Owner and Data Controller

PolicyStore Gmbh
Birsigstrasse 2
4054 Basel
Switzerland

Owner contact email: tech@policystore.ch

Types of Data collected

Among the types of Personal Data that PolicyStore collects, by itself or through third parties, there are: email address, first name, last name, phone number, country, address, company name, website, Cookies and Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using PolicyStore.
Unless specified otherwise, all Data requested by PolicyStore is mandatory and failure to provide this Data may make it impossible for PolicyStore to provide its services. In cases where PolicyStore specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies \u2013 or of other tracking tools \u2013 by PolicyStore or by the owners of third-party services used by PolicyStore serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through PolicyStore and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of PolicyStore (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (\u201copt-out\u201d), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner\u2019s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Hosting and backend infrastructure, Managing contacts and sending messages, Registration and authentication, Analytics, Interaction with data collection platforms and other third parties, Backup saving and management and Tag Management.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  AdEspresso conversion tracking (Creative Web Srl)

  AdEspresso conversion tracking is an analytics service provided by Creative Web Srl that connects data from the Facebook advertising network with actions performed on PolicyStore.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: Italy – Privacy Policy.

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (\u201cGoogle\u201d). Google utilizes the Data collected to track and examine the use of PolicyStore, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  Analytics collected directly (PolicyStore)

  PolicyStore uses an internal analytics system that does not involve third parties.

  Personal Data collected: Cookies and Usage Data.

• Backup saving and management

  This type of service allows the Owner to save and manage backups of PolicyStore on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to PolicyStore.

  Backup on Google Drive (Google Inc.)

  Google Drive is a service to save and manage backups provided by Google Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Contacting the User

  Mailing list or newsletter (PolicyStore)

  By registering on the mailing list or for the newsletter, the User\u2019s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning PolicyStore. Your email address might also be added to this list as a result of signing up to PolicyStore or after making a purchase.

  Personal Data collected: address, company name, country, email address, first name, last name, phone number and website.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable PolicyStore to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of PolicyStore. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

  Heroku (Heroku, Inc.)

  Heroku is a hosting service provided by Heroku, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy; Germany – Privacy Policy.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of PolicyStore for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  ConvertKit widget (ConvertKit LLC)

  The ConvertKit widget is a service for interacting with the ConvertKit email address management and message sending service provided by ConvertKit LLC.

  Personal Data collected: Cookies, email address, first name and Usage Data.

  Place of processing: United States – Privacy Policy.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Amazon Simple Email Service (Amazon)

  Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

  Personal Data collected: email address.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  ConvertKit (ConvertKit LLC)

  ConvertKit is an email address management and message sending service provided by ConvertKit LLC.

  Personal Data collected: Cookies, email address, first name and Usage Data.

  Place of processing: United States – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow PolicyStore to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, PolicyStore will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Direct registration (PolicyStore)

  The User registers by filling out the registration form and providing the Personal Data directly to PolicyStore.

  Personal Data collected: company name, email address, first name and last name.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on PolicyStore in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google LLC)

  Google Tag Manager is a tag management service provided by Google LLC.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

• Surveygizmo

  Provider
  Surveygizmo inc.
  
  Purpose
  Interaction with online survey platforms
  
  Personal Data collected
  Email
  Name
  Usage data
  
  Privacy Policy
  The Surveygizmo is a service for interacting with the Surveygizmo online survey platform provided by Surveygizmo Inc. Personal data collected in the survey may be transferred to various countries, including the United States and other locations Surveygizmo has offices.

• Social Compass

  Personal Data:
  Name
  Email Address
  User-generated content such as questions, likes, answers
  
  Purpose:
  To create a platform for sharing Q&A on moral dilemma.

• Moral Plugin

  Personal Data: Name, location, IP address, analytics and usage data.
  
  Purpose: Improve honestly in online reports.

• PolicyApp

  Personal Data: Name, email address
  
  Purpose: to deliver ethical guidance to employees

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

PolicyStore uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of PolicyStore or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, PolicyStore may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, PolicyStore and any third-party services may collect files that record interaction with PolicyStore (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How \u201cDo Not Track\u201d requests are handled

PolicyStore does not support \u201cDo Not Track\u201d requests.
To determine whether any of the third-party services it uses honor the \u201cDo Not Track\u201d requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within PolicyStore and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User\u2019s consent, the Owner shall collect new consent from the User, where required.