Statement of data protection


This privacy statement from myfreelap.com, a service of Freelap SA, informs you of the way in which we process your data whether it is through the use of our websites and mobile applications or in any other way. Regarding these portals, we are responsible for the processing of your personal data and the compatibility of their treatment with the law. To do this, we comply with the provisions in force regarding data protection.


"Personal data" means all individual information concerning the personal and material situation of an identified or identifiable natural person. This means that it is information that can be attached to you and provide information about you. These data protection provisions also use the wording "your data". The term "processing" means any handling of your data, in particular the collection, recording, management, use, transmission, disclosure or deletion of your data.


Please note that the following information can be adapted at any time. We therefore recommend that you review this privacy statement on a regular basis. The websites of third parties accessible via our portal are not subject to the principles laid down here. We are not responsible for the respect of data protection by third party sites.


Below you will find information about the nature of your personal data that we collect and store when you visit our portals, how we use this data and who we can pass it to, if applicable. In addition, you will find information about the rights you hold against us regarding the use of your data:


1 Scope and purpose of the processing of personal data


a. During visits to our portals

If you use our digital offerings without providing further guidance, the web server technology we use automatically saves general technical navigation data in so-called log files. This includes, among other things, the IP address of the device used for the visit, the data relating to the type of browser, the internet service provider and the operating system used, our digital offers consulted, the landing pages/ exit, date and duration of the visit.

The purpose of the collection and processing of this information is to allow the use of our websites (connection), to ensure and strengthen the security and stability of our systems and our offers, to analyze the use of our offers and services, gather general demographic information and optimize our internet offer (in particular but not only product improvement, marketing measures, targeted advertising etc.), as well as internal statistics. The user is not identified. Similarly, there is in principle no link between this information collected automatically and the personal data registered with us. However, there may be an exception to this rule of principle if you already have a registered user account on one of our portals. You will find in numbers 1.b and 1.c below more detailed information concerning the treatment of the personal data of registered users.

We may use personal data about you that you may have disclosed using a free service or with your message (email address, phone number, etc.) for marketing or analysis purposes. You will find further in section 4 more specific information on the processing of personal data for marketing or analysis purposes.

We can - if necessary by adapting the format - publish on other platforms and media (e.g in newspapers) the information you have published on our portal.

If you access our portals through a mobile device, we ask for your permission before determining your exact location using GPS or other tools.

In addition, we use cookies and analytics tools (for example, Google Analytics) when visiting our portals. In this regard, we refer you to chs. 9 and 10 of these data protection provisions.


b. When opening a user account

Your registration and the creation of a user account are required for the use of our personalized services or access to protected areas. It is then necessary that you provide certain personal data. This includes, for example, your e-mail address which can at the same time serve as a username,


- your email address which can at the same time serve as a username,

- a password and other data, if any, depending on the context and the offer, such as

- the name and the first name

- the address (complete postal address, postcode, locality)

- phone number

- the birth date

- sex

- information about subscription newsletters or other advertisements

- preferred language


In addition to the data marked as mandatory for the use of a specific digital offer, you may freely provide and save other personal data.

We use the data for the provision and management of our digital offerings, to check the plausibility of the data provided, ie. for the justification, the structure of the content, the realization and the modification of the contractual relations concluded with you concerning your user account.

All contributions posted (comments, photos, videos, etc.) through the corresponding functions of our portals to share with other users, are in no way disclosed and publicly available. This also applies to your username or a pseudonym that you may have chosen for this purpose.

By confirming the entry and transfer of your user account data during registration, you guarantee the accuracy of the data you have entered.


c. When using a portal as a registered user

When using the portal by a registered user, we collect the data for statistical reasons in order to allow the portal to function properly and to analyze, optimize and personalize the use of our offers and services. We collect data about your use of our digital offerings, including which features you use. You will find further information on the processing of this personal data in numbers 1.d and 4.


2 Direct Marketing and Online Advertising


Following your registration on our portal, we may use your personal data also for personalized advertising purposes. This concerns as well the personalization of advertising by e-mail such as e-mails containing general information or with an advertising character (newsletter), by telephone, mail, telefax, text messages, image messages as well as via instant messaging as the provision of personalized content and advertising on our portals.

To this end, we can automatically analyze the information about your behavior on our portals as a user that is brought to our attention, to prevent you from receiving inappropriate advertising. You can consult these treatments in paragraph 4.

By creating a user account, you automatically subscribe to our newsletter and your email address can also be used for our own ads until you unsubscribe from the newsletter. You will find at the end of each e-mail sent by us a link allowing you to unsubscribe from the newsletter at any time.

You can also unsubscribe from the newsletter at any time by sending an e-mail to

contact@myfreelap.com.

Unsubscription is possible at any time.

We are entitled to mandate third parties for the technical treatment of advertising measures and for our own advertising and to transmit your data to this effect (see section 3 below).


3 Transmission of data to third parties


We work with other companies or people and mandate them for processing as well as recording data. These may gain access to your personal or usage data, but only to the extent necessary for the performance of their tasks.

The transmission of data to companies according to this number 3 is in principle done with pseudonymized or anonymized data. That is to say, it is no longer possible, without collecting additional information, to make the connection between you and these data. We ensure, by contract and by means of technical and organizational measures within companies that it is no longer possible to identify individuals.

In addition, we transmit your data to third parties to the extent necessary for the performance of the contract. To this end, we may transmit the required data to transport companies, banks and other service providers. These service providers use your data exclusively for processing the order and not for other purposes. To the extent necessary for the purposes mentioned in the first sentence, the data may also be transmitted abroad, for example to deliver goods. You will find more information about the transmission of data abroad under number 5.

The personal data about you that you make available to us are not sold, rented or exchanged outside Freelap SA.

Except for the transmissions described above, we transmit your personal data only if you have expressly consented to it, if there is a legal obligation to do so or if we need to do so to enforce our rights, including those arising from the contractual relationship.

In case of sale, merger or any other reorganization of all or part of the assets of our company, personal data may be transferred, sold or otherwise shared with third parties as part of said transaction or reorganization.


4 Processing of your personal data for marketing and analysis purposes


Freelap SA aims to continuously improve the digital offers that are offered, to structure them according to the needs and in a more secure way.

To this end, various analytical tools can be put in place to link user-specific data, future and past, which we have at our disposal and to analyze, aggregate, pseudonymize and anonymize user behavior at the aggregate level of our offers. In order to update our database, we may use publicly available data or data from third-party providers. Results from your use of our services can be used and evaluated as part of user behavior analysis by other participating companies. This data processing relies above all on pseudonymized or anonymized data. Its purpose is in particular to send you or to post on one of our portals anonymous advertising in accordance with number 2 as well as to improve the security of our portals.


5 Transmission of personal data abroad


We are entitled to transfer your personal data to third-party companies (authorized service providers) located abroad, as long as this is appropriate for processing the data described in this data protection declaration. These are subject to the obligation of data protection to the same extent as us. If the level of data protection in a country does not match that of Switzerland, we ensure through contracts that the protection of your personal data corresponds to the level of protection in Switzerland. We do this by one or more of the following measures:

• by concluding standard EU contract clauses with mandated service providers, cf.

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_fr

• ensuring that the mandated service providers are Swiss-US or EU-US Privacy Shield certified (provided that the data recipient is based in the USA or if the data is stored there), cf.

https://www.privacyshield.gov/

• by the presence of Binding Corporate Rules (BCR) recognized by a European Data Protection Authority among mandated service providers, cf.

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en


6 Right to information, rectification, deletion or in case of complaint


You have the right to invoke your data protection rights at any time and to require information about the personal data about you that we process. You can also at any time rectify, block or delete your personal data by informing us in writing and by justifying your identity to the following address:

contact@myfreelap.com

We reserve the right to correspond with you on this subject.

Please note that we are required to keep some of your personal data as part of our legal custody obligations even after your request for blocking or deletion and in this case only to block your personal data in the extent of what is required. In addition, the deletion of your personal data may have the effect of preventing you from continuing to acquire or use the services you have registered.

Under certain conditions, you can ask us to transmit to you or to a third party designated by you, your personal data in a common format.

You may object at any time to the processing of your data for marketing and advertising purposes as well as to the transmission of your data within Freelap SA according to numbers 2 and 4 by e-mail.

Such opposition does not entirely exclude the collection of personal data. Under the following link you can prevent the collection of your usage data. The opposition excludes only collected personal data from being treated in a non-anonymous way for marketing purposes as well as transmitted to other companies for this purpose and processed by them.

Excluding totally or, at least, reducing the collection of personal data requires performing the steps mentioned in number 8 concerning the deactivation of cookies. This may have the effect of preventing you from using the services you have ordered In addition, you are entitled to take action against the processing of the data with the competent supervisory authorities. You can do this at the supervisory authority in your home, at your place of work or at the place of the alleged breach of data protection.


7 Retention period of your personal data

We only keep your data for the legal or necessary duration of the treatment. During analyzes, we only save your data until the end of the process. If we save your data under a contractual relationship with you, we will only retain it for the duration of this relationship and at most the limitation periods of any claims in our favor or if the law or contractual provisions provide.


8 Data security

We employ appropriate technical and organizational security measures to protect your personal data stored on our premises from unauthorized, illegitimate, unauthorized manipulation, deletion, modification, access, transmission or use and from total or partial loss. Our security measures are continuously adapted and improved in line with technological advances. We do not accept any liability for the loss of data or the communication of these data to third parties and their use by them.

If you register with us as a user, access to your user account is only possible with your personal password.

We also consider data protection very seriously internally. Our employees and those of the service providers we have appointed are bound by the secrecy and the respect of the legal data protection provisions.


9 Cookies

Cookies help us to better organize your visit on our websites to make it easier, more pleasant and more relevant. Cookies are files containing information that the internet browser automatically saves to your computer's hard drive during your visit to our website.

Cookies do not damage the hard drive of your computer nor do they send us the personal data of the users.

For example, we use cookies to find out who has visited our portal and how often certain pages or offers are viewed, which parts of the portal are particularly popular and how the portal is used. We use other cookies so that you can freely browse our portal and use its functions such as access to protected areas. The use of cookies also makes it possible to use the choices you have made or the decisions you have made as parameters to make your visit on our portal more enjoyable. In general, the use of cookies serves to improve our services and make them more efficient and safer. Most internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or you are always informed when you receive a new cookie.

Our digital offers can in principle be used even in the absence of cookies, although some functions may be limited.


10 Monitoring and Analysis Tools

The use of our digital offerings is further measured and analyzed by various technical systems, mainly from third-party vendors such as Google Analytics. These measurements can be done anonymously or not. It is then possible that the collected data will be passed on to third parties for processing by us or third party providers of these technical systems for processing. The most used analysis tool is Google Analytics, a service of Google Inc. Thus, the collected data can in principle be transmitted to a Google server in the United States, but IP addresses are anonymized by an ad -hoc process so that no association is possible. This way Google will not be able to associate the IP address transmitted by your browser as part of Google Analytics with other data that it has about you. It is possible to oppose the entry and processing of this data by Google Analytics by installing an opt-out cookie that prevents future data entry during your browsing this website:

https://tools.google.com/dlpage/gaoptout?hl=en


11 Plug-ins and other integrations of offers from third parties

Our digital offerings are connected in a variety of ways to third-party functions and systems, for example through the integration of third-party social plug-ins such as Facebook, Google Plus.

If you have a user account with these third parties, they may also be able to measure and analyze your use of our digital offerings. Other personal data such as the IP address, personal browser settings and other parameters can then be transmitted to and stored by these third parties. When you use a connection service through social networks such as Facebook Connect, the provider may send us personal data such as name, e-mail address and profile photo, which are stored at the provider. We do not exercise any control over the use of such personal data collected by third parties and disclaim any liability.


12 Legal basis

We only process your personal data as part of the data processing principles and if there is a legal basis. This legal basis exists during the preparation and execution of our contract. In addition, there is an interest for us to constantly improve our offers, in order to adapt them to your needs. This is necessary to continue to develop and finance our offers and to guarantee their security. We therefore start from the premise that our interests prevail. If you have consented to the processing of your data, it is valid.


13 Contact

If you have any questions regarding the protection of data on our website, if you wish to obtain information or request the deletion of your data, please contact our contact in charge of data protection law sending an e-mail to the following address:

contact@myfreelap.com.


14 Updating and changes to the data protection provisions

The development of our website or the implementation of new technologies may make it necessary to modify the present data protection provisions. Each important modification of these provisions is communicated to the registered users by e-mail to the electronic address indicated at the time of registration or by a corresponding mention placed appropriately after connection to the user account.

You can also consult the data protection provisions currently in force on our website at any time and print them out.

The original privacy statement is in French. The translated versions are intended to facilitate a better understanding. In case of divergences, the French text is authentic.

Version: May 25, 2018

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