Privacy Policy

We Care About Your Privacy

We and our partners store and/or access information on a device, such as unique IDs in cookies to process personal data. You may accept or manage your choices by clicking below, including your right to object where legitimate interest is used, or at any time in the privacy policy page. These choices will be signaled to our partners and will not affect browsing data.

We and our partners process data to provide:

Actively scan device characteristics for identification. Use precise geolocation data. Store and/or access information on a device. Personalised ads and content, ad and content measurement, audience insights and product development.

Privacy Notice Wardah Immobilier Sàrl (WI)

This privacy notice policy informs you as to how WI and partners (hereinafter jointly “we”, “us”, “our”, “WI and partners”), handle your personal data, to whom we may disclose your data, if applicable, and the rights you have vis-à-vis us in relation to the use of your data when you use our websites, platforms, portals or mobile applications (hereinafter collectively “offering”), as well as in cooperation with you.

We may provide you with additional privacy notices if we deem it appropriate. Such additional privacy notices supplement this privacy notice and must be read together with it.

We process your personal data in accordance with applicable data protection law (including the Swiss Data Protection Act, “FADP” and, where applicable, the EU General Data Protection Regulation, “GDPR”; hereinafter collectively “applicable data protection law”) at all times.

“Personal data” means any information relating to an identified or identifiable natural person or, where protected by the FADP, legal entity. This may include, for example, your first and last name, postal address, email address, date of birth, telephone number and data concerning the use of our website, purchases made via our portals and your preferences. This privacy notice also refers to this as “your data“. Information that cannot be directly or indirectly associated with you as a person, i.e. with your identity, does not generally constitute personal data.

“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of your data.

Please note that third-party websites accessible via our own offerings provide information about the data processing they perform in their own privacy notices. We do not accept any responsibility or liability for compliance with data protection requirements by these third parties and recommend that you consult the privacy notices of these third-party websites.

1. Who is responsible for the processing of your data?

WI and partners are responsible for the processing of your data that is collected or received in connection with our offerings or in cooperation with you or that is processed for any other purpose as defined in this privacy notice.

2. How do we collect your data?

We may collect your data directly from you or may obtain your data from third parties, such as our affiliated companies, public authorities, consultants, our service providers or from publicly available sources.

3. Scope, purpose and legal basis for the processing of your data

We process your data if you use our offerings, cooperate with us or otherwise contact us.

In general, we process your data for the following purposes:

fulfilling and performing contractual or statutory obligations;
verifying access authorisation and administering the user account (if any);
communicating with you and informing you of updates or changes to our offerings or events and in the event of amendments to our privacy notice and our specifications as to how you may advertise on our portals and websites;
combatting fraud;
developing and maintaining the customer relationship;
for marketing purposes on our part and that of third parties, i.e. all promotional measures, e.g. newsletters, telephone, online advertising, SMS and push notifications for market research, conducting analyses and surveys, as well as for statistical purposes;
designing and improving our offerings in order to meet our customers’ needs;
evaluating user behaviour;
initiation of contractual relationships with third parties;
training purposes.

Below, we have summarised in detail for you the data we process in connection with our offerings, the purpose for which we process the data and the legal basis on which we rely for this processing.

3.1 Visiting our offerings (log files)

Should you utilize our services without furnishing additional details, our web server technology automatically records general technical visit information in log files. This information encompasses, but isn’t restricted to, the IP address of the device used for the visit, specifics about the browser type, internet service provider, operating system, the services requested, referring/exit sites, and the timing and duration of the visit.

The purpose of collecting and processing this information is to facilitate the use of our websites (establishing connections), ensure and bolster the security and stability of our systems and websites, analyze the usage of our services, acquire general demographic information, optimize our services, and for internal statistical analysis. Notably, during this process, the user remains unidentified. Generally, no association is made between this automatically collected information and any personal data retained by us. However, a connection may be established between the automatically collected data and personal information stored if you have a registered user account on our portals or if, as a guest user, you utilize certain features like our contact form or request function.

This linkage enables the analysis of service usage, collection of demographic data, and optimization of our internet services. Specific instances, such as sending a message to a third party through our portal, may result in the storage of your message and its content by us.

Free services offered on our portal may involve the use of personal data provided (e.g., email address, telephone number) for marketing and analysis purposes as detailed in Chapter 3.9 below.

If your personal data is processed for the aforementioned purposes while using our services, this processing is carried out in our legitimate interest. This interest includes enabling website usage (establishing connections), ensuring system and service security and stability, analyzing and improving service utilization, as well as optimizing our internet services.

3.2 Registering a user account

To access personalized services or secure areas and to handle requests and manage subscriptions, registration and the creation of a user account may be necessary. This involves providing specific personal information, which could encompass:

Email address (which may double as your username)
Password
Additionally, depending on the context and service:
- First and last name
- Proof of identification, such as official identification document copies
- Complete postal address, postcode, city/town
- Telephone number
- Date of birth
- Gender
- Information regarding subscribed newsletters or other advertising
- Language preferences

In addition to the mandatory details required for a particular service, you have the option to voluntarily provide and store extra personal data. By confirming the accuracy of the information you provide during the registration process for your user account, you ensure the accuracy of the collected information.

The data collected is utilized for the management and operation of our digital services, validating the accuracy of the submitted data, which includes creating, adjusting, processing, and modifying the contracts established through your user account. In the case of fee-based services, this information is used for proper invoicing. Accordingly, the processing of your data aligns with the relevant data protection laws in this respect.

3.3 Using our offerings as a registered user

While registered users utilize our services, we gather data for statistical purposes to facilitate the smooth operation of the portal and to analyze and enhance our services. This involves collecting information on the use of our digital services, including specifics about the features and advertisements accessed and the methods employed. Our legitimate interest lies in optimizing, evolving, and enhancing our services in compliance with relevant data protection laws.

If you engage with our services as a registered user, certain statistical data may be visible to other registered users. However, this data is shared with other registered users in anonymized and/or aggregated formats to maintain privacy and confidentiality.

3.4 Using mobile applications

If you utilize our mobile applications on a mobile device and have allowed the transmission of your GPS signal data to a third party in your device settings, we may utilize this GPS signal data to gather your mobile device’s location information, including longitude, latitude, and horizontal accuracy data.

The purpose of using this location data is to enrich your user experience by presenting location-based online advertising and other digital content tailored to your location through the mobile application(s) on your device, such as location-based weather information and messages. We seek your consent in accordance with relevant data protection regulations before collecting your location data for the aforementioned applications.

Even after granting consent, you retain the right to withdraw, deactivate, or object to the collection, processing, and sharing of your location data at any time. If you prefer not to receive location-based online advertising and content, you have the option to deny access to your location or disable location services in your device’s settings whenever you wish. To deactivate location services, please refer to the guidelines provided by your device’s manufacturer: for Apple devices: https://support.apple.com/en-us/HT207092, for Android devices: https://support.google.com/accounts/answer/3467281?hl=e.

3.5 Purchasing/receiving a fee-based offering

If you make a purchase on our website or utilize a fee-based service, providing information such as your full name, complete postal address, including postal code and city/town, and other relevant details (like delivery address, billing information, etc.) is obligatory. This necessity is rooted in our obligation to execute our contract with you in compliance with relevant data protection laws.

Opting for an online payment method, such as credit card, TWINT, or PayPal, for the acquisition of a product or fee-based service entails the processing of the payment through the pertinent provider’s online payment system. In this scenario, your personal and payment information is handled directly by the payment system provider concerned. We neither access nor store your payment information. The privacy policy of the specific online payment system provider applies in these cases.

Information obtained during the purchase or reception of a fee-based service might be stored in your user account for future transactions or contracts as per our internal data protection policies or as mandated by law. We utilize this data for optimizing, enhancing, and progressing our services, for marketing endeavors, and for statistical purposes. This might encompass storing information about your past and present purchases and contracts, including details about products, services, quantities, and payment amounts.

3.6 Contacting customer service or using the contact form

When you reach out to our Customer Service, we may handle your contact information (including title, full name, phone number, email, or postal address) along with the conversation content to address your inquiry. This action aligns with our legitimate interest, as outlined in relevant data protection laws, to furnish precise information and appropriately manage your request.

Conversations, both incoming and outgoing, with our customer service may be recorded and retained for training and quality assurance purposes, subject to your consent.

Upon completing a contact form within our services, the personal information provided (such as title, full name, phone number, email, postal address, and the inquiry content) is processed. This action also falls within our legitimate interest of providing accurate information and effectively managing your request in accordance with applicable data protection laws.

3.7 Participation in events, sweepstakes or contests (hereinafter jointly referred to as “Events”)

To enable your voluntary participation in Events, we utilize the information you’ve provided, including your title, full name, email address, postal address, and data pertinent to the event. This information is employed for the organization and facilitation of events and for notifying or announcing winners either directly or via social media. Your data might be disclosed as per Chapter 5, for instance, if we enlist a third party to manage or assess the event, or if a third party conducts the event through our services. During Events, photos and videos may be captured on-site, and audio or video recordings will remain unaltered thereafter. These recordings (photos and videos) are exclusively used for our internal purposes, such as posting on our websites, flyers, event reviews on social media, newsletters, providing information to participants via email, and similar activities.

3.8 User surveys, Interviews and market research

If you willingly engage in a user survey, an interview, or other market research initiatives organized by us, we gather personal data including your title, full name, contact information, and any other details requested throughout the survey. The information you provide is employed exclusively to enhance user experience and to advance the development of our products, which aligns with our legitimate interest in compliance with relevant data protection laws. The outcomes of these surveys solely comprise aggregated and anonymized data.

3.9 Marketing and analysis purposes

When you register or place an order as a guest through our platforms, we may utilize your data for personalized advertising by ourselves, our affiliates, third parties, and shareholders. These tailored advertising strategies may encompass personalizing digital ads on our websites, mobile applications, via email (such as newsletters), telephone, postal mail, fax, text messages, picture messages, and instant messaging services.

Newsletter distribution will only occur if they pertain to similar offerings or if you’ve expressly consented to receive them. Otherwise, delivering personalized content and advertising, like on our platforms or those of our affiliates, aligns with our legitimate interest under applicable data protection laws. This interest involves offering products or services that might interest you and optimizing our marketing efforts. When prior consent is necessary, particularly for data processing by our affiliates or shareholders, we will acquire this consent beforehand.

To achieve this goal, user-specific historical and future data at our disposal can be continuously linked using diverse analysis tools, allowing for analysis of user behavior, aggregation, pseudonymization, and anonymization across our platforms. We may also enhance our database by using publicly available or third-party-provided data. Findings based on your interaction with our platforms might be utilized in analyzing user behavior at other participating companies, generally using pseudonymized or anonymized data. You have the right to object to this data processing at any time by adjusting the default cookie settings.

We conduct automated assessments of user behavior across multiple platforms to build user profiles for more targeted approaches. With consent, these profiles may be shared among platforms within our network and partners for advertising management, marketing, and analysis purposes.

Additionally, we process your data for analysis to continually enhance our offerings, align them with your needs, and ensure their security. This aligns with our legitimate interest in tailoring our services to customer needs, market improvement, and security, in accordance with data protection laws.

Upon registering a user account, you might automatically subscribe to one of our newsletters. Consequently, your email address may be used to advertise our similar offerings until you opt out from the specific newsletter.

For the stated purposes, we may engage data processors for technical processing of advertising measures, exclusively for the outlined purposes as detailed in chapter 5 below.

3.10 Combatting fraud, legal disputes and legal processing obligations

We reserve the right to process the data collected and managed in accordance with Sections 3.1 to 3.9 to counteract fraud or in case of a legal dispute. This action is in our legitimate interest, aligning with applicable data protection laws, as it pertains to safeguarding our business and asserting any claims we might have. Additionally, we may process your data to fulfill our legal obligations as per the relevant data protection laws.

4. Profiling

We reserve the right to conduct automated assessments (referred to as “profiling”) based on your data, as described in Chapter 3. This is intended to discern preference data and identify instances of misuse or security risks, perform statistical analyses, or aid in operational planning. Profiles may be created for these purposes, involving the amalgamation of behavioral, preference, master, contract, and technical data related to you, aiming to gain a comprehensive understanding of your diverse interests and characteristics.

In these scenarios, we prioritize the appropriateness and accuracy of the outcomes and take steps to prevent misuse of these profiles or profiling. If such assessments might have legal consequences for you or significantly influence you, we generally ensure human review is conducted.

5. Disclosure of your data to third parties

We collaborate with other companies or individuals and may enlist their services to process and store data in compliance with this privacy policy. These third parties may have access to your personal or usage data only as necessary to accomplish the assigned tasks or fulfill the purposes outlined in this privacy policy. However, such access might also occur if mandated by legal obligations.

5.1 Disclosure to WI and partners

Subject to compatibility with the purposes delineated in Chapter 3 above, your data and usage information associated with you or your user account may be utilized and shared with WI and partners. This serves the intent of assessing and enhancing our services to better meet customer needs, for customer service, personalization, and marketing purposes.

If your consent is necessary for this process, we will seek it beforehand, and you retain the right to withdraw this consent at any time. In instances where consent isn’t mandatory, data sharing is founded on our legitimate interest, or the legitimate interest of WI and its partners, affiliated companies, or joint ventures. This interest pertains to enabling website usage, ensuring system security and stability, analyzing and improving service utilization, displaying or sending advertisements, and optimizing our online services in line with relevant data protection laws.

Moreover, we employ automated assessments of user behavior across various platforms to develop user profiles for more targeted approaches. With your consent, we share these profiles with platforms associated with WI and partners to create an overarching profile for advertising management, marketing, and analysis purposes.

5.2 Disclosure to Shareholders of WI and partners

We might share your data with the shareholders of WI and partners according to the guidelines outlined in this Chapter 5. Shareholders may share this data with their subsidiaries, ensuring that they process your data solely for the same purposes as those permissible for the shareholders themselves.

This disclosure aims to evaluate, enhance, and customize the products and services of the shareholders to align with their needs, for personalization, marketing purposes, and to counteract fraud and misuse. Data will only be shared as specified here if allowed by law or upon obtaining your prior consent, which can be retracted at any time.

5.3 Disclosure to service providers

Moreover, we might divulge your information to third parties if it is essential for contract fulfillment in compliance with relevant data protection regulations. For this reason, essential data may be disclosed to shipping companies, financial institutions, and other service providers, including hardware and software suppliers. These entities will solely utilize your data to execute the contract and not for any other intentions. In cases where it is necessary for the purposes specified in the first sentence of this paragraph, your data may even be shared with providers located overseas, for instance, to facilitate product delivery. For further details on international data transfers, please refer to Chapter 7.

5.4 Disclosure to other third parties

If you interact with integrated third-party features or utilize integrated third-party contact forms, we may share your data in accordance with the specific offering or contact form. Additionally, your data may be disclosed to third parties if they intend to present personalized advertising or services within our offerings or if we jointly present an offer with a third party.

To combat fraudulent activities or suspected criminal behavior, we may share your data with domestic and foreign law enforcement agencies and courts. In cases where necessary, we might transfer debts to other companies, such as debt collection agencies.

Apart from the abovementioned disclosures, we will only share your data if you have given explicit consent in compliance with relevant data protection laws, if there is a legal obligation to do so, or if it is vital to uphold our rights, especially for enforcing claims arising from contractual relations or to counteract fraud, both of which are our predominant interests.

In the event of a sale, merger, or reorganization involving our company assets, personal data might be transferred, sold, or shared with third parties as part of such transactions.

If an advance delivery is provided, such as in the case of purchasing on account, we may conduct a credit assessment using mathematical and statistical procedures from a credit agency. This is to safeguard our legitimate interests in engaging with financially solvent customers. The necessary personal data for a credit check will be transmitted to a credit agency, and the received information on the probability of non-payment will help decide on establishing, executing, or terminating the contractual relationship. The credit check may involve probability values (scores) calculated through recognized mathematical processes that factor in contact details. Your lawful interests will be considered as prescribed by law.

Apart from WI and partners and our shareholders, no other disclosure, transfer, or sale of your personal data to third parties will occur unless it is essential for the execution of a contract you have with us or you have expressly consented to it.

6. Use of cookies, tracking and analysis tools, as well as plug-ins and other integrated third-party offerings

6.1 Cookies

Cookies enhance the ease, quality, and significance of your visit to our websites while ensuring the functionality of our offerings and portals. They also enable interest-based advertising. These files are data that your web browser automatically stores on your computer’s hard drive upon visiting our site. Although our digital offerings are generally accessible without accepting cookies, doing so may limit certain features.

Cookies set by us during your website use may gather and retain usage data, like device IP addresses, visited pages, browser type, date, time, etc. Generally, this data cannot identify you unless logged into your user account.

When the browser closes, cookies are saved in a text file on the computer and accessed the next time the web server is queried. They neither damage your computer’s hard drive nor transmit personal user data to us.

We utilize cookies to recognize your return visits to our websites, offerings, or portals, primarily identifying the computer, mobile device, or browser used. Additionally, cookies aid in understanding site visits, determining page popularity, and assessing portal usage. Some cookies facilitate site navigation, enabling access to restricted areas, efficient navigation between pages, storing preferences, using shopping baskets, or enabling payment features. They also preserve user-selected settings to enhance user-friendliness. Overall, cookies contribute to improved, more efficient, and secure services. However, they also gather data for interest-targeted advertising and better alignment of online ads with your interests to minimize irrelevant advertisements.

Most web browsers accept cookies automatically, but configurations can be adjusted to prevent their storage or to receive notifications about new cookies. It’s also possible to delete cookies through your browser settings.

You have the choice to opt in or out of tailored ads reflecting your potential interests. Opting out doesn’t eliminate all online ads but may result in less personalized ad content on our sites.

Most of the cookies we use are temporary session cookies, automatically deleted at the end of your browsing session. However, some are permanent cookies, remaining on your device for periods ranging from one month to ten years, automatically deactivated after their designated timeframe.

For further information about the cookies and tracking tools used, please refer to the cookie settings.

6.2 Tracking and analysis tools

The usage of our digital services is assessed and analyzed through various technical systems, predominantly operated by third parties like Google Analytics. These assessments can be conducted anonymously or with reference to specific individuals. As part of this process, the data collected by us or by third-party providers of these technical systems might be shared with external parties for processing.

For instance, we might use Google Analytics, a service provided by Google Inc. This service generally involves transferring the collected data to one of Google’s servers in the USA. However, the IP addresses are anonymized through IP anonymization to prevent association with specific owners. The IP address sent from your browser in connection with Google Analytics is not merged with other data held by Google. To prevent further data collection when visiting our website in the future, you can object to the collection and processing of this data by setting an opt-out cookie: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

For more details about the cookies and tracking tools we use, please refer to the cookies settings.

6.3 Plug-ins and other integrated third-party offerings

Our digital services can be interconnected with various third-party functions and systems, such as integrating third-party plug-ins.

If you hold a user account with third parties, they might, in certain instances, assess and analyze your usage of our digital services. As part of this process, additional personal data, including your IP address, specific browser settings, and other parameters, may be transmitted to and retained by these third parties. When employing a social login service, the provider may transmit personal data it holds concerning you, like your name, email address, and profile picture. Nonetheless, we do not have control over the use of such personal data gathered by third parties, nor do we hold responsibility or liability for such usage. For further details, please refer to the linked additional comprehensive information. Information about the collection and utilization of data by third-party providers can be found in the data protection policies of the respective third-party providers.

7. Transfer of personal data abroad

We might also transmit your personal information to third-party firms or contracted service providers situated overseas, specifically in Europe, Asia, and the USA, as deemed necessary for the data processing described in this privacy policy. Nonetheless, these third parties must adhere to data protection regulations to the same degree as we do.

8. How long will we store your data?

We will retain your data for the duration required by law or in alignment with the purpose of processing, especially for order fulfillment, contract compliance, and adherence to our legal obligations.

When conducting data analysis, we’ll store your information until the analysis concludes or until you object to further processing. If data is stored due to a contractual relationship, it will be maintained for at least the duration of that relationship and, at most, for the duration of any potential claims or statutory and contractual retention obligations. Generally, we retain personal data for as long as there’s a legitimate interest, notably to support claims, for archiving, and for ensuring IT security.

As per legal requirements, contents of contact forms and subsequent email correspondence are held for at least six months.

Subsequently, we aim to anonymize the data for continued statistical use. If anonymization is not feasible, the data will be deleted when no longer necessary for the specified processing purposes and when legal retention is no longer mandatory.

9. How do we protect your data?

We implement suitable technical and organizational measures to diligently safeguard your data against loss, destruction, tampering, manipulation, or unauthorized access. Our secure data networks comply with the prevailing technical standards, and we continually adapt and enhance our security protocols in response to technological advancements.

When you register as a user on our website, accessing your user account necessitates entry of your personal password. It’s important to maintain confidentiality regarding payment and access information, and it’s recommended to close your browser window after concluding a session, especially when sharing your computer with others.

Our staff and contracted service providers are committed to upholding confidentiality and complying with data protection regulations.

10. What rights do you have in relation to your data?

Under applicable data protection law, you have the following rights:

Right to restrict or block the processing of your data:
You have the right to restrict or block the processing of your data at any time, provided that we are not under any other obligation to retain and process your data for a certain period of time.

Right to erasure of your data:
If the processing of your data is no longer necessary, e.g., because your contractual relationship with us has ended or because you no longer consent to the processing of your data, you may request the erasure of your personal data. We will erase your personal data, provided we have no other relevant obligation (e.g. a statutory retention obligation) or overriding interest (e.g. in connection with legal proceedings or fraud prevention) in continuing to retain or process your personal data for a certain period of time.

Please note that the erasure of your personal data may mean that you can no longer obtain or use the services registered by you.

Right to information:
You have the right to find out at any time whether and which of your personal data is being processed by us.

Right to disclose your data:
Under certain circumstances, you are entitled to have us disclose your personal information to you or a third party designated by you in a commonly used format or to provide your data to you in a commonly used format.

Right to rectification of your data:
You have the right at any time to have your personal data rectified if you notice that we are processing erroneous data about you.

Right to object:
You may object to the processing of your data for marketing and analysis purposes and to the disclosure of your data within WI and partners in accordance with Chapter 3.9 at any time by sending an email to wardah.immobiler@hotmail.com .

Such an objection does not entirely preclude the collection of personal data, but only for marketing and analysis purposes and for the disclosure of your data within the WI and partners in accordance with Chapter 3.9.

You may also object to any data processing that is based on a legitimate interest of ours by sending an email to wardah.immobiler@hotmail.com, indicating the reasons relating to your particular situation.

Withdrawing your consent:
You always have the right to withdraw at any time any consent previously given. Once we have received notice that you are withdrawing your consent, we will no longer process your personal data for those particular purposes unless there is another legitimate interest in continuing to process it. Please note that the withdrawal of your consent has no effect on data processing that took place prior to the withdrawal.

Complaint to a supervisory authority:
In addition, you have the right to lodge a complaint regarding data processing with the appropriate supervisory authority. In Switzerland, this authority is known as the Federal Data Protection and Information Commissioner. You can lodge a complaint with the supervisory authority at your place of residence, place of work or at the location of the alleged data breach.

You may exercise your rights at any time by giving written notice and proof of your identity to the address below.

To do this, please use the e-mail account that you used to register with us. This allows us to verify your identity. In addition, we reserve the right to verify your identity by means of a copy of your passport, a copy of the front and back of your ID card or a copy of your Swiss driving licence or by any other means. We may correspond with you in response to your initial contact about exercising your rights.

Please note that, in some cases, the granting of your rights may be refused or restricted for legal reasons or based on data protection law. Where legally required or permitted, we will inform you of the reasons for our decision.

11. How can you contact us?

If you have inquiries concerning the handling of your data, wish to request details or the deletion of your data, kindly contact our Data Protection Contact via email at:

wardah.immobiler@hotmail.com.

12. Changes to this Privacy Notice

The prevailing privacy policy posted on our website remains effective.

We regularly update this privacy policy to align with the latest standards for handling and safeguarding personal data. We encourage you to review this privacy policy regularly to stay informed about the management of your personal data and to understand how you can exercise your rights.

Last updated: 27 October 2023

13. Languages

This Privacy Notice has been drawn up in English. In case translations are applied and discrepancies arise, the English language shall prevail.

Privacy Notice Wardah Immobilier Sàrl (WI)​