This privacy statement was last updated on February 28, 2023 and applies to citizens and legal permanent residents of the European Economic Area and Switzerland.
The current privacy statement outlines our procedures for data processing of personal data obtained through https://codeway.ch. It is highly recommended that individuals thoroughly review this statement. Our data processing activities are executed in compliance with relevant privacy legislation.
Our practices are characterized by:
- The transparent articulation of the objectives for which personal data is processed, which is accomplished through this privacy statement;
- The restriction of personal data collection to that which is necessary for valid purposes;
- The acquisition of explicit consent from individuals prior to processing their personal data in circumstances where such consent is required;
- The implementation of appropriate security measures to safeguard personal data, as well as the stipulation of these measures for third parties that process personal data on our behalf;
- The recognition of individuals' rights to access their personal data or have it amended or erased, upon request.
If you have any questions, or want to know exactly what data we keep of you, please contact us.
Owner and Data Controller
Codeway SaglVia Maestri Comacini, 8, 6830 Chiasso (TI), SwitzerlandOwner contact email: email@example.com
Types of Data collected
Personal Data may be voluntarily provided by the User or collected automatically while utilizing this Website, in the case of Usage Data. Unless otherwise stated, all Data requested by this Website is mandatory, and the absence of such Data may render it impossible for this Website to provide its services. In instances where this Website specifies that some Data is non-mandatory, Users are free to withhold the Data without affecting the availability or performance of the Service. Users who are unsure of which Personal Data is obligatory are advised to contact the Owner.
Mode and place of processing the Data
Methods of processing
The Owner of this Website employs adequate security measures to prevent unauthorised access, disclosure, modification, or destruction of the Data. The processing of Data is performed using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the specified purposes. In addition to the Owner, the Data may be accessible to certain persons in charge, such as administrators, sales and marketing personnel, legal and system administrators, or external parties, such as third-party technical service providers, mail carriers, hosting providers, IT companies, or communications agencies, who may be appointed as Data Processors by the Owner, if necessary. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The processing of Personal Data by the Owner is based on one or more of the following legal bases:
- Users have provided their consent for one or more specific purposes, in accordance with applicable laws. It should be noted that, under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other legal basis. However, this does not apply whenever the processing of Personal Data is subject to European data protection law;
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which the Owner is subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party, in accordance with applicable laws.
The Owner is willing to assist in clarifying the specific legal basis that is applicable to the processing of Personal Data. This includes determining whether the provision of Personal Data is mandatory due to a legal or contractual obligation or is necessary to enter into a contract.
The Data undergoes processing at the operating offices of the Owner and at any other location where the parties involved in the processing are situated.
Depending on the User's location, data transfers may involve the transfer of the User's Data to a country other than their own. Users can check the section that contains details about the processing of Personal Data to learn more about the location of such transferred Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or by inquiring with the Owner using the information provided in the contact section.
Personal Data will be processed and stored for the duration required for the purpose for which it was collected. Hence, the following applies:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be kept until the contract has been fully executed;
- Personal Data collected for the purposes of the Owner's legitimate interests shall be retained for as long as necessary to fulfill such purposes. Users may obtain specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may retain Personal Data for a more extended period if the User has given their consent to such processing, provided that such consent is not withdrawn. Additionally, the Owner may be obligated to retain Personal Data for a more extended period when necessary to comply with a legal obligation or an order from an authority.
Once the retention period has elapsed, Personal Data will be erased. As a result, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the retention period has expired.
The purposes of processing
The collection of User data is carried out by the Owner for the purpose of providing the Service, fulfilling legal obligations, responding to enforcement requests, protecting its rights and interests, as well as those of Users or third parties, detecting malicious or fraudulent activity, and conducting Analytics, Displaying content from external platforms, Contacting the User, SPAM protection, and Tag Management. For a detailed description of the Personal Data processed for each purpose, Users may refer to the section titled "Detailed information on the processing of Personal Data".
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a free service that safeguards websites from spam and abuse. It employs sophisticated risk analysis methods to differentiate between humans and automated bots.
Contacting the User
Contact form (this Website)By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.Personal Data processed: email address; first name; last name; curriculum vitae or other files uploaded by the User
The rights of Users
Users are entitled to exercise certain rights with respect to their Personal Data processed by the Owner. Specifically, Users have the following rights:
- The right to withdraw their consent at any time. Users have the right to withdraw their previously given consent for the processing of their Personal Data;
- The right to object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is based on a legal basis other than consent. Further details are provided in the dedicated section below;
- The right to access their Data. Users have the right to know if their Data is being processed by the Owner, obtain information regarding certain aspects of the processing, and receive a copy of the Data being processed;
- The right to verify and rectify their Data. Users have the right to verify the accuracy of their Data and request for it to be updated or corrected;
- The right to restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In such cases, the Owner will only store the Data and not process it for any other purpose;
- The right to have their Personal Data erased or removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner;
- The right to receive their Data and transfer it to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision applies when the Data is processed by automated means and when the processing is based on the User's consent, on a contract which the User is part of, or on pre-contractual obligations thereof;
- The right to lodge a complaint. Users have the right to file a complaint before their competent data protection authority.
Details about the right to object to processing
In cases where Personal Data is processed for public interest, exercise of official authority vested in the Owner, or for legitimate interests pursued by the Owner, Users have the right to object to such processing by providing a ground related to their particular situation to justify the objection. Users should be aware that, in case their Personal Data is processed for direct marketing purposes, they have the right to object to such processing at any time without the need to provide any justification. Users may refer to the relevant sections of this document to learn whether the Owner is processing Personal Data for direct marketing purposes.
How to exercise these rights
Users may submit requests to exercise their rights regarding their Personal Data by contacting the Owner through the contact details provided in this document. These requests are free of charge and will be addressed by the Owner as expeditiously as possible and always within one month.
Cookies and similar technologies are tiny text documents or code fragments that often contain a unique identification code. When a user visits a website or uses a mobile application, a computer requests permission to store this file on their computer or mobile device and obtain access to information. The information collected through cookies and similar technologies may include the date and time of the visit and how the user interacts with a particular website or mobile application.
Cookies are necessary for the following reasons: (a) to provide and monitor the effectiveness of our Service; (b) to diagnose or fix technology problems.
Additional information about Data collection and processing
The Owner may use the User's Personal Data for legal purposes, including in court or in the stages leading to possible legal action resulting from the improper use of this Website or related Services. The User is aware that the Owner may be obligated to disclose personal data upon request by public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operational and maintenance purposes, this Website and third-party services may collect files that record interactions with this Website (System logs) and use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
Additional details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Contact information is provided at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To find out if any third-party services used by this Website support such requests, Users should review the privacy policies of those services.