Privacy policy

Privacy policy

24.10.2019

Loyco SA (hereinafter “Loyco”) is a company with its registered office at 8 rue Jacques-Grosselin, 1227 Carouge – Geneva, Switzerland.

Loyco is committed to respecting your privacy and complying with the provisions of the Swiss Data Protection Act (DPA) and the EU’s General Data Protection Regulation (GDPR).

This Privacy Policy describes how Loyco collects, uses, transfers and stores Personal Data (defined below in section 1.1) when using our services (the “Services”) and/or our website (the “Website”) and/or our platform (the “Platform”) and informs you of your rights (hereinafter the “Privacy Policy”). If you have a question or request, please send us an e-mail at info@loyco.ch.

This Privacy Policy is in addition to any customer confidentiality obligations we may have to you. Please refer to our terms and conditions applicable to your engagement for more detailed information regarding confidentiality.

By using our Services and Website, you expressly consent to Loyco collecting and processing your Personal Data (as defined below) in accordance with this Privacy Policy.

1. The information we collect

1.1 Personal data

The data collected by Loyco includes all information necessary for Loyco to fulfil all its contractual and legal obligations (“Personal Data”).

  • Personal identifying information, including: first name, last name, date of birth, gender, address, e-mail, telephone numbers, nationality, country of citizenship, residence, identity documents. Personal Data includes any document you provide to us, such as a copy of your passport;
  • Information on relevant family members and business relations ;
  • Education, professional qualifications, employment and professional information, references ;
  • Wage and tax data ;
  • Health data ;
  • Bank details ;
  • Information collected by our Website, as described below (see point 1.3).

1.2 Sources

Personal Data are collected at different times and from different sources:

  • When you or your organization/company contact us to review or request our services;
  • Information collected by our team as part of contractual obligations ;
  • By e-mail, fax or telephone ;
  • Our website.

1.3 Cookies, visit tracking and similar techniques

1.3.1 In order to optimize your experience on the website, cookies or similar tracking techniques may be used. These are small files saved in the Internet browser that store certain information and data for exchange with the Loyco system. They are not used to store your personal data.

You can refuse the use of cookies in your browser settings. We draw your attention to the fact that by deactivating cookies, you may not have access to all the functionalities of the Website.

1.3.2 The Website uses Google Analytics, a service provided by Google Inc. based in the United States of America. Google Analytics is a tool that analyzes the use of the website. This tool may use cookies to collect anonymous information and generate reports on website usage statistics without the User being personally identifiable to Google. The information generated by these cookies (including the user’s IP address) may be sent to and stored on Google servers in the United States of America. Google complies with the data protection requirements of the Privacy Shield framework between Switzerland and the United States and is registered with the US Department of Commerce’s Privacy Shield program. If you do not wish Google Analytics to record your visit data, you can install an extension on your browser to deactivate Google Analytics.

1.3.3 Please note that the Website also uses third-party services such as the aforementioned Google Analytics tool or Mix Panel, Hotjar and others.

By using the Website, you consent to the processing of data about you by Google, Google Analytics, Mix Panel, Hotjar and others in accordance with the above privacy policy and Google’s privacy policy. You admit that Loyco accepts no responsibility for this process.

1.3.4 The Website may use social plug-ins for various social networking sites (hereinafter referred to as a “Social Network”) such as facebook.com (operated by Facebook, Inc.), twitter.com (operated by Twitter, Inc.) and plus.google.com (operated by Google, Inc.) (hereinafter referred to as the “Plug-ins”). When the User visits a website containing plug-ins, the User’s browser connects directly to the servers of the relevant Social Network. The content of the plug-in is transmitted directly to the User’s browser from each Social Network and is integrated into the Website. By integrating the Plug-in, the Social Network receives information that the User has visited the Website.
If you are connected to a Social Network, it may associate your visit with the account of the Social Network concerned. If you interact with the plug-in, the corresponding information from your browser is sent directly to the relevant Social Network and stored there.

For more information about the purpose and scope of data collection, data processing and use by the Social Network concerned, as well as your rights and how to protect your privacy, please consult the privacy policy of each Social Network.

2. Why we collect and process your Personal Data

Personal Data collected and processed by LOYCO may be used for :
(i) Contacting you ;
(ii) Identify yourself ;
(iii) To fulfill our contractual obligations to you or your organization/company and, in this context, to provide relevant information to third parties or authorities;
(iv) Carry out administrative or operational processes within Loyco ;
(v) Handle and respond to requests, questions or complaints received from you or any other person within your organization/company;
(vi) Manage and administer your or your organization’s/company’s business relationship with Loyco, including payment processing and invoicing;
(vii) Comply with any legal obligation on Loyco to process Personal Data, for example record keeping for legal purposes (tax, company law);
(viii) To provide, monitor and improve Loyco’s services;
(ix) Send newsletters and promotional material ;
(x) Monitor the use of the Website;
(xi) Responding to any request or discharging any obligation to public authorities, law enforcement agencies, regulatory bodies and judicial bodies;
(xii) To establish, exercise or defend Loyco’s legal rights or in legal proceedings;
(xiii) For any other legitimate business interest or higher interest of Loyco ;

3. Information sharing, access and transfer

3.1 Loyco access

Loyco’s management and employees may access your Personal Data in order to comply with Loyco’s contractual and legal obligations.

3.2 Access by third parties, public authorities and organizations

In order to fulfill its contractual obligations, Loyco must communicate Personal Data to third parties, authorities and public bodies (in particular in tax and insurance matters) in Switzerland, including sensitive data such as your health information if necessary. You hereby consent to such transfers.

3.3 Access by service providers, business partners and other persons

You hereby expressly authorize Loyco to use service providers and to delegate certain tasks (such as IT services and infrastructure, server hosting, maintenance and other services) to third parties. In addition, you expressly authorize Loyco to transfer Personal Data to third parties in the event of a merger, sale, liquidation or transfer of all or part of Loyco’s assets. This implies that Personal Data may be communicated to such companies outside Switzerland.

In this context, we hereby inform you that certain jurisdictions do not have legislation ensuring an adequate degree of protection within the meaning of the Swiss Federal Data Protection Act. If the User’s Personal Data is to be shared with such companies and if the other conditions of the DPA and/or the RGPD are not met, LOYCO will request your consent.

Loyco will never sell your personal data to third parties.

3.4 Compliance with applicable laws and official requests; Loyco’s best interests

LOYCO may transfer Personal Data to third parties such as Swiss or foreign public authorities, law enforcement agencies, regulatory bodies or judicial bodies where such transfer is reasonably necessary to comply with the provisions of the law or a compelling legal request or to protect an overriding interest of LOYCO.

4. Storage and safety

Your Personal Data is entered into our electronic systems and paper files, processed and stored both physically and electronically on servers located in Switzerland.

We take all reasonable and necessary steps to ensure that your Personal Data is processed and stored securely in accordance with this Privacy Policy. Loyco implements the appropriate administrative, technical and physical measures reasonably necessary to protect the confidentiality, integrity and availability of your Personal Data.

5. Retention of Personal Data

We retain your Personal Data for as long as is necessary for the purposes set out above, in order to provide our Services and to fulfil our contractual and legal obligations (e.g. our reporting and accounting obligations).

If Personal Data is no longer required to fulfill our contractual obligations, it will be returned or deleted unless it is required to comply with a legal obligation, in particular tax and commercial law retention obligations. This includes in particular the Swiss Code of Obligations, the Swiss Anti-Money Laundering Act, the Swiss VAT Act and Swiss tax legislation.

Personal data collected via cookies and other tracking, analysis and other data is stored for 24 hours.

6. Your rights

You have a right of access under Article 8 of the DPA (Article 15 of the RGPD), a right of rectification where the information we hold about you is inaccurate under Article 5 of the DPA (Article 16 of the RGPD), a right to request the deletion of your Personal Data under Article 5 of the DPA (Article 17 of the RGPD) or the restriction of the use of your personal information under Articles 12, 13 and 15 of the DPA (Article 18 of the GDPR), a right to object to the processing of your Personal Data under Article 4 of the DPA (Article 21 of the GDPR) and, finally, a right to data portability under Article 20 of the GDPR. You can also lodge a complaint with the competent data protection authority in the event of a problem (Article 77 of the GDPR).

If you have a question or request, please send us an e-mail at info@loyco.ch.

You may withdraw your consent at any time. Please note that this withdrawal of consent applies only to subsequent collection/processing of your Personal Data and does not affect any collection/processing carried out in the past. It should be noted that Loyco retains the right to process your Personal Data in the event of a legal obligation or in Loyco’s best interests, including in order to exercise its own legal rights. Withdrawal of your consent may terminate your business relationship with Loyco.

7. Miscellaneous

Please inform us as soon as possible of any changes to your Personal Data (including your correspondence details). Failure to provide accurate information or to update information when it changes may hinder our ability to provide our services.

You are responsible for the accuracy and completeness of the data provided to Loyco, and you are required to provide updates if your Personal Data changes.

Loyco cannot be held responsible for any situation caused by its possession of inaccurate, incomplete, false or otherwise deficient personal data communicated to us by you or by a third party.

This Privacy Policy may be modified at any time. Loyco will inform you of any changes.