Data Protection Information
The registered office of InformatiCH Sagl is located within the Swiss Confederation and therefore this company is primarily subject to the Federal Act on Data Protection (FADP) in the handling of personal data, in particular of persons residing in Switzerland. In addition, the EU General Data Protection Regulation (GDPR) serves as the legal basis for the handling of personal data of citizens of the European Union.
In this regard, InformatiCH Sagl informs you that it needs to process your personal data collected automatically, or provided by you, through navigation and/or use of the website.
This applies to the following sites:
- informatich.ch
- teledidattica.ch
- lavororemoto.ch
- ellepidi.ch
- lpdday.ch
- suisselegaltech.ch
- hyperspectral.ch
- fl0wer.me
(hereinafter “Website”).
1. DATA CONTROLLER
The Data Controller is InformatiCH Sagl, with registered office in Via Vallera 16, 6852 Genestrerio (hereinafter “Data Controller”).
2. DEFINITIONS AND TYPES OF PERSONAL DATA PROCESSED
Personal data means any information that identifies or makes identifiable, directly or indirectly, a natural person and that can provide information on his or her characteristics, habits, lifestyle, personal relationships, health, economic situation, etc.
Processing of personal data means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, even if not recorded in a database, such as collection, recording, organization, storage, modification, extraction, use, communication by transmission, dissemination or any other form of making available, limitation, cancellation or destruction.
The personal data that are processed to respond to any requests for information through the contact form are the following:
- name, surname, telephone number, email address.
The personal data that are processed for the newsletter subscription and to be constantly informed about the initiatives of InformatiCH Sagl, or to receive various promotions and discounts, are those relating to your email address.
For certain newsletters, the following may also be requested, on an optional basis:
- company you belong to and role you hold.
In the context of the use of the Website, it is communicated that, in principle, all users can visit the website without providing personal information.
The types of data processed and the related specific information for “cookies” are specified below.
Browsing data
During their normal operation, the software procedures and computer systems that determine the functioning of the Website acquire some personal data whose transmission is implicit in the use of internet communication protocols.
This information is not collected to be associated with identified interested parties, but it is specified that by its very nature it could, through processing and association with other data held by the Owner or by third parties, allow users to be identified.
This category of data includes:
- the IP addresses of the computers used by users connecting to the Website which will be anonymized for statistics;
- the URI (Uniform Resource Identifier) addresses of the requested resources;
- the time of the request;
- the method used in submitting the request to the server;
- the size of the file obtained in response;
- the numeric code indicating the status of the response given by the server (successful, error, etc.);
- other parameters relating to the user’s operating system and computing environment.
This data may be used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Website and possibly to check its correct functioning.
Furthermore, the data collected could be used, in agreement with the judicial authority, also for the ascertainment of responsibility in the event of hypothetical computer crimes against the Data Controller. Except for this hypothesis, we inform you that the data on contacts to the Website are not stored on board the servers for more than thirty days.
Data provided voluntarily by the user
To consult the site, no provision of personal data by the user is required.
However, any contact with InformatiCH Sagl, or the optional, explicit and spontaneous sending of messages, by electronic or traditional mail, to the addresses indicated on the site entail the subsequent acquisition of the e-mail address, or even postal address, of the sender or the relative telephone number, necessary to respond to requests, as well as any other personal data included in the relative communications.
Such data will be used for the sole purpose of following up on the user’s request and may be communicated to third parties only if this is necessary for this purpose.
Your consent is not required for the processing of data for these purposes, as the processing is necessary for the performance of a contract to which you are a party or for the performance of pre-contractual measures adopted at your request, as well as, where applicable, to comply with a legal obligation.
Such data are retained for the time strictly necessary to provide the user with the requested service and are deleted immediately thereafter, except for further retention obligations required by law. Your data will not be disclosed.
Cookie Policy
Below are the types of cookies used by this Website, to understand how personal data will be processed through this type of technology.
Technical cookies
This Website uses so-called “technical cookies”, that is, small fragments of text containing a certain amount of information exchanged between the Website and your terminal that allow normal navigation of the site and are essential to guarantee its operation.
The site uses technical cookies for the purposes that allow it to function correctly.
However, cookies are not used to transmit information of a personal nature, nor are persistent cookies of any kind used, except for access by System Administrators.
Analytical cookies
This Website uses so-called “analytics cookies” created and made available by third parties, namely Google Analytics. This is done for mere internal statistical analysis of access, to improve the Website and simplify its use, as well as to monitor its correct functioning. The Data Controller has however adopted the most suitable tools to reduce the identifying power of this type of cookie to a minimum.
Google Analytics publishes its cookie policy here.
Third party cookies
The site also uses third-party cookies in the following ways:
- The user, through acceptance or denial through the cookie warning banner, is responsible for the decision about the use, for his/her session, of such cookies within the website.
- InformatiCH Sagl does not receive identifying data of any kind through the use of these cookies, nor is it able to individually identify the people involved in the statistics.
- InformatiCH Sagl and the user have both accepted the information and conditions of service of the owners of the platforms to which third-party cookies refer, therefore the responsibility for the use of personal data lies solely with the third party.
- InformatiCH Sagl is solely responsible for the decision of adequacy regarding the adoption of third-party cookies and technical measures (banners with the possibility of total or selective refusal) that allow the user to not accept the aforementioned tracking.
Third parties have their own privacy policies and data collection methods.
The information can be found at the following links:
Meta (Facebook) – https://www.facebook.com/legal/FB_Work_Privacy
Google (Analytics) – https://marketingplatform.google.com/about/analytics/terms/it/
Linkedin – https://it.linkedin.com/legal/privacy-policy
Google (Youtube) – https://www.youtube.com/howyoutubeworks/user-settings/privacy/
Profiling cookies
This site does not use so-called “profiling cookies”, as the Data Controller does not intend to create profiles relating to the user in order to send advertising messages in line with the preferences expressed by the user while browsing the Internet.
Options regarding the use of cookies by the site through browser settings
The provision of all cookies, both first and third party, can be deactivated by changing the settings of your browser in use. It should be noted, however, that this could make the Website unusable if cookies essential for the provision of certain services are blocked. Each browser has different settings for deactivating cookies.
3. PURPOSE OF THE PROCESSING AND LEGAL BASIS
The processing of personal data is carried out solely for the following purposes:
- to respond to user requests for information and assistance. The processing is functional to fulfilling a user request and is based on the execution of a contract or pre-contractual measures;
- to ensure the correct functioning of the web pages and their contents. In this case, the data processing is based on the legitimate interest of the Owner;
- for sending one or more newsletters upon request of the user. The processing is based on the consent of the interested party;
- to communicate your personal data, where this is requested by the competent authorities. In this case, the processing of your data is based on the need to comply with a legal obligation.
By accepting this Privacy Policy, you declare that you approve it in all its points.
To unsubscribe from the newsletter you can do so at any time, just click on the appropriate link found in each communication received.
4. PERIOD OF STORAGE OF PERSONAL DATA
Personal data are processed both with automated tools and with paper supports, only for the purposes indicated and for the time strictly necessary for the purposes for which they were collected. It is specified that the Data Controller has adopted all necessary security measures to prevent data loss, illicit or incorrect use and unauthorized access.
The data on contacts to the Website will not be stored for more than thirty days, unless these are necessary to ascertain responsibility in the event of hypothetical computer crimes against the Data Controller.
Data relating to requests sent containing personal data are deleted after 6 months from receipt.
With regard to any further personal data, not being able to precisely determine the retention period, the Data Controller undertakes from now to inspire the processing of personal data to the principles of adequacy, relevance and data minimization, as required by the European Regulation and Federal Legislation, constantly verifying the need for their conservation.
Therefore, once the purposes for which they were collected and processed have been achieved, they will be removed from the systems or made completely anonymous.
5. CATEGORIES OF DATA RECIPIENTS
In order to pursue the purposes indicated above, it may be necessary for the Company to communicate your personal data to the following categories of recipients:
- the company’s employees, duly authorised and designated as System Administrator by the Data Controller pursuant to the European Regulation and Federal Legislation;
- third parties who may access the data pursuant to legal provisions established by European Union law or by that of the Member State to which the Data Controller is subject;
- third parties (companies, freelancers, etc.) operating both inside and outside the Swiss Confederation, undertaking to remain exclusively within the borders of the European Union and the countries that adopt the GDPR regulation, which process your Personal Data for purposes ancillary to the activities and services previously indicated, such as companies that offer advertising, marketing and communication services, IT and information technology services, design and creation of Internet sites.
Any communication of personal data will take place in full compliance with the provisions of the law set forth by Swiss and European legislation and by the technical and organizational measures put in place by the Company to guarantee an adequate level of security.
6. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
The data will be mainly processed within the national territory, but could also be transferred to other countries within the EU territory.
Any transfer of the Data Subject’s Data to countries located outside the European Union will only take place in compliance with adequate guarantees for the purposes of the transfer itself, i.e. that the Confederation has confirmed that the Third Country has an adequate level of data protection or there are other guarantees relating to the protection of the same, such as binding corporate rules or the subscription of EU standard contractual clauses.
7. RIGHTS OF THE INTERESTED PARTY
The subjects to whom the personal data refer have the right, at any time, to obtain confirmation of the existence or otherwise of the same data and to know its content, verify its accuracy or request its integration or updating, or rectification.
It is also specified that:
- you can withdraw your consent to the processing at any time.
It should be noted, however, that the withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal; - it is possible to ask the Data Controller for access to personal data;
- it is possible to obtain from the Data Controller the rectification and integration of personal data deemed inaccurate, also by providing a simple supplementary declaration;
- it is possible to obtain from the Data Controller the deletion of personal data;
- it is possible to obtain from the Data Controller the limitation of the processing of personal data if one of the hypotheses provided for by the relevant legislation occurs;
- it is possible to receive from the Data Controller the personal data concerning you in a structured, commonly used and machine-readable format, and it is also possible for such data to be transmitted to another Data Controller without impediments, as provided for by the relevant legislation;
- you may object at any time, for reasons relating to your particular situation, to the processing of your personal data, including profiling;
- you can lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the relevant legislation. The complaint can be lodged in the country where you habitually reside, work or in the place where the alleged violation occurred.
To exercise each of your rights, requests should be addressed:
- by email, to privacy@informatich.ch ;
- or by post, to InformatiCH Sagl – Via Vallera 16, 6852 Genestrerio;
providing the following data:
- name, surname and postal address;
- request details;
- a clearly legible, colour copy of a valid identity document.
8. CONSENT OF MINORS IN RELATION TO INFORMATION SOCIETY SERVICES
To use the services provided through the Website, you must be over sixteen years of age: consent to the processing of personal data of a minor under the age of sixteen is lawful provided that it is exercised by the person exercising parental responsibility.
9. GOOGLE RECAPTCHA
Our primary goal is to ensure the highest level of security and protection of the site for the benefit of the user and our organization.
For this purpose we use the Google reCAPTCHA service provided by Google Inc.
Responsible for providing all Google services for the European area is Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland), reCAPTCHA allows us to verify that the user is a person and not a robot and that he is not entering spam; by spam we mean any unwanted information that is sent to us electronically without our request.
The classic CAPTCHA setup involves verification by solving text- or image-based questions. Using Google’s reCAPTCHA service, however, there is usually no need to bother the user with such operations. In most cases, it is sufficient to check the appropriate box to confirm that you are not a bot.
With the new version Invisible reCAPTCHA the check mark is no longer necessary. This privacy policy provides more details about this function and the data used for this purpose.
What is reCAPTCHA?
ReCAPTCHA is a free Captcha service provided by Google that protects sites from spam and abuse by robots. It is a service frequently used in association with online forms. A Captcha service is a kind of automatic Turing test aimed at ensuring that a certain online operation is performed by a human and not by a bot.
The classic Turing test requires a human to detect the difference between a bot and a person. In the case of Captcha, the verification is done by a computer or a software program. Classic Captcha works with small questions that are easy for a human to solve, but are very difficult for a machine.
The reCAPTCHA tool does not require the solution of questions, as it uses modern risk detection technologies to distinguish between humans and bots. In this case, it is sufficient to tick the box in the “I am not a robot” field, a function that is not necessary with the Invisible reCAPTCHA solution.
reCAPTCHA integrates a JavaScript element into the source text and analyzes the user’s behavior in the background. Based on the user’s actions, the software calculates a so-called Captcha score. Even before the Captcha is entered, Google uses this score to calculate the probability that the user is a human.
reCAPTCHA or Captchas in general are used in cases where bots could manipulate or abuse certain operations (e.g. registrations, surveys, etc.).
Why does our site use reCAPTCHA?
We only want to welcome people on our site. Bots or spammers of any kind are not welcome. For this reason, we use every means available to protect the site and make it as easy as possible for the user to use our pages.
This is the reason why we use the reCAPTCHA service provided by Google. By doing so, we can minimize the possibility that no bot will be able to access our site.
The use of reCAPTCHA involves the transmission of data to Google in order to detect that the user is a human being.
reCAPTCHA therefore guarantees the security of our site and, consequently, of the user by preventing the occurrence of certain attacks. Without this function, it could happen, for example, that during the registration phase a bot enters a series of email addresses to subsequently flood multiple forums or blogs with unwanted content (spamming); or, in the case of the sale of tickets to events, it could happen that a bot reserves all (or part) of them, making them unavailable.
What data does reCAPTCHA save?
reCAPTCHA collects personal data from the user in order to verify that the use of the site is carried out by a human being. The IP address and other data are transmitted to Google to enable this service.
Within member states of the European Union and in other states party to the Agreement on the European Economic Area, IP addresses are truncated prior to transmission to a server in the United States.
The IP address is not associated with other data held by Google unless the user is logged into their Google account when using reCAPTCHA. The reCAPTCHA algorithm first checks whether the user’s browser contains cookies from other Google services (YouTube, Gmail, etc.). ReCAPTCHA then saves an additional cookie in the user’s browser and takes a snapshot of the browser window.
Below is a list of the user and browser data collected in this context, although we do not guarantee its completeness. Rather, these are examples of data that we know Google processes.
- Referrer URL;
- IP address;
- operating system data;
- cookies;
- mouse and keyboard movements;
- date and language settings;
- all JavaScript elements;
- screen resolution.
There is no doubt that Google uses and analyzes this data even before the user checks the box “I am not a robot”. In the Invisible reCAPTCHA version, even the check mark is omitted and the entire identification process takes place in the background.
Google does not provide details on the amount and type of data it stores.
reCAPTCHA uses the cookies listed below. The information refers to the demo version of Google’s reCAPTCHA available at www.google.com/recaptcha/api2/demo ( www.google.com/recaptcha/api2/demo ).
How long do I keep my personal data?
The integration of reCAPTCHA involves the transmission of user data to the Google server.
Despite numerous requests, Google does not provide clear information about where the data is saved.
In the absence of confirmation from Google, it is assumed that data such as mouse interactions, duration of the visit to the site or language settings are saved on Google servers in Europe or the USA. The IP address transmitted to Google by the user’s browser is not associated with other data held by Google from other services offered.
However, the data will be associated if the user is logged into their Google account when using the reCAPTCHA plugins. In this context, the privacy policy of the Google company applies.
How can I delete my data or prevent it from being saved?
If you do not want your personal and website usage data to be transmitted to Google, you must log out of Google and delete all cookies before visiting our website or using reCAPTCHA, or use an anonymous session window.
The data is usually transmitted to Google automatically as soon as the user opens the website page.
To delete this data you need to contact Google support at https://support.google.com .
By using our site, you agree that Google LLC and its representatives automatically collect, process and use data.
For more details on reCAPTCHA, please visit the Google page dedicated to web developers developers.google.com/recaptcha/ .
Google discusses the technical development of reCAPTCHA here, but unfortunately does not provide precise information on data storage and other privacy aspects.
We point out a good overview of the use of data in the Google privacy policy at: www.google.com/intl/it/policies/privacy/
10. DOWNLOAD THE INFORMATION
In order to better protect its users, InformatiCH Sagl invites you to download the information and check that it is the latest version available.