Privacy
Policy

Date of issuance: 30.09.2020

1.     What is it about?

This privacy policy (“Policy”) sets out the basis on which any personal data contained on the platformClasseekLink accessible at this address https://www.classeek.com (“Platform”) will be processed by Classeek SA (“Classeek” or “we”).

“Personal data” means any information relating to an identified or identifiable natural or legal person, according to the Federal Act on Data Protection (“FADP”). It could bePersonal data of registered users or of anyone visiting the Platform (“User”or “you”). The processing of persons of interest’s Personal data is explained in a specific notice of information, available at www.classeek.com/notice-of-information.

Please read the following carefully to understand our views and practices regarding yourPersonal data and how we will process it.

2.   Who is responsible for your Personal data?

Classeek is the data controller for Personal data covered by thisPolicy. Its headquarters are at EPFLInnovation Park, Building F, 1015 Lausanne (Switzerland). We may be contacted by email at the address info@classeek.com.

We hope to be able to answer your questions regarding the way we process your Personal data. Should you have any concern in this regard, please do not hesitate to contact us in writing or by email.

3.     Which Personal data do we collect from you and for what purpose?

3.1       When you visit our Platform

When you visit our Platform, we may automatically collect the followingPersonal data:

-       information regarding the use of our Platform, including language, date and hour of your visit, browser used, location, volume of data transmitted, links you might follow, visited web pages and content, and duration of the visit;

-       technical information, including the IP (Internet Protocol) address used to connect your computer to theInternet, the type of device you use, a unique device identifier (for example your device’s IMEI number, the MAC address of the wireless network interface or the mobile phone number used by the device);

-       any information you may share with us.

This Personal data is in particular collected through cookies and similar technologies as described in art. 6.

The purpose of this processing is to allow you to use our Platform while storing your settings and optimising your overall User experience.

In addition, Google Analytics, as developed in art. 5, is used in order to understand your usage patterns and to develop statistics on the latter.

This processing is justified by your consent, unless applicable law does not contain any requirement for such consent and that the processing is justified by our prevailing interest to improve our Platform and its services.

3.2       When you register on our Platform

When you register or log in to the Platform, you agree that we process the Personal Data that you share with us.

The User must communicate the following data:

-       Name;

-       First name;

-       Mobile phone number.

This Personal Data is collected in order to allow your identification, to ensure that a User creates only one account and to provide you with the services offered on the Platform. Its processing is justified by the performance of the contract between you and Classeek.

Moreover, if you ask for paid services, you will be asked to communicate your credit card information and billing address. This processing is also justified by the performance of the contract between you and Classeek.

4.   Who do We share your Personal data with?

4.1       With our data processors

We may share yourPersonal data with those who provide us with services as data processors, in particular IT services, for example Google Analytics.

Our data processors are bound by an obligation of confidentiality and are entitled to use yourPersonal data only in accordance with our instructions and this Policy.

4.2       With third-parties (data controllers)

When allowed or required by law, when it is necessary to defend our interests or with your consent, we may share your Personal data with third-parties, for example at the request of judicial authorities or to assert our rights in court.

Personal data may be shared with other Users of the Platform, or any other person consulting thePlatform. As a registered User, you may choose to limit the information and data that is shared on your account. However, your name and first name will remain visible at all times.

5.   Cookies

5.1       Our cookies

Type of cookies(including our data processors’ cookies) that we use on our Platform and the reason why we use them are described below:

Category 1: strictly necessary cookies

These cookies are essential in order to enable you to move around our Platform and to use its features. Without these cookies, some elements of our Platform may be blocked and/or not function correctly.

We use these cookies in order to let you access the services that we offer on our Platform.

Category 2: performance cookies

These cookies collect information on how you or other Users use our Platform, for instance which pages you go to more often, and if you get error messages from web pages.

We use these cookies in order to preserve our Platform’s efficiency and ease of use and to know the way it is used. Most of the time, these cookies don’t collect information that identifies the User.

Category 3: functionality cookies

These cookies allow our Platform to remember choices you have made (such as your User name, language, or the region where you are) and may also be used to provide the services you have asked for.

We use these cookies to maintain the Platform’s efficiency, ease of use, and to provide you with a seamless experience.

You can at any time refuse these cookies through your browser’s settings.

5.2       Third-parties’ cookies

We may include on our Platform third-parties’ computer applications allowing you to share our Platform’s content with other people and let them know your consultation or opinion abouta content of our Platform.

These cookies use is subject to third-parties’ privacy policies over which we have no control.Please refer to their respective privacy policies in order to learn more about the way they use their cookies.

6.   Transfer of Personal data abroad

Your Personal data maybe processed abroad when appropriate, in particular when using data processors. We respect all applicable rules and shall adopt all required and necessary measures prior to the transmission of Personal data to a country that provides a lower level of protection than Switzerland.

7.   Security

Classeek takes security matters seriously and makes all the reasonable efforts to ensure the best possible security level according to its means. In this regard, Classeek takes standard security measures, implemented by specialists.

 

Classeek uses in particular standard technology and security precautions, and organisational procedures to protect your Personal data from unauthorised access, improper use, disclosure, loss or destruction. Industry standard firewalls and passwords protection are also used to protect your Personal data.

8.   Data retention period

As a rule, anyPersonal data that has been collected through the Platform or transmitted by you shall be deleted within three months after termination of the User’s account, by the deletion of the User’s account content or by the closure of thePlatform, unless a legal obligation obliges us to retain the data for a longer period of time. After the end of the retention period of twelve months, we shall delete your Personal data without further notification. It is however expressly underlined that these data may be kept even after the termination of the User’s account, the deletion of the User’s account content or the closure of the Platform, at least temporarily, in particular (without limitation) incase of back-up systems.

If your Personal datais processed exclusively with your consent, we may process your data during a short period of time after your consent’s withdrawal (in order to follow-up your request) and to keep a record of your request.

Anonymous information(including but without limitation data collected through the use of Cookies)may be kept without any limitation.

9.   Your rights

You are entitled to inquire about the Personal data held by Classeek and to receive a copy thereof, as well as to request an update, rectification, deletion and minimisation of the processing of your Personal data. You may at any time withdraw your consent and have the right to object to the processing of your Personal data, unless a legitimate interest justifying the data processing exists. You also have the right to data portability regarding the data that you have transmitted to us and that are processed with your consent or for the performance of a contract.

You may also refuse any use of your Personal data by Classeek for marketing purpose.

Should you wish to make use of one or more of these rights, please contact us at: Classeek SA,EPFL Innovation Park, Building F, 1015 Lausanne (Switzerland) or by electronic means at info@classeek.com. You may also lodge a complaint with the FederalData Protection and Information Commissioner (FDPIC).

10.  How will we let you know of changes to our Policy?

We may update this Policy from time to time without notice. So, please check it regularly. We will however aim to bring any significant changes to your attention.

11.  Applicable law and jurisdiction

This Policy, as well as all matters arising out or in relation to it (including non-contractual disputes or claims and their interpretation) shall be governed by the laws ofSwitzerland, to the exclusion of the rules on conflicts of laws.

Any claim and dispute in relation to this Policy (including non-contractual disputes or claims and their interpretation) shall be subject to the exclusive jurisdiction of the Courts of Lausanne, Switzerland.