Loway only collects and information you choose to give us, and processes it with your consent or on legal basis. We collect as little personal information as we can to allow us to provide our services. Personal information is not sold to third parties and is used and processed as described on this page.
We comply with the US’s Privacy Sheld framework and the european General Data Protection Regulation (GDPR). We provide the same level of privacy protection regardless of your country of origin or location.
The controller is:
Via Laveggio 3
Tel.: +41 (0)91.6309765
VAT ID No. CHE 498.426.270
HOW DO YOU PROCESS PERSONAL DATA?
We save and use your personal data only to process your orders and to get in touch with you. If you subscribe to our customer newsletter, we also use your email address to send it out. We also save and process data that job applicants provide us as part of the job application process.
WHAT CATEGORIES OF DATA DO WE COLLECT?
Every time you visit our website, your IP address and other pieces of information are saved in anonymized form. If you register an account with us, your contact information will be stored. If you order products from us, your address and payment information will also be stored.
In particular, we save the following data from you.
When you register an account with us, we collect and process certain personal data from you as your registration data. For example, we need your name, address information, telephone number, payment information and your email address to process your order.
If you pay using a credit card, we do not collect and store any payment information such as credit card numbers or verification codes. You disclose this information only to the respective payment service provider.
We delete all your registration data either: within 24 months, as soon as you delete your user account with us, or once the statutory retention period expires. You can delete your user account with us by sending an email to the data protection officer with your deletion request. The legal basis for this data processing is Art. 6 (1) lit. b GDPR.
If you subscribe to our newsletter or request that you receive automated messages from Loway, we also store your email address. We delete your email address once you delete your user account or if you unsubscribe from our newsletter. The legal basis for this data processing is Art. 6 (1) lit. a or Art. 6 (1) lit. b GDPR.
SERVER LOG FILES
Whenever you visit our websites, we automatically store certain data. This includes your IP address, type and version of the browser you use, time, date, website from which you come to our site. Your IP address is saved for 7 days and then anonymized. You can then no longer be identified. The legal basis for this data process is Art. 6 (1) lit. f GDPR.
If you register on our online discussion forum, we save your username and email address. After you delete your account on the forum, saved data will also be deleted. The legal basis for this data processing is Art. 6 (1) lit. a GDPR.
If you send us job application documents such as your resume, references and cover letter, we will save and process these pieces of data. Application documents from job applicants that do not result in hires are deleted after 3 months. If you wish to be considered for future job openings and you consent to a longer storage period, your application documents will be deleted after 24 months. With applications that result in hires, the documents are forwarded to our HR department. The legal basis for the processing of your personal data in the job application process is Art. 6 (1) lit. a,b GDPR
WHO WE FORWARD YOUR DATA TO
External service providers may have access to your data while they assist us in providing our services. In some cases, third parties such as government authorities, external consultants, or our business partners may receive your data.
IN PARTICULAR, THIS MAY OCCUR IN THE FOLLOWING CASES:
PAYMENT / SUBSCRIPTION VIA CREDIT CARD OR PAYPAL
When paying via credit card or with a PayPal account, the payment is processed by an external service provider. For credit card payments and PayPal payment, your information is collected directly by:
PayPal Pte. Ltd.
5 Temasek Boulevard,
#09-01 Suntec Tower Five,
DEBT COLLECTION AGENCY
If you as a customer fail to pay your invoices on time, your necessary data are passed on to an external debt collection agency.
Data is transferred to third countries in adherence to the legally regulated admissibility requirements. We will not transfer your data to a third country
- if it does serve the purpose of performing our contract with you
- we have no consent from you
- the transfer is not necessary to assert, exercise or defend legal claims
We will only transfer your data to a third country if there is an adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR. Once such adequacy decision (regarding an adequate level of protection) is the "Privacy Shield" for the USA.
For transfers to a company certified under the Privacy Shield, the data privacy level is considered essentially as adequate within the meaning of Art. 45 GDPR. However, we usually do not rely on the Privacy Shield, but rather create appropriate privacy guarantees and complete the EU standard data privacy clauses issued by the European Commission with the receiving party. Together these actions establish appropriate safeguards in accordance with Art. 46 GDPR and provide an adequate level of protection.
OTHER CATEGORIES OF RECIPIENTS
State authorities and courts
WHERE DO WE PROCESS YOUR DATA?
We process your data exclusively in our data centers in South Africa, Germany and United States.
SOCIAL MEDIA DATA
ONLINE PRESENCE ON SOCIAL MEDIA
We maintain online presence on social networks and platforms in order to communicate with our customers, interested parties, and users and to inform them about our services.
We use Facebook, Twitter, and Instagram, Twitter, Google +, Linked-in and Vimeo, among others. When visiting each of these platforms, you as a user agree to the terms and conditions and the data processing guidelines of the corresponding operator. Unless stated otherwise in our data privacy notice, we process user data if users communicate with us on these social networks and platforms, e.g. publish posts on our pages or send us messages.
GOOGLE UNIVERSAL ANALYTICS
Google is certified under the Privacy Shield agreement and thus provides a safeguard in adherence to European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use this information on our behalf to assess how you use our online offers, to put together reports about activities within these online offers, and to provide other services to us in connection with the usage of these online offers and the Internet use of related services.
Pseudonymized usage profiles of you can be created from the processed data. We use Google Analytics in the "Universal-Analytics" version.
We use also HotJar to create an "hotmap" and to see anonymized visits of our visitors, to understand better how improve our services & products.
YOUR RIGHTS AS A "DATA SUBJECT"
As an Loway Client, you are entitled to exercising the following rights with regard to the personal data Loway holds about you:
- Right of information
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right to not to be subject to a decision based solely on automated processing.
If you do not make requests for information in writing, please bear in mind that we might ask you to provide proof that you who you claim to be. Furthermore, you have a right to rectification or deletion or restriction of processing, as it is applicable to you under the law. Furthermore, in accordance with legal requirements, you have the right to object to us processing your data. You also have the right of data portability.
Exercise-of-rights enquiries should be addressed by emailing Loway to be handled by the Loway's team.
RIGHT TO LODGE A COMPLAINT
You have the right to lodge a complaint about the processing of your personal data by us to a supervisory authority for data protection.
VOLUNTARY NATURE OF DATA PROVISION
There is no statutory obligation for you to provide your data to Loway. However, you cannot use some of our services if you do not provide your data to us. Your decision to provide us with your personal data is completely voluntary.
Loway as Controller
Loway act as controller for all the data collected and needed to fulfill his normal business activity (GDPR art.6 lit a,b).
Loway as Processor
Loway is processor of personal data on behalf of his customers. The typical example are the personal data stored by a Loway’s customers in a hosted instance of Queuemetrics-Live.
As processor, Loway respects the GDPR and commit himself to process data safely and legally.