SA is a Swiss Limited Company (“Société
registered Rue de la Place-d’Armes 3, 2000 Neuchâtel, Switzerland,
under number CHE-258.642.458 (“Company”,
“us”, “our” or
handling practices when you access content we own or operate on any
websites, pages, features, or content we own or operate (“Site(s)“)
and/or when you use our web application or our mobile applications
our application programming interfaces (“API”)
or third party applications and related services (“Third
Company 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.
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
235.1), the Ordinance on the Federal Data Protection Act (RS 235.11)
and, where applicable, the General Data Protection Regulation
Data which is deemed to be personal consists of all the information
relating to a person who is either identified or identifiable
part of our commitment to protect your Personal Data in a transparent
manner, we want to inform you
and how the Company Collects, uses and stores your Personal Data,
lawful basis on which your Personal Data is Processed and
your rights and our obligations are in relation to such Processing.
terms not defined in this Privacy (hereinafter: the “Policy”)
Policy have the meanings set forth in the Terms.
read this Policy carefully to understand our policies and practices
regarding your Personal Data and how we will treat and Process them.
using the Services and/or visiting or registering on the Site(s), the
API, the Webapp (altogether: the “Platform”),
you accept the Collection and Processing described below.
this Policy, the following terms shall have the following
a systematic approach to gathering and measuring Personal Data
from the User to achieve a given result.
means any freely given, specific, informed and unambiguous by
which you, by a statement or by a clear affirmative action,
consent to the Processing of Personal data.
natural or legal person, which, alone or jointly with others,
determines the purposes and means of the Processing of Personal
Data and who is in charge of this Processing.
or legal persons whose data is processed, whether it is a User or
Personal Data accessible, for example by permitting access,
transmission or publication.
means act of God (such as, but not limited to, fires, explosions,
earthquakes, drought, tidal waves and floods), any other natural
disaster of overwhelming proportions, act of war (whether declared
or not), hostilities, invasion, act of foreign enemies, terrorism
or civil disorder, rebellion, revolution, insurrection, or
military or usurped power, or civil war, contamination by
radio-activity from any nuclear fuel, or from any nuclear waste
from the combustion of nuclear fuel, radio-active toxic explosive,
or other hazardous properties of any explosive nuclear assembly or
nuclear component of such assembly, pressure waves from devices
travelling at supersonic speeds or damage caused by any aircraft
or similar device; riot, commotion, strikes, go slows, lock outs
or threats of terrorism;
of electricity or water supply;
unforeseeable circumstances beyond the control of the Parties
against which it would have been unreasonable for the affected
party to take precautions and which the affected party cannot
avoid even by using its best efforts.
the User’s personal data, including but not limited to his last
name, first name, mailing address, email address and phone number,
the Swiss Data Protection Act (RS.235.1).
the internet website available at the following address
www.tokenestate.io and/or the API or the Webapp made available by
the Company to
means any operation or set of operation which is performed on
Personal data or set of Personal data, whether or not by automated
means, such as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure or
means third, public authority, agency or other body – that is,
someone or something other than the Data subject or the Company –
to which the Personal Data is disclosed.
means the services provided by the Company to a User and/or the
services available on the Platform.
means user(s) of the Platform provided by the Company.
means an account created by a User on the Platform, including
means a person or entity using the Platform without having
registered as a User.
of our Policy
visiting or using the Platform or the Services, the
Collect and Process a certain number of Personal Data relating to
Policy shall apply to any Visitor or User of the Platform 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.
visiting or using the Platform 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 that apply to
the Platform and agree to be bound by them.
may modify this Policy from time to time and will post the most
current version on the Platform. You will be notified by email and
you will be asked to consent to these modifications before they
accessing to and/or using the Platform and/or the Services, you
signify acceptance to the terms of this Policy. Where we require your
consent to Process your Personal Data, we will ask for your consent
to the Collection, use, and disclosure of your Personal Data.
you do not agree with or you are not comfortable with any aspect of
this Policy, you should immediately discontinue visiting, accessing
or using our Platform and/or Services.
of the Collection
uses Personal Data mainly for the purpose of improving the user
experience and the Platform and targeting the Services to your needs.
and our Service providers may use your information for our legitimate
business interests. Our legitimate business interests are explained
below, alongside examples of how your Personal Data may be used for
main reason why we Collect Personal Data about you is:
proceed to the KYC and comply with our AML obligations;
improve the Platform features and the Platform Content;
administer your Account;
identify your needs and target the Services;
fulfill your specific requests through the Platform;
enable you to enjoy and easily navigate the Platform and benefit
from the Services;
accomplish our business purposes, especially to comply with a legal
obligation, because we have a legitimate interest and/or with your
specific purposes stated below.
Personal Data will be freely provided by you to the Company or
Collected automatically while using the Platform, in accordance with
this Policy. In addition to the information contained in this Policy,
the Platform may provide Users with additional and contextual
information concerning particular services or the Collection and
Processing of Personal Data upon request.
Data transmitted to the Company by you are controlled by TOKENESTATE
SA, Rue de la Place-d'Armes 3, 2000 Neuchâtel, Switzerland.
of Personal Data Collected
Consent to this Policy followed by your submission of Personal Data
represent your agreement to the Collection, Processing and storage of
Personal Data by the Company as described in this Policy.
accessing to and/or using the Platform and/or the Services, cookies
are placed on your computer, mobile or tablet. A cookie is a piece of
data stored on your hard drive by the Company’s server. It contains
the following data:
name of the server that has placed it there
identifier, in the form of a unique number
expiration date (some cookies only)
are managed by the web browser on your computer (like Internet
Explorer, Firefox, Safari or Google Chrome).
types of cookies which have different purposes are used:
These cookies are essential to allow you to browse our Platform and
use their functionalities. Without them, services such as shopping
baskets and electronic invoicing would not be able to work.
These cookies Collect information on the use of our Platform, such
as which pages are consulted most often. These cookies enable us to
optimise our Platform and simplify browsing. These cookies do not
Collect any information which could be used to identify you. All the
information Collected is aggregated, and, therefore, anonymous.
These cookies enable our Platform to remember the choices you have
made when browsing. For example, we can store your geographical
location in a cookie so that the Platform corresponding to your area
is shown. We can also remember your preferences, such as the text
size, font and other customisable aspects of the Platform. The
cookies may also be able to keep track of the products or videos
consulted to avoid repetition. The information Collected by these
cookies cannot be used to identify you and cannot monitor your
browsing activity on sites which do not belong to the Company.
or refusing cookies:
We must remind you that reconfiguration is liable to alter the
conditions under which you access any of our services which require
cookies. You can set your browser to refuse or delete certain
cookies. As a rule, you can also manage similar technologies in the
same way, using your preferred browsers. The following links show
you how to set the cookies, depending on the browser used:
on the Services, we Collect:
details such as your name, identification number, date of birth,
KYC/AML documents (national identity card or passport, utility bill,
payslips, etc.), phone number, physical and electronic address, and
family details / status such as the name of your spouse, partner, or
password, settings and preferences;
information, including payment and transaction records and
information relating to your assets (including fixed properties),
financial statements, liabilities, taxes, revenues, earnings and
investments (including your investment objectives);
applicable, professional information about you, such as your job
title and work experience;
records of emails/written exchanges/phone calls between you and us;
applicable, details of your nomination of a mandate;
we assign to you, such as your client or account number, including
for accounting purposes;
you access our Platform, data transmitted by your browser and
automatically recorded by our server, including date and time of the
access, name of the accessed file as well as the transmitted data
volume and the performance of the access, your Operating System, web
browser, browser language and requesting domain, and IP address.
may obtain information about you from third party sources as required
or permitted by applicable law, such as public databases, credit
bureaus, ID verification partners, KCY/AML partners, resellers and
channel partners, joint marketing partners, and social media
platforms. In the case we obtain any additional information from
third parties, you will be notified by email.
for which your Personal Data will be used
will not use your Personal Data for purposes other than those
purposes we have disclosed to you, without your Consent.
maintain legal and regulatory compliance
of our core Services are subject to laws and regulations requiring us
to Collect and use your personal identification information, formal
identification information, financial information, transaction
information, employment information, online identifiers, and/or usage
data in certain ways.
Company Collects and Processed your Personal Data in order to comply
Swiss Federal Act on Combating Money Laundering and Terrorist
Financing (Anti-Money Laundering Act, AMLA) and its Ordinances (“Loi
fédérale concernant la lutte contre le blanchiment d’argent et
le financement du terrorisme (LBA) et ses Ordonnances”);
Financial Market Supervisory Authority (FINMA) Ordinance
on Combating Money Laundering and Terrorist
de l’Autorité fédérale de surveillance des marchés financiers
sur la lutte contre le blanchiment d’argent et le financement du
terrorisme dans le secteur financier (OBA-FINMA)”)
enforce our Terms in our User agreement and other agreements
Process Personal Data, such as your identification and financial
data, in order to actively monitor, investigate, prevent and mitigate
any potentially prohibited or illegal activities, enforcing our
agreements with third parties, and/or violations of our agreements.
addition, we may need to Collect fees based on your use of our
Services. We Collect information about your account usage and closely
monitor your interactions with our Services. We may use any of your
Personal Data Collected on our Services for these purposes. The
consequences of not Processing your Personal Data for such purposes
is the termination of your Account as we cannot perform our Services
in accordance with our Terms.
provide the Services
cannot provide you with Services without being able to use and
Process your Personal Data.
provide Service communications
send administrative or account-related information to you to keep you
updated about our news (provided you have subscribed to our
newsletter) or inform you of relevant security issues or updates to
the Platform or the Services, changes of the Terms or to this Policy
or provide other transaction-related information. Without such
communications, you may not be aware of important developments
relating to your Account that may affect how you can use our
provide customer service
Process your Personal Data when you contact us to resolve any
questions, disputes, Collect fees, or to troubleshoot problems. We
may Process your information in response to another customer’s
request, as relevant.
ensure quality control
Process your Personal Data for quality control and staff training to
make sure we continue to provide you with accurate information. Our
basis for such Processing is based on the necessity of performing our
contractual obligations with you.
ensure network and information security
Process your Personal Data in order to enhance security, monitor and
verify identity or service access, combat spam or other malware or
security risks and to comply with applicable security laws and
regulations. The threat landscape on the internet is constantly
evolving, which makes it more important than ever that we have
accurate and up-to-date information about your use of our Services.
research and development purposes
Process your Personal Data to better understand the way you use and
interact with the Services. In addition, we use such information to
customize, measure, and improve the Services and the content and
layout of our Platform and applications, and to develop new services.
Our basis for such Processing is based on legitimate interest.
enhance your experience
Process your Personal Data to provide a personalized experience and
implement the preferences you request. For example, you may choose to
provide us with access to certain Personal Data stored by third
facilitate corporate acquisitions, mergers, or transactions
may Process any information regarding your account and use of our
Services as is necessary in the context of corporate acquisitions,
mergers, or other corporate transactions. You have the option of
closing your account if you do not wish to have your Personal Data
Processed for such purposes.
engage in marketing activities
on your communication preferences, you Consent that we may send you
marketing communications to inform you about our events or our
partner events; to deliver targeted marketing and to provide you with
promotional offers based on your communication preferences. We use
Personal Data about your usage of our Services and your contact
information to provide marketing communications. You can opt-out of
our marketing communications at any time.
Data Disclosure & Sharing
staff use and Process usually Personal Data in order to ensure a
consistently high service standard, to provide Services to you.
providing products and services to you, we will share Personal Data
with persons acting on our behalf or otherwise involved in the
transaction (depending on the type of product or service you receive
some instances, you Consent that we may also share Personal Data with
our suppliers and other business partners who provide services to us,
such as IT and hosting providers, marketing providers, communication
services and printing providers, debt Collection, tracing, debt
recovery, fraud prevention, and credit reference
agencies, KYC/AML, and others. When we do so we take steps
to ensure they meet our data security standards and sign
confidentiality agreements, so that your Personal Data remains
or regulatory authorities
required from time to time, we disclose Personal Data to public
authorities, regulators or governmental bodies, including when
required by law or regulation, under a code of practice or conduct,
or when these authorities or bodies require us to do so.
our business is sold to another organization or if it is
re-organized, Personal Data will be shared so that you can continue
to be provided with the Services.
will usually also share Personal Data with prospective purchasers
when we consider selling or transferring part or all of our business.
We will in such event take steps to ensure such potential purchasers
keep the data secure.
understand and agree that we may need to disclose Personal Data to
exercise or protect legal rights, including ours and those of our
employees or other stakeholders, or in response to requests from
individuals or their representatives who seek to protect their legal
rights or such rights of others.
& Transfer of Personal Data
Personal Data will be stored and hosted in Germany.
hereby expressly Consent to such transfer outside Switzerland but
within a country of the European Union where GDPR is applicable.
where the relevant country has been determined by the Swiss Federal
Data Protection and Information Commissioner and the European
Commission to provide an adequate level of protection, the
Company requires its recipients to comply with appropriate measures
designed to protect Personal Data contained within a binding legal
agreement. A copy of these agreements can be obtained by
Company using the details in section 15 of this Policy. If
and to the extent required by applicable law, we implement the
necessary legal, operational and technical measure and/or enter into
an agreement with you before such international transfers.
Controller of your Personal Data, we work with Processors in order to
provide high quality of the Services. All our Processors are GDPR
compliant and agreements have been setup between them and us in order
to define exactly which Personal Data are shared and which legal
requirements should be applied.
of Personal Data
will only retain Personal Data for as long as necessary to fulfil the
purpose for which it was Collected or to comply with legal,
regulatory or internal policy requirements. To help us do this, we
apply criteria to determine the appropriate periods for retaining
your Personal Data depending on its purpose, such as proper account
maintenance, facilitating client relationship management, and
responding to legal claims or regulatory requests.
do not request to Collect or Process Personal Data from any person
under the age of 18. If a User submitting Personal Data is suspected
of being younger than 18 years of age, the Company will require the
User to close his or her account and will not allow the User to
continue using any Service. We will also take steps to delete the
information as soon as possible. Please notify us if you know of any
individuals under the age of 18 using our Services so we can take
action to prevent access to our Services.
of your Personal Data
security of your Personal Data is very important to us. The Company
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.
use internal rules with our staff and partners and use software,
hardware, IT providers and datacenters which provide maximum
Services use strong cryptographic standards such as HTTPS protocol.
follow the evolving of the technology and the Art in order to
continuously offer the best quality, security and protection of our
Services. We continuously assess and change our internal procedures
accordingly with our staff, partners and providers.
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 the Company, in
some cases, the Personal Data may be accessible to certain types of
persons in charge, involved with the operation of the Platform
(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 the Company.
The updated list of these parties may be requested from the Data
Controller at any time.
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, the Company 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.
HOWEVER ACKNOWLEDGE THAT THE USE OF THE INTERNET IS NOT SAFE AND THAT
THERE ARE CERTAIN INHERENT RISKS TO YOUR PERSONAL DATA. THE COMPANY
SHALL MAKE REASONABLE EFFORTS TO PROTECT YOUR PERSONAL DATA BUT IT
CANNOT GUARANTEE OR WARRANT THAT PERSONAL DATA YOU PROVIDE TO THE
COMPANY IS SAFE AND PROTECTED FROM UNAUTHORIZED THIRD PARTY ACCESS
AND THEFT AND, THEREFORE, WAIVES ALL LIABILITY IN THIS RESPECT. IN NO
EVENT, SHALL THE COMPANY BE HELD LIABLE FOR CIRCUMVENTION OF ANY
PRIVACY SETTINGS, VIRUSES OR SECURITY MEASURES CONTAINED ON THE
the security of your data is protected with our best effort, you
agree that the Company should not, in any case, be held responsible
for any lost, damages, unauthorized manipulation, access or
modification in case of events beyond our control, such as and not
electronic attack (not exhaustive): DDoS, Penetration, Brute-Force,
attack (not exhaustive): Fishing by email/writing/call, MITM, Fake
behaviour (not exhaustive): weak or disclosed user/password, Stolen
user/password, Stolen Key;
Activities (not exhaustive): Fake ID, Stolen ID, physical break-in;
with unsecure means (not exhaustive): email, phone, SMS, Fax;
Platform uses Google Analytics, an Internet Platform analysis service
which are text files placed on your computer to help to analyse the
use made of the Platform by its Users. The data generated by the
cookies concerning your use of the Platform (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 Platform, compile reports on Platform
activity for its publisher and provide other services relating to the
activity of the Platform 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.
on your web browser. However, deactivation of this kind might prevent
the use of certain functions of this Platform. By using this
Platform, you specifically Consent to the Processing of your Personal
Data by Google under the conditions and for the purposes described
have a right to ask the Company to rectify inaccurate Personal Data
we Collect and Process and the right to request restriction of your
Personal Data pending such a request being considered. Where we
Process your Personal Data on the basis of your consent, you have the
right to withdraw that consent at any time. Please also note that the
withdrawal of consent shall not affect the lawfulness of Processing
based on consent before its withdrawal.
have a right to ask us to stop Processing your Personal Data, or to
request deletion of your Personal Data – these rights are not
absolute (as sometimes there may be overriding interests that require
the Processing to continue, for example), but we will consider your
request and respond to you with the outcome. When Personal Data are
Processed for direct marketing purposes, your right to object extends
to direct marketing, including profiling to the extent it is related
to such marketing.
may object to direct marketing by clicking the “unsubscribe” link
in any of our emails to you, or by contacting us by
the address set out in section 15. Where we Process your
Personal Data on the basis of your consent, or where such Processing
is necessary for entering into or performing our obligations under a
contract with you, you may have the right under applicable data
protection laws to request your Personal Data be transferred to you
or to another controller.
have the right to ask the Company for a copy of some or all of the
Personal Data we Collect and Process about you. In certain
circumstances the Company may Process your Personal Data through
automated decision-making, including profiling.
this takes place, you will be informed of such automated
decision-making that uses your Personal Data, be given information on
the logic involved, and be informed of the possible consequences of
such Processing. In certain circumstances, you can request not to be
subject to automated decision-making, including profiling. You can
exercise the rights by contacting us by
the details in section 15 of this notice.
to withdraw consent.
You have the right to withdraw your consent to the Processing of your
Personal Data Collected on the basis of your consent at any time.
Your withdrawal will not affect the lawfulness of the Company’s
Processing based on consent before your withdrawal.
of access to and rectification of your Personal Data.
You have a right to request that we provide you a copy of your
Personal Data held by us. This information will be provided without
undue delay subject to some fee associated with gathering of the
information (as permitted by law), unless such provision adversely
affects the rights and freedoms of others. You may also request us to
rectify or update any of your Personal Data held by the Company that
is inaccurate. Your right to access and rectification shall only be
limited where the burden or expense of providing access would be
disproportionate to the risks to your privacy in the case in
question, or where the rights of persons other than you would be
You have the right to request erasure of your Personal Data that: (i)
is no longer necessary in relation to the purposes for which it was
Collected or otherwise Processed; (ii) was Collected in relation to
Processing that you previously consented, but later withdraw such
consent; or (iii) was Collected in relation to Processing activities
to which you object, and there are no overriding legitimate grounds
for our Processing. If we have made your Personal Data public and are
obliged to erase the Personal Data, we will, taking account of
available technology and the cost of implementation, take reasonable
steps, including technical measures, to inform other parties that are
Processing your Personal Data that you have requested the erasure of
any links to, or copy or replication of your Personal Data. The above
is subject to limitations by relevant data protection laws.
to data portability.
If we Process your Personal Data based on a contract with you or
based on your consent, or the Processing is carried out by automated
means, you may request to receive your Personal Data in a structured,
commonly used and machine-readable format, and to have us transfer
your Personal Data directly to another “controller”, where
technically feasible, unless exercise of this right adversely affects
the rights and freedoms of others. A “controller” is a natural or
legal person, public authority, agency or other body which, alone or
jointly with others, determines the purposes and means of the
Processing of your Personal Data.
to restriction of or Processing.
You have the right to restrict or object to us Processing your
Personal Data where one of the following applies:
contest the accuracy of your Personal Data that we Processed. In such
instances, we will restrict Processing during the period necessary
for us to verify the accuracy of your Personal Data.
Processing is unlawful and you oppose the erasure of your Personal
Data and request the restriction of its use instead. We no longer
need your Personal Data for the purposes of the Processing, but it is
required by you to establish, exercise or defence of legal claims.
You have objected to Processing, pending the verification whether the
legitimate grounds of Coinbase’s Processing override your rights.
Personal Data shall only be Processed with your consent or for the
establishment, exercise or defence of legal claims or for the
protection of the rights of another natural or legal person or for
reasons of important public interest. We will inform you if the
restriction is lifted.
of erasure, rectification and restriction.
We will communicate any rectification or erasure of your Personal
Data or restriction of Processing to each recipient to whom your
Personal Data has been disclosed, unless this proves impossible
or involves disproportionate effort. We will inform you about those
recipients if you request this information.
to object to Processing.
Where the Processing of your Personal Data is based on consent,
contract or legitimate interests you may restrict or object, at any
time, to the Processing of your Personal Data as permitted by
applicable law. We can continue to Process your Personal Data if it
is necessary for the defence of legal claims, or for any other
exceptions permitted by applicable law.
individual decision-making, including profiling.
You have the right not to be subject to a decision based solely on
automated Processing of your Personal Data, including profiling,
which produces legal or similarly significant effects on you, save
for the exceptions applicable under relevant data protection laws.
to lodge a complaint.
If you believe that we have infringed your rights, we encourage you
to contact us by
the details in section 15 of this notice so that we can try to
resolve the issue or dispute informally.
can also complain about our Processing of your Personal Data to:
information requests may be addressed by e-mail to our Data
Protection Officer: email@example.com
will answer within 3 working days.
request regarding your Personal Data should be made by
a proof of your identity to:
de la Place d’Armes 3
representative in the European Union is:
par actions simplifiée à associé unique
RTE DE LASNELAZ
aware that communicating by e-mail/SMS/phone/FAX do not ensure
confidentiality, integrity and authenticity. We will not answer to
any request which will be considered unsafe or not ensuring your
any notice regarding this Policy and/or the Collection and/or
Processing of Personal Data shall be made to the Swiss Federal Data
Protection and Information Commissioner:
of the Federal Data Protection and Information Commissioner FDPIC
– 3003 Berne
the European Union: any
notice regarding this Policy and/or the Collection and/or Processing
of Personal Data shall be made to:
+43 1 52152 2550
de la protection des données (APD-GBA)
de la Presse 35
+32 2 274 48 00
+32 2 274 48 35
Mr Willem Debeuckelaere, President
for Personal Data Protection
Prof. Tsvetan Lazarov blvd.
+ 359 2 915 3580
+359 2 915 3525
Personal Data Protection Agency
+385 1 4609 000
+385 1 4609 099
for Personal Data Protection
Box 23378, CY-1682 Nicosia
+357 22 818 456
+357 22 304 565
for Personal Data Protection
00 Prague 7
+420 234 665 111
+420 234 665 444
+45 33 1932 00
+45 33 19 32 18
Data Protection Inspectorate (Andmekaitse Inspektsioon)
+372 6274 135
Data Protection Supervisor
Rue Montoyer 30, 6th floor
+32 2 283 19 00
+32 2 283 19 50
of the Data Protection Ombudsman
+358 29 56 66700
+358 29 56 66735
Nationale de l’Informatique et des Libertés – CNIL
Place de Fontenoy
80715 – 75334 Paris, Cedex 07
+33 1 53 73 22 22
+33 1 53 73 22 00
Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
+49 228 997799 0; +49 228 81995 0
+49 228 997799 550; +49 228 81995 550
Data Protection Authority
Av. 1-3, PC 11523
+30 210 6475 600
+30 210 6475 628
National Authority for Data Protection and Freedom of Information
Erzsébet fasor 22/C
+36 1 3911 400
76 110 4800
per la protezione dei dati personali
di Monte Citorio, 121
+39 06 69677 1
+39 06 69677 3785
+371 6722 3131
+371 6722 3556
Data Protection Inspectorate
Juozapaviciaus str. 6
+ 370 5 279 14 45
+370 5 261 94 94
Nationale pour la Protection des Données
avenue du Rock’n’Roll
+352 2610 60 1
+352 2610 60 29
of the Information and Data Protection Commissioner
Floor, Airways House
Street, Sliema SLM 1549
+356 2328 7100
+356 2328 7198
AJ Den Haag/The Hague
+31 70 888 8500
+31 70 888 8501
Ochrony Danych Osobowych (Personal Data Protection Office)
+48 22 531 03 00
+48 22 531 03 01
Nacional de Protecção de Dados – CNPD
D. Carlos I, 134, 1º
+351 21 392 84 00
+351 21 397 68 32
National Supervisory Authority for Personal Data Processing
+40 31 805 9211
+40 31 805 9602
for Personal Data Protection of the Slovak Republic
07 Bratislava 27
+ 421 2 32 31 32 14
+ 421 2 32 31 32 34
Commissioner of the Republic of Slovenia
+386 1 230 9730
+386 1 230 9778
Española de Protección de Datos (AEPD)
+34 91399 6200
+34 91455 5699
+46 8 657 6100
+46 8 652 8652
Information Commissioner’s Office
Lane, Wycliffe House
– Cheshire SK9 5AF
+44 1625 545 700
+354 510 9600
https://www.personuvernd.is or https://www.dpa.is
Protection Office, Principality of Liechtenstein
+423 236 6090
+47 22 39 69 00
any part of the Platform contains links to third party’s Platforms
or pages, those third party’s Platforms or pages do not operate
under this Policy. If you choose to visit third party Platforms or
pages, you will be directed to these third party's Platforms or
pages. We do not exercise control over third party Platforms and
therefore recommend you to examine the privacy statements posted on
these other Platforms or pages to understand their procedures for
Collecting, using, and disclosing Personal Data. We reject any
party’s Platform, the Collection and use of your Personal Data by
the latter and relating to the contents of said Platforms (whether
the links are hypertext links or deep-links).
Personal Data may be accessed and stored as necessary for the uses
stated above in accordance with this Policy. While the Company may
share your Personal Data with agents and contractors in order to
perform the functions listed above, including hosting services and
Platform management, we require that they treat your Personal Data,
and limit their use, in accordance with the standards specified in
you use the Platform, you submit information to the Company that we
store in order to offer you personalized features.
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.
otherwise stated, the third parties who receive data from the Company
are prohibited to use this Personal Data beyond what is necessary to
provide the service to you, directly or by participating to our
any question and/or compliance aspects, please contact:
with Laws and Law Enforcement
Company 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 and Conditions or as otherwise required or
permitted by law.
and Applicable Law
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.
controversy, claim or dispute between a User and the Company arising
out of or relating to this Policy shall be subject to the exclusive
jurisdiction to the ordinary courts of Lausanne, Switzerland, without
prejudice to an appeal to the Swiss Federal Court.
date of issue: June 7, 2019