Last Update: 2024-08-01
We, at Novaccess, along with our subsidiaries and affiliates ("Novaccess", "we" or "us"), take your privacy very seriously and we have taken every measure so you rest assured your information and your experience with us stays safe and private. It is our policy to respect the confidentiality of information and the privacy of individuals. We are bound by the data protection principles contained in the Federal Act on Data Protection.
In this privacy notice (the "Privacy Notice"), we aim to provide clear and useful explanations on what information we collect when you visit our website https://www.novaccess.ch/ including any (sub)pages and Novaccess mobile apps (the "Website") or when you use our services and how this information is used, processed, transferred and stored. Our Privacy Notice also contains information on our practice in relation to the placement of cookies, including the types of cookies we use and how you can manage them, and how you can control the collection, correction and/or deletion of such personal information.Our Privacy Notice will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Any information we hold will be governed by our most current Privacy Notice.
1.1 Novaccess is the responsible data collector, processor and controller of personal information relating to identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This includes information such as your real name, address, telephone number and date of birth. Information which cannot be linked to your real identity - such as favorite websites or number of users of a site - is not considered personal data ("Personal Data"). Novaccess's registered offices are at Rue Galilée 6 1400 Yverdon-les-Bains, Switzerland.
1.2 If you have any questions about this Privacy Notice or your rights under data protection law, you can contact us directly by email at info@novaccess.ch.
1.3 You are the data subject, i.e. in the data protection terminology, the identified or identifiable natural person, whose Personal Data is collected and processed by the controller responsible for the processing. This Privacy Notice applies to you if you are a customer/user of our services and products, our supplier, if you contact Novaccess, or by visiting our Website, using social media or if you receive emails from Novaccess.
2.1.1 When you visit our Website or use our app, our servers always temporarily save for connection and set up and security purposes the connection data of the computer connecting to our Website, a list of the web pages that you visit within our Website, the date and duration of your visit, the IP address of your device, the identification data of the type of browser and operation system used as well as the Website through which you linked to our Website and any other similar data and information that may be used in the event of attacks on our information technology systems. Additional personal information such as your name, address, telephone number or e-mail address is not collected unless you provide this data voluntarily, e.g. while completing an online contact form, as part of a registration, survey, competition, fulfillment of contract or an information request.
2.1.2 The legal basis for the processing of the aforementioned data categories is Art. 6 (1) (a) of the European General Data Protection Regulation ("GDPR"). Due to the said purposes, in particular to guarantee security and a smooth connection setup, we have a legitimate interest to process these data.
2.3 For contractual reasons, we also need Personal Data to provide our services and products and comply with the obligations arising from contractual agreements concluded with you. As a rule, the Personal Data that you provide directly or indirectly to Novaccess when registering with us and using our services are:
2.3.1 Some of our services and features will require that you enable geolocalization in your browser or app, respectively in your operating system. We will collect, use, and share precise location data, including the real-time geographic location of your computer or device to offer you location-based services. We will not use this data for any other purpose. Where available, location- based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. If you disable this function your data will be deleted in due time.
2.3.2 The legal basis is usually Art. 6 (1) b) GDPR since the processing is for the performance of a contract to which you are a party.
2.4.1 If you are an existing customer/user of Novaccess, your postal data (e.g. name, address, email address) may be processed to contact you in order to provide you with the latest information about our offers, news, products and services. Apart from an existing consent, we will process your e-mail address exclusively in order to provide you with information regarding Novaccess own and similar products or services.
2.4.2 Legal basis for the aforementioned processing is Art. 6 (1) f) GDPR. The processing of customer data for own direct marketing purposes is regarded as carried out for a legitimate interest. You have right to object at any time to the said processing. To exercise your right, simply get in touch with us by using the contact details mentioned in this Privacy Notice.
2.4.3 If you register for one of our newsletters, we are entitled to use your e-mail address for this purpose. During the newsletter registration process, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by you at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of your e-mail address at a later date, and it therefore serves the aim of our legal protection. As part of your registration we also obtain your consent to our personalizing the content of our newsletter in line with your needs and interests based on the data received from you and stored about you, such as your account information, order history or other information provided by you (including, for example, your participation in surveys). Where you have also given your consent to the placement of cookies and to the monitoring of your user behavior on our Website, we use data about your use of our Website so you can receive personalized messages in line with your specific interests and preferences. Our newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened, and which links in the e-mail were called up. You may unsubscribe from the newsletter at any time by clicking the relevant link at the bottom of the newsletter. In case you file an objection or unsubscribe from our newsletter services the respective data will be blocked and no longer be processed for such purposes.
3.1.1 We use tracking software to determine how many users visit our Website and how often. We do not use this software to collect individual Personal Data or individual IP addresses. The data are used solely in anonymous and summarized form for statistical purposes and for developing the Website.
3.2.1 Cookies are small files containing a string of characters that are sent to your device when you visit our Website. When you visit our Website, the cookie allows our Website to recognize your browser and read certain information stored in this cookie. Cookies are widely used on many sites for various purposes. Cookies may be placed on your device by us as the Website operator. These cookies are called first party cookies. Some cookies may be placed on your device by other parties than us, such as parties that place cookies to enable chat services or analyze the use of our Website. These cookies are called third party cookies.
3.2.2 We use cookies and similar technologies, such as tracking pixels, tags, web beacons, clear GIFs, JavaScript and local storage on our Website (the "Cookies") to help us and third parties obtain information about your visits to our Website, facilitate the provision of our services, deliver advertising, communications and content from us and third parties on our Website and those of third parties, as specific as possible to your interests, remember your language and other preferences, help you obtain information you are looking for, provide safe and secure services for online transactions, measure how many people use our Website and how they use them to keep our Website running efficiently, improve our Websites and better understand our audiences, analyze and solve technical or organizational issues related to our Website (troubleshooting) and allow you to share content of our Website through your social media accounts, such as Facebook, LinkedIn or Instagram.
3.2.3 The Cookies we use are functional and analytical. Functional cookies are used for the purpose of carrying out or facilitating the transmission of communication via the Internet. Furthermore, we use these cookies when they are strictly necessary in order to provide our services to you. Analytical cookies are used in order to learn and understand how our visitors engage with our Website. These cookies allow us to improve and optimize our Website, for example by ensuring that our visitors can easily find the information they are looking for. In order to analyze how our Website are used, we count the number of visitors, the number of visits, the number of pages you use or the location from which you visit our Website.
3.2.4 If you no longer want cookies to be stored on your device, you can withdraw your consent at any time by adjusting your browser settings, so that your browser refuses all Cookies or the third-party Cookies. You can also delete the Cookies that have already been placed on your device. If the cookies are disabled, our Website will continue to work. However, some parts of our Website might not work when Cookies are disabled.
3.3.1 Our Website uses Google Analytics, a web analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses cookies, which allow an analysis of your use of the Website. The information generated by the cookie about your use of this website is typically transmitted to one of Google servers in the United States of America and stored there. However, due to the activation of IP anonymization on the Websites, your IP address will be truncated beforehand by Google within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the United States of America and truncated there. On our behalf, Google will use this information to evaluate your use of the Website, summarize reports on Website activities and provide other services related to website and Internet usage to us. The IP address transferred from your browser as part of Google Analytics will not be combined with other data from Google.
3.4.1 In order to present our content correctly and graphically appealing across all browsers, we use "Google Webfonts", a service provided by Google to display fonts on this website. We do not collect any Personal Data via the integration of Google Webfonts. The use of script libraries or font libraries automatically triggers a connection to the operator of the library. It is theoretically possible – but currently also unclear whether and to what end – that the operator, in this case Google, will collect Personal Data. The data protection guidelines of the library operator Google can be found under https://www.google.com/policies/privacy/.
3.5.1 We embed YouTube videos on our Website. The operator of the respective plugins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter "YouTube"). YouTube is a subsidiary of Google. When you visit a page with the YouTube plug-in, a connection to YouTube’s servers will be created, which tells YouTube, which pages you visit. When you are logged into your YouTube account, YouTube can associate your browsing behavior with you personally. You can prevent this by logging out of your YouTube account beforehand. If a YouTube video is started, the provider uses cookies that collect information about user behavior. Additional information on the purpose and scope of the data collection and its processing by YouTube in the provider’s privacy policy, as well as additional information on your rights and setting options for protecting your privacy (https://policies.google.com/privacy).
4.1 Subject to this Privacy Notice, Novaccess does not sell, transfer or otherwise disseminate your Personal Data to third parties and will not do so in future, unless required by law, for the purpose of the contract or unless you have given explicit consent to do so.
4.2 We may share your Personal Data in the following circumstances:
4.3 We may transfer the Personal Data we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Notice and in accordance with applicable law. We use contractual protections for the transfer of personal jurisdictions.
5.1 Novaccess takes all of the necessary technical and organizational security measures to protect your personal data from being lost or misused. In particular, your Personal Data is protected against unauthorized access, the confidentiality of your Personal Data is assured, the integrity and availability of your Personal Data will be maintained, our Personnel is trained in information security requirements and actual or suspected data breaches are reported in accordance with applicable law. To protect the security of your data during transmission, we use state-of-the-art encryption methods (such as TLS) via HTTPS.
6.1 Your personal information will not be stored for longer than necessary for the purposes for which they were collected or as required under applicable retention policies and/or in accordance with applicable law. Our retention policies reflect local statute of limitation periods and national statutory obligations of Novaccess. The criteria used to determine the period of storage of personal data is the respective statutory retention period.
6.2 After the retention period we will delete or anonymize your Personal Data, unless we need to retain certain of your Personal Data for another purpose. We will only do so if we have a legal ground to retain your Personal Data. We will also ensure that Personal Data are only accessible for that other purpose.
7.1 As Data Subject, you have the following rights in relation to your Personal Data:
7.1.1 Right of access You are entitled to a copy of the Personal Data we hold about you and to learn details about how we use it. Your Personal Data will usually be provided to you digitally. We may require you to prove your identity before providing the requested information.
7.1.2 Right to rectification We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you have the right to request that any incomplete or inaccurate Personal Data that we process about you is amended.
7.1.3 Right to erasure You have the right to ask us to erase your Personal Data, for example where the Personal Data is no longer necessary for the original purpose for which they were collected, where Personal Data has become obsolete or where you withdraw your consent to the grounds on which data is processed.
7.1.4 Right to restriction of processing You are entitled to ask us to (temporarily) stop using your Personal Data, for example where you think that the Personal Data we hold about you may be inaccurate or where you think that we no longer need to use your Personal Data.
7.1.5 Right to data portability You may have the right to ask that we transfer Personal Data that you have provided to us to a third party of your choice.
7.1.6 Right to object You have the right to object to processing which is based on our legitimate interests. You may also ask us to stop using your Personal Data for marketing purposes at any time, and if you do so, we will immediately cease to use your Personal Data. For other purposes based on our legitimate interests, we will no longer process the Personal Data on that basis when you file an objection, unless we have a compelling legitimate ground for the processing. Note, however, that we may not be able to provide certain services or benefits if we are unable to process the necessary Personal Data for that purpose.
7.1.7 Rights relating to automated decision- making You have the right not to be subjected to a decision based solely on automated decision- making, including profiling, which produces legal effects concerning you or similarly significantly affects you. If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision.
7.1.8 Right to withdraw consent We may ask for your consent to process your Personal Data in specific cases. When we do this, you have the right to withdraw your consent at any time. We will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
7.1.9 Complaint You have the right to lodge a complaint with the supervisory authority.
8.1 This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Please check back frequently to be informed of any changes.
8.2 By using our Websites and services you agree to this Privacy Notice.