Last updated: May 25, 2018
- What personally identifiable information is collected from you through the Website, how it is used and with whom it may be shared.
- What choices are available to you regarding the use of your data.
- The security procedures in place to protect the misuse of your information.
- How you can correct any inaccuracies in the information.
2. DATA CONTROLLER
The Personal Data controller is the Swiss Société Anonyme (SA) under the name "IC Products SA", based in Gordola, Via Santa Maria 68a, Postcode 6596, in Switzerland and is legally represented, VAT ID: CHE-108.462.936 MWST, email: email@example.com, and is active in manufacturing and selling disinfecting products.
3. PERSONAL DATA
3.1.1. The term "personal data" means any information related to an identified or identifiable natural person. The identifiable natural person is a person whose identity can be identified directly or indirectly, in particular by reference to an identifier such as name, address, location data, or an online identity identifier such as an Internet Protocol (IP) address.
3.1.2. Personal information does not include any information that, by itself, cannot recognize you as a particular person or entity (e.g., anonymized information) or data collected for statistical purposes.
3.2.1. The personal data you may give us through phone, email or the contact page on our Website, are subject to processing and are stored in a file under the responsibility of the controller mentioned above, only for reasons relating to:
a. management and processing of your requests, and
b. the provision, with your consent, of the information regarding IC Products' products.
Your personal data are not allowed to be used by any third party, except as provided by the law and this Policy.
3.2.2. We collect and process information that is considered purely personal data, as well as other information that is not considered as such. Information that cannot identify you as a specific person can be used without restrictions.
3.2.3. Our Website does not collect or process sensitive personal data, namely, data related to a user's health, sex, sexual orientation, genetic or biometric data, or data revealing one's racial or ethnic origin, political opinions, religious or philosophical beliefs or membership in a trade union.
3.2.4. When you send us emails or contact us through our Website, we collect the information you provide us, such as your first name, your last name, and a valid email address. We maintain those communications and their contents so that we can resolve your inquiries or otherwise assist you. We only have access to and collect information that you voluntarily give us via e-mail or other direct contact form. We will not sell or rent this information to anyone.
3.2.5. Location information. Your devices (depending on your settings) may transmit location information to our third-party service providers. We will not sell or disclose your information with any third party other than necessary to fulfill your request, e.g. to ship an order. We only store and process information related to your address when we send you products that you ordered from us and we store this information for future orders.
3.2.6. If not required by law, we will not obtain your consent before collecting your personal data from third parties. Instead, it will be deemed that you have previously given such consent to any third party from whom our platform receives such information.
3.2.7. If you wish so, we may use the personal data you provide when contacting us to inform you by email about services that may be of interest, new product features, promotional communications and other announcements. These ways of communication do not occur at a regular basis and are infrequent.
3.2.8. Administrative access to your data. Please be aware that IC Products team members are also authorized in specific situations to access the administrative section of your data when fulfilling your orders and customer service requests, or tracking errors.
3.3.3. We may provide personal data to other persons in cases where:
- you have provided your explicit consent by clicking on the checkbox "I accept";
- this is required by law, court order or at the request of any other competent governmental, judicial, police, administrative or regulatory authority, upon legal request and in accordance with the relevant laws;
- this is necessary to protect our rights;
- the Website is used in a manner that violates the Terms of Service or for purposes other than those for which it was intended specifically; or
3.3.4. We may also transfer personal data we have about you in the event we sell or transfer all or portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
The personal information we collect will be only used for the defined, explicit, and legitimate purposes explained to you and will not be further processed in a manner incompatible with those purposes. Moreover, we limit the collection to only those information that is appropriate, relevant and necessary for the purposes explained to you.
3.5. Period of Maintenance
3.5.1. We keep personal data, such as name, phone number, email address and physical address used to answer your questions and complete your orders, for as long as necessary to fulfill the purpose described in this policy, unless otherwise required by law, or for up to 5 years after your last placed order or last communication with us. We do not have access to or retain your payment data.
3.5.2. After five years, when we no longer require your personal information, we will destroy or delete the information without prior notice to you. In case you place an order or contact us after this period of time, we will retain your newly submitted information for up to five years from the last contact with you.
4.1. To prevent unauthorized access and transmissions, promote data security, and encourage appropriate use of information, we and our website service provider (Smoolis GmbH) use a variety of tools (encryption technologies, passwords, physical and electronic security, procedural safeguards) to assist in the protection of your information. However, "perfect security" does not exist on the internet or through data transmissions, so we make no guarantees. Third parties may unlawfully intercept or access transmissions or private communications and you should not expect that your personal information will remain private.
4.2. We also protect your data offline by granting access to personally identifiable information only to employees who need the information to perform a specific job (for example billing or customer service). The computers and servers in which we store personally identifiable information are kept in a secure environment.
4.3. For the HTTPS encryption (TLS) of our Website, Smoolis uses the free service "Let's Encrypt". Via the integration of encryption certificates, they can provide a so-called transport encryption that protects the communication to our Site from unwarranted access of unauthorized third parties.
4.4. Smoolis supports security protocols (SSLs) and encryption mechanisms (HTTPS protocol) that allow secure data transmission to the network. Smoolis also uses mechanisms for access control, SQL injection, Cross-site scripting (XSS) vulnerabilities, and session hijacking security mechanisms to effectively protect data and minimize risks. They employ security measures such as using firewalls to protect against intruders, building redundancies throughout their network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. Payment information is transmitted using HTTPS encryption, and they maintain a PCI DSS Compliance.
5.2. What are cookies? Cookies are pieces of information in the form of very short alphanumeric text, stored on your computer with your own approval, and they help the more efficient operation of our Website. Cookies in no way cause harm to your computer or the files kept on them.
5.3. What cookies does Smoolis use and why?
- Some cookies are functional cookies to remember choices you've made or information you've provided, such as your language. This allows us to tailor your website experience specifically to your preferences.
- Smoolis also uses performance cookies to collect information about how you interact with our Website. These cookies only gather information for statistical purposes and do not gather any information that can personally identify you. However, because these cookies are not strictly necessary for the use of our Website, we require your consent to use them. The performance cookies we use include:
- First party analytics cookies to estimate the number of unique visitors and to improve our Website.
- For statistical purposes we use Google Analytics cookies to help us understand how visitors arrive at and browse our Website to identify areas for improvement such as navigation, user experience, and marketing campaigns. The data collected is processed in a non-personally-identifying form (anonymizeIp - IP Anonymization). Google Inc. discloses this information only to third parties to the extent required by law. To opt-out of Google Analytics visit Google Analytics Opt-out Browser Add-on.
You can find more information about the individual cookies Smoolis uses and the purposes for which they use them below:
- publisher: Smoolis
- purpose: strictly necessary / functionality (expires when the browsing session ends; "session cookie")
- publisher: Smoolis
- publisher: Smoolis
- purpose: strictly necessary / functionality (expires after 14 days; "persistent cookie", refreshes every time a user visits on a different day)
- _ga / _gat / _gid
- publisher: Google Analytics
- purpose: analytical / performance
- __stripe_mid / __stripe_sid
- publisher: Stripe
- purpose: strictly necessary / functionality
5.4. How can you opt out?
- More information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.
5.5. For safe browsing on our Website, IC Products complies with the European Directive 2002/58/EC on the processing of personal data and the protection of privacy in the electronic communications sector, as amended by Directive 2009/136/EC.
6.1. We can receive personal information about you from various sources or by different methods. The way of consent may vary depending on each source or method.
6.4. You can revoke your consent at any time by sending an email to firstname.lastname@example.org, without prejudice to the legitimacy of the consent-based processing prior to its revocation. Your data is then deleted, or provided that it is necessary for billing and accounting purposes, blocked accordingly.
7. ACCESS TO PERSONAL DATA
7.1. To modify the personal information you have provided to us, simply contact us and let us know the changes you want to make. We may retain certain information as required by law or for necessary business purposes.
7.2. You are entitled to receive from us a confirmation of whether or not your personal data is being processed and, if so, you have the right to access your personal data, as well as know
- the purposes of the processing;
- the relevant categories of personal data, recipients or any types of recipients to whom personal data have been or will be disclosed;
- where possible, the period during which personal data will be stored;
- the existence of a right to request us to correct or delete personal data or to restrict the processing of personal data or the right to object to such processing;
- the right to submit complaint to a supervisory authority;
- when personal data are not collected by us, any available information about their origin;
- the existence of automated decision-making, including profile making and important information about the philosophy followed, as well as the importance and predicted consequences of such processing for you.
7.3. You can ask us to provide to you a copy of your processed personal data.
7.4. Any request for access to information should be addressed to email@example.com and we will respond within one (1) month.
8. RIGHTS OF CORRECTION, DELETION, LIMITATION, PORTABILITY AND OBJECTION
8.1. We are committed to ensure that your personal data is kept confidential and to ensure that you exercise your rights of access, correction, deletion, restriction, portability and objection by sending an email to firstname.lastname@example.org. If necessary, we will ask you to provide us with a photocopy of your identity card, passport or other valid documentary evidence.
8.2. Right of correction. The user is entitled to require us without undue delay to correct inaccurate personal data. Having regard to the purposes of the processing, the user is entitled to require the completion of incomplete personal data, including among others through a supplementary statement.
8.3. Right of deletion. The user is entitled to ask us to delete personal data if:
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
- the user has revoked the consent on which the processing is based and there is no other legal basis for the processing,
- the user objects to the processing,
- the personal data have been processed illegally,
- data must be deleted so that the controller's legal obligation is respected; and
- personal data has been collected in connection with the provision of services in the information society. Requests for deletion of personal data are processed within one (1) month. In the event that personal data is disclosed, we, taking into account the available technology and implementation costs, shall take reasonable steps, including technical measures, to inform third parties processing such data that the Website's user has requested the deletion of any links to such data or copies or replications of personal data. Please note that there may be latency in deleting your personal information from our servers and backup storage, and we may retain your personal information in order to comply with the law, protect our rights, resolve disputes or enforce our agreements.
8.4. You have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the General Data Protection Regulation (EU) 2016/679 (GDPR).
9. DISCLAIMER ON THIRD-PARTY WEBSITES
9.1. Links to third-party websites. When you visit our Site, you may be forwarded to third-party internet pages which are not under our control. These links are set up to make it easier for you to use the internet. Please be aware that we are not responsible for the privacy practices or content of such other sites and expressly disclaim any liability for any loss or damage that may be caused by the use of such links. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personally identifiable information.
9.2. Social media platforms and widgets. We also maintain presences on social media platforms including Facebook, Twitter, Pinterest, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
10.1. We may email you to inform you about changes in our Website, our offerings / discounts, and important service-related announcements such as security and fraud notices. We will also send you emails related to your transactions with us. These communications are considered part of our services and you may not opt out of them.
10.2. We may also send you marketing or promotional communications. Such messages are sent only if you subscribe to them and for as long as you wish. You can opt out of receiving subsequent marketing or promotional communications by emailing us at email@example.com.
12. FINAL PROVISIONS
We respect and esteem the users of our Website and their privacy. Therefore, we want to hear from you, if you have any questions, comments or complaints about our privacy practices, or if you want to update, delete, or change any personal information we hold. You can email us at firstname.lastname@example.org or mail us to "IC Products SA, Via Santa Maria 68a, 6596 Gordola, Switzerland".