We are dedicated to protecting the confidentiality and privacy of information entrusted to us. We comply with applicable Data Protection Regulations including in particular the Swiss Federal Act on Data Protection (FADP). Please read this Privacy Policy to learn about your rights, what information we collect, how we use and protect it.
1. WHO WE ARE
This Privacy Policy applies to Approovd AG (Approovd Ltd, Approovd SA), Dufourstrasse 107, 8008 Zurich, Switzerland (“Approovd” or “we”), the operator of the online platform for legal services called Approovd (the “Platform”). We are responsible for the collection, processing and use of your personal data as a user (hereinafter “user” or “you”) and compliance with applicable law. The Platform includes automated legal documents (the “Templates”) and related features. Registered users may generate legal documents that are derived from the Templates by answering a set of predefined questions about Template-specific topics on the Platform. The information and data thus provided by Users is stored on servers in Switzerland.
2. WHO CAN YOU CONTACT FOR PRIVACY QUESTIONS?
If you have questions or comments about this Privacy Policy or how we handle personal data, please direct your correspondence to:
Approovd AG
Dufourstrasse 107
8008 Zurich
Switzerland
info@approovd.com
3. HOW DO WE COLLECT PERSONAL DATA?
Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, write us emails or place online inquiries, subscribe to our newsletter, attend meetings or events we may host, visit our premises or apply for open positions. We may also obtain personal data directly when, for example, individuals are registering and/or using our Platform.
Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including from our users. We may attach personal data to our customer relationship management records to better understand and serve our users, prospects, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
Public sources: Personal data may be obtained from public registers (such as Commercial Registers), news articles, sanctions lists, and Internet searches.
Social and professional networking sites: If you register or login to our Platform using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
4. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through our users, from applicants, our suppliers and through other situations including those described in this Privacy Policy.
Personal data: Here is a list of personal data we usually collect to conduct our business activities.
- Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work email and postal address)
- Payment details (e.g., billings address, payment information, depending on the chosen payment method)
- Information provided by our users while using the Platform (e.g., name of contractual parties, signatories, etc., depending on the relevant Template).
Sensitive personal data: As a principle we do not need to and we do not process sensitive personal data. However, we do not control which information is provided by the users when generating legal documents, and we cannot exclude that such information may include sensitive personal data about users or their contractual counterparts. If it is the case, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include:
- Personal identification documents that may reveal race or ethnic origin, religious beliefs or physical health, and possibly biometric data of private individuals.
- Adverse information about users or their contractual coutnerparts that may reveal criminal convictions or offences information.
- Dietary restrictions when registering for events that reveal religious beliefs or physical health.
5. WHAT LAWFUL REASONS DO WE HAVE FOR PROCESSING PERSONAL DATA?
We may rely on the following lawful reasons when we collect and use personal data to operate our Platform and provide our products and services:
Contract/Subscription: We may process personal data in order to perform our contractual obligations.
Consent: We may rely on your freely given consent at the time you provided your personal data to us.
Legitimate interests: We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include the delivery of services and products our clients have subscribed for, the marketing of our Platform, offerings and invitations we believe are welcomed by our users, prospects and other individuals.
Recruitment: To seek for qualified candidates.
Legal obligations and public interest: We may process personal data in order to meet regulatory obligations.
6. WHY DO WE NEED PERSONAL DATA?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
- Operating and improving the experience of the users of our Platform;
- Gathering of data for statistical reasons to enable the samless functioning of our Platform;
- Promoting our Platform and services to existing users and prospective business clients;
- Sending invitations and providing access to guests attending the events, webinars or sponsored events we may hold;
- Administering, maintaining and ensuring the security of our Platform and website;
- Authenticating registered users to certain areas of our website;
- Processing online requests, including responding to communications from individuals or requests for proposals and quotations;
- Contacting journalists regarding market insights, corporate news, invitations to press conference;
- Complying with applicable legal and regulatory obligations;
- Preventing fraud or criminal activity, safeguarding our IT systems and handling of claims;
- Employment of personnel and work processes;
- Seeking for qualified candidates;
- The provision of personal data may be required to provide the services and grant access to our Platform. In such cases this is indicated on the website accordingly or pointed out in the disclaimers or contractual agreements. Furthermore, we may be required to collect certain personal data by law. If you fail to provide such data, we may not be able to provide the services or grant you access to the Platform, or we may have to cancel a product or service you have with us
7. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE SWITZERLAND?
We store personal data on servers located in Switzerland. We may transfer personal data to reputable third party organisations situated inside or outside Switzerland when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and applicable data protection legislation. Such safeguards may include transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner; applying standard data protection model clauses, binding corporate rules or other standard contractual obligations which provide for appropriate protection of data.
8. DO WE USE COOKIES? DO WE AUTOMATICALLY COLLECT PERSONAL INFORMATION?
We may use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of our Platform, and to measure the effectiveness of our marketing activities. Where cookies are used, a statement will be sent to your browser explaining the use of cookies.
9. WHAT ARE YOUR DATA PROTECTION RIGHTS?
If we processes personal information about you, you have the rights listed below. Before responding to your request, we may ask for proof of identity. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for sufficient information about your interactions with us so that we can locate your personal information.
Access: You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
Correction: You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
Erasure: You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected and no retention requirements exist.
Processing restrictions: You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it.
Data portability: In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data in electronic form to the extent technically feasible.
Automated Individual Decisionmaking: You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, provided that it produced legal effects concerning you or which significantly affected you.
Right to Object to Marketing including Profiling: You can object to our use of your personal data for marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
Right to Object to Active Sourcing: You can object to our use of your personal data for active sourcing purposes. We may need to keep some minimal information to comply with your request to cease recruiting activities.
Right to Withdraw Consent: You can withdraw your consent that you have previously given to one or more specified purposes of processing your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
To submit a data request please direct your correspondence to:
Approovd AG
Dufourstrasse 107
8008 Zurich
Switzerland
info@approovd.com
We aim to respond within 30 days from the date we receive privacy-related communications.
No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
10. WHAT ABOUT PERSONAL DATA SECURITY?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We limit access to personal data in general. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymization, deidentification and anonymization techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our Platform, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
11. HOW LONG DO WE RETAIN PERSONAL DATA?
We retain personal data to provide operate our Platform, provide our services, make offerings, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We retain personal data for so long as the personal data is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements. We will dispose of personal data when we no longer need it.
12. DO WE LINK TO OTHER WEBSITES?
Our website and Platform will typically contain links to other sites, including sites maintained by partner firms that are not governed by this Privacy Policy. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
13. DO WE CHANGE THIS PRIVACY POLICY?
We regularly review this Privacy Policy and will post any updates to it on this webpage. This Privacy Policy was last updated on September 13, 2018.
