Privacy Policy of CY.TALK SWITZERLAND S.A.


CY.TALK SWITZERLAND S.A. collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

CY.TALK SWITZERLAND S.A. 7,
Place du Rondeau,
1227 Carouge (Geneva),
Switzerland
Owner contact email: email

Types of Data collected

Among the types of Personal Data that CY.TALK SWITZERLAND S.A. collects, by itself or through third parties, there are: Cookies; Usage Data; Data communicated while using the service; app information; country; date of birth; device information; device logs; email address; first name; gender; last name; username; website; phone number; VAT Number; company name; profession; address; state; ZIP/Postal code; various types of Data; city; Tax ID; field of activity; User ID; number of employees; Contacts permission; Camera permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Phone permission; SMS permission; Social media accounts permission; Call permission; password; picture; workplace; billing address; language; Twitter handle; geographic position; county; payment data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using CY.TALK SWITZERLAND S.A.
Unless specified otherwise, all Data requested by CY.TALK SWITZERLAND S.A. is mandatory and failure to provide this Data may make it impossible for CY.TALK SWITZERLAND S.A. to provide its services. In cases where CY.TALK SWITZERLAND S.A. specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by CY.TALK SWITZERLAND S.A. or by the owners of third-party services used by CY.TALK SWITZERLAND S.A. serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through CY.TALK SWITZERLAND S.A. and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of CY.TALK SWITZERLAND S.A. (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Beta Testing, Content commenting, Contacting the User, Data transfer outside the EU, Device permissions for Personal Data access, Advertising, Registration and authentication, Access to third-party accounts, Interaction with external social networks and platforms, Interaction with live chat platforms, RSS feed management, Managing contacts and sending messages, Infrastructure monitoring, Location-based interactions, Remarketing and behavioral targeting, Handling payments, SPAM protection, Tag Management, Social features and Displaying content from external platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by CY.TALK SWITZERLAND S.A.

CY.TALK SWITZERLAND S.A. may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows CY.TALK SWITZERLAND S.A. to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer Facebook permissions documentation and to the to the Facebook privacy policy.
The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Age range

Provides access to the User's age range.

Contact email

Access the User's contact email address.

Current City

Provides access to the User's current location.

Email

Provides access to the User's primary email address.

Gender

Provides access to the User's gender.

Hometown

Provides access to the User's hometown.

Device permissions for Personal Data access

Depending on the User's specific device, CY.TALK SWITZERLAND S.A. may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of CY.TALK SWITZERLAND S.A.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by CY.TALK SWITZERLAND S.A.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. CY.TALK SWITZERLAND S.A. may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. CY.TALK SWITZERLAND S.A. may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for CY.TALK SWITZERLAND S.A. to derive the approximate position of the User on a continuous basis.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts


This type of service allows CY.TALK SWITZERLAND S.A. to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (CY.TALK SWITZERLAND S.A.)


This service allows CY.TALK SWITZERLAND S.A. to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked:
About Me; Age range; Contact email; Current City; Email; Gender; Hometown.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Twitter account access (Twitter, Inc.)


This service allows CY.TALK SWITZERLAND S.A. to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Advertising


This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on CY.TALK SWITZERLAND S.A., possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside CY.TALK SWITZERLAND S.A. For more information, please check the privacy policies of the relevant services.
In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain advertising features by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Direct Email Marketing (DEM) (CY.TALK SWITZERLAND S.A.)


CY.TALK SWITZERLAND S.A. uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by CY.TALK SWITZERLAND S.A.
Personal Data collected: email address; first name; last name.

Google AdSense (Google Ireland Limited)


Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks use of CY.TALK SWITZERLAND S.A. and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Opt Out. Privacy Shield participant.

SMS contact


This service uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application.

Personal Data collected: mobile phone number; first name; last name.

Analytics


The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

AWStats (CY.TALK SWITZERLAND S.A.)


AWStats is an analytics software used by CY.TALK SWITZERLAND S.A. to analyze Data directly without the help of third parties.
The User can disable the collection of this statistical information by turning off JavaScript in their web browser. However, this action may negatively affect the User's navigation experience on CY.TALK SWITZERLAND S.A. as well as other applications.
Personal Data collected: Cookies; Usage Data.

Google Analytics (Google Ireland Limited)


Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of CY.TALK SWITZERLAND S.A., to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Opt Out. Privacy Shield participant.

Google Analytics with anonymized IP (Google Ireland Limited)


Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of CY.TALK SWITZERLAND S.A., to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Opt Out. Privacy Shield participant.

Beta Testing


This type of service makes it possible to manage User access to CY.TALK SWITZERLAND S.A., or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of CY.TALK SWITZERLAND S.A. in a personally identifiable form.

Beta by Crashlytics (Google Ireland Limited)


Beta by Crashlytics is a beta testing service provided by Google Ireland Limited.
Personal Data collected: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender.
Place of processing: Ireland – Privacy Policy.

Google Play Beta Testing (Google Ireland Limited)


Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.
Personal Data collected: Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Contacting the User


Contact form (CY.TALK SWITZERLAND S.A.)


By filling in the contact form with their Data, the User authorizes CY.TALK SWITZERLAND S.A. to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: address; city; company name; country; date of birth; email address; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code.

Mailing list or newsletter (CY.TALK SWITZERLAND S.A.)


By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning CY.TALK SWITZERLAND S.A. Your email address might also be added to this list as a result of signing up to CY.TALK SWITZERLAND S.A. or after making a purchase.
Personal Data collected: address; city; company name; Cookies; country; county; date of birth; email address; first name; gender; last name; phone number; profession; state; Usage Data; website; ZIP/Postal code.

Content commenting


Content commenting services allow Users to make and publish their comments on the contents of CY.TALK SWITZERLAND S.A.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Comment system managed directly (CY.TALK SWITZERLAND S.A.)


CY.TALK SWITZERLAND S.A. has its own internal content comment system.
Personal Data collected: Cookies; email address; first name; last name; phone number; Usage Data; username; website.

Facebook Comments (Facebook, Inc.)


Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Data transfer outside the EU


The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (CY.TALK SWITZERLAND S.A.)


If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data collected: various types of Data.

Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (CY.TALK SWITZERLAND S.A.)


If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data collected: various types of Data.

Other legal basis for Data transfer abroad (CY.TALK SWITZERLAND S.A.)


If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via CY.TALK SWITZERLAND S.A.
Personal Data collected: various types of Data.

Device permissions for Personal Data access


CY.TALK SWITZERLAND S.A. requests certain permissions from Users that allow it to access the User's device Data as described below.

Device permissions for Personal Data access (CY.TALK SWITZERLAND S.A.)


CY.TALK SWITZERLAND S.A. requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data collected: Approximate location permission (continuous); Approximate location permission (non-continuous); Call permission; Camera permission; Contacts permission; Phone permission; SMS permission; Social media accounts permission.

Displaying content from external platforms


This type of service allows you to view content hosted on external platforms directly from the pages of CY.TALK SWITZERLAND S.A. and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

YouTube video widget (Google Ireland Limited)


YouTube is a video content visualization service provided by Google Ireland Limited that allows CY.TALK SWITZERLAND S.A. to incorporate content of this kind on its pages.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Handling payments


Unless otherwise specified, CY.TALK SWITZERLAND S.A. processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers.
CY.TALK SWITZERLAND S.A. isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Google Pay (Google Ireland Limited)


Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Payment by bank transfer (CY.TALK SWITZERLAND S.A.)


In the event that the chosen payment method is a direct bank transfer to the current account indicated by CY.TALK SWITZERLAND S.A., the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data collected: address; company name; first name; last name; payment data.

Infrastructure monitoring


This type of service allows CY.TALK SWITZERLAND S.A. to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of CY.TALK SWITZERLAND S.A.

Firebase Performance Monitoring (Google Ireland Limited)


Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Interaction with external social networks and platforms


This type of service allows interaction with social networks or other external platforms directly from the pages of CY.TALK SWITZERLAND S.A.
The interaction and information obtained through CY.TALK SWITZERLAND S.A. are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on CY.TALK SWITZERLAND S.A. isn’t being connected back to the User’s profile.

Facebook Like button and social widgets (Facebook, Inc.)


The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

LinkedIn button and social widgets (LinkedIn Corporation)


The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data collected: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Twitter Tweet button and social widgets (Twitter, Inc.)


The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data collected: Cookies; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

VK Like button and social widgets (VKontakte Ltd)


The VK Like button and social widgets are services allowing interaction with the VK social network provided by VKontakte Ltd.
Personal Data collected: Cookies; Usage Data.
Place of processing: Russian Federation – Privacy Policy.

YouTube button and social widgets (Google Ireland Limited)


The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.
Personal Data collected: Usage Data.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Interaction with live chat platforms


This type of service allows Users to interact with third-party live chat platforms directly from the pages of CY.TALK SWITZERLAND S.A., for contacting and being contacted by CY.TALK SWITZERLAND S.A. support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Facebook Messenger Customer Chat (Facebook, Inc.)


The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Personal Data collected: Cookies; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Location-based interactions


Geolocation (CY.TALK SWITZERLAND S.A.)


CY.TALK SWITZERLAND S.A. may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by CY.TALK SWITZERLAND S.A.
Personal Data collected: geographic position.

Managing contacts and sending messages


This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Firebase Notifications (Google Ireland Limited)


Firebase Notifications is a message sending service provided by Google Ireland Limited. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Registration and authentication


By registering or authenticating, Users allow CY.TALK SWITZERLAND S.A. to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, CY.TALK SWITZERLAND S.A. will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Direct registration (CY.TALK SWITZERLAND S.A.)


The User registers by filling out the registration form and providing the Personal Data directly to CY.TALK SWITZERLAND S.A.
Personal Data collected: address; billing address; city; company name; country; date of birth; email address; field of activity; first name; gender; language; last name; number of employees; password; phone number; picture; state; Twitter handle; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.

Facebook Authentication (Facebook, Inc.)


Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google OAuth (Google Ireland Limited)


Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Linkedin OAuth (LinkedIn Corporation)


Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Log In with PayPal (PayPal Inc.)


Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.

Login with Amazon (Amazon)


Login with Amazon is a registration and authentication service provided by Amazon.com, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

VK Client Authorization (VKontakte Ltd)


VK Client Authorization is a registration and authentication service provided by VKontakte Ltd and is connected to the VK social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Russian Federation – Privacy Policy.

Remarketing and behavioral targeting


This type of service allows CY.TALK SWITZERLAND S.A. and its partners to inform, optimize and serve advertising based on past use of CY.TALK SWITZERLAND S.A. by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain remarketing features by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ad Manager Audience Extension (Google Ireland Limited)


Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of CY.TALK SWITZERLAND S.A. and allows selected advertising partners to display targeted ads across the web to them.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Opt Out. Privacy Shield participant.

Google Ads Remarketing (Google Ireland Limited)


Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of CY.TALK SWITZERLAND S.A. with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Opt Out. Privacy Shield participant.

RSS feed management


This type of service allows CY.TALK SWITZERLAND S.A. to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.

Feedburner (Google Ireland Limited)


Feedburner is a service to manage RSS feeds provided by Google Ireland Limited. It allows the collection of statistics on what content is consumed and to insert ads in it.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy.

Social features


Inviting and suggesting friends (CY.TALK SWITZERLAND S.A.)


CY.TALK SWITZERLAND S.A. may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data collected: various types of Data.

SPAM protection


This type of service analyzes the traffic of CY.TALK SWITZERLAND S.A., potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited)


Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google terms of use.
Personal Data collected: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Tag Management


This type of service helps the Owner to manage the tags or scripts needed on CY.TALK SWITZERLAND S.A. in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)


Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data collected: Usage Data.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Further information about Personal Data


Access the address book


CY.TALK SWITZERLAND S.A. may request access to your address book.

Analysis and predictions based on the User’s Data (“profiling”)


The Owner may use the Personal and Usage Data collected through CY.TALK SWITZERLAND S.A. to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Personal Data collected through sources other than the User


The Owner of CY.TALK SWITZERLAND S.A. may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Push notifications


CY.TALK SWITZERLAND S.A. may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for CY.TALK SWITZERLAND S.A., some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of CY.TALK SWITZERLAND S.A.

Push notifications based on the User's geographic location


CY.TALK SWITZERLAND S.A. may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of CY.TALK SWITZERLAND S.A.

Unique device identification


CY.TALK SWITZERLAND S.A. may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

CY.TALK SWITZERLAND S.A. uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing


Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of CY.TALK SWITZERLAND S.A. or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, CY.TALK SWITZERLAND S.A. may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, CY.TALK SWITZERLAND S.A. and any third-party services may collect files that record interaction with CY.TALK SWITZERLAND S.A. (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

CY.TALK SWITZERLAND S.A. does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within CY.TALK SWITZERLAND S.A. and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references


Personal Data (or Data)


Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data


Information collected automatically through CY.TALK SWITZERLAND S.A. (or third-party services employed in CY.TALK SWITZERLAND S.A.), which can include: the IP addresses or domain names of the computers utilized by the Users who use CY.TALK SWITZERLAND S.A., the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User


The individual using CY.TALK SWITZERLAND S.A. who, unless otherwise specified, coincides with the Data Subject.

Data Subject


The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)


The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)


The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of CY.TALK SWITZERLAND S.A. The Data Controller, unless otherwise specified, is the Owner of CY.TALK SWITZERLAND S.A.

CY.TALK SWITZERLAND S.A. (or this Site/Application)


The means by which the Personal Data of the User is collected and processed.

Service


The service provided by CY.TALK SWITZERLAND S.A. as described in the relative terms (if available) and on this site/application.

European Union (or EU)


Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies


Small sets of data stored in the User's device.

Legal information


This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to CY.TALK SWITZERLAND S.A., if not stated otherwise within this document.

Last updated on November 26th, 2019