Effective date: 1 Jan, 2022
939 Privilege Owners Club is a non-profit association based in Switzerland, Canton Zürich (“us”, "we", or "our") which operates the website www.939privilege.club (the “Website”). We act in the capacity of a data controller with regard to the personal data processed through the Website in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
Sources of Personal Data
We obtain your personal data from the following categories of sources:
Directly from you. For example, if you submit certain personal data directly to us when contacting us;
Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect technical information about your use of the Website; and
From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.
Types and Purposes of Personal Data Personal Data
Registration of your user account. When you register your user account on the Website, we collect your first and last names, country, language, email address, interests, and professional category. We use the said information to register and maintain your user account, enable your access to the Website, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer the Website). We keep your personal data until you delete your user account.
Inquiries. When you contact us by email we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We keep your personal data until you stop communicating with us.
Comments. When you submit a comment under a blog post, we collect any information that you decide, at your sole discretion, to provide. We do not require any personal data from you. If you decide to reveal your personal data, we will use it to feature your comment and enforce our legal terms. The legal bases on which we rely are ‘your consent’ and ’pursuing our legitimate business interests’ (i.e., to ensure security of the Website and enforce our terms).
IP address. When you use the Website, we or our third-party analytics service providers (as explained in section 3 below) collect your IP address in an anonymised form. We use your IP address to analyse the technical aspects of your use of the Website, prevent fraud and abuse of the Website, ensure the security of the Website, and tailor the Website for your location. The legal basis on which we rely when processing your IP address is ‘pursuing our legitimate business interests’ (i.e., to analyse and protect the Website). We keep your personal data as long as it is necessary for analytics purposes.
We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation.
If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.
Refusal to provide personal data
If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Website, receive our products and services, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
When you access the Website, we may collect certain information automatically, including, but not limited to, the type of device you use, your device unique ID,, your operating system, the type ofInternet browser you use, unique device identifiers, and other diagnostic data (the "Usage Data”).
We use the Usage Data for the following purposes:
To analyse what kind of users visit the Website;
To examine the relevance, popularity, and engagement rate of the Website;
To investigate and help prevent bugs, security issues and abuse;
To develop and provide additional features to the Website; and
To personalise the Website for your specific technical needs (e.g., to adjust the design and resolution for your device).
Aggregated and de-identified data
If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data and make sure that we have a legal basis for processing it. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.
We may use and store information about your location if you give us permission to do so ("Location Data"). We use the Location Datato provide features of, improve and customise our Website.You can enable or disable the Location Data when you use the Website at any time by way of your device settings.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept all cookies, you may not be able to use some portions of our Website. Also, we place a cookie consent banner on the Website that asks you to provide us with your consent for non-essential (analytics and marketing) cookies. If you do not provide your consent, we will use our essential cookies only that are strictly necessary for the functioning of the Website.
Examples of cookies that we use include:
Essential technical cookies that are strictly necessary to ensure the correct functioning of the Website and provide the services requested by you; and
Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement.
Disclosure & Transfer of Data
Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. The disclosure is limited to the situations when your personal data is required for the following purposes:
Ensuring the proper operation of the Website;
Ensuring the delivery of the products and services ordered by you;
Providing you with the requested information;
Pursuing our legitimate business interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations; or
If you provide your prior consent to such a disclosure.
Our cloud storage service provider WIX located in United States;
Our marketing service provider Hubspot located in United Stetes;
Our transactional email service provider Microsoft located in United States; and
Our independent contractors and consultants.
Disclosure of technical (non-personal) data
Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving The Website, responding to lawful requests from public authorities or developing new products and services.
If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
Selling personal data
We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your cookies as described in the section Tracking & Cookie Data.
Retention of personal data
Retention of the Usage Data
Retention as required by law
In certain cases, we are required by law to store your personal data for a certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.
Our Communication with You
If we have your email address, we may, from time to time, send you a newsletter informing you about the updated editorial content, latest developments related to the Website and our special offers. You will receive our newsletters in the following instances:
If we receive your express (“opt-in”) consent to receive marketing messages; or
If you voluntarily subscribe for our newsletter on the Website; or
If we decide to send you information closely related to services already used or products purchased by you.
You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.
If necessary, we will send you important informational messages, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal pata, we cannot guarantee its absolute security. The security measures taken by us include:
Anonymisation of personal data (when possible); and
Carefully selected data processors.
Links to Other Sites
Our Website does not address anyone under the age of 18 ("Children").
We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us. If we become aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.
You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):
Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
Right to rectification: you can rectify inaccurate personal data that we hold about you;
Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
Right to restriction: you can ask us to restrict the processing of your personal data;
Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
Right to object: you can ask us to stop processing your personal data;
Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
Right to complaint: you can submit your complaint regarding our processing of your personal data.
How to exercise your rights?
If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.
• By email: firstname.lastname@example.org