At Klap Solutions, we recognise the importance of your privacy and transparency in our handling of your personal data.
This Privacy Policy describes how we collect and process the personal data of any user of (i) the website accessible at https://www.klapsolutions.com/ (the “Website”) and (ii) the services associated with it, in particular the services related to the sale of health protections (the “Services”).
When you provide information or download material from the Website, you acknowledge the processing of your personal data in accordance with this Privacy Policy.
1. Data Processor
Klap Suisse SA (CHE – CHE-393.409.045), Place Cornavin 3, 1201 Geneva, Switzerland, is the data controller of your personal data collected on the Website and in the course of providing the Services, subject to the discussion in the paragraph below and in Section 4.
If you believe that your personal data has been used in a way that is not in accordance with this Privacy Policy, or if you have any questions about our processing of your personal data, please contact us by mail at the above address.
2. On what legal grounds do we collect your personal data?
We only process your personal data if we have a valid legal basis to do so. Depending on the processing, we will only process your personal data if:
- we have obtained your prior consent;
- the processing is necessary to perform our contractual obligations to you;
- processing is necessary to comply with our legal or regulatory obligations;
- processing is necessary for the protection of our legitimate interests, unless these are overridden by your interests, freedoms or fundamental rights. Our “legitimate interests” include being able to (i) provide our professional services; (ii) obtain cost-effective services (for example, we may choose to use certain services offered by suppliers instead of others); and (iii) protect the security of our computer systems and networks.
3. What types of personal data do we process and for what purposes?
We process personal data that is necessary for the purposes set out in this Privacy Policy (see below), only to the extent relevant to achieving those purposes. To the extent permitted by law, we may process sensitive personal data, such as health-related data. We will only do so to the extent strictly necessary for the purposes listed below.
FOR YOUR REGISTRATION ON THE WEBSITE AND THE MANAGEMENT OF THE SERVICES
a) CATEGORIES OF PERSONAL DATA CONCERNED
We process the personal data you provide to us when you use the Website and the Services linked to it, namely:
| Contact details | Surname, first name, postcode, country, email address, telephone number |
| Other identifying data | Civility |
The data fields marked with a red frame or an asterisk (*) are mandatory. Without this data, we cannot provide you with access to the Services. Some data are optional, depending on the Service chosen, and you can access the Services without completing them.
b) PURPOSES OF PROCESSING
Your personal data is collected and processed for the purpose of operating the Website and/or providing you with the Services. Our purposes are as follows:
- to contact you about our Services;
- to interact with you, for example to answer your questions;
- to offer you new products and services in the future;
- to enable us to carry out internal analysis and statistics (including customer satisfaction surveys or similar) to improve the Website and the Services.
Other purposes may be specified at the time of collection of your personal data.
3.1 TO COMPLY WITH OUR LEGAL OBLIGATIONS
We may process your personal data to comply with our legal obligations. This may be the case if we are required to disclose certain information to the authorities or retain such information for tax, accounting or legal purposes.
3.2 IF WE HAVE OBTAINED YOUR CONSENT
We may also process your personal data if we have obtained your prior consent for specific purposes.
You may withdraw your consent at any time, which will not affect the validity of the processing of your personal data carried out prior to the withdrawal.
3.3 FOR STATISTICAL PURPOSES AND TO IMPROVE OUR WEBSITE
We may automatically collect analytical data on the use of the Website and the Services, including through the use of cookies. You will find more detailed information on the use of cookies in section 8 below.
We use this data for statistical purposes and to improve our Website. We do not use this data to identify you directly and do not cross-reference it with other data.
4. Who has access to personal data and with whom is it shared?
We may disclose your personal data in order to comply with our legal obligations if required to do so by law or by an authority.
Your personal data relating to your use of the Website may be disclosed to third parties where this is necessary for the operation of the Website, including our contractors providing services in relation to the Website, for example IT service providers (including cloud computing providers) who assist us in managing the Website and providing the Services.
5. Processing methods and security
We process your personal data in accordance with the Swiss Federal Data Protection Act (DPA) and the General Data Protection Regulation (GDPR). Data processing is carried out with the help of computers or IT tools and in accordance with the purposes indicated in this Privacy Policy.
We do not make decisions exclusively on the basis of automated processing that has legal effects on or significantly affects the data subject (automated individual decision) and do not use profiling systems via the Website. We maintain appropriate physical, technical and procedural measures to secure your personal data and we encrypt personal data where it is stored.
Although we take appropriate steps to protect your personal data, no system is completely secure. We do not and cannot guarantee the absolute security, integrity or confidentiality of any electronic communication or other electronic processing of data, even if such data is encrypted.
6. International transfers
We store your personal data on servers located in Switzerland and the European Union that are under the control of our company or our subcontractors.
As a general principle, we do not transfer or make available your personal data to other countries (outside Switzerland and the European Union). To the extent that your personal data needs to be transferred, or become accessible, outside of Switzerland or the European Union due to the technical or operational infrastructure of our chosen suppliers, we will ensure that such transfer or access complies with the Swiss Federal Data Protection Act (DPA) as well as the General Data Protection Regulation (GDPR) and will put in place the appropriate safeguards required (e.g. by relying on the standard clauses adopted by the European Commission). You can contact us (see section 1) for more information on this subject.
7. Duration of storage
Your personal data is retained for as long as necessary to fulfil the purposes for which it was collected.
We delete or anonymise personal data as soon as it is no longer necessary for the purposes of this Privacy Policy or at your request.
Please be aware that the independent data processors with whom we share your personal data (see section 4 above) may retain your personal data for a longer period of time for their own purposes. We recommend that you read their data protection policies carefully for any information relating to the processing they carry out in relation to your personal data.
8. Cookies and how we use them
We use various types of cookies, analytical tools, or other similar technologies, which may automatically process analytical data directly on your devices and/or transfer personal data about you to Klap Solutions or third parties.
These technologies are generally used to monitor and analyze your interactions with the Website and/or to allow us to improve the Website and its functionality. For example, they allow us to customize the Website and Services based on your interactions. We may also use cookies to measure and monitor traffic, Website usage and performance.
You can manage cookies through the settings on your web browser and/or electronic device. If you do not want cookies to be stored on your electronic device, you can set your web browser or electronic device to refuse and/or restrict them. However, some cookies are essential to the operation of the Website and its use may be impaired if you refuse them completely. If you do not refuse or restrict cookies, you consent to their use and to the processing of your personal data collected through them.
For more information, you can visit http://www.allaboutcookies.org/fr.
You can also consult the help section of your web browser or electronic device for more specific instructions on cookie management.
We use the following cookies:
COOKIES THAT ARE ABSOLUTELY NECESSARY FOR THE OPERATION OF THE WEBSITE
Necessary cookies make the Website usable by providing basic functionality such as page navigation and access to secure areas. The Website cannot function properly without these cookies.
a) Preference / functional cookies
Preference / functional cookies are useful for the operation of the Website, in particular to remember your actions, etc. They allow us to remember information that affects the behaviour or appearance of the Website. In particular, they allow us to remember information that affects the behaviour or appearance of the Website.
b) Marketing cookies
Marketing cookies are used to display advertisements that are relevant and attractive to you, based on your preferences.
c) Statistical / productivity cookies
Statistical / productivity cookies, such as those related to Google Analytics, help us to understand how users interact with the Website, by collecting and reporting information anonymously.
9. Your rights
You have the right to know whether we process personal data about you. You can contact us to find out the content of this personal data, check its accuracy and request that it be completed, deleted, updated or rectified. You may also object to the processing of your personal data or request a restriction on the processing of your personal data.
You can exercise these rights by contacting us via the contact details in section 1. If you feel that the response provided is not satisfactory, you can contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/fr/home.html).
Your rights must be exercised within the limits of the legal provisions applicable to our activities. The exercise of these rights may affect our ability to provide you with access to the Website and/or the Services.
10. Changes
We may amend this Privacy Policy at any time, including to adapt it to any changes in law or new business or technological practices. We will notify you by any appropriate means, including by email or on the Website directly (e.g. by banner or pop-up).
