Data Privacy

1.  Introduction

Data protection, data security and the responsible handling of personal data are important to Amazee Labs (“Amazee Labs”, “we”, “us”).

In this privacy policy, we describe how we collect and process personal data (information that relates to a person and identifies this person directly or indirectly). Also this policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. Please refer to our Cookie Notice for more information to learn how we are using cookies. You can manage your preferences relating to the use of cookies on our website by visiting the Cookie Settings.

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via URL.

By using our Sites or by giving us your personal data, you accept the practices described in this Privacy Notice. If you do not agree to this Privacy Notice, please refrain from using or visiting our Sites or providing personal data.

2.  How we use your personal data

In this Section 2 we have set out:

• the general categories of personal data that we may process;
• in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
• the purposes for which we may process personal data; and
• the legal bases of the processing.

We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system Matomo. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your consent and our legitimate interests, namely monitoring and improving our website and services. You may opt-out of this at any point by visiting our preference center: Preference Center

We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your salutation, first name, last name, email address, mobile phone number, place of residence, city, post code, country, company, job title, language. The legal basis for this processing is consent.

We may process information contained in any enquiry you submit to us regarding services, namely website design and development services (“enquiry data“). The enquiry data may include your first name, last name, email address, mobile phone number, city, post code, country, company. The enquiry data may be processed for the purpose of supplying the services mentioned above and keeping proper records of those transactions. The legal basis for this processing is consent.

We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Please do not enter any personal data in the site search box.

3.  Providing your personal data to others

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose personal data which may include IP address, geographical location, browser type and version, operating system, your email address to our hosting providers, IT-providers and social networks, providers such as:

– Facebook, LinkedIn, Google Analytics, Google Ads,
insofar as reasonably necessary to provide you with the requested service.

We may disclose (“usage Data“) to our advertising, analytics and social media providers insofar as is reasonably necessary to measure the success of and improve our advertising and social media efforts. This personal data may include IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. These advertising providers include Facebook, Google Adwords, Google DoubleClick, LinkedIn, Twitter and Youtube. The legal basis for this processing and provision is consent. You may opt-out of this at any point by visiting our Preference Center.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.  International transfers of your personal data

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to a country outside of your country of domicile and the European Economic Area (EEA), potentially including countries such as the United States, whose data protection laws may differ from those in the country in which you are located.

Our Advertising and Social Media providers, listed in section 3, are located in the United States of America. The European Commission and Switzerland has made an “adequacy decision” with respect to the General Data Protection Regulation and Federal Data Protection Act. Transfers to the United States of America will be protected by appropriate safeguards, namely the EU and Swiss approved Standard Contractual Clauses (SCCs) included in contracts with our providers.

5.  Retaining and deleting personal data

This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data for a minimum of time.

It is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

• the period of retention of Usage Data will be determined based on user requests for deletion or the data is no longer required.
• the period of retention for Enquiry Data will be determined based on user requests for deletion or the data is no longer required.
• the period of retention for Notification Data will be determined based on user requests for deletion.
• the period of retention for Correspondence Data will be determined based on user requests for deletion or the data is no longer required and the correspondence has been completed.

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.  Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

7.  Your rights

In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

To the extent that the legal basis for our processing of your personal data is:

• consent; or
• that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by email or written notice to us, in addition to the other methods specified in this Section 7.

8. About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

We use cookies for the following purposes:

• personalisation – we use cookies to store information about your preferences and to personalise the website for you;
• security – we use cookies [as an element of the security measures used to protect our website and services generally;
• analysis – we use cookies to help us to analyse the use and performance of our website and services; and
• cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Please find further information about the use of cookies on our website on our Cookie Notice.

10. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Matomo Analytics to analyse the use of our website. Matomo Analytics gathers information about website without cookies since we are using the cookie-free version. The information gathered relating to our website is used to create reports about the use of our website. Matomo Analytics’s privacy policy is available at: https://matomo.org/privacy-policy/.

11. Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647?hl=en (Chrome);(b)
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• http://www.opera.com/help/tutorials/security/cookies/ (Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
• https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

12. Our details

This website is owned and operated by Amazee Labs AG.

We are registered in Switzerland under registration number CHE-113.816.951, and our registered office is at Amazee Labs AG, Förrlibuckstrasse 190, 8005 Zurich, Switzerland.

You can contact us:

• by post, to the postal address given above;
• using our website contact form;
• by telephone, on +41 43 883 06 14; or
• by email, using privacy@amazeelabs.com

13. How to contact us

Please contact us by phone at +41 43 883 06 14; email at privacy@amazeelabs.com; regular mail at Amazee Labs AG, Förrlibuckstrasse 190, 8005 Zurich, Switzerland.

This Privacy Notice is governed by Swiss law and any dispute relating to the Sites shall be brought before the Courts of Canton Zurich, Switzerland.

Amazee Labs AG, 2023