This privacy policy (the “Privacy Policy”) applies to www.redeemswitzerland.com as well as any other affiliated sites, digital services, or applications on which a link to the Policy appears (collectively, the “Redeem® Website”) and applies to all visitors. “You” or “your” refers to the person accessing or using the Redeem® Website. “Redeem® ” or “we” or “our” refers to the operating legal entity conducting and operating the business activity of Redeem with a main place of business in Switzerland.

The Privacy Policy is intended to provide you with general information on the processing of your personal data (“Personal Data”). Personal Data is any information about you by which you can be identified. This can include information such as: your name, date of birth, email address, postal address, phone number, mobile phone number; information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and information relating to your personal circumstances and how you use the Redeem® Website.

By accessing the Redeem® Website you accept the Privacy Policy. If you do not agree to this Privacy Policy, do not proceed to access further web pages of the Redeem® Website.

How do we collect Personal Data?

We collect Personal Data from you under the following events and circumstances:

• Browsing over the Internet;
• Access to the Redeem® Website, through cookies and other similar technology;
• Surveys;
• User content;
• Use of digital applications;
• Requests for information;
• Participation in an event.

We collect Personal Data from you through the following points of contact:

• Browsing of redeem.com;
• Contact with our online advisers;
• Contact with us during an event that we organise;
• Contact with our customer service unit;
• Forms that you fill in, whether offline or online;
• Digital applications that you use;
• Redeem® pages on the social networks that you access and comment on/like;
• Advertisements in online media that you click on;
• Advertisements in search engines that you click on.

Why do we use your Personal Data?

We use Personal Data collected through the Redeem® Website for a number of purposes, including the following:

• To send you marketing communications when we have your permission, or when permitted by law.
• To personalise our services, e.g. remembering your settings, displaying personalised advertising as well as measuring how effective our online adverts are, recognising you when you sign in on different devices and tailoring our marketing communications based on what you read on the Redeem® Website.
• To carry out marketing analyses to better understand what your interests and preferences are, and to improve our marketing by making it more relevant to your interests and preferences. You can opt out from having your personal data used for marketing analyses by contacting Redeem® through the contact form of the Redeem® Website (available at “Write to Redeem® ”).
• To improve our marketing communications, Redeem® uses a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
• For statistical purposes such as analysing the performance of the Redeem® Website and to understand how visitors use them.
• To respond to your queries and to resolve complaints.
• For security and fraud prevention, and to ensure that our sites and apps are safe and secure and used in line with our Terms of Use on the Redeem® Website.
• To comply with applicable laws and regulations.

You may withdraw your consent at any point in time by contacting Redeem® through the contact form of the Redeem® Website (available at “Write to Redeem® ”). The withdrawal of your consent shall not affect the lawfulness of any processing of your personal data based on your consent prior to the withdrawal of your consent. Should you not provide the requisite information in these mandatory fields of the aforementioned contact form, we shall not be able to respond to your requests.

What is lawfulness for using your Personal Data?

We will only use your Personal Data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your Personal Data. In every case, the legal ground will be one of the following:

•  Consent: where you have provided your consent to receive marketing emails from Redeem®. You can withdraw your consent at any time. You may withdraw your consent at any point in time by contacting Redeem® through the contact form of the Redeem® Website (available at “Write to Redeem® ”). 
• Our legitimate interests: Where it is necessary for us to understand our readers, promote our services and operate the Redeem® Website efficiently for the creation, publication and distribution of marketing content both online and in print form, globally. It is also in our legitimate interest to carry out marketing analyses to determine what products and services may be relevant to the interests of the users of the Redeem ® Website. You can opt out from having your Personal Data used for marketing analyses by contacting Redeem® through the contact form of the Redeem® Website (available at “Write to Redeem® ”).
• Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.

How long do we keep your Personal Data for?

Generally, to the extent permitted by applicable laws and regulations, we retain your Personal Data for at most ten (10) years after the last communication where you have been involved. Additionally, as the case may require, we may have to extend Personal Data retention on the grounds of establishment, exercise or defence of legal claims or execution of our internal investigations. This retention period is justified due to our obligations or needs related to e.g. burdens of proofs in possible litigation situations.

Otherwise, your Personal Data is kept for a period of time that does not exceed two  (2) months for geolocation data; and twelve (12) months for any cookies stored on your computer.

How do we deal with Disclosures and Transfers of Personal Data?

Your Personal Data is generally not disclosed (to be independently processed for purposes other than ours) to third parties outside our affiliates. In some circumstances, we may have to disclose your Personal Data by law, because of a court order issued to the police or to other law enforcement agency that has asked us for it. Your Personal Data may, however, be transferred to our affiliates or to third parties (e.g. subcontractors) who process Personal Data on behalf of Redeem® for the purposes described in the Privacy Policy.

We may provide aggregate statistics about the users of Redeem® Website, and other related information to third parties, but these statistics are anonymous and will not include your Personal Data.

Your Personal Data may be processed in locations other than the country in which you are situated because of technical and practical requirements. Therefore, countries to which your Personal Data may be sent and/or accessed from may have a different standard of data protection than the country in which you are situated.

Nonetheless, the processing and administration of Personal Data shall be in accordance with applicable legislations and the Privacy Policy.

What should you consider about security when sending data over the Internet? The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the Redeem® Website or via electronic message) may be accessed by unauthorised third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and may be forwarded to a country with a lower data protection level than in your country of residence. The transmission of information via the internet is generally not regarded as secure. Redeem® cannot fully guarantee the security of your Personal Data transmitted to us; any such transmission is therefore at your own risk.

Please note that we accept no responsibility or liability for the security of your information whilst in transit over the Internet to Redeem® .

In order to protect your privacy, we would like to remind you that you may choose another means of communication with Redeem® , where you deem it appropriate.

How do we deal with information from individuals under the age of 18?

Neither Redeem® nor the Redeem® Website seek to collect personal data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before using the Redeem® Website and submitting any Personal Data to Redeem® on the Redeem® Website.

How do we use Cookies?

From time to time, Redeem® may place information on your computer which allows us to recognise your computer. This information is commonly known as a “cookie”. Redeem® may use cookies for statistical purposes and to improve user experience and online advertising. Redeem® has established a Cookie Policy, as modified from time to time, which explains why and how personal data is collected on the Redeem® Website and used (available at “Cookie Policy”). References to the Cookie Policy above and below include also the contents of the Cookie Policy unless otherwise stated case by case. In case of possible discrepancy, the information provided in the Cookie Policy prevails over information of the Privacy Policy. The Cookie Policy is part of the Terms of Use of the Redeem® Website (available at “Terms of Use”).

What are your Rights?

You may, where permitted by applicable law and/or regulation:

• Check whether we hold your Personal Data;
• Ask us to provide you with a copy of your Personal Data;
• Require us to correct any of your Personal Data that is inaccurate;
• Request the erasure of your Personal Data;
• Manage any cookies;
• Issue instructions to us on the fate of your Personal Data after your death.

What about links to other websites?

The Redeem® Website may contain hyperlinks to other websites that are not operated or monitored by Redeem® . These other websites are not subject to our Privacy and Cookie Policies and Redeem® is not responsible for their content or for the policy they apply to the treatment of personal data. Your use of these links will be at your own risk.

How can you contact us on data protection and privacy related matters?

If you want to contact Redeem® on data protection and privacy related matters, please use the contact form of the Redeem® Website (available at “Write to Redeem® ”).

Please note that we may ask you for evidence of your identity as well as the full details of your request prior to dealing with it.

Latest Update: January 20, 2020