Privacy policy

The purpose of this Privacy Policy is to inform you about the processing of your personal data in connection with our online presence and the provision of our services. These include your use of our online presence, such as websites, mobile applications and other digital platforms, your visits to our workshops and shops and your attendance at events, your interactions with our customer service and your communication with us via social media platforms. We will also inform you about the use of cookies and similar technologies, about your rights as a data subject under data protection legislation and about the available means of contact. In other situations, when you contact our company or in connection with data processing, different or additional data protection provisions may apply. We therefore invite you to familiarise yourself with the applicable data protection provisions available from the relevant point of contact.

1. DATA CONTROLLER AND CONTACT DETAILS

LabOr Pesciallo SAGL parent company of the Vanni Pesciallo/Vanni Pesciallo Gioielli brand, attaches great importance to the responsible handling of customer data. The controller responsible for processing your personal data, depending on the contracting party and/or the customer’s location, is the company LabOr Pesciallo SAGL owner of the website www.vannipesciallo.ch :

 

LabOr Pesciallo SAGL, Via Motta 5, 6828 Balerna, Switzerland (Ticino)

hereinafter jointly referred to as “Vanni Pesciallo” or “Vanni Pesciallo Gioielli”. If you have any questions about our processing of your personal data and your related rights, or any comments and suggestions, you can contact the data protection contact person or the data protection officer, if one has been appointed. The latter can be contacted by e-mail at info@labor.ch or info@vannipesciallo.ch or by post at the addresses given above, marked “Data Privacy”.

2. SCOPE, PURPOSE AND LEGAL BASIS OF THE PROCESSING OF YOUR DATA

When you choose and use our services and the functions made available in connection with them, personal data are processed. Personal data consist of all individual data that relate to you or that can be attributed to you. Such data may include your name, address, e-mail address, telephone number or the number of, or other information on, your identity document. Non-personal data refer in particular to information that does not make it possible to identify a person. We process personal data in accordance with the relevant data protection laws, such as the Swiss Federal Act on Data Protection (FADP). Processing means any operation involving personal data, in particular the collection, storage, gathering, consolidation, anonymisation, use, transmission or erasure. Your personal data are processed only where this is permitted by the applicable statutory provisions. To this end, we process your data only with reference to, among others, the following legal bases: For the performance of a contract or for taking steps prior to entering into a contract: in particular, we need certain types of data to initiate or implement your contractual relationship with LabOr Pesciallo SAGL. For the protection of legitimate interests: LabOr Pesciallo SAGL will process certain data to protect its own interests or those of third parties, provided that your interests as a data subject do not override them. On the basis of consent: we will process certain types of data only on the basis of the consent you have previously given, which you may withdraw at any time with effect for the future. For compliance with a legal obligation: we may also process your personal data in order to comply with legal obligations, such as anti-money laundering provisions or obligations under commercial and tax law. In connection with the provision of certain services, it may be necessary to provide certain types of data. We will inform you of such data in detail by appropriate means (for example by highlighting *mandatory fields). Without such data, we will generally be unable to offer you our services. In addition, you may provide optional data that are not strictly necessary for the acceptance and performance of an order. The storage of voluntary information is based on our legitimate interests. In particular, personal data collected during the use of our services will be processed for the following purposes and with reference to the following legal bases:

3. PERFORMANCE OF ORDERS AND CONTRACTS

We collect your personal data for the preparation, performance and management of our services and contracts; sales or service enquiries, orders, sale, purchase and part-exchange, purchase and redemption of coupons, production, repair and servicing, exchanges, inclusion on product lists and waiting lists, organisation of competitions, events and activities, arranging appointments, etc. Any customer interaction in this connection, and processing such data for the purpose of providing customer support and handling services and contracts in the central customer relationship management database. This includes in particular the processing of your data for the purposes of invoicing and payment handling, customer support, delivery of goods, returns and the handling of any warranty/guarantee claims and mutual legal claims. The information collected about you usually consists of your master data (in particular title, first name and surname, address, telephone number, e-mail address), the information required to provide the service (for example the selected items, product information, order details, information on the purchase contract, service data) and payment data (in particular billing address, payment method, payment details and bank details for purchases). We collect the data directly from you when an order is placed or when a contract is concluded and managed at one of our branches, in the case of certain enquiries on our online platforms (for example via contact forms or live chat) or by e-mail, telephone, messaging apps or post. To the extent that this is necessary for the provision of our services, we will transmit certain types of master data and order/contract data to third parties. In connection with the performance and management of certain orders/contracts (for example, in the case of personalised engravings of watches or uploading information and documents to your customer account), you may need to provide personal data originating from third parties. In such cases, you are responsible for the lawful transmission of such data to the respective company LabOr Pesciallo SAGL. Such data will be used exclusively for the performance of the service ordered. The legal basis for the types of data processing described above is the preparation and performance of a contract or the protection of the legitimate interests of LabOr Pesciallo SAGL.

 

 

4. PAYMENT, SHIPPING AND INSURANCE

For payment handling and the shipping of orders, we work with the service providers engaged by the contracting party responsible for your order, which you can find at the bottom of the web page under “Payment” or “Shipping” on the website of the country in which you place your order. In these cases, your payment data and master data are transferred to the relevant third-party provider for payment handling and the shipping of the order. For certain types of delivery methods, we may, for example, transmit the e-mail address and/or telephone number you provided during the ordering process to the shipping agent in order to enable the order to be tracked or to coordinate the delivery date. We do not store any payment-related data. In particular, via our online platforms, we can arrange insurance for you, to be taken out directly with the respective service provider. In these cases, we transmit to the respective service provider the information required to conclude the insurance you have chosen. In these cases, please take note of the applicable data protection or security provisions of such third-party providers. In general, the legal basis for data processing in these cases is the implementation of a contract concluded with you or our legitimate interests. We have a legitimate interest in enabling communication between you and the service provider, so that we can ensure the proper handling of the corresponding contract. You may object to the processing of your data on the basis of our legitimate interests. Please send us a message/e-mail using the contact details.

5. CONTACT AND CUSTOMER SERVICE

We collect and process data when we contact customers, provide customer support and for other forms of interaction. The information collected consists of master and contact data (title, name, address, date of birth, e-mail address, telephone number), other information provided voluntarily (e.g. interests and preferences regarding the product range; preferred watch brands, models and materials; allergies to precious metals; hospitality preferences; hobbies; information on family events such as wedding dates and concerning your family circle; nationality; attendance at events; social media profiles) and responses to contact and sales activities and other commercial data of LabOr Pesciallo SAGL (reservations, orders, sales, exchanges, repairs, goods, prices, points of sale, dates, etc. ), which are transmitted to us and recorded at the point of sale or by e-mail, by telephone or otherwise by electronic means (e.g. via Messenger or social media channels, etc). This information is used to contact you for the reasons described above, to provide you with the best possible advice when you shop in the shops or on our online platforms owned by LabOr Pesciallo SAGL, for evaluations for internal analysis purposes or for personalised marketing, and to carry out targeted advertising – by e-mail or by post, telephone or Messenger – on this basis within the scope of the statutory provisions.

6. VISITS TO OUR PLATFORMS

When you visit our online platforms, information relating to your visit is stored, such as the IP address of the end device sending the request; the name of the website / file requested; the web page from which you are visiting the online platform (referrer URL); the date and time of the request to the server; the type and version of the browser; the operating system used by the requesting end device and the search term used, for example in Google, to find the website. We process such data on the basis of our legitimate interest in providing the online platforms and ensuring the proper functioning and security of our IT systems. Our legitimate interest in this respect is to enable the use of our online platforms and to ensure their proper functioning from a technical point of view and the ability to access them on a continuous basis. When you visit our online platforms, such data are processed automatically. We do not use such data to draw conclusions about your identity. We are unable to comply with requests to refrain from collecting and storing server log data, as such data are essential for the proper functioning of our online platforms. In addition, we may analyse and process data relating to your use of our platforms through the use of cookies and other tracking technologies and, to the extent that this is technically feasible, assign such data to an existing user profile.

7. CUSTOMER ACCOUNT AND LOGIN

When you use our online platforms, you can create a personal password-protected customer account or, where this option exists, log in via a social media site (for example Google, Twitter or Facebook). At the time of registration, the data collected from the registration form or provided by the social login provider and, where applicable, updated and collected during subsequent interactions, are used to create a user profile or are assigned to an existing user profile and are stored and managed in the central CRM database operated by LabOr Pesciallo SAGL. In your customer account you can manage your contact details, view your transactions and contact us to change the marketing settings of your account. The range of functions of your customer account may vary depending on the online platform. In general, you can use the same password to log in to your customer account (for example, web page and app). The information collected when a customer account is created generally consists of master and contact data (in particular title, first name and surname, address, telephone number, e-mail address, password) and any other information and data provided voluntarily or uploaded (e.g. on your interests and preferences regarding the products offered, preferred brands/models, hospitality preferences, date of birth and wedding date, watches and sales data and other commercial data at LabOr Pesciallo SAGL (reservations, orders, purchases, exchanges, repairs, goods, prices, points of sale, dates, etc.), which are transmitted to us and recorded at the point of sale or by e-mail, by telephone or otherwise by electronic means. In the case of a social login, certain information such as your name, e-mail address and other public information is retrieved from your social media profile in order to offer a simplified login process and a personalised user experience. We use this information only to authenticate and manage your account. Please note that we have no access to your password and no control over your social media account. We recommend that you regularly consult the data protection provisions and privacy settings of your social media provider, so that you are fully aware of how the provider in question uses your data. If you are logged in to your account when you visit our online platforms, information on your behaviour (e.g. information on your shopping basket and wish lists) may be processed and assigned to your user profile. When you register and subsequently log in and when you use our online platforms, we reserve the right to store the IP address and the time of access to the website. Such storage takes place on the basis of our legitimate interest in protecting against misuse and other unauthorised use of our online platforms. Such data will be transmitted to third parties only if this is necessary to enable us to pursue our claims or where there is a legal obligation to do so. Registering a user account is voluntary, unless the reason for registering the account is to enable us to offer you certain services such as bespoke quotations and purchases directly in the shop. If the legal basis for data processing in connection with a customer account does not lie in pre-contractual measures and the implementation of a contract or in the protection of the legitimate interests of LabOr Pesciallo SAGL or third parties, such processing takes place on the basis of your explicit consent. Your consent will be deemed valid until it is withdrawn. You may withdraw your consent at any time with effect for the future by contacting us by e-mail.

8. LOCATION DATA

Some of the services we offer (in particular when our online platforms are used) may access and process location data. This happens, for example, if you use the location function to find a point of sale near you. Location data may be collected via your IP address, your browser, GPS, sensors, signals or Wi-Fi access points and are used to provide you with a personalised and optimised service. Data processing generally takes place with your consent. You may withdraw your consent to the processing of location data at any time by changing the settings of your device and/or withdrawing your consent in the corresponding cookie settings. Please note that if you withdraw your consent, some functions of our services may no longer be available in their entirety.

9. DATA FROM THIRD-PARTY SOURCES

We may use data about you taken from public sources (for example, social media profiles) to improve our services (for example, to provide more targeted recommendations). Data obtained from third-party sources may contain information about your preferences, interests and demographic characteristics. The processing of such data is based on our legitimate interest. In general, you have the right to object to the processing of your data originating from third-party sources. Please take note of the right to object to processing based on our legitimate interests set out in section 8 below. On the basis of your consent, we may also use data in the context of so-called customer matching. In this case, we transfer data (such as e-mail address, telephone number or other identifying characteristics) in encrypted form to social media platforms (such as Facebook) or advertising platforms (e.g. Google), which compare such data with the corresponding data available to them. If the compared data match, this means that you are also active on this third-party platform. On the basis of the compared customer data, a target group is created, which enables us to deliver targeted advertising to this target group and to increase the relevance and effectiveness of the advertising. Depending on the third-party platform, different advertising formats may be used, such as social media ads or search engine advertising. You may withdraw your consent to Customer Match at any time by revoking your consent in the preference centre.

10. USER PROFILES

The nature and scope of the interactions with us described in the previous section enable us to create a user profile, which we maintain in our CRM database. User profiles help us to understand the behaviour and interests of our customers. This allows us to continually improve our services and, if you so wish, to deliver targeted advertising based on your interests and usage patterns. We may combine user profiles with other types of customer data that we lawfully process (for example, name, contact details, user and purchasing behaviour, including purchase history, demographic data, interests and preferences regarding the product range, such as preferred brands, models and materials, hospitality preferences) or assign them to an existing user profile. If the legal basis for data processing in connection with the creation of a user profile does not lie in pre-contractual measures and the implementation of a contract or in the protection of the legitimate interests of LabOr Pesciallo SAGL or third parties, such processing takes place on the basis of your consent. Your consent is presumed until it is withdrawn. You may withdraw your consent at any time with effect for the future.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other tracking technologies on our online platforms. Please take note of the cookie guidelines, a link to which is also available on the corresponding online platform.

12. USE AND BEHAVIOUR

When you use our online platforms, we collect, analyse and use data relating to that use and to your behaviour in general. This is the case, for example, with purchases made in our online shop or the use of our website and our apps (for example, baskets created and abandoned, wish lists, items viewed, search terms and results, ratings and comments). For this purpose we use various technologies, the most important of which are described below.

13. GOOGLE

If you have given your consent or if we are entitled to rely on a legitimate interest in the use of specific functions, we will use Google Analytics and/or Google Firebase, a web analytics service offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses so-called “cookies”. The information generated by a cookie about the use of our online platforms is usually transferred to a server operated by Google in the United States and stored there. The legal basis for this transfer is your consent. We expressly reserve the right to rely on other legal bases. Data transfers to the United States are governed by the EU standard contractual clauses concluded with the parent company Google LLC. We commission Google to use this information on our behalf in order to evaluate the use of our online platforms, compile reports on online activities and provide other services associated with the use of the platform. Anonymised profiles may be created from the processed data. We use Google Analytics only with IP anonymisation activated. This means that your IP address is shortened by Google within Member States of the European Union (EU) or in other contracting states of the European Economic Area (EEA). Only in exceptional cases is the full IP address transmitted to a Google server in the United States and shortened there. The data are erased as soon as they are no longer required for our retention purposes. You may withdraw your consent to the use of Google Analytics at any time by changing your cookie settings. You can also prevent the storage and use of cookies by setting your browser accordingly and/or by using browser add-ons (see also our cookie guidelines). You can also prevent the collection of data generated by cookies and relating to your use of our online platforms (including your IP address) and the further processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can obtain further information on the processing of data by Google, on how to adjust the settings and on how to object to such processing by visiting Google’s web pages using the following links: https://www.google.com/intl/en/policies/privacy/partners (“How Google uses information from sites or apps that use our services”); https://www.google.com/policies/technologies/ads (“Use of data for advertising”); https://adssettings.google.de/anonymous?hl=en (“Managing the information Google uses to show you ads”). We also use Firebase, an analytics and monitoring tool from Google for mobile and web applications. When Google Firebase is used, certain information about your use of our online platforms may be collected and processed (for example device information, IP addresses, app usage data). Google Firebase services may insert “instance IDs”. Instance IDs are unique identifiers that carry a timestamp and make it possible to link various events or processes relating to the app. These data are used to analyse and optimise user behaviour, for example to evaluate crash reports. According to Google, these instance IDs do not process any personally identifiable data. For Firebase Analytics, Google also uses the advertising ID of the end device. You can object to the collection of data by Google Firebase at any time with effect for the future by deactivating Firebase Analytics data collection in the app settings or by limiting the use of the advertising ID in the settings of your mobile device. For Android: Settings > Google > Ads > Reset advertising ID For iOS: Settings > Privacy > Advertising > Limit Ad Tracking You can consult the Google Firebase privacy policy here: https://firebase.google.com/support/privacy?hl=en

 

14. MOUSEFLOW

If you have given your consent to the use of certain cookies, we will use Mouseflow on our website, a web analytics tool provided by Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark. Mouseflow uses cookies that allow us to track the activity of certain selected visitors to the web pages. For this purpose, the following data are usually processed: mouse clicks, clicks, scrolling movements, browser information, type of end device, operating system, language, screen resolution, IP address (anonymised). This tracking is carried out on anonymous or pseudonymised data, which means that at no time are we able to uniquely identify the visitor to the web page. Web analysis by Mouseflow takes place on the basis of your consent, in order to enable our website to be optimised according to requirements. You may withdraw your consent to Mouseflow web analysis at any time by changing the corresponding cookie settings. You can also prevent the storage and use of cookies by changing your browser settings or by preventing the installation of browser add-ons (see also our cookie guidelines). You can also opt out of Mouseflow web analysis by clicking here: https://mouseflow.com/opt-out/. We cannot rule out that the use of Mouseflow may result in data being transferred to Mouseflow’s parent company (Mouseflow Inc.) in the United States. Such data transfers are governed by the EU standard contractual clauses. You can obtain further information on Mouseflow and on Mouseflow’s privacy provisions at https://mouseflow.com/legal/visitor/ and https://mouseflow.com/legal/gdpr/.

15. RETARGETING/REMARKETING

On our online platforms we use so-called retargeting/remarketing services from third-party providers. This involves the collection of data, subject to your consent, with the aid of cookie/tracking technologies for the purpose of optimising our advertising and our online presence. We do not use these data to identify you personally, but to evaluate the use of our online platforms and to provide interest-based advertising on our platforms or on third-party platforms (for example, social media platforms) to users who have already shown an interest in our content and offers. The advertisements displayed on our online platforms or on websites operated by our partners are based on an analysis of previous usage behaviour. The data used to create usage profiles in accordance with the instructions of the retargeting/remarketing service provider we have engaged are generally anonymised/pseudonymised. In the following sections you will find more information on the main third-party providers we work with, on how your data are processed and on how to deactivate retargeting/remarketing technologies.

16. GOOGLE MARKETING PLATFORM / GOOGLE ADS

On our platforms we use the Remarketing or “Similar Audiences” function of Google Ads/Google Marketing Platform (formerly DoubleClick by Google) provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookie/tracking technologies that are stored on your end device to analyse the use of the online platforms and to show you advertisements for products or services that may be of interest to you. According to Google, the cookies used for this purpose do not contain any personal information. The information obtained through the use of cookies/tracking technologies about your use of the online platforms is transmitted to a server operated by Google in the United States and stored there. If you are registered with a Google service and are logged in, Google may be able to associate your visit to our online platforms with your account. Even if you are not registered with Google, Google may identify your IP address and create and store user profiles about you. We will use Google’s function for matching customer lists only with your prior consent (see also section 2.7). To find out more about the analysis of your search/browsing behaviour, click here: https://policies.google.com/privacy?hl=en-GB and https://policies.google.com/technologies/ads?hl=en-GB and https://marketingplatform.google.com/intl/en_uk/about/enterprise/ . You can deactivate personalised ads on Google via the following link: http://www.google.com/settings/ads/plugin.

17. FACEBOOK PIXEL

We also use services provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “Facebook”) such as the Facebook Pixel for retargeting/remarketing purposes. When you visit certain of our online platforms and have given us your consent, a direct connection is established via the Facebook Pixel between your browser and the Facebook server. Facebook is also informed that you have visited our online platforms, thereby enabling us to organise our activities on Facebook more effectively and, for example, to show items or advertisements intended exclusively for visitors to our online platforms or for predefined customer groups (“custom audience”). The Facebook Pixel tool also enables us to analyse the use of our online platforms and to show advertisements for content and offers that may be of interest to you. The data collected are sent to Facebook only in encrypted form and are anonymous from our point of view, i.e. we cannot view the personal data of individual users. We will use the “advanced matching” customer audience function to match customer lists only with your prior consent (see section 2.7). We are jointly responsible (but not with regard to further processing) with Facebook for the exchange of data collected or obtained via the Pixel or similar functions, the display of advertising material based on users’ interests, the improvement of ad delivery and the personalisation of functions and content. Accordingly, we have concluded a supplementary agreement with Facebook. Users may therefore contact Facebook directly for any information and for other matters concerning our joint responsibility. You can obtain further information on the Facebook Pixel, on the manner, scope, purposes and legal bases of, and the possibilities of objecting to, the processing of data by Facebook, and on how to adjust the settings to protect your privacy by consulting Meta’s Privacy Policy at https://www.facebook.com/about/privacy/ and https://www.facebook.com/business/tools/meta-pixel . You may withdraw your consent to our storage and use of cookies (including the Facebook Pixel) for retargeting/remarketing purposes at any time with effect for the future by changing your cookie settings accordingly. You can also prevent the storage and use of marketing cookies (including the Facebook Pixel) by adjusting your browser accordingly and/or by preventing the installation of add-ons (see also our cookie guidelines).

18. TIKTOK PIXEL

We use services provided by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (hereinafter “TikTok”) on our online platforms, such as the TikTok Pixel, for retargeting/remarketing purposes. If you visit certain of our online platforms and provided that you have given your consent, a direct connection is established via the TikTok Pixel between your browser and the TikTok server. TikTok may then receive information about your visit to our online platforms, such as information on certain interactions with our online platforms (clicks or product views), your IP address and information about your device and browser. This enables us to organise our activities on TikTok more effectively and, for example, to show items or advertisements only to visitors to our online platforms. The TikTok Pixel also makes it possible to analyse the use of the online platforms on our behalf and to show content and offers that may be of interest to you. The data collected are anonymous as far as we are concerned, i.e. we cannot examine the personal data of individual users. We will use the “advanced matching” function to match customer lists only with your prior consent (see section 2.7). You can obtain further information on the TikTok Pixel, on the manner, scope, purposes and legal bases of, and the options for objecting to, the processing of data by TikTok, and on how to adjust the settings to protect your privacy by consulting TikTok’s Privacy Policy at https://www.tiktok.com/legal/privacy-policy-eea?lang=en and at https://ads.tiktok.com/help/article?aid=6669727593823993861. You may withdraw your consent to TikTok’s storage and use of cookies (including the TikTok Pixel) for retargeting/remarketing purposes at any time with effect for the future by changing your cookie settings accordingly. You can also prevent the storage and use of marketing cookies (including the TikTok Pixel) by adjusting your browser accordingly and/or by preventing the installation of add-ons (see also our cookie guidelines).

19. SOCIAL MEDIA FUNCTIONS

On our online platforms you will find links (hyperlinks) to our social media profiles on the social media networks and platforms operated by Facebook, LinkedIn, Instagram, Twitter, YouTube and Pinterest. These services are provided by the companies listed below (hereinafter also referred to as “Social Media Providers”):Facebook and Instagram are operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”, “Instagram”); Privacy policy: https://www.facebook.com/privacy/explanation. LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”); Privacy policy: https://www.linkedin.com/legal/privacy-policy. Twitter is operated by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland (“Twitter”); Privacy policy: https://twitter.com/en/privacy YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (‘YouTube’ or ‘Google’); Privacy policy: https://policies.google.com/privacy?hl=en Pinterest is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland (“Pinterest”); Privacy policy: https://policy.pinterest.com/en-gb/privacy-policy. With regard to the purpose and scope of the data collection, the further processing and use of the data by these Social Media Providers, your rights in this respect and the possibilities of adjusting your settings to protect your privacy, please consult the information of the corresponding Social Media Provider using the links above. By clicking on the corresponding symbols of these Social Media Providers, you are automatically forwarded to our profile on the Social Media Provider in question. In order to use the functions of the network in question, you must be partially logged in via your user account on the network. If you do not want a Social Media Provider to associate your action of clicking on a link that forwards you to the network’s site with your user account on the network in question, you must log out of the service in question before clicking on the link. Even if you are not registered with the Social Media Provider, data may be sent to the Social Media Provider with the aid of cookies after you have clicked on such a link. If we are jointly responsible with the provider for certain types of processing, we will conclude a corresponding agreement, the essential content of which can be consulted with the provider. For further information on the processing of data by social media providers, please consult their respective privacy policies. Our online platforms may also contain plug-ins from social media providers (e.g. Facebook, Twitter, Pinterest and Google+) such as the “Share” or “Like” buttons. These interfaces contain a link to the corresponding social media platform. If you select one of the available functions and click on the symbol of the corresponding Social Media Provider, a direct connection is established between your browser and the server of the Social Media Provider in question. During this process, the Social Media Provider is informed that you have visited our platforms using your IP address and have requested the link. If you click on a link to a social media platform while you are logged in to the account of the provider in question, the content of our website may be linked to the Social Media Provider, which means that the provider will be able to associate your visit to our website directly with your user account. To prevent this from happening, you must log out before clicking on the corresponding link. The association will take place in any event if you log in to the Social Media Provider after clicking on the link.

20. MONITORING OF MISUSE

In order to prevent abusive requests and unauthorised transactions (for example, receipt of stolen goods and counterfeiting), we compare the information relating to the order with all customer information already stored in our CRM database. This may include identification by presentation of a valid identity document and, if necessary, a copy thereof. In the event of suspected abuse, we may also carry out further investigations to the extent. The legal basis for data processing in the cases described above is the protection of the legitimate interests of LabOr Pesciallo SAGL or third parties. Both the manufacturer concerned and we have a legitimate interest in preventing unauthorised trading/sales and abusive requests, in preventing and investigating criminal offences and in ensuring the secure operation of our business. Under the conditions set out in section 8, you may object to the processing of your data for these purposes.

21. COMPLIANCE WITH LEGAL OBLIGATIONS

In certain circumstances, we are obliged to collect information on the identity of a contracting party or of the persons representing it or of the beneficial owners for identification purposes in line with anti-money laundering provisions (usually the person’s name, place and date of birth, nationality, residential address, details of the business relationship and, if necessary, other information about the contracting party) and to verify the identity of the contracting party by means of a valid identity document. It may also be necessary to collect and process data from officially accessible sources (e.g. public registers, the Internet) and to obtain and retain a copy of a valid identity document. The legal basis for data processing in this respect is compliance with the legal obligations relating to anti-money laundering provisions. We also process personal data in compliance with other legal obligations, such as compliance with the documentation and record-keeping obligations under commercial and tax law. The legal basis in this case is compliance with the relevant legal obligations.

22. OVERALL MARKETING

By using the contact forms, you have the opportunity to give us general consent to the processing and use of your data for marketing purposes and to contact you through the communication channels you have indicated, in particular by e-mail, telephone (including messaging apps), online platforms (e.g. push notifications) and/or social media (“general consent”). For this purpose, we collect and store the following types of data (* mandatory information): e-mail address*, title*, first name*, surname*, telephone number, address, country. In line with our general marketing strategy and on the basis of your consent and the information stored and compiled in future in your user and/or customer profile (see paragraphs 2.8 and 2.5), you will receive interest-based information about our products, services and benefits and accompanying recommendations. In this way we pursue the following objectives: to analyse, evaluate and optimise the use of our services; to offer you personalised content, product recommendations and exclusive offers based on your transactions, your use of the services and your individual interests; to draw your attention to services associated with the purchase of products; to invite you to exclusive events; to measure the reception and success of marketing campaigns; to frame our advertising and that of our partners in a more appealing way and, in so doing, to provide you with promotional content through other channels (for example, social media platforms and advertising networks) – remarketing/retargeting; to offer you social media services; to conduct and evaluate e-mail campaigns; to send customer surveys and evaluate them. We will record your consent to overall marketing in order to provide proof of the underlying consent in line with legal requirements. The recording of your consent and the necessary processing of the data you have entered will therefore take place on the basis of our legitimate interests. If at a later date you decide to withdraw, in whole or in part, your consent to the collection, processing and use of your data by LabOr Pesciallo SAGL or third parties for marketing purposes and for sending promotional messages, you can do so at any time by visiting the Preference Centre and changing the preference settings in your customer account, or by e-mail message or by contacting our customer service. It should be noted that when promotional e-mails are sent, your behaviour in relation to our promotional e-mails is evaluated by us. This evaluation takes place with the aid of “web beacons”, also known as tracking pixels / pixel tags, and related coded links. Web beacons are one-pixel image files that establish a link with our online platforms and, together with the coded links, enable us to analyse user behaviour in relation to promotional e-mails (“open or click tracking”). This is done by collecting technical information, for example about your browser, your system, your IP address and the time at which the e-mail or link was opened, via web beacons and coded links, which are assigned to your e-mail address, have their own associated identifier and may be assigned to your user profile. Open tracking via web beacons is not possible if you have disabled the display of images in your e-mail program by default. In that case, however, our promotional e-mails will not be shown to you in full and/or not all functions will be available. By manually allowing the display of images, the tracking described above can take place. You can prevent “click tracking” only by refraining from clicking on the links in promotional e-mails.

23. TARGETED MARKETING TO EXISTING CUSTOMERS

If we have obtained your data in connection with an order or purchase of yours – and provided that legal authorisation has been granted for such marketing initiatives – we may send you promotional e-mails with information on similar goods and services. For this purpose we generally process the following types of data: e-mail address, title, first name, surname and/or address. This is done for promotional purposes on the basis of a legal authorisation and our legitimate interest in maintaining customer relationships and conducting related targeted marketing campaigns. As a former customer, we also reserve the right to send you promotional material by post, unless you have objected to being contacted by post. As a previous customer, you may object to promotional contact at any time. In that case, you will receive no further promotional information about our products and services based on our legitimate interest. You may exercise your right to object in writing (e.g. by e-mail) using the contact details provided above.

24. CRM DATABASE AND INFORMATION ON JOINT RESPONSIBILITY

In order to ensure the uniform availability of our online platforms, financial and resource planning, customer management, marketing activities, order processing and data analysis, LabOr Pesciallo SAGL uses systems managed centrally at group level. These systems are responsible for the uniform group-wide management, maintenance and processing of customer, order and contract data, as well as data from various sources (for example, relating to the use of our online platforms and your interactions with us) to the extent and for the purposes described above. Other group companies may have access to the stored information, provided that this is necessary for internal administrative purposes or for customer support or for abuse control. The legal basis for such group-wide transfer of personal data generally lies in the protection of the legitimate interests of LabOr Pesciallo SAGL. Our company LabOr Pesciallo SAGL has a legitimate interest in processing such data in centralised systems, in order to ensure customer support that extends to local shops and group companies and a better service to customers, to prevent unauthorised transactions and abusive requests and to implement uniform technical and organisational security measures. The agreement essentially provides for the following: Areas of responsibility: Responsibility for the operation and administration of the systems and the management of the stored customer and order data and for related privacy matters (for example, customers’ requests for information and erasure of data) lies primarily with LabOr Pesciallo SAGL, based in Switzerland. The collection and updating of data in the systems, for example during customer registration, order fulfilment or contract implementation, and communication with the customer in this respect generally take place through the branches or online platforms of the respective companies of LabOr Pesciallo SAGL, which are accordingly responsible in this regard. All companies process personal data in accordance with data protection provisions. Data security: LabOr Pesciallo SAGL, with its registered office in Switzerland, is primarily responsible, together with the group companies concerned, for ensuring adequate levels of security of personal data when they are processed in the centralised systems and for the underlying data protection principles. Information and notification obligations: The information obligations are fulfilled by the corresponding LabOr Pesciallo SAGL company in line with this Privacy Policy. Compliance with notification obligations in the event of a data protection incident is also the responsibility of the respective LabOr Pesciallo SAGL company. Data subject rights / contact persons: LabOr Pesciallo SAGL is solely responsible for processing and responding to data protection requests and questions from its customers. This means that your point of contact for all data protection matters is the company LabOr Pesciallo SAGL. If you wish to exercise your data protection rights (e.g. a request for information or erasure of data), you can contact the data protection contact person or the data protection officer by writing to info@lab-or.ch or info@vannipesciallo.ch .

 

25. DATA RETENTION PERIOD

Unless otherwise stated, your personal data will be erased or, in some cases, anonymised if it is no longer required for the stated purposes in connection with the services provided, if no other legal basis can be invoked for its further processing, or if its erasure is necessary to comply with a legal obligation. Data may be retained for longer periods if and to the extent that this is necessary to comply with a legal obligation (for example, data retention obligations under commercial and tax law, depending on the locally applicable legislation, e.g. 10 years) or for other legitimate reasons (for example, to pursue legal claims). If there is no other legal basis for the further processing of customer data collected with your consent, such data will be erased if you withdraw your consent.

26. DATA RECIPIENTS

In addition to the cases described in this Privacy Policy regarding the transfer of certain categories of customer data to service providers, data will be transferred to the recipients described below if this is necessary to enable us to provide our services and provided that you have given us your consent or that another legal authorisation exists: In particular, your data may be transferred to the following recipients: In processing contracts and providing our services, and in order to comply with legal obligations, we may use the services of other external service providers (in particular postal and shipping service providers, banks and payment service providers, insurance companies, travel service providers, credit and debt collection agencies, marketing agencies, e-mail providers, web, cloud and IT service providers, data destruction companies) and external advisers (for example, lawyers, anti-money laundering officers, accountants and tax advisers). The transfer of your data to these service providers will take place only in compliance with the relevant statutory provisions, when an order is being processed and on the basis of appropriate agreements. In some cases, you may need to enter into separate agreements with specific service providers (for example, payment service providers and insurance companies). In these cases, you should take note of the data protection and security provisions accessible via the links provided. In order to provide the warranty services offered by manufacturers, or in the case of organising joint events or activities and in connection with limited editions, waiting lists, certificates and special requests, we may be obliged to transmit your personal data to the manufacturer or partner brand. The legal basis for such data transfers is generally the need to perform a contract or a legitimate interest for the aforementioned purposes. to companies of LabOr Pesciallo SAGL; transfers of personal data in connection with acquisitions, mergers and sales of companies; We may also be obliged, in accordance with legal obligations, to transfer your personal data to other recipients, such as authorities, in order to meet disclosure requirements (for example, supervisory, financial or law enforcement authorities).

27. PROCESSING OF DATA IN THIRD COUNTRIES

If we transfer your personal data to third countries outside Switzerland, the European Union (EU) or the European Economic Area (EEA), before the transfer takes place we will verify, subject to the exceptions provided for in the receiving country, whether an adequate level of data protection exists or whether you have consented to the data transfer. An adequate level of data protection is ensured, for example, by the conclusion of EU standard contractual clauses or by the existence of so-called Binding Corporate Rules (BCR). We transmit and process data in Europe and the United States.

28. YOUR RIGHTS

The rights listed in this section may be subject to certain exceptions or additional conditions in accordance with the applicable data protection laws. Right to information: You may request information from us at any time about the personal data we process. The provision of information must respect the rights and freedoms of other persons who could be harmed by the transfer of the data. Right to rectification: You may request the rectification of inaccurate personal data or the completion of incomplete personal data stored by us. Right to erasure: you may also request the erasure of the personal data stored by us, if the processing is not necessary for exercising the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims. Right to restriction of processing: You may request the restriction of the processing of your personal data. This applies in particular if you contest the accuracy of the personal data stored by us or if you have objected to the processing. In this case, we are obliged to restrict the processing of the data pending the examination of your concern. Right to data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to request that they be transferred directly to another controller. This right to data portability exists only if the processing is based on your consent or on a contract and is carried out by automated means. Right to object to data processing on legitimate grounds: If we process your data to protect legitimate interests, you may object at any time to the processing of your personal data on grounds relating to your particular situation. If a legitimate objection is made, we are obliged to stop processing your data, unless we can demonstrate compelling legitimate grounds that override your interests or if we are obliged to process such data for the establishment, exercise or defence of legal claims. The right to object may be subject to limitations as laid down by the applicable data protection laws. Right to object to data processing for direct marketing: If we process your personal data for direct marketing purposes, you have the absolute right to object at any time to the processing of your data for such marketing. In these cases, it is not necessary to provide details relating to your particular situation. This also applies to any profiling, insofar as it is connected with such direct marketing. If you raise an objection, your data will no longer be processed for direct marketing purposes. Right of withdrawal: If we process personal data on the basis of your consent, you also have the right to withdraw it at any time. The consequence of the withdrawal will be that we will no longer continue to process the data on the basis of your previous consent in the future. If you wish to withdraw your consent to the use of certain cookies, please take note of our explanations in the cookie guidelines. If you wish to exercise your data protection rights, please contact the data protection contact person or the data protection officer. Please note that, depending on the applicable data protection laws, the exercise of the aforementioned rights may be framed differently or limited and/or subject to different conditions. In order to prove the identity of the person exercising the rights described in this paragraph, LabOr Pesciallo SAGL may request the presentation of an identity document and process it accordingly.

29. YOUR RIGHTS

If you believe that our processing of your personal data infringes your data protection rights, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. You can find an overview of all European supervisory authorities by clicking here: https://www.bfdi.bund.de/DE/Service/Anschriften/Europa/Europa-node.html.

 

30. SECURITY

We take technical and organisational security measures to protect your personal data, in particular against accidental or intentional manipulation, loss, destruction or access by unauthorised persons. These security measures are regularly updated in line with the latest technological innovations and market developments. All our employees, as well as the companies we rely on, are bound to confidentiality.

31. CHANGES

From time to time it may be necessary to revise the content of this Privacy Policy. Accordingly, we reserve the right to amend it at any time. Italian version January 2024.