At My Swiss Keeper SA (we, our or MSK), we recognize the importance of your privacy and of transparency.
This privacy notice (
Privacy Notice) describes how we process your personal data when you interact with our My Swiss Keeper Solution accessible at
https://www.myswisskeeper.com/privacy-notice-solution/ or as a mobile App (the
Solution), and the services we provide in this context (together with the provision of the Solution, our
Services).
By using our Services, you expressly acknowledge that we may process your personal data in accordance with this Privacy Notice.
This Privacy Notice is incorporated into and forms an integral part of our general terms & conditions forthe Solution (GTC). All capitalized terms not defined in this document have the meaning given to them in the GTC.
The My Swiss Keeper Solution is operated by us, My Swiss Keeper SA, a Swiss company with registered office in Vaud, Switzerland. You will find our contact details below in section 12.
Except when we process your personal for our legitimate business operations related to providing the Services, as further detailed in this Privacy Notice, the Keeper to whom you are affiliated is responsible, as data controller, for the processing of your personal data through the Services. In that case, we act as a data processor for your Keeper in accordance with our GTC.
We process your personal data in compliance with applicable law, in particular Swiss data protection laws and, to the extent they apply to us, other data protection legislations, such as the EU General Data Protection Regulation (GDPR), manually or automatically using computer tools.
This means that we will only process your information for certain reasons (see Section 7) where we have a legal basis to do so.
We process your personal data for the following reasons:
We will only share your personal data with third parties if this is necessary for the operation of our Services, if there is a legal obligation or permission to do so, or if there is another valid reason to do so.
We store your personal data on servers located in Switzerland.
We will not transfer your personal data to other countries or make it available there except if we have a legal obligation to do so. Note that we do not control from where you (or your Keeper and authorized users) access and use our services.
Your personal data will not be stored longer than necessary. We will erase or anonymize your personal data as soon as it is no longer necessary for us to fulfill the purposes set out in section 6 of this Privacy Notice. This period varies, depending on the type of data concerned and the applicable legal requirements:
We are committed to the security of your personal data, and have in place physical, administrative and technical measures designed to keep secure your personal data and to prevent unauthorized access to it. Your content information is protected using strong encryption processes. We do not have access to encryption keys of our users as part of the normal operation of the Solution.
Although we take appropriate steps to protect your personal data, no IT infrastructure is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.
The internet is a global environment. As a result, by sending information to us electronically, such data may be transferred internationally over the internet depending upon your location. Internet is not a secure environment and this Privacy Notice applies to our use of your personal data once it is under our control only. Given the inherent nature of the internet, all internet transmissions are done at your own risk.
If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication (including by posting a notice on the Solution).
Cookies are small files of letters and numbers downloaded on to your computer when you access certain websites. In general, cookies allow a website to recognize a user’s computer.
There are various types of cookies. But in connection with the Solution, we only use "essential cookies", which are required to make the Solution capable of being used (the Solution cannot function properly without them).
We currently only use the following cookie in connection with the Solution:
By accessing your user account, you can review, update, correct or delete the personal data available within your user account. We do not have access to your content and therefore cannot help you exercise your data protection rights in that context. You should direct your privacy inquiries relating to your content, including any requests to exercise your data protection rights, directly to your Keeper’s contact person.
You may contact us directly to exercise your rights pertaining to your account information or usage data. Unless otherwise provided by law, you have the right to know whether we are processing your personal data, to know the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be supplemented, updated, rectified or erased. You also have the right to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law, and you have the right to object to any processing of personal data for legitimate reasons.
The above does not restrict any other rights you might have pursuant to applicable data protection legislation under certain circumstances.
If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in addition to the rights described above.
Although this is not required, we recommend that you contact us first, as we might be able to respond to your request directly.
If you believe your personal data has been used in a way that is not consistent with this Privacy Notice, or if you have any questions or queries regarding the collection or processing of your personal data, please contact us at privacy@myswisskeeper.com.
This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you (including by email and/or via the Solution, e.g. banners, pop-ups or other notification mechanisms). If you do not agree to the changes made, you must stop accessing and/or using the impacted Services.
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