Privacy policy

Elephants SAGL, a company registered under the laws of Switzerland, with registered address Via Mercoli 3, 6900 Lugano, ("Company") collects personal data (as defined below) in accordance with applicable laws and regulations, in particular the Swiss Federal Act on Data Protection ("FADP") and the General Data Protection Regulation (EU/2016/679) (General Data Protection Regulation, "GDPR"), both defined as "privacy regulations".

Definitions 

In accordance with the privacy regulations, the terms below have different meanings: 

"Personal Data" includes any information relating to an identified or identifiable natural or legal person; 

"Processing" shall mean any operation or set of operations, whether or not by automatic means, which applies to (groups of) personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, diffusion, communication by transmission, dissemination or any other form of disclosure, alignment or combination, restriction, erasure or destruction.

The "Navigation data" are acquired by the computer systems and procedural software used to operate this site during their normal operation. This is personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the type of request, the size of the outgoing packet, the status of the response given by the server (received, error, etc.) and other parameters relating to the operating system.

"Personal Data" includes any information relating to an identified or identifiable natural or legal person; 

"Processing" shall mean any operation or set of operations, whether or not by automatic means, which applies to (groups of) personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, diffusion, communication by transmission, dissemination or any other form of disclosure, alignment or combination, restriction, erasure or destruction.

The "Navigation data" are acquired by the computer systems and procedural software used to operate this site during their normal operation. This is personal data whose transmission is implicit in the use of Internet communication protocols. This category includes IP addresses, addresses in URI/URL (Uniform Resource Identifier/Locator) notation, the time of the request, the type of request, the size of the outgoing packet, the status of the response given by the server (received, error, etc.) and other parameters relating to the operating system.

Data Controller 

The data controller is the Company.

Type of personal data acquired, purpose, legal basis and data retention 

The data are collected and managed for the purposes and within the times indicated below:

Data	Mode of data acquisition	Purpose of the treatment	Legal basis of the treatment	Data retention time
Technical data, such as IP address, browser characteristics (type, language, installed plug-ins, etc.)	Automatic during the platform visit	Visit of the platform by the user	Predominant private interest	During the website visit
Identity information such as name, email address	Entered by the user when registering for the platform or using the contact forms	Registration of personal data for accounting reasons	Fulfilment of contractual obligations	Until cancellation request
E-mail	Entered by the user	Newsletter registration	Predominant private interest	Until cancellation request
System information such as: Operating System information, Installed software, Hardware information	Automatic during the platform usage	Detection of system requirements	Fulfilment of contractual obligations	Until cancellation request
User platform usage	Automatic during the platform usage	Internal data analytics	Fulfilment of contractual obligations	Until cancellation request

The platform is not designed to store "special categories", including race or ethnicity, religious or philosophical beliefs, life and sexual orientation, political opinions, trade union membership, health status information. We do not use tracking cookies and do not monitor user behaviour within the site.

To whom will the data collected be communicated? 

We will only disclose your personal data if we are obliged to do so in order to comply with our legal or regulatory obligations, for business or administrative reasons or because you have asked us to do so. This probably also includes disclosure: 

• within the Company;
• to third parties who process personal data on our behalf (IT system providers and other service providers);
• to any government, regulatory agency, enforcement or exchange body or court that so requires under applicable law or regulation.

How we protect your personal data 

The security of your personal data is important to us, and we use various technical and organisational measures to protect it. We are committed to safeguarding and protecting personal data by taking appropriate measures against accidental or unlawful destruction, loss, alteration or unauthorised disclosure.

Rights of the interested parties 

Under the privacy regulations, users have a number of rights in relation to their personal data. They have the right to request access, correction or deletion of such information, the right to limit or oppose the processing and, under certain circumstances, the right to data portability. If a user has given his or her consent to the processing of his or her data, he or she has the right (under certain circumstances) to revoke this consent at any time. If you wish to exercise the above rights, please send an e-mail to info@elephantsclub.io. We try to answer you within a maximum of one month, although we reserve the right to extend this period for more complex requests. We also reserve the right to charge a reasonable administration fee for any manifestly unfounded or excessive requests for access to personal data and for any additional copies of personal data requested.