What is the purpose of this policy?
When we refer to the “processing” of personal data, we mean any operation or set of operations on such personal data regardless of the method used – for example: collecting, managing, storing, using, transferring, disclosing, deleting and accessing, etc. The processing of your personal data is carried out through both automatic and non-automatic means.
Once you accept this Policy, it shall constitute a binding agreement between you and us. Please read the Policy carefully.
How does Swisscom process personal data?
When using beem (without registration)
When you use beem, we process information about your use of beem (“session information”), such as the date, time, duration, location and frequency of use of beem, how you navigate through beem, the number and duration of visits to beem, the types of browsers and operating systems you use. We process session information to analyze the use of beem and improve its functionality and the design of our advertising partners’ offerings available in beem.
When you register for and use beem
To provide and maintain beem and to measure and improve beem over time, we will process the following information about you (“Personal Data”):
- Registration Data: Salutation, your first name, middle name, last name; date of birth, email address; country of residence; username; password; IP address; preferences, your customer contacts and any other data you enter during your registration or at a later stage;
- Usage information: date, time, duration, location and frequency of your use of beem, how you navigate through beem, the number and duration of visits to beem, the types of browsers and computer operating systems you use;
- information from our affiliates and our advertising partners, customers and other third parties that participate in the placing of advertising and other services in beem, such as how you respond to offers.
If you decide to register for beem, we may process the Personal Data for the purpose of:
- Providing, managing and improving beem;
- Managing our contractual relationship with you;
- Validation of your data;
- Allowing users to create and update their accounts;
- Establishing the contact between us and you;
- Answering your requests and questions;
- Issuing invoices, if applicable;
- Providing you with newsletters and other news on beem;
- Keeping beem and our infrastructure secure;
- Server maintenance, troubleshooting, data analysis, testing, research and service improvement;
- Developing new features and functionalities, improving user experience and enhancing user friendliness;
- Providing you with marketing or promotional information by email on products, initiatives and events of the Swisscom group of companies or selected business partners (one-to-one marketing);
- Building individual and group profiles (profiling), in order to be able to submit individualised, targeted advertising or offers that are better tailored to the respective needs of users. For this purpose, we link and analyse the data relevant for our marketing purposes;
- Preventing misuse of beem; and
- Complying with applicable laws and regulations or requests by competent courts and authorities.
How does Swisscom share Personal Data?
If you use beem and accept an offer from one of our advertising partners available in it (such as participation in a competition, purchase of goods or services), then you disclose your personal data as displayed in beem for this specific case to the respective advertising partner, or authorize us to forward this data to the advertising partner for further processing of the offer. With regard to further use of this data by the advertising partner, the advertising partner’s data protection provisions applicable to the respective offer shall apply. We assume no responsibility or liability for the use of this data by the advertising partner or other third parties, their data protection measures, nor do we support them. We encourage you to familiarize yourself with the applicable privacy policies provided by the advertising partner before authorizing us to disclose information about yourself to them or enter into any business with such Advertisers.
We may share any Session Data and Personal Data with other members of the Swisscom group of companies for the purposes stated in this Policy and with third-party service providers (“Service Providers”) for obtaining professional, technical or organizational services that are functional to achieving the purposes set out herein. The Service Providers will process the Session Data and Personal Data as data processors on our behalf.
We may also share your Session Data and Personal Data if we consider it necessary or appropriate to do so:
- In order to comply with any applicable laws and regulations;
- In the case of judicial proceedings, request by competent courts and authorities or other legal obligation; and
- To protect or to defend our rights and property.
In the event that we are involved in a bankruptcy, merger, acquisition, reorganisation or sale of assets, your Personal Data may be sold or otherwise transferred to affiliates or third parties as part of such transaction. This Policy will apply to any Personal Data sold or otherwise transferred to the acquirer.
We may also share your Personal Data with affiliates and third parties for them to help us provide, understand and improve beem and our affiliates’ services, including the design of our advertising partner’s offerings.
We may share or disclose your aggregated, anonymized or otherwise non-personal information regarding the use of beem and the offers it contains, such as clicks on “My beems” or the number of users who clicked on a particular offer or link (even if only one clicked) or similar reports to third parties.
How does Swisscom protect Personal Data?
We maintain technical and organizational security procedures to maintain the security of your Session Data and Personal Data, as well as to safeguard your Session Data and Personal Data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access. Our security procedures include contractual terms with any Service Provider to ensure that they protect the security and confidentiality of your Session Data and Personal Data in accordance with our standards and this Policy.
However, please be aware that while we strive to protect your Personal Data against potential risks and exposures, there is no absolute security in the online sphere.
Where does Swisscom store my Personal Data?
The personal data that we collect from you is stored by a cloud provider on servers in the EU and Switzerland. At present, we do not intend to store your personal data outside this area, but reserve the right to do so in the future. Recipients of your personal data may then be located in any country. This may include countries located outside of Switzerland or the EU Area, where data protection laws provide a lesser degree of protection than in Switzerland defined by the Federal Data Protection and Information Commissioner or the General Data Protection Regulation (GDPR). In such case, we will ensure an adequate level of protection for your Personal Data in accordance with applicable laws, by requiring the recipient to enter into data transfer agreement based on the EU Model Clauses or an equivalent standard corresponding to the contractual clauses adopted by the European Commission for the purpose of adducing adequate safeguards for the protection of personal data with the event of cross-border transfers.
How long does Swisscom retain my Personal Data?
Your Personal Data is not retained by us for longer than necessary for the legally permissible purposes for which they were collected. If you want us to delete some or all of your Personal Data, you may delete your account and discontinue your use of beem. Please be aware, however, that we may be entitled or obliged to retain some of your Personal Data based on applicable laws and regulations.
What about links to other websites?
beem contains offers from our advertising partners and may contain links to websites of these advertising partners or other third parties. Such third-party websites are not controlled by us. When you visit such third party websites you do so at your own risk. We cannot, and do not, assume any responsibility or liability for such third party websites, the content of such websites and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such other websites prior to providing them with information about you or entering into any transactions on them.
Can the data processing and this Policy change over time?
Possibly. We reserve the right to adapt, amend, modify or change our data processing practices and, consequently, this Policy at any time in our sole discretion. In the case we decide to modify, change and amend our data processing practices and this Policy, we will notify you of the relevant modification, change or amendment by email and place a respective notice on beem at least fourteen (14) calendar days prior to the modification, change or amendment becoming effective. If you disagree with the relevant modification, change or amendment, you may deactivate your account and discontinue your use of beem. If you do not deactivate your account, your continued use of beem after we make changes to this Policy will be deemed acceptance of the relevant modification, change or amendment.
How to contact us
If you have any questions or concerns about: (a) access to Session Data and/or Personal Data; (b) the processing of Session Data and Personal Data; (c) rectification, cancellation and opposition with respect to Session Data and/or Personal Data; (d) objection to the processing of your Personal Data for marketing purposes; (e) this Policy or our information handling practices or (f) with whom your Session Data and Personal Data is shared, or if you need further assistance with respect to our Policy, you can contact us via www.beem-now.ch or by regular mail or email to the following addresses: Swisscom (Schweiz) AG, Digital Business Unit, beem, Konradstrasse 12, 8005 Zürich, Schweiz or firstname.lastname@example.org. We will attempt to respond to your questions or concerns promptly after we receive them.
Last updated on May 20, 2019