1. Preamble and consent
The present Website and Social Media Cookie and Privacy Policy (“Privacy Policy”) governs your relationship with the website genevasolutions.news (the “Website”) and our dedicated pages on the following social media and platforms: Facebook, Twitter, Instagram, WhatsApp and LinkedIn, all operated by Heidi Media SA (“us”, “we”, “our”), with its headquarters located at rue de Malatrex 50, 1201 Geneva, Switzerland.
Please read this Privacy Policy carefully before using the Website and our dedicated social media pages, as it explains how your personal data will be collected, used and protected. Your access and use of the Website and social media pages are conditional upon your acceptance of, and compliance with this Privacy Policy.
By browsing our Website, you agree to be bound by this Privacy Policy and you agree and consent to the collection, use and processing of Personal Data in accordance with this Privacy Policy. If you do not consent to the terms of this Privacy Policy, we kindly ask you not to use our Website and/or dedicated pages on social media.
Please also note that you have the right to withdraw your consent at any time, it being however specified that such withdrawal:
- will not affect the lawfulness of processing based on your consent before its withdrawal;
- may prevent you from using some features of our Website or dedicated pages on social media.
2. General Principles
2.1 Our Website and social media platforms contain the following information and provide the following services:
- information about our mission, our team, our partnerships and our offered services, including the provision of articles, videos, and podcasts;
- various channels to get in touch with us (e-mail, links to social media accounts, etc.);
- subscription to our newsletters, including the “Daily Brief”.
2.2 This Privacy Policy details our policies and procedures concerning the collection and processing of any information that identifies you (“Personal Data”), which you provide to us when visiting our Website or social media platforms or using one of the services described under 3.1.
2.3 This Privacy Policy applies only to our Website and our dedicated pages on social media. Please note that if you access our dedicated pages on social media, information you provide will also be subject to the privacy policy of operator of the social media platform.
2.4 This Privacy Policy does not apply to any of our offline services.
3. Personal data we collect and purpose of processing
A - Sources of Personal Data
3.1 The main sources of Personal Data collected via our Website and social media are as follows:
- cookies, analytics and other similar tools (Section B below);
- Personal Data you provide us with (Section C below);
- data from other sources (Section D below).
B - Cookies, Analytics and other similar tools
a) What are Cookies and what information they collect?
3.2 Cookies are files with small amount of data which are sent to your browser from a website and stored on your device (computer or mobile device). Tracking technologies also used are scripts to collect and track information and to improve and analyze our Website.
3.3 Through cookies and other tracking technologies, we may collect Personal Data from you when you visit our Website or dedicated pages on social media. We may log in particular usage data when you view or click on content.
3.4 The following information and Personal Data are collected through the cookies and other tracking technologies we use:
- IP address;
- location, based on the IP address;
- date and time of access;
- accessed resources on the Website;
- name and URL of the retrieved file;
- website/application from which the access was made (referrer URL).
3.5 The following information and Personal Data are collected through your web browser:
- the type of browser you use,
- if necessary, your computer operating system and the name of your access provider.
3.6 In order to control / limit the collection of this information, you can:
- if available, set up your browser to refuse all cookies or to indicate when a cookie is being sent,
- when reaching our Website, select what cookie you allow and what cookie you want to block,
- delete cookies and clear your browsing data directly from your browser’s settings.
However, please note that if you do not accept certain cookies, you may not be able to use some features of our Website.
3.7 List of the Cookies and Scripts we use:
| Cookie | Provider | Function | Period | Type |
|---|---|---|---|---|
| collect | google-analytics.com | Used to send data to Google Analytics about the device and the visitor’s behaviour. Tracks the visitor through the devices and promotional channels. | Session | Pixel Tracker |
| Mailchimp | mailchimp.com | Used to recognize when the newsletter subscriber has opened an email or clicked certain links. | Session | Cookie |
| youtube | youtube.com | Third-party cookies allowing us to upload videos on the Website. | Session | Cookie |
| twitter.com | Third-party cookies allowing us to display tweets on the Website. | Session | Cookie |
b) Why do we collect information through cookies (purpose) ?
3.8 We use cookies and the Personal Data collected:
- to make the functionalities of our Website available to you and to offer you additional functionalities,
- to improve the Website or our dedicated pages on social media,
- to speed up your searches,
- to compile behavioral and statistical information about uses of our Website or our dedicated pages on social media, in particular to estimate our audience size and usage patterns,
- to produce aggregate insights that do not identify you.
3.9 For information about the processing and use of the data by Google, Facebook, Twitter, Instagram, WhatsApp and LinkedIn, as well as related rights and settings options for the protection of your privacy, please refer to the privacy policy of the relevant provider.
c) Legal basis for processing
3.10 The purpose for implementing all of the above is to maintain and monitor the performance of our Website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 13(1) of the Swiss Federal Act on Data Protection (“FADP”) as well as article 6(1)(f) of the European General Data Protection Regulation (“GDPR”) as applicable, which allows us to process personal data when its necessary for the purpose of our legitimate interests.
3.11 In addition, cookies and other functionalities mentioned above which would go beyond the purposes of our legitimate interests (for example: Analytics Cookies), are implemented upon your acceptance through the means of our cookie banner.
C - Personal Data you provide us with
a) What Personal Data do you provide us with?
3.12 We collect Personal Data offered by you voluntarily when you browse on our Website or subscribe to our newsletters, including the “Daily Brief”.
3.13 The Personal Data collected may include:
- your first and last names;
- your e-mail address.
b) Why do we collect such Personal Data (purpose) ?
3.14 We use the Personal Data you provide us with in order to send you our newsletters, including the “Daily Brief”, as per your subscription, as well as to ensure a certain presentation, security and fluidity of our Website.
c) Legal basis for processing
3.15 The legal basis we rely on to process the Personal Data you provide us is article 13(1) of the FADP and article 6(1)(f) GDPR as applicable, which allows us to process personal data when the data subject has given consent to the processing of his or her personal data, as well as for the purpose of our legitimate interest.
4. Personal Data collected by Third parties (Links to other websites and Social Media
4.1 Where we provide links to websites of other organizations (such as the links provided in our newsletters, including the “Daily Brief”, to articles published by other organizations), this Privacy Policy does not cover how that organization processes your Personal Data. We encourage you to read the privacy policies related to the other websites you visit.
4.2 Our Website and our dedicated pages on social media contain links that direct you to the social networks such as Facebook, Twitter, Instagram and LinkedIn (the “Social network”) or to another website, in order to connect you with the content displayed in these platforms. When you access a Social network or another website via our Website or one of our dedicated pages on social media, responsibility for compliance with data protection is to be guaranteed by the respective providers.
4.3 If you establish a connection with the Social network of your choice or another website, your browser connects directly to the provider’s servers. Through this integration, the Social network or the other website receives the information that your browser previously accessed the corresponding page of our Website or our dedicated page on a social media, even if you do not have a profile or are currently not logged in to your account. This information (including your IP address) will be transmitted from your browser directly to a provider’s server and stored there. If you are logged in to your account, the provider can immediately assign the visit to our Website or our dedicated page on a social media to your profile. If you interact with the Website or our dedicated page on a social media, for example by clicking a "Like" or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.
4.4 If you establish a connection with the Social network of your choice or another website, your browser connects directly to the provider’s servers. Through this integration, the Social network or the other website receives the information that your browser previously accessed the corresponding page of our Website or our dedicated page on a social media, even if you do not have a profile or are currently not logged in to your account. This information (including your IP address) will be transmitted from your browser directly to a provider’s server and stored there. If you are logged in to your account, the provider can immediately assign the visit to our Website or our dedicated page on a social media to your profile. If you interact with the Website or our dedicated page on a social media, for example by clicking a "Like" or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.
4.5 For information about the purpose and scope of the data collection and the further processing and use of the data by the requested Social network or the other website, as well as related rights and settings options for the protection of your privacy, please refer to the privacy policy of the relevant provider.
5. Sharing your personal data with third parties
5.1 As noted above, we may compile usage statistics relating to our Website or our dedicated pages on social media based notably on your Personal Data.
5.2 Your Personal Data may be transferred to a successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is amongst the assets transferred.
5.3 We may give certain independent contractors and affiliates access to the Personal Data you made available to us through our Website or our dedicated pages on social media in order to assist us with the operation of our Website or our dedicated pages on social media, as well as data management and marketing activities.
5.4 We will take all necessary steps to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable laws. All those contractors are required to sign contracts in which they promise to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.
5.5 To date, we notably share your Personal Data with MailChimp, a company who manages our mailing lists for newsletter subscriptions and therefore has access to and stores the e-mail addresses of our subscribers.
5.6 The purpose for sharing your personal data to the above-mentioned third-party is to support our business and to maintain and to constantly look to improve our Website and the services it offers to our users. The legal basis we rely on to process your personal data is article 13(1) FADP and article 6(1)(f) GDPR as applicable, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
6. Transfer of your personal data with authorities
6.1 We may also transfer your Personal Data (including your communications) if we think it’s necessary for security purposes, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Website or our dedicated pages on social media. Hence, we may share or transfer your Personal Data to investigate, respond to and resolve complaints and issues relating to our Website or our dedicated pages on social media.
6.2 It is possible that we will need to disclose your Personal Data when required by law or if we have a good faith belief that disclosure is necessary to:
- investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies,
- investigate and defend ourselves against any third-party claims or allegations,
- protect the security or integrity of our Website or our dedicated pages on social media, or,
- exercise or protect the rights and safety of our users, personnel, or others.
6.3 We attempt to notify users about legal demands for their Personal Data when we deem appropriate and where technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, at our discretion, that the requests are too broad, vague or lack proper authority, however we do not guarantee to challenge every demand.
6.4 The purpose for sharing your personal data to the above-mentioned authorities is to support our obligation within the meaning of article 13(1) FADP and article 6(1)(c) GDPR as applicable, which allows us to process personal data when its necessary for compliance with a legal obligation to which we are subject.
7. No commercial disclosure of your personal data
7.1 We will not sell your Personal Data to third parties. We will not share or otherwise make available your Personal Data to third parties except as provided in this Privacy Policy.
8. How and where we store your personal data
8.1 We take data protection issues seriously and we have chosen to store your Personal Data on MailChimp’s servers, which are located in the United States of America.
9. Cross-border data transfer
9.1 For some of the third-party service providers, we may transfer your data to one of their databases outside Switzerland or the European Economic Area, potentially including countries which may not have an adequate level of protection for your Personal Data compared with that provided in Switzerland or the European Economic Area. In such event and unless provided otherwise in this Privacy Policy, we enter into agreements with such third-parties ensuring an adequate level of protection for your Personal Data.
9.2 By providing us with your Personal Data or by accepting analytics cookies, you agree that we may transfer, store and process your Personal Data outside of Switzerland and the European Economic Area – in particular in the USA – and acknowledge that governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
9.3 We notably share your Personal Data with MailChimp, a US-based company who manages our mailing lists for newsletter subscriptions and therefore has access to and stores the e-mail addresses of our subscribers, with whom we have entered into the EU Standard Contractual Clauses in order to transfer your Personal Data from Switzerland to the USA.
10. Cross-border data transfer
10.1 We exercise commercially reasonable efforts to prevent unauthorized exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (comprising administrative, physical, and technical safeguards) for managing unauthorized disclosure or exposure of your Personal Data.
10.2 In the event of a data breach, or in the event that we suspect a data breach, we will (i) do our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach, including without limitation by providing reasonable assistance to you in notifying injured third-parties. We will give you prompt access to such records related to a data breach as you may reasonably request; provided that we shall not be required to provide you with records belonging to, or compromising the security of, other users.
10.3 In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.
11. Cross-border data transfer
11.1 Right to access, update or to delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us at the following e-mail address: info@genevasolutions.news. Should you wish to simply unsubscribe from our newsletters, including the “Daily Brief”, click on the “unsubscribe” button located at the bottom of each newsletter.
11.2 Right of rectification: You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.
11.3 Right to object: You have the right to object to our processing of your Personal Data
11.4 Right of restriction: You have the right to request that we restrict the processing of your Personal Data.
11.5 Right to data portability: You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
11.6 Right to withdraw consent: You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data.
11.7 Right to complain to an Authority: You have the right to complain to a data protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or in Switzerland.
11.8 Please note that we may ask you to prove your identity before responding to requests based on the previous rights or somehow related to your Personal Data.
12. Retention of your Personal Data
12.1 We retain the Personal Data you provide to the extent necessary to provide you access to and use of our Website or our dedicated pages on social media and of their functionalities (such as access to our newsletters).
12.2 The storage period of cookies depends on their purpose and is the same for everyone.
12.3 We may retain de-personalized (anonymous) information after the deletion of your Personal Data.
13. Security of your personal data
13.1 The security of your Personal Data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use technical and organizational commercially acceptable means to protect your Personal Data against manipulation, partial or complete loss and unauthorized access by third party, we cannot guarantee its absolute security.
14. Personal data relating to children
14.1 We do not provide services directly to children or proactively collect their personal information.
15. Amendment of this Privacy Policy
15.1 We may change this Privacy Policy at any time by posting a new version on this page or on a successor page, without prior notification. If we make changes to this Policy, we will notify you through a notice on the Website home page. By continuing to access or use our Website or our dedicated pages on social media after such modifications become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Website and our dedicated pages on social media.
15.2 However, we will always handle your Personal Data in accordance with the Privacy Policy that was in effect at the time of collection.
15.3 The new version will become effective on the date it's posted, which will be listed at the top of the page as the new effective date.
16. Miscellaneous
16.1 Our failure to enforce any right or provision of this Privacy Policy will not be considered a waiver of those rights.
16.2 If any provision of this Privacy Policy is held to be invalid or unenforceable by a court, the remaining provisions of this Policy will remain in effect.
16.3 This Privacy Policy constitutes the entire agreement between us regarding the Privacy Policy of our Website and our dedicated pages on social media. It supersedes and replaces any prior agreements we might have between us regarding the privacy and cookie policy of our Website and our dedicated pages on social media.
17. Miscellaneous
17.1 Should you have questions or complaints regarding this Privacy Policy, please contact us online at info@genevasolutions.news.
17.2 You can also reach us at our headquarters by post at rue de Malatrex 50, 1201 Geneva, Switzerland.
17.3 Please further note that you have the right to lodge a complaint with the relevant supervisory authority should you consider that your Personal Data is not processed in accordance with this Privacy Policy or in compliance with applicable regulations.