Confidentiality Policy of Vasperis

This Confidentiality Policy (“Confidentiality Policy”) describes how Vasperis SA (hereinafter “Vasperis”) uses your personal data. It applies to the Vasperis web site www.otentika.com and to all of the web sites for products and services proposed by Vasperis (hereinafter the “Site”).

The personal data are collected by Vasperis, a private company formed under Swiss law, registered with the Corporate Registry of the Canton of Geneva under the number CHE 116.281.302 and whose registered offices are located at 2 Rue Fançois-BELLOT – CH-1206  Geneva, Switzerland.

Your personal data are collected on our Site in the following two ways:

• directly, when you freely provide us with your personal data ;
• automatically via your browsing history

Personal data collected directly from you may include the following data and any other type of information that we expressly ask you to enter in our collection formulas, such as:

• Last name
• First name
• Postal address
• E-mail address
• Telephone number
• Number and means of payment

You will be informed as to whether the data is obligatory or optional during collection by an asterisk.

We also gather certain data automatically when you browse the Site.

The information gathered automatically includes:

• Your computer’s IP address;
• Information relating to your computer, your means of connecting, such as your internet browser type and version, your operating system, the operating system of your mobile or tablet computer, and the unique digital identifier ("UDID") and other technical identifiers;
• The URL address for your connections, including the date and time, and the content you access;

We can use and communicate this date for the purposes described in the article “Purposes – use of your data” of this Confidentiality Policy, up to the limits under applicable law.

We hereby inform you that we can associate this data with your personal data, and such associated information will be processed by Vasperis as personal data as defined in European directive 95/46 on the protection of personal data, and, as of 25 May 2018, General Regulation 2016/679 on Data Protection (“RGDP”) adopted on 27 April 2016.

We also hereby inform you that we can use the data collected automatically on an aggregated basis for various purposes without such data making it possible to identify you personally: this aggregated data is not considered as personal data.

In connection with improving the service, cookies are installed during navigation on the Site.

A “cookie” is a small file that does not make it possible to identify the user but which records information relative to the navigation of a computer on a site.

2.3.1 vasperis’ cookies

a) the strictly necessary cookies

Certain of our cookies are for the exclusive purpose of making it possible or easier to communicate by electronic means and are strictly necessary for the provision of our on-line communications services at the user’s express request.

These are primarily session cookies and shopping cart cookies that make it possible to authenticate and connect to the Site, as well as memorization of navigation elements during a session.

b) cookies that are not strictly necessary

The cookies that we use record the information in your favorites and enable us to adapt to your interests.

You can define, through your browser, the rules for accepting all cookies, and can be informed when a cookie is sent to you, or even specify that you do not wish to receive any cookies. If this last case is implemented by you, we inform you that certain characteristics of our Site may not function as planned.

 
The information provided by the cookies can help us to better analyze your navigation on the Site.

We use the three following types of cookies:

• The session cookies that are temporary and are deleted when you close your browser;
• The permanent cookies that remain until you have deleted them or they have expired;
• The web beacons, which are electronic images also called invisible pixels.

In general, the cookies, web beacons and other similar technologies do not contain any personal data, but when you provide your personal data through the Site, this personal data may be linked to cookies.

We use the cookies and other similar trackers to personalize our services and advertising, specifically to manage your shopping cart, memorize what you have consulted and personalize our offers for you and the information we send you. These cookies can notably enable you to benefit from our personalized recommendations and to be informed of our promotional offers.

Most web browsers automatically accept cookies, but you may modify the parameters to reject them if you wish.

The period of validity of your consent to the use of the cookies will not exceed thirteen (13) months and may be extended by a new form of consent by you.

 
2.3.2 Google Analytics

The Site uses Google Analytics, an analysis tool for internet sites from Google Inc. (hereinafter “Google”).

We therefore hereby inform you that the information obtained from the cookies linked to your use of the Site is likely to be sent to a Google server in the United States where it will be stored.

We use Google Analytics, specifically for advertising purposes, and to enable you to receive targeted advertising that is pertinent and up to date.

We hereby inform you that the use of Google Analytics may authorize Google to collect data on the Site’s traffic.

We also hereby inform you that third party suppliers use, jointly with Vasperis, cookies or owner handles (such as the Google Analytics cookie), and cookies or third party identifiers (such as Google’s advertising cookies).

You may deactivate the Google Analytics advertising functionalities, including through the advertisement parameters.

If you wish to deactivate the Google Analytics advertising functionalities, we encourage you to download the complementary Google module available through the following link: http://tools.google.com/dlpage/gaoptout

2.3.3 third party cookies

When you access the Site, one or several cookies from partner companies (“third party cookies”), may be added to your computer. These third party cookies are for the purpose of identifying your interests through the products viewed or purchased on the Site and collecting browser data in order to personalize the advertising we send you outside of the Site.

In the context of this sort of advertising partnership, Vasperis may send to the partner certain data concerning your purchases and the products viewed on the Site.

We hereby inform you that Vasperis does not have access to or control over the third party cookies. However, we ensure that the partner companies accept to process the information collected on the Site in compliance with applicable regulations and commit to implementing the appropriate security and protection measures to maintain confidentiality of the data.

We hereby inform you that you may reject third party cookies.

Your information and data are necessary for the management of your order and our commercial relations. This information and data are also kept for security reasons, in order to comply with legal and regulatory obligations.

Your information and data enable us to improve and personalize the services that we offer you and the information we send you.

Your information and data enable us to respond to your messages and provide you with any information you may request using the Site’s “Contact” tab.

Vasperis is committed to ensuring the security of sensitive data provided by customers. We take every possible precaution available for the personal data provided and the risks associated with their processing in order to protect the security of personal data and, specifically, to prevent their corruption, damage, or use by unauthorized third parties. In this way, your data remains secure when customers purchase our products online. 
We provide a secure online payment system using the latest technologies. 

Data collected on the website is stored as long as your account with us remains opened. If you did not create an account, Vasperis is authorized by law to archive your personal data as long as required for data processing purposes and in accordance with all statutory periods of limitation. Vasperis is also is authorized by law to store your personal date for a period of 3 years after your last purchase on the site or your last contact with Vasperis. Your credit card information will be stored on an encrypted server for 13 months after your last purchase.

Your personal data is exclusively intended for Vasperis.

The following may, within the confines of their respective remits, have access to your personal data:

• The people working in the marketing, commercial, client relations and development, administrative, logistics and IT departments and their respective managers;
• The services responsible for auditing (statutory auditors, internal control and audit procedures departments...);
• the sub-contractors when the contract signed between the sub-contractors and the processing manager states the obligations incumbent on the sub-contractors with regard to security and confidentiality of data.

In compliance with European regulations on protection of personal data, you have a right to access and correct – and in legitimate cases – a right to contest your personal data. To exercise your rights, you need only to write to us at the following address:

 Vasperis SA – 2 Rue François-BELLOT CH-1206 Geneva - Switzerland.

In compliance with applicable regulations in effect, your request must be signed and accompanied by a copy of your identity documents with your signature, and you must specify the address to which you wish the response to be sent. A response will be sent to you within two months at most following the date of receipt of your request

We use a variety of data security measures to guarantee the confidentiality and the integrity of your personal information including the latest technologies

our personal data may be transferred to other countries; by using the Site, you consent to the transfer of your data towards countries outside of the European Union.

All transfers are made to the following:

-          either a country recognized by the European Commission as guaranteeing an adequate level of protection

-          or a country that does not provide an adequate level of protection but where the transfer is covered by contractual clauses of the European Commission type that guarantee a level of protection of the privacy rights and the fundamental rights of persons.

This Confidentiality Policy may be amended at any time at Vasperis’ discretion.

If we modify this Confidentiality Policy, we will publish the revised version here, with the date of the update.

If you have any comments or questions on this Confidentiality Policy or our processing of your information, you may contact us at the following address: 2 Rue François-BELLOT –1206 Geneva, Switzerland.

This Confidentiality Policy was updated on Feb 25 2019