PRIVACY POLICY (GDPR compliancy)

In short

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.

GENERAL INFORMATION

This privacy policy applies to all online services of Loway.ch

The controller is:

Loway SA
Via Laveggio 3
6855 Stabio
Switzerland

Tel.: +41 (0)91.6309765
E-Mail: support@loway.ch

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.

REGISTRATION DATA

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.

EMAIL ADDRESSES

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.

FORUM

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.

CAREER PORTAL

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,
Singapore 038985

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.

THIRD COUNTRIES

Data is transferred to third countries in adherence to the legally regulated admissibility requirements. We will not transfer your data to a third country

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

YOUTUBE

We integrate videos from the YouTube platform provided by Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated. The legal basis for this data processing is Art. 6 (1) lit. f GDPR.

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

On the basis of our legitimate interests (i.e. interests in analysis, optimization and commercial operation of our online offers within the meaning of Art. 6 (1) lit. f GDPR), we use Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offers by you, the user, is usually sent to a Google server in the USA and stored there.

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:

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.

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