1           Privacy Policy

2             INFORMATION ABOUT COLLECTION AND PROCESSING OF YOUR PERSONAL DATA

Care and transparency are the foundation for trusting cooperation with our customers. Therefore, we are informing you about how we process your data and how you can exercise the rights you have under the General Data Protection Regulation. What personal data we process and for what purpose depends in each case on the contractual relationship.

3             1. WHO IS RESPONSIBLE FOR DATA PROTECTION?

The responsible party is:

appoff.com

Route de L’Ancienne Papeterie

1723 Marly

Switzerland

4             2. HOW CAN YOU CONTACT THE DATA PROTECTION OFFICER?

You can contact our Data Protection Officer under:

appoffdotcom@gmail.com

5             3. WHAT PERSONAL DATA OF YOURS DO WE USE?

If you make an enquiry, get a quote from us or enter into a contract with us, we process your personal data. We also process your personal data for other purposes, including fulfilment of legal duties, protection of a legitimate interest or due to consent that you have given.

The following categories of personal data: are concerned, depending on the legal basis:

–  Name
– First name, Surname
– Official address
– Official communication data (telephone, e-mail address)
– Basic contract data especially contract number, period, notice of termination, type of contract
– Sales and invoicing data
– Payment and account data
– Account information, particularly registration and log-ins

In the course of setting up the contract we will also access data which has been provided to us by third parties. The following types of personal data are concerned, depending on the type of the contract:

– Information about credit standing (via credit agencies)

6             4. WHAT ARE THE SOURCES OF THE DATA?

We process personal data which we receive from our customers.

and/or

We receive personal data from the following places:

– Credit agencies
– Publicly accessible sources: Trade or association registers, record of debtors, land registries
– Other group companies
– Websites

7             5. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA AND ON WHAT LEGAL BASIS?

We process your personal data particularly under consideration of the General Data Protection Regulation (GDPR) and the Federal Data Protection Law and all other applicable laws.

8             5.1 Due to consent that you have given

If you have declared your voluntary consent for us to collect, process or transfer certain personal data, then this consent constitutes the legal basis for processing this data.

In the following cases, we will process your personal data on the basis of consent given by you:

– Contact form: Personal data is collected by us if you give this to us yourself, for example if you get in contact with us. If we ask for inputs on our contact form that are not required to make contact, we have marked these as optional. These details help us to make your enquiry more concrete and deal more efficiently with your issue. Supply of these details is on an entirely voluntary basis and with your consent. Where this concerns communication channels (for example-mail addresses, telephone numbers), you also consent to us possibly contacting you via these channels to answer your issue.
– Sending of an e-mail newsletter
– personalized newsletter tracking
– Market research (e.g., customer satisfaction survey)
– Marketing and advertising- formation of customer profiles
– Publication of a customer reference (name and picture)

9             5.2 To fulfill a mediation

We use your personal data to complete a contractual obligation. Within this contractual relationship, we will process your data in particular to carry out the following activities:

– Contract-related contact
– Ongoing customer support, Service Centre
– Account administration
– Accounts receivable management
– Tracking and tracing Delivery/shipment of consignment/notification of problems
– Passing to the service provider concerned for fulfilment of contract

10          5.3 For fulfilment of legal obligations or in the public interest

As a company, we are subject to various legal obligations. It may be necessary to process personal data to discharge these obligations.

– Duties of checking and reporting
– Prevention/defense of illegal acts
– IATA guidelines

11          5.4 Due to a legitimate interest

In certain cases, we will process your data to protect our legitimate interest or that of a third party.

– Direct marketing or market and opinion research
– Central customer data management in the group of companies
– Consultation and data exchange with credit agencies to establish credit or default risks
– Guarantee of IT security and the IT operation
– Use of cookies on our homepage that are necessary to provide our services.

12         6. TO WHOM IS YOUR DATA PASSED ON?

Your personal details will be disclosed to various internal or public bodies to fulfil our contractual and legal obligations.

Companies in the group of companies:

The App Off Group maintains a central customer administration which is accessible to the employees of all companies in order to be able to offer the whole spectrum of our services from one point. The companies in the App Off Group can call you up under this link www.appoff.com.

External service providers

– IT service providers (e.g., servicing providers, hosting providers)
– Service providers for File and data destruction
– Print service providers
– Telecommunication
– Payment service providers
– Advice and Consultation
– Service providers for marketing or sales
– Credit agencies
– Contract traders
– Carrier (Airlines, Freight forwarders, Trucker)
– Service providers for telephone support (call center)
– Webhosting service provider

Public bodies

Furthermore, we may be obliged to pass your personal data to other recipients, such as to authorities, to fulfill legal obligations of disclosure.

– Tax authorities
– Customs authorities
– Social security agencies
– Responsible authorities for reporting of contraventions of the IATA guidelines

13         7. IS YOUR DATA TRANSFERRED TO COUNTRIES OUTSIDE SWITZERLAND AND THE EUROPEAN UNION (SO-CALED THIRD COUNTRIES)?

Countries outside Switzerland and the European Union (and the European Economic Area, EEA) deal differently with the protection of personal data to countries within the European Union. We also employ service providers located outside the European Union for processing your data. There is currently no resolution of the EU Commission that these third countries generally offer an appropriate level of protection.

We have taken special measures to ensure that your data is processed just as securely in these third countries as it would be in Switzerland and the European Union. We sign data protection clauses provided by the Commission of the European Union with service providers in third countries. These clauses provide guarantees for the protection of your data with service providers in third countries.

If you wish to inspect the existing guarantees, you can contact us under appoffdotcom@gmail.com

14         8. HOW LONG IS MY DATA STORED?

We will store your personal data as long as is required to fulfil our legal and contractual obligations.

If storage of data is no longer required to fulfil our legal and contractual obligations, your data will be deleted unless

– Fulfilment of duty to retain for reasons of tax and trade law. The retention periods are 10 years.
– Preservation of evidence in the context of legal statute of limitation. The regular statute of limitation is 3 years.

15         9. WHAT RIGHTS DO YOU HAVE IN CONNECTION WITH PROCESSING MY DATA?

Every affected person has the right to information, the right to correction in accordance, the right to deletion in accordance, the right to restriction of processing in accordance, the right to objection in accordance and the right to data transferability in accordance. The restrictions in accordance to the right to information and deletion apply.

16          9.1 Right to object

You can object at any time to the use of your data for promotional purposes without incurring costs other than the transmission costs at the basic tariff. Specifically, you can unsubscribe from the newsletter by clicking the link provided at the end of the newsletter.

• What rights do you have in case of data being processed due to your legitimate interest or the public interest?

You have the right, in accordance, for reasons arising from your particular situation, to object to the processing of personal data relating to you arising (data processing in the public interest) or (data processing for protection of a legitimate interest), and this applies to any profiling supported by this regulation.

In the event of your objection, we will no longer process your personal data unless we can demonstrate compelling reasons to do so that outweigh your interests, rights and freedoms, or the processing is for the purpose of making, exercising or defending legal claims.

• What are your rights in relation to data processing for operation of direct advertising?

If we process your personal data to operate direct advertising, then you have the right to object to the processing of the personal data relating to you for the purpose of this kind of advertising; this also applies to profiling, if this is in connection with such direct advertising.

If you object to the processing for purposes of direct advertising, we will no longer process your personal data for these purposes.

17          9.2 Withdrawal of consent

You can withdraw your consent to the processing of your personal data at any time. Please note that this withdrawal is only effective for the future. Specifically, you can unsubscribe from the newsletter by clicking the link provided at the end of the newsletter.

18          9.3 Right to Information

You have the right to demand that we tell you whether we are storing your personal data. If you wish, we will inform you what data is concerned, for what purposes the data is processed, to whom this data is disclosed, how long it is stored for and what other rights you have in relation to this data.

19          9.4 Further Rights

Furthermore, you have the right to have incorrect data corrected or the deletion of your data. If there is no further reason to store your data, we will delete it or restrict processing of it. You can also require us to make available to you or to a person in an organization of your choice, all personal data that you have provided us with in a structure, accessible and machine-readable format.

In addition, there is a right to complain to the responsible Data Protection Authority.

20          9.5 Exercising your rights

To exercise your rights, you can approach the responsible person or the Data Protection Officer under the contact details given, and especially at: appoffdotcom@gmail.com. We will process your enquiry immediately and in accordance with legal stipulations and inform you what actions we have taken.

21         10. IS THERE AN OBLIGATION TO PROVIDE YOUR PERSONAL DATA?

To enter into a business relationship with us, you must provide us with the information necessary for execution of the contract or that we are required to collect due to legal stipulations. If you do not provide us with this data, then processing and carrying out the contractual arrangements will not be possible for us.

22         11. DATA COLLECTION AND PROCESSING ON OUR WEB-PAGES

When our website is called up, we temporarily store general technical information such as the software and hardware you are using, the IP address of the requesting computer, the internet page from which you are visiting us, along with the date, time and duration of your visit. We only collect this data to guarantee the functionality of our website.

Our website uses cookies to enable the use of certain functions. Cookies are files that are placed on the hard-drive of your computer and make navigation easier. It avoids you having to re-submit all required data at each use. Cookies help us to tailor our website precisely to your needs, e.g., your language.

The use of cookies is required to provide our services and therefore rests on a legitimate interest.

23         12. CHANGES TO THIS INFORMATION

If the type of data processing should change significantly, this information will be updated promptly, and you will be informed promptly of the changes.