey;
- as part of your interaction with SwissPerio as you enter into a business relationship with SwissPerio; or give us some feedback.
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the cookie section of this policy for further details.
Third parties or publicly available sources. We may receive Technical Data about you from the following parties:
- analytics providers such as Google Analytics based outside the EU, Hubspot Analytics based outside the EU, Wistia based outside the EU, Inspectlet based outside the EU, Crazy Egg based outside the EU and Privy based outside the EU;
- advertising networks such as Google Ads based outside the EU, Bing Ads based outside the EU, Facebook Ads based outside the EU, Linkedin Ads based outside the EU and Adroll based outside the EU; and
- search information providers such as Google Analytics based outside the EU and Swiftype based outside the EU.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact |
Necessary for our legitimate interests (to conclude our contract with our Customers and to provide access to our services under such contract) |
| To manage payments, fees and charges | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
Necessary for our legitimate interests (to conclude our contract with our Customers) |
| To collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction |
Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: Notifying you (a) about changes to our terms or privacy policy. | (a) Identity (b) Contact (c) Profile |
Necessary to comply with a legal obligation |
| To manage our contractual relationship with our Customers which will include: (a) contacting Individual contacts at our customers for account administration, support and relationship management purposes (b) responding to support queries raised by Individual users of our Customers | (a) Identity (b) Contact (c) Marketing and Communications (d) Profile |
Necessary for our legitimate interests (to ensure we comply with out contractual obligations to our Cus-tomers and respond to queries raised in connection with our services). |
| To ask you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT ser-vices, network security, to prevent fraud and in the context of a business reorganisation or group restruc-turing exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effective-ness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To tailor our direct marketing to you and to send you direct marketing communications including via Email or text message | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
In terms of tailoring our direct marketing, necessary for our legitimate interests, being to develop our business and inform our marketing strategy. In terms of sending direct marketing where you are a customer and have not previously opted out of receiving such direct marketing, as necessary for our legitimate interests, being to offer you relevant products and services related to what we have previously provided to you. In terms of sending direct marking where you are not one of our customers, with your consent given when you sign up to receive marketing communications on our website or otherwise give your details and provide consent when doing so. |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Third-party marketing
We process personal data to undertake marketing activity in conjunction with or on behalf of our third party partners (in particular reseller partners, implementation partners and trade association partners). The personal data processed by us for the purposes of conducting such marketing activity is provided to us by our partners. Prior to undertaking marketing activity on behalf of a relevant partner, we require such partner to confirm that they have a lawful basis for holding the data and providing such data to SwissPerio for the purposes of undertaking the marketing activity concerned (including any necessary consent required from relevant data subjects).
We will obtain your consent before we share your personal data with any company outside the SwissPerio group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a software solution purchase, warranty registration, software solution experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURE OF YOUR INFORMATION
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal third parties – companies in the SwissPerio Group acting as joint controllers or processors and provide IT and system administration services and undertake reporting.
- External third parties – these include:
- Service providers acting as processors, who help us run our website, for the purposes of hosting and running our website and our services, to provide support services to our Customer, and performing the transactions concluded through our website.
- Service providers acting as processors, whose services enable us to send marketing communications to our Customers, measure the effectiveness of marketing communications, send feedback requests and surveys to our Customers. Service providers acting as processors who provide IT and system administration services which enable us to provide our services to our Customers.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Customers acting as controllers who require us to provide Profile Data regarding use of our services by their users.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may also have to share your personal information with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Website Use, Terms of Service or any other terms or agreements.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
We share your personal data within SwissPerio. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
SwissPerio takes reasonable precautions to protect personal data relating to Individuals which is processed and collected by SwissPerio. SwissPerio applies generally accepted industry standard security measures to such personal data and protect it from unauthorized access or against loss, misuse or alteration by third parties. SwissPerio maintains personal data behind a firewall.
Although we make good faith efforts to store personal data in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of personal data during its transmission or its storage on our systems.
Further, while we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.
We do not warrant or represent that personal data will be protected against, loss, misuse, or alteration by third parties.
9. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers for tax purposes. In some circumstances we may aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a „data subject access request“.
- Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data‘s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.)
If you wish to exercise any of the rights set out above, please contact us.
Please note, where we process your information for statistical purposes, certain of the above rights will not be available to you. Please contact us for further information on which of the above rights will not apply to our processing of personal data for statistical purposes.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. You should ensure that you review this Policy from time to time.
CONTACT US
If you have any concerns about material which appears on our website, or any questions, comments or requests regarding our Terms of Website Use or Privacy and Cookie Policy, please contact us at info@SwissPerio.com or at our postal address of SwissPerio Education, Burgstockstrasse 15, 9050 Appenzell, Switzerland or use the “Contact Us” form on our website at https://swissperio.com/contact/.