Privacy Policy

Dismart Sagl (hereinafter: “XDSone”)

Registered seat: Via luganetto 4 | 6962 | Viganello (Switzerland)

E-mail: support@xdsone.com

Websites: xdsone.com 

Contact details of the data protection officer: privacy@XDSone.com.

The data controller under the General Data Protection Regulation (EU) 2016/679 (“GDPR“) is XDSone (the “Privacy Policy”).

XDSone has prepared this Privacy Policy to describe to you our practices regarding the Personal Data we collect from users of our website and our app (the “Platforms”) and online services (collectively, the “Service”).

By accessing and using our Platforms and/or Service you agree to our Privacy Policy. If you don’t agree to our Privacy Policy, you cannot and should not access our Platforms or use our Service. Our Privacy Policy is subject to change at any time for any reason, such as changes in the law and changes in technology, or at our sole discretion. You are responsible for regularly reviewing the Privacy Policy that appears on the Platforms. Our Privacy Policy becomes effective and immediately binding upon being posted on the website and apps.

1. Personal data which is processed

We may collect, receive, use, store and transfer the following kinds of personal data about you:

• Identity or Contact Data such as name, address, e-mail address, telephone number, date of birth, username or similar identifier, title, gender.
• Technical Data including details about the devices and technology you use including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platform or Service.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties including your communication preferences.
• Information about disputes/complaints.

Further data which may be processed through technological tools:

• Log files: IP addresses, browser type, type of device, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.
• Pixel Tag: we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are very small graphic images with a unique identifier that are used to track online movements of Web users. Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
• Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our service. This includes third party analytics services, that we engage to help analyze how users use the Service. The information received from Analytics services is solely used to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at the address given above.

We use different methods to collect data about you including:

• By phone, post, email, or online;
• By use of or access to our websites or device applications;
• By emails, letters and other correspondence;
• By surveys or when you give us feedback; and
• When you request marketing to be sent to you by us or selected third parties.

We may automatically collect Technical Data as well as employ the use of cookies and similar technologies.

2. Purpose of the data processing

• The primary objective of the data processing is for XDSone to be able to provide you an efficient Service and improve our website and products/services (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with our regulatory obligations and hosting of data).
• We may use the contact details to notify you for security, fraud protection or support and maintenance updates. 
• Customer support data is collected on a case-by-case basis and stored for the purpose of resolving disputes and service quality issues.
• If you have consented to it, we may send you our newsletter to keep you updated on the development of XDSone and the Services and marketing material subject to the conditions established below.
• In case you lodge a complaint through the Platforms or otherwise, we process the latter and run an investigation. 

3. Legal Basis for the data processing

• Personal data is processed in order to provide the Service contracted with us. We collect and process the personal data submitted in the course of the use of our Service.
• Personal data may be also processed on the ground of legitimate interest, for example in investigating and detecting fraudulent behaviour.
• The legal basis for the data processing related to marketing purposes is the consent explicitly provided for by the passenger via the Platforms.

4. Recipients of the personal data

As part of providing you with our services and running our business, we may disclose your personal information to:

• Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries as reasonably necessary for the purposes, and on the legal basis, detailed in this policy;
• Our agents, advisors and business partners who we use to help manage our services, improve services and resolve issues such as legal disputes;
• Government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law;
• Any party linked with you or your business’s products or services;
• Organizations we introduce you to for marketing purposes; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may disclose your personal information to the above mentioned third parties:

• If we are under a duty to disclose or share your personal data in order to comply with a specific legal obligation; and
• To enable us to run our website and offer our services to you.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

This Privacy Policy only applies to the Platforms and Service it does not apply to third-party websites, plug-ins and applications that have been linked to or from or are redirected to whether or not such a link or redirection is authorised by us. Visiting or using any third-party websites, plug ins or applications is done so at your own risk and we are not responsible for the results or their privacy policy. 

5. Data processors, Security and Access

• We may use the platforms of our contractual partners to investigate and to respond to relevant complaints. 
• Only the authorized employees of XDSone, and the authorized employees of contractual partners, can access personal data, to the extent necessary to comply with requests of the users in connection with the Services. 
• Geolocation data is processed in anonymised form.
• For research and scientific purposes, the data is used in unidentified form (anonymized).

6. Access, correction and restriction 

• You can access and update your personal data via the Platforms.
• You can request information related to your personal data, in which case we will provide information in connection with the categories of personal data concerned, the purposes of the processing, the period for which the personal data is stored, your rights related to data processing and your rights to lodge a complaint with the supervisory Authority in charge (hereinafter: “Authority”). 
• You are entitled to request the restriction of the processing of your personal data according to Article 18 of GDPR, also where we no longer need your personal data for the purpose of processing, but they are required by you for the establishment, exercise or defence of legal claims.

7. Retention of personal data 

• Your personal data will be stored by XDSone as long as you have an active account. If your account is closed, personal data will be deleted (according to the policies set out in this section), unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
• In the event that there are suspicions of criminal offence, fraud or false information having been provided, the data will be stored for 10 years in order to hinder the renewed registration of the person who acted unlawfully. 
• In case of payment disputes, personal data will be retained until the dispute has been resolved or until the statute of limitation of the claim has elapsed (in principle for 5 years).

8. Deletion

• You should also bear in mind that any request to delete your personal data is handled by XDSone and possible only if your account is also deleted. As a result of that you will not be able to use our Services.
• We respond to any request to delete personal data submitted by e-mail within a month and will specify the period of data deletion.
• In case we are required to store personal data pursuant to a legal obligation, we will not be able to comply with your request for deletion. 

9. Portability

• We will respond to any request for transfer of personal data submitted by e-mail within a month and specify when the data transfer will take place. After we have verified the identity of the user in question, we will provide you with your personal data.

10. Direct marketing and sweepstakes

• We will only use your e-mail address to send direct marketing messages if you have given us the permission to do so via our Platforms. 
• If you no longer wish to receive direct marketing messages, please click the “Unsubscribe” link in the footer of our e-mail or change the settings related to direct marketing in the Platforms.
• We may direct to you marketing campaigns that contain gifts, sweepstakes and other marketing or promotional materials of our partners.

11. Data Security

There are appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a business based requirement to do so. They will only process personal data on our instructions and they are subject to a duty of confidentiality. There are in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Dispute resolution and remedies

• Disputes relating to the processing of personal data are resolved through customer support (info@XDSone.com) or by contacting XDSone’s Data Protection Officer (privacy@XDSone.com).
• In case you believe that the data processing is unlawful, you are entitled to start the procedure before the competent National Authority. For users resident in the European Union, you can find the list and contacts of EU National Data Protection Authorities here.