Legal Notices

for our cooperation

24

DATA PRIVACY STATEMENT

of oneclick AG, CH-8008 Zurich (hereinafter called “oneclick”)

Version 2017-04-05

1. Handling of Data

The trust in correct handling of data is an important requirement for oneclick. Therefore data protection has a great importance for oneclick. Customer data is only collected, processed and used whilst complying with the applicable data protection regulation and only for the purposes described as follows. Handling includes saving, alteration, transfer, blocking and deletion of customer data.

2. Collection and Use of Personal Data

Personal data is data that can be used to identify a person or to contact a specific person. When you contact oneclick or an associated organisation, you may be asked to provide personal data. oneclick and associated organisations can exchange this personal data with each other and use it in accordance with this Data Privacy Statement. We can also combine such personal data with other information to offer or improve our products, services, content and advertisements. You are not obliged to submit your personal data. However, in this case we may not be able to inform you about our products or services or respond to or process your enquiries.

3. What Personal Data is Being Collected

We collect various data from you when you create a user account, buy a product or service, when you register on our website, get in contact with us or participate in an online survey, including your name, address, telephone number, email address, information about your preferred contact channel, bank and credit card information.

When you share content with business partners or friends and thereby use products of oneclick, forward gift vouchers or invite others to participate in services of a forum of oneclick, then oneclick can collect the data that you have provided about these persons, such as name, address, email address and telephone number. oneclick uses this data to process your enquiries, provide products or services as well as tackling fraud.

4. How we Use Personal Data

The collated personal data enables us to inform you about the latest product announcements, software updates and future events. If you do not wish to be included in our distribution list, you can opt out any time by changing your settings.

Personal data also supports us with the creation, development, provision, delivery and improvement of our products, services, content and advertising. Furthermore it also makes it easier to tackle fraud.

Sometimes we can use personal data to send important messages, for example about purchases or amendments of our business terms and regulations. As this information is important and necessary for the relationship with oneclick, customers cannot refuse the receipt of such information.

We can also use personal data for internal purposes, such as accounting, data analysis and research to improve the products and services of oneclick and the communication with customers.

If you participate in competitions or similar activities, then we can use the data made available to us for the administration of these activities.

5. Collection and Use of Non-Personally identifiable Data

We also collect data in a form that, without more information, does not allow a direct association to a specific person. We can collect, use, transfer and disclose non-personally identifiable data for any purpose.

We collect data such as profession, language, postcode, area code, individual unique device identifier, forwarding URL as well as location and time zone, where the products of oneclick are used so that we can better understand the behaviour of our customers and improve our products, services and marketing activities.

We may also collect information regarding customer activities on our oneclick websites, in addition to our other products and services. This data is merged and serves as a tool to provide our customers with more useful information and to understand, which parts of our websites, products and services are most interesting for our customers. The merged data is considered non-personally identifiable data for the purpose of this Data Privacy Statement.

If necessary, we also collect and save more information about how you use our services, for example search requests. This information enables us to improve the significance of the results provided by our services. Such information is generally not associated with your IP address, except on a limited scale to ensure the quality of our services provided via the internet.

With your explicit consent, we are also allowed to collect data about your usage of your device and programmes installed. This information may be used by the developers to help improve your software applications (“Apps”).

In the case that we link non-personally identifiable data with personal data, then this linked data will be treated as personal data.

6. Cookies and Other Technologies

The websites of oneclick, online services, interactive applications, email messages and advertisements can use “cookies” and other technologies such as pixel tags and web beacons. These technologies allow us to better understand user behaviour, it informs us which parts of our website were visited and simplifies and measures the efficiency of advertising and web search. We treat all data collected by cookies and other technologies as non-personally identifiable data. However, if internet protocol (IP) addresses or similar identifiers are classed as personal data by the applicable regulation, then we will also treat these identifiers as personal data. Accordingly, we will also treat linked data as personal data, for the purpose of this Data Privacy Statement, as long as non-personally identifiable data is linked with personal data.

The websites of oneclick, their online services and interactive applications all use cookies for the improved usage and security of the connection. For this purpose, a unique session ID can be saved in a cookie by the server to accurately recognise this client again when visiting again.

As with most internet services, we will also capture certain data automatically and save it in log files. This information includes IP addresses, browser types, browser language, internet service providers (ISP), referring and exit pages and programmes, operating system, date/time stamp and clickstream data.

We use this information to evaluate and analyse trends, to administer the website, to gain information about user behaviour on the website, to improve our products and services as well to capture demographic data regarding the overall user base. oneclick can use the captured data in their marketing and advertising services.

In some of our email messages we use a so-called “click-through-URL”, that leads directly to content of an oneclick website. If customers click onto these URLs, they are directed via a separate web server before they reach the target page on our website. We track this “click-through“ data to determine for which specific topics there is an interest and to measure the efficiency of our customer communication. If you do not wish that such data is captured and tracked, do not click onto text or graphic links in emails.

“Pixel tags“ allow us to send email messages in a format readable by the customer. They also enable us to check if emails have been opened. This information can be used to reduce or to stop sending messages to a customer.

Google Analytics

The websites of oneclick use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files saved on your computer) to help analyzing how you use the websites. The information generated by the cookie about your use of our websites will be transmitted to and stored by Google on servers in the United States. In case IP anonymization is activated on our websites, your IP address will be truncated by Google within a EU member state or other EEA state before being transmitted to the US. However, it cannot be fully excluded that in exceptional cases your full IP address will be transmitted to Google servers in the United States and truncated there. Upon our order, Google will use this information for the purpose of evaluating your use of our websites, compiling reports on website activity and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our websites. You can also prevent Google from collecting information (including your IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout

You can prevent data collection via Google Analytics by clicking here. An “Opt-out Cookie” shall then be applied to our websites which shall prevent any future collection of your data when visiting our websites.

By using our websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Further information concerning the terms and conditions of use and data privacy of Google can be found at the Google Analytics Terms of Service or at the Google Privacy Overview. Please note that on our websites, Google Analytics is supplemented by “gat._anonymizeIp();” to ensure anonymized collection of IP addresses (IP masking).

7. Transferring Data to Third Parties

Occasionally oneclick can transfer specific personal data to strategic partners that work together with oneclick to make products and services available, or that support oneclick with marketing to customers. Personal data are only transferred by oneclick to supply or improve our products, services or marketing. Personal data is not transferred to third parties for their marketing purposes.

8. Subcontractor

oneclick can transfer personal data to companies that provide services indirectly to you, such as the processing of information, fulfilling customer orders, delivery of products to you, administration and maintenance of customer data, delivering customer service, the appraisal of your interest on our products and services as well as conducting customer research or customer satisfaction surveys. These organisations are obliged to protect your personal data to the same extent as oneclick and can be based wherever oneclick operates. Upon your request we will inform you about Auxiliary Persons which are given your personal data.

9. Other Third Parties

Due to legal requirements, legal processes, legal disputes and/or requests by public and governmental authorities within or outside of your country of residence, it can sometimes become necessary for oneclick to disclose personal data. In addition, we can disclose data about you, if we are convinced that this is necessary or appropriate for public safety, law enforcement or other public interests.

We can also disclose data about you if we are convinced that this is reasonably necessary to enforce our business terms or to protect our business activities or users. In addition, if applicable, we will also transfer all collected personal data to the relevant third party in the case of a reorganisation, a merger or a sale. In case of possible disclosure of personal data, oneclick will as far as possible inform you, whereas there is no legal entitlement for such information.

10. Protection of Personal Data

The security of your personal data is important to oneclick. Our online services protect your personal data during the transmission using encryption processes such as transport layer security (TLS). When your personal data is saved by oneclick, it is used by computer systems in facilities that limit access through physical security measures.

If you use certain products, services or applications of oneclick or enter personal data in a forum, chat room or social media network of oneclick, then this personal data and content is visible to other users and can be read, captured or used by them. You alone have responsibility for the personal data that you share or provide. For example, if you provide your name and email address in a forum, then this information is public. Use this function with caution.

11. Integrity and Storage of Personal Data

oneclick makes it easier for you to keep your personal data correct, complete and up to date. We store personal data as long as necessary to fulfil the purposes described in this Data Privacy Statement, as long as there is no longer a storage period demanded or permitted by law.

12. Information About Personal Data

You can help us to ensure that your contact data and settings are correct, complete and up to date by logging into your account via https://oneclick.services/. We enable you to access for any purpose personal data that we save about you. You can demand from us for example to correct incorrect data or also the deletion of data, as long as oneclick is not obliged to store the data by law or for legitimate business purposes. We can reject the processing of enquiries if these are offensive or harrassing, endanger the privacy rights of others, are extremely impractical, or if otherwise disclosure according to the respective legal system is not provided for. The right to information, correction or deletion can be asserted by contacting moc.d1506183274uolc-1506183274kcilc1506183274eno@t1506183274roppu1506183274s1506183274.

13. Location-based Services

In order to provide location based services, oneclick, their partners and licence holders can collect, use and share precise location data, including the geographic location of your computer or device in real time. As long as location based services are available, these can determine the approximate location of your devices. Apart from GPS, Bluetooth and your IP address, the data of public WLAN hotspots and mobile phone masts as well as other technologies are used. If you have not provided agreement for their use, these location based data are used in an anonymous way that means that you cannot personally be identified. The data is used by oneclick, their partners and licence holders to offer location based products and services to you and to improve those services. Your device can for example pass on its geographic location to programme or app providers, if you select their location services.

14. Website and Services of Third Party Providers

The website, products, applications and services of oneclick include links to websites, products and services of other organisations. Our products and services can also use or offer the products and services of third party providers – for example a software application (“App”) of a third party provider. The data protection methods of the third party provider regulate the collection of data that may include location based or contact data. We therefore recommend that you find out more about the data protection methods at these organisations.

15. International Users

Within the requirements of this Data Privacy Statement, all data provided by you can be subject to transmission or access by organisations in different locations in the world. oneclick adheres to the basic principles set up by the European Union regarding the collection, use and storage of personal data of organisations within the European Economic Region and Switzerland (“EU-US Privacy Shield” / “Safe-Harbor“).

Personal data, including data provided by persons with a residence in a member state of the European Economic Area (EEA) are monitored and processed by oneclick in Zurich, Switzerland. oneclick adheres to the requirements of the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules-Systems.

16. Obligation of the Employees

All our employees are made familiar with this Data Privacy Statement and security measures to protect privacy are strictly implemented within our organisation in order to ensure the safety of personal data.

17. Amendments to the Data Privacy Statement

oneclick reserves the right, at its own discretion, to amend this Data Privacy Statement at any time. We will inform you in time about such amendments and will announce the date from which these amendments will be effective. Amendments are deemed as accepted by you, when you continue to use the website after the amendments have come into force. In case of substantial amendments of this Data Privacy Statement you will be informed at least 30 days prior to enactment of such amendments. In case you don’t contradict to the new Terms of Use within 30 days, this will be considered your explicit approval to the amendments made. Relevant messages will be sent by oneclick to the email address provided in each account.

18. Questions Regarding Data Protection

If you have questions or concerns in relation to this data privacy statement or our data processing, or if you would like to inform us about a possible violation of local data protection laws, we would ask you to contact us via telephone number + 41 44 578 88 93 or via email moc.d1506183274uolc-1506183274kcilc1506183274eno@t1506183274roppu1506183274s1506183274.