Last update: September 1, 2024
1. PREAMBLE
In accordance with the Swiss Confederation’s new Federal Data Protection Act of September 25, 2020, and the provisions of European Regulation 2016/678 (the General Data Protection Regulation), Zzzest has established this Data Privacy Policy (hereinafter, the “Data Privacy Policy”).
Zzzest Sàrl (“Zzzest”, “we” or “us”) is a limited liability limited company organized under the laws of Switzerland with a principal place of business at Rue de la Corraterie 14, 1204 Geneva, Switzerland.
Zzzest acts, in relation to the processing operations mentioned in this notice, as a “data controller” in the meaning of the applicable new Federal Data Protection Act.
Zzzest is fully committed to protecting your privacy. This Data Privacy Policy addresses how we process and safeguard your personal data as a data controller, amongst others when you are interacting with us, in particular by visiting our website, contacting us, acquiring our services, subscribing to our newsletters, or taking part in our events.
For any question or concern regarding this Data Privacy Policy, you can directly contact:
Zzzest Sàrl
Data Privacy
Rue de la Corraterie 14
1204 Genève
Switzerland
2. PROCESSING OF PERSONAL DATA
Zzzest applies the minimization principle across all processing of personal data, and therefore only processes data required for the pursued purposes or legitimate interests.
The personal data processed by Zzzest in the context of its activities may be communicated directly by you (for example when you contact us, subscribe to our newsletters, or when you register for and/or participate in our events), originate from your purchase of our services (e.g. identification of authorized signatories of our contractual documents), or may be obtained by us if your data is available in the public domain (for example your company’s website).
The following personal data are processed by Zzzest for the indicated purposes:
| General scope | Categories of collected personal data | Purpose for data collection and legal basis |
| Usage Data Usage of Zzzest website : We may process data about your use of our website. | Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Zzzest website. The source of the usage data is our analytics tracking system. | Usage Data may be processed for the purposes of analysing the use of the website and to improve our service offering. The legal basis for collecting and processing Usage Data is our legitimate interests. |
| Contact Data | The contact data includes your first and last name, phone number and email address. | We use Contact Data such as your first name and last name, phone number and email to enable to identify you as a Client or as a Supplier (or a representative of a Client or Supplier) of Zzzest, to authorize you to log in to select Zzzest website portals and use the portals’ features, to ensure the security of our website and services, to maintain back-ups of our databases, and to communicate with you regarding the services offered to you or by you, or any new service offerings that may be of interest to you. The legal basis for collecting and processing Contact Data is consent provided by you, the execution of a contract and our legitimate interests. |
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. DATA DISCLOSURES AND TRANSFER
Zzzest transfers personal data to:
| Type of transfer | Categories of data | International transfers | Applicable safeguards |
| Transfer to Zzzest Contractors and Suppliers | Zzzest uses Contractors and Suppliers to provide its services. In order to execute the contract, these Contractors and Suppliers may need to obtain certain personal data from our Clients and/or other Suppliers. Only minimal data will be shared on a need-to-know basis to Contractors and Suppliers that are bound by data privacy laws and regulations or agreements that are at least as restrictive as Zzzest’s own obligations towards the owner of the personal data (data subject). | Zzzest’s Contractors and Suppliers may be located outside of Switzerland. | Data processing agreements or equivalent For international transfers to non-adequate countries: – Formal review of the service-provider; – Signed Standard Contractual Clauses (SCCs); – Swiss appendix to the SCCs. |
| Transfer to insurers and/or professional advisers | All categories in scope of this Policy, on a strict need-to-know basis, with the purpose of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or to ensure compliance with a legal obligation to which we are subject. | Zzzest’s insurers and/or professional advisers may be located outside of Switzerland. | Data processing agreements or equivalent For international transfers to non-adequate countries: – Formal review of the service-provider; – Signed Standard Contractual Clauses (SCCs); – Swiss appendix to the SCCs. |
| Transfer to third-party payment service providers | All categories in scope of this Policy, on a strict need-to-know basis, with the purpose of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. | Zzzest’s payment service providers may be located outside of Switzerland. | Data processing agreements or equivalent For international transfers to non-adequate countries: – Formal review of the service-provider; – Signed Standard Contractual Clauses (SCCs); – Swiss appendix to the SCCs. |
| Transfer to hosting facilities | All categories in scope of this Policy. | The hosting facilities for our website and servers are situated in [the USA (Virginia), Canada (Montreal), Ireland (Dublin), UK (London), Singapore (Singapore), Australia (Sydney), Brazil (San Paolo), Japan (Tokyo), United Arab Emirates (Dubai).] | Data processing agreements or equivalent For international transfers to non-adequate countries: – Formal review of the service-provider; – Signed Standard Contractual Clauses (SCCs); – Swiss appendix to the SCCs. |
4. YOUR RIGHTS
You can at any time request access to, correction of and deletion of your personal data, by contacting DataPrivacy@Zzzest.com. Such rights may be limited by our legal obligations.
Whenever data processing activities are based on your consent, you may at any time withdraw it. You may also, in other situations, have the right to object to the processing of your personal data.
In relation to the newsletters, you can at any time consult, edit, revise and correct your data (email, name, preferences) using a link in the footer of the email, as well as unsubscribe.
5. SECURITY
We take the security of your personal data very seriously and implement technical and organizational measures to protect your personal data from unauthorized access, improper use, disclosure, loss or destruction.
6. RETENTION AND DELETION OF PERSONAL DATA
Your personal data shall not be kept for longer than is necessary for the specific processing purposes as stated above.
We will retain your personal data as follows:
- (a) Your name and e-mail will be retained for a minimum period of three years after the end of the year during which our collaboration with you has ended or during which we had a last contact with you.
- (b) Any systems-related personal data will be destroyed as soon as the purpose of the data processing activity has been achieved.
- Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
7. COOKIES
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use cookies for the following purposes:
- (a) Authentication – we use cookies to identify you when you visit our website and login to Zzzest as well as while navigating our website;
- (b) Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our service providers: Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about websites using cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/
8. POLICY UPDATES
We may occasionally update this policy by publishing a new version on our websites, and may notify you of changes to this policy via email.