DATA PROTECTION Policy
This websites www.valuemanifesto.ch and app.valuemanifesto.ch are produced and published by Value Manifesto GmbH, Grenzacherstrasse 92, 4058 Basel, registered in the Commercial Register of the Canton of Basel under No. CH-155.867.983.
We are therefore responsible for the collection, processing and use of your personal data in accordance with the law. We take data protection very seriously and are committed to the protection of your personal data. Consequently, we comply with the applicable data protection laws, in particular the General Data Protection Regulation of the European Union (GDPR) and other provisions of Swiss and European Data Protection Law.
We would like to inform you below how we handle your personal data. Please be aware that the following information may be reviewed and amended from time to time. We therefore recommend that you consult this Data Protection Policy on a regular basis.
1) Extent and purpose of the collection, processing and use of personal data
a) When visiting our websites
When you visit our websites, our servers temporarily store each access in a log file. The following data is collected and stored, without any action on your side, until it is automatically deleted after 12 months:
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- the IP address of the requesting computer;
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- date and time of access;
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- name and URL of the data accessed;
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- the website from which access is made to our domain;
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- your computer’s operating system and the browser you use;
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- the country from which access to our website is made;
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- the Status-Code, and
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- the name of your Internet provider
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This data is collected and processed for the purpose of allowing the use of our websites (establishing a connection), ensuring system security and stability in the long term, and allowing the optimization of our Internet offering as well as for internal statistical purposes.
The aforementioned information is not linked to or stored with any personal data. Only in the event of an attack on the website's network infrastructure or where unauthorized or abusive use of the website is suspected will the IP address be evaluated for clarification and defensive purposes and, where necessary, used within the framework of criminal proceedings for identification and to bring legal action against the users concerned under civil and criminal law.
We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process the data for these purposes.
b) When you register to our mailing list (only www.valuemanifesto.ch)
In order to receive the newsletter, it is essential that you enter the following personal data truthfully:
- E-Mail-Address
We require this information to be able to send you our newsletter. For this processing we rely on your consent for the processing of your data within the meaning of Art. 6 para. 1 lit. a GDPR.
c) When you contact us via E-Mail (only www.valuemanifesto.ch)
If you contact us via E-Mail or the contact form, the data you provide will be used for the purpose of processing your request. We require this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.
This processing is based on the fulfilment of the contract within the meaning of Art. 6 para. 1 lit. b GDPR.
d) When you create an account (only app.valuemanifesto.ch)
When you create an account to use the Value Manifesto we may collect, store and process the following data (* mandatory):
- E-Mail-Address*;
- Name*;
- Address (Street; Town; Postcode)*;
- Date of birth*;
- Place of birth*;
- Nationality*.
This processing is based on the fulfilment of the contract within the meaning of Art. 6 para. 1 lit. b GDPR. You can object to this data processing at any time (see Section 7). This would however, result in a revocation of the account.
e) When we verify your account (app.valuemanifesto.ch)
After you have created an account, we have a verification procedure as part of our security measures. When we verify your account, we may process and collect the following data (* mandatory):
- Copy of your ID card*;
- Utility bill not older than three months*;
- Source of fund (light or extended)
This processing is based on the fulfilment of the contract within the meaning of Art. 6 para. 1 lit. b GDPR. You can object to this data processing at any time (see Section 7) below). This would however, result in a revocation of the account.
f) When you place a bid (app.valuemanifesto.ch)
When you place a bid we may collect, store and process the following data (* mandatory):
- Your ID*;
- Your bid*;
- Type of Art Work;*
- other online activities related to the bid (e.g. transmission of acquired Art Work or similar).
This processing is based on the fulfilment of the contract within the meaning of Art. 6 para. 1 lit. b GDPR.
2) Tracking and re-targeting
a) Use of Google (Universal) Analytics (only www.valuemanifesto.ch)
This website uses Google Analytics, a web analysis service provided by Google Inc. (www.google.com). Google (Universal) Analytics uses methods that allow analysis of your use of the website, such as so-called "cookies", text files that are stored on your computer. The information generated on your use of this website is usually transferred to a Google server in the USA and stored there. Due to the activation of IP anonymization on this website, the IP address will be shortened within Member States of the European Union or in other contracting states acceding to the Agreement on the European Economic Area and in Switzerland before transmission to the USA. Only in exceptional cases is the full IP-address transmitted to a Google server in the USA and shortened there. The anonymized IP address transmitted by your browser in the context of Google Analytics will not be combined with other Google data.
This information is used to evaluate your use of the website, in order to compile reports on the activities on our website and to provide other services associated with the use of the website for the purpose of market research and customizing the website.
Furthermore, you can prevent the Google cookie from recording and processing your data (including your IP address) by downloading and installing the browser plugin provided by Google under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.
As an alternative to the browser plugin, you can click this link to prevent Google Analytics recording on this website in the future. This stores an opt-out cookie on your device. If you delete your cookies, you have to click on the link again.
For the sake of completeness, we advise users domiciled or residing in Switzerland that the US authorities have put monitoring measures in place in the USA which generally allow for the storage of all personal data belonging to all persons whose data has been transmitted from Switzerland to the United States. This is done without differentiation, qualification or exception in terms of the aim pursued and without an objective criterion that allows access by US authorities to the data and their subsequent use to be restricted to specific, strictly defined purposes justifying both access to this data and intervention related to their use. Furthermore, we draw your attention to the fact that no remedies are available in the USA for persons from Switzerland directly affected which would allow them to gain access to the data concerning them or to bring about their correction or deletion and there is no effective legal protection against general access rights by US authorities.
We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process the data for these purposes.
b) Google Fonts (only www.valuemanifesto.ch)
This website uses Google Fonts, a service provided by Google Inc. When you access our site, a connection to Google is established from which Google can identify the site from which your request has been sent and to which IP address the fonts are being transmitted for display.
Through certification according to the EU-US Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active) Google guarantees that it will follow the EU's data protection regulations when processing data in the United States. To enable the display of certain fonts on our website, a connection to the Google server in the USA is established whenever our website is accessed. Google offers detailed information at https://adssettings.google.com/authenticated and https://policies.google.com/privacy
We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process the data for these purposes.
c) Double Click (only www.valuemanifesto.ch)
This website uses DoubleClick by Google, a service of Google Inc. Google uses for this purpose the so-called DoubleClick cookie, which makes it possible to recognize the browser used by the user when visiting other websites. The information generated by the cookie about visiting these websites (including the IP address) will be transmitted to and stored on a Google server in the United States (see above Section 2.a)).
Google will use this information to evaluate the use of the website in regard to the advertising to be shown in order to compile reports for the operator of the website regarding the website activities and advertisements, and to provide further services relating to the use of the website and internet usage. Google may also pass this information on to third parties insofar as this is required by law or if third parties process the data on Google's behalf. Google will not under any circumstances, however, associate the IP address of a user with any other data held by Google.
Users can prevent re-targeting at any time by rejecting or de-activating the relevant cookies in the menu bar of the web browser (see below Section 6).
We base the creation of pseudonymised user profiles for advertising and analysis purposes on a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. This applies to all listed data processing operations. The legitimate interest is in direct marketing and analysis of the use of our website. Users can prevent re-targeting at any time by rejecting or de-activating the relevant cookies in the menu bar of the web browser (see below Section 6).
3) Social Media Presence (only www.valuemanifesto.ch)
On our websites, we might incorporate social media links to our social media profiles on the following social networks:
- Instagram Inc., 1601 Willow Road, Menlo Park, California 94025, USA;
- YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA
- Facebook inc., 1601 S. California Ave, Palo Alto, Ca 94304, USA
If you click on the relevant social network icons, you will be automatically redirected to our profile on the relevant network. In order to use the functions of the relevant network there, you must partially log in to your user account for the relevant network.
When you open a link to one of our social media profiles, a direct connection is established between your browser and the server of the relevant social network. This gives the network the information that you have visited our website with your IP address and accessed the link. If you access a link to a network while logged in to your account on the relevant network, the contents of our page may be linked to your profile in the network, which means that the network can link your visit to our website directly to your user account. If you want to prevent this, you should log out before clicking on the relevant links. An assignment takes place in any case, if you log into the relevant network after clicking on the link. For more information regarding the protection of your data on the social media platforms itself, you can also consult the data policies of the respective platforms.
4) Disclosure of personal data to third parties
We will only transfer your personal data to third parties if you have given us your explicit consent, if there is a legal obligation to do so, or if it is necessary for the enforcement of our rights.
In addition, we will disclose your personal information to third parties as far as it is necessary for the use of the website and the providing of any services you requested. The use of this data by third parties is strictly limited to the mentioned purposes.
A service provider to whom personal data collected on the website is forwarded, or who has or could have access to said data, is our website hosting company. The website is hosted on servers based in Frankfurt, Germany (operated by or on behalf of Amazon Web Services Cloud (AWS) by Amazon Web Services Inc., 410 Terry Avenue North, WA 98109 Seattle, USA). The data is shared for the purpose of providing and maintaining the functionalities of our website. For this processing we rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR.
5) Transmission of personal data abroad
We are entitled to transfer your data to third-party companies located abroad to the extent this is required in connection with the processing described in this Data Protection Policy. Any such third-party companies are obliged to respect the privacy of users to the same extent as the provider itself. If the level of data protection in a country does not correspond to the Swiss or European level, we will ensure, by means of a contract, that the protection of your personal data corresponds to that in Switzerland or the EU at all times.
6) Cookies
In many respects, cookies help to make the visit of our website easier, more pleasant and more useful. Cookies are information files stored automatically by your browser on the hard disk of your computer when you visit our website. Cookies neither damage the hard disk of your computer nor do they transmit your personal data to us.
Most Internet browsers accept cookies automatically. However, you can configure your browser in such a way that no cookies are stored on your computer or a notice always appears when you receive a new cookie. The following pages explain how to configure the processing of cookies for the most common browsers:
- Microsoft Windows Internet Explorer
Please note that deactivating cookies may prevent you from using all the features of our website.
The legal basis for processing the data for the above purposes lies in our legitimate interest in ensuring the functionality and optimization of the website (Art. 6 para. 1 lit. f GDPR). You can object to the processing at any time. The possibility of opting out has been mentioned above.
7) Information, deletion, revocation, correction, limitation of processing and data transferability rights, right to complain to a supervisory authority
You can object to data processing at any time. You also have the following rights:
Information right: You have the right at any time to request access to your personal data stored by us. This gives you the opportunity to check which personal data we process about you and that we use it in accordance with applicable data protection regulations.
Correction right: You have the right to have inaccurate or incomplete personal data corrected and to be informed of the correction. We will inform the individual concerned of the adjustments made to any incorrect data, unless such notification is impossible or involves a disproportionate effort.
Deletion right: You have the right to require us to delete your personal data, as long as there is no legal basis that allows us to further process such data.
Right to limitation of processing: You have the right, under certain conditions, to request the processing of your personal data to be restricted.
Data transferability rights: Under certain circumstances, you have the right to receive from us the personal data that you have provided to us, free of charge and in a readable format.
Right to complain: If you are a resident of an EU or EEA member country, you have the right to lodge a complaint with a competent supervisory authority against the way in which your personal data is processed at any time.
Right of revocation: You can withdraw your consent to certain data processing at any time, with effect for the future.
8) Data retention
We only store personal data for as long as is necessary to carry out the processing in the context of our legitimate interest and to fulfill our contractual obligations. We keep contract data for longer, as this is required by legal storage obligations. Obligations to store data, which oblige us to store data, result from accounting regulations and tax regulations. According to these regulations, business communication, concluded contracts and accounting documents must be stored for up to 10 years. If we no longer need this data to perform the services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.
9) Data security
We take all reasonable technical and organizational security measures that we deem appropriate in order to protect your stored data against manipulation, loss, or unauthorized third party access. Our security measures are continually adapted to technological developments.
We also take internal data privacy very seriously. Our employees and the service providers are required to maintain secrecy and to comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.
10) Contact
If you have any questions on data protection on our website, would like more information or would like to arrange for your data to be deleted, please get in touch with us by sending an E-mail to Timo Niemeyer, info@valuemanifesto.ch.
Version 1.0, August 26th 2019