- Privacy policy for LaLuz
1.1 Preliminary remark
(a) General
Laluz.ch (the Website) is owned and operated by the Company. The Company is part of LaLuz.
We are committed to protecting the privacy of users. We understand that visitors and users of the Website are concerned about their privacy and the confidentiality and security of any personal information that is provided.
We will only use and disclose personal information in accordance with this Privacy Policy and the laws of the jurisdictions in which we collect personal information. If there is any inconsistency between this Privacy Policy and any applicable law, the relevant law will prevail to the extent of the inconsistency. (b) Kontakt
Our contact details are:
Email: info@laluz.ch
Phone number: +41 796 265 296
Post: Laluz.ch, Höheweg 12, 3800 Interlaken – Switzerland
E-mail for data protection issues: info@laluz.ch
2 Basis for the survey
This Privacy Policy sets forth LaLuzpolicies regarding the collection and use of your Personal Data while you use the Website and related websites of LaLuz or any affiliated LaLuz website. Capitalized words such as “Personal Data” and “Special Category Personal Data” are defined in Section 9 of this Policy.
When we collect your personal data, we do so on the following basis:
(a) Contractual services
If you have created an account through our website or one of LaLuzrelated websites or a website operated by LaLuz and have requested that we provide services to you, we will need to collect and use your personal information to:
(i) enter into our agreement with you; and
(ii) provide you with our services available through our website. (b) legitime
Business purposes
If we do not collect and use your personal data to enter into a contract with you or to provide you with our services, we may still collect and use your personal data if we take the following into account:
(i) you will not be adversely affected by our collection and use;
(ii) such collection and use is consistent with what you would reasonably expect in relation to our use of your personal data; and
(iii) it is necessary to fulfill our legitimate interests.
This may include, for example, using your personal data to improve our website or the services we provide to you.
(c) Legal conformity
There are certain situations where we may need to process your personal data in order to comply with the law, for example if we are subject to a court or regulatory order requiring such processing.
(d) Your consent
By accessing and using the Website, you consent to the collection and use of your personal data in accordance with the terms of this Privacy Policy. By registering an account or logging in as a member on the Website or a related website, you consent to the collection and use of your personal data and special categories of personal data.
You may withdraw your consent to our collection and use of your personal data at any time by discontinuing your use of the relevant website or related website. If you are a member who has created an account, you may withdraw your consent to the collection and use of your personal data and special categories of personal data by discontinuing the use of your account and requesting the suspension or deletion of your account. Requests for suspension or deletion can be made through your account or by contacting us using the contact information contained in Section 1.1(b) of this Privacy Policy.Bitte beachten Sie, dass zum Löschen von personenbezogenen Daten, die wir bereits von Ihnen erfasst haben, eine Anfrage gemäss dem in Abschnitt 7(f) dieser Datenschutzerklärung beschriebenen Verfahren gestellt werden muss.
3 Anonymity
Due to the nature of the services offered by the Company, it is impractical for us to contact you without knowing your full name. When you register for our services, you must identify yourself and provide truthful and accurate information.
4 Collection of data
(a) All users
As soon as you (including non-registered users) visit our website, our servers automatically record information about your use of the website for statistical purposes, such as
(i)the type of browser used;
(ii) the referring URL;
(iii) the IP address;
(iv) the number and type of pages viewed;
(v) the date and time of the visits; and
(ii) the exiting URL;
This information that we collect about you is not personal data and remains anonymous in all cases. We do not associate the anonymous information with any other personally identifiable information unless you have either registered as a member or are logged in at the time of use. Therefore, if you have not identified yourself on the website, e.g. by registering as a member or logging in as a member, we will not associate any records of your use of our website with you personally.
(b) Cookies und andere Tracking-Technologien
To improve your experience on our website, we may use cookies and other tracking technologies, such as pixel tags, web beacons, device IDs or advertising IDs.
You can opt out of the use of cookies by selecting the appropriate settings on your browser. Please note, however, that you may then not be able to use all the functions of our website.
Our website uses Google Analytics, a service that transmits data about our website traffic to Google’s servers in the United States. Google Analytics does not identify individual users, nor does it associate your IP address with any other data held by Google. We use the reports provided by Google Analytics to understand our website traffic and website usage.
You can customize or disable Google Analytics for ads through your Google Account ad settings.
Our website uses cookies and other tracking technologies to support Google Analytics for:
(i) Google Marketing Platform integration;
(ii) Demographics and interest reporting;
(iii) Advertising, including remarketing and Google Display Network Impression Reporting, to promote our services online;
(iv) optimization and personalization of ad services based on your past visits to our website; and
(v) reporting on the use of ad services and interactions with ad impressions and how these relate to visits to our website.
Cookies and other tracking technologies may also be used to support analytics by other third parties.
(c) Interactions with third parties
We may allow third parties, including authorized service providers, advertising companies, data management platforms and advertising networks, to serve advertisements on our websites. We may also share your profile data with LaLuz affiliates for analytics purposes and to optimize advertising campaigns.
These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs or advertising IDs) to collect information about users who view or interact with their advertising. Any information these third parties collect via cookies is completely anonymous and non-identifiable. Examples of such third parties are: 360, Adobe, Akamai, Appnexus, Baidu, Bing, Cake, Chargeback.com, Criteo, Dating Group, Ecom Services, Facebook, Firebase, Google Ads, Google Ads Manager, Google Analytics, HotJar, Index Exchange, Naver, Olark, Oracle, Publift, Pubmatic, Pusher, RayGun, Rubicon Project, SDL, Sentient, Taboola, TikTok, Twitter, Urban Airship, Visa Inc. Yahoo, Yandex, Zero Bounce.
There are also a number of touch points on our website where you may access third party websites that do not operate under this Privacy Policy and which we do not control. Such third party websites may collect your personal data. We encourage you to read the privacy statements of any third party websites you visit.
(d) Advertising
We show ads to our non-subscription users. Non-subscription users see the ads served by the Google Ads Manager platform – an open ad exchange that allows advertisers from around the world to buy our inventory through Google and third-party ad networks that are compatible with Google Ad Exchange. We do not provide any personal data to Google Ads Manager, with the exception of the advertising token, which allows the advertiser to distinguish one user from another without revealing the identity of the user.
(e) Social Media
The Company has links to social media sites such as Facebook, Twitter, YouTube, Instagram, Pinterest, Weibo, Tiktok and others. If you choose to “like” or “share” information from our website via these services, you should read the privacy policy of the relevant service before doing so. If you are a member of a social media site, these links may allow the social media site to associate your visits to this website with other personal data.
5 Purposes of the collection, storage, use and disclosure of personal data
(a) Only collected directly from you
Wherever it is reasonable or practicable to do so, we will only collect personal data about you directly from you.
(b) Purposes of collecting personal data
We will only collect personal data that is reasonably necessary for the following:
(i)to enable us to process your application for membership and provide you with services (including creating your publicly viewable profile, finding suitable members and providing mechanisms for communication between members);
(ii)to allow you to easily transfer a profile you have created on our Website to another website or service that we own, operate or are affiliated with, including another service offered by a LaLuz member;
(iii) for our internal research and statistical purposes (including market segmentation and customer value analysis)
(iv) so that we can provide you with other information or materials that we believe may be of interest to you
(v) so that we can authorize a payment processor to process payments you make to us; and
(vi) for any other purpose specified in our website terms of use available on our website (the “Primary Purpose”).
We do not sell personal data to third parties or disclose personal data to third parties for business purposes (unless this business purpose has been explicitly mentioned in this privacy policy).
(c) Use and disclosure of personal data
The use of personal data for the Primary Purpose includes the use of personal data in automated decision-making processes.
We will only use or disclose Personal Data about you for a purpose other than the Primary Purpose (the “Secondary Purpose”) if the following applies:
(i) the Secondary Purpose is related to the Primary Purpose and, where the Personal Data is Special Category Personal Data, the Secondary Purpose must be directly related to the Primary Purpose; and
(ii) you would reasonably expect us to use or disclose the personal data for the secondary purpose; or
(iii) you have consented to the use or disclosure for the secondary purpose; or
(iv) the use or disclosure of the personal information is required or permitted by law, regulation or court order.
In order to promote our products and services to you, we may also share a hash of your email address (and no other personal information) with third parties, such as Faceboo and other companies within LaLuz, to better target our advertising to you using products such as Facebook’s Custom Audiences.
A comparison of your hashed email address will only be used for the purpose of promoting our goods and services to you and will not be used by that third party for any other purpose. The matching of the hash of your email address will not be used to identify you or your email address and we will not share any other information about you with this third party. In the event of an intra-group transfer of your personal data, you will be asked for your consent.
You may withdraw your consent to the use of your personal data for primary and secondary purposes at any time by contacting us using the contact information provided in Section 1.1(b) of this Privacy Policy. However, this may affect or limit your ability to use the LaLuz website and services.
(D) Protection of personal data
We will apply best practice processes and take all reasonable steps to protect the personal data we hold from the following:
(i) misuse, interference and loss; and
(ii) unauthorized access, alteration or disclosure.
In the unlikely event of a serious data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority in your jurisdiction without undue delay. If there is a high risk of a serious data breach affecting your rights and freedoms, we will also inform you of this breach.
(e) Disclosure abroad
All profile information that you have made available to us is publicly visible in your profile, regardless of the viewer’s location. By creating a profile, you confirm that recipients from abroad can also view your profile.
In order to provide customer support, back office functions, fraud prevention tasks or other services to you, we may need to provide our employees or suppliers (who may be located in a location other than your place of residence or whose resources may be located in a location other than your place of residence) with access to your profile information, billing information or other personal information you have provided.
We have taken security precautions to protect your personal data. However, as with any data transfer, there is still a risk of data breaches. There may be instances where your personal data is transferred to third countries and international organizations that have not been the subject of an adequacy decision by the General Data Protection Regulation Commission or a decision by the relevant supervisory authority in your jurisdiction. Such transfers are necessary for us to fulfill our obligations set out in the LaLuz Website Terms of Use and to provide our services to you.
By providing your personal data and special category personal data, you expressly consent to the international transfer and processing of such data in accordance with this Privacy Policy, including without limitation to any member of LaLuz, with full and informed knowledge of the risks associated with such transfers and processing.
You may withdraw your consent at any time by contacting us using the contact information contained in Section 1(b) of this Privacy Policy. However, this may affect or limit your ability to use the Liebwahl website and services.
In all other circumstances, we will only disclose personal information to a recipient in a third country or to an international organization if the disclosure of the information is required or authorized by law, regulation or court order.
(f) Unsolicited information
If we collect personal information that we have not sought or requested from you, and if we determine that we are legally authorized to collect that information, we will treat that information in accordance with the terms of this Privacy Policy. In all other cases, we will destroy or de-identify the personal information in question as soon as possible, where lawful and reasonable to do so.
(g) Non-confidential information
Any material or information you provide for inclusion in a Member Profile will be treated as non-confidential and non-proprietary. We may use such material or information without restriction. In particular, LaLuz will use any such material or information (including any profile information, photographs, video or audio recordings) provided by you to copy your profile to any other relevant dating site owned and operated by LaLuz or any other relevant dating site that is part of LaLuz. Any material or information you provide will be made available for other members or users of the website to read.
(h) Communication
We reserve the right to send you emails regarding recommended profile matches, notifications of activities such as interest or news alerts, promotions or offers, changes or additions to our services or to products and services of our affiliated companies.
If you are a member of our website, you can manage your email preferences by using the settings on the “Notifications” page to customize what type of email communications you would like to receive.
6 Destruction of personal data
We will only retain your personal data for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to delete any personal information we hold about you if:
(i) we no longer need that personal information for the purposes for which it was collected and we are no longer authorized to otherwise retain that information; and
(ii) we are not required by law, regulation or court order to retain the information.
Where certain information has been disclosed to third parties in accordance with this Privacy Policy, the retention of that information will be subject to the policies of the relevant third party.
- Access, correction and portability
(a) Access to personal data
We will provide you with access to the personal data we hold about you on request, except to the extent that:
(i) access to the data would be unlawful; or
(ii) the denial of access is required or authorized by a relevant law, regulation or court order.
To request access to your personal data, please contact us using the details provided in Section 1(b) of this Privacy Policy.
Upon your request, we will contact you within one (1) month from the date of receipt of your request and provide you with the Personal Data requested, unless we have determined that there is a reason or obligation that requires us to deny access to the Personal Data.
(b) Disclosure to third parties
We do not sell your personal data to third parties. Except as expressly stated in this Privacy Policy, we also do not share your personal information with third parties for other business purposes. Notwithstanding the above, you can always ask us to confirm that your personal information has not been sold to a third party, or you can request details of third parties to whom information has been sold or disclosed for business purposes.
Notwithstanding the above, in certain circumstances we may provide your personal information to our third party service providers (so that we can provide our services to you), to our affiliates who operate dating services that we control, or to other members of LaLuz (for example, if you have requested that we port or transfer the profile you have created on one of our websites to an alternative website or dating service).
(c) Data portability
Insofar as it does not adversely affect the rights and freedoms of others, we will provide you with the following upon your successful request to us:
(i) where we have used an automated means to process your personal data, we will provide you with a copy of that personal data in a structured, commonly used and machine-readable format; and
(ii) upon receipt of your request, we will, where technically feasible, transfer your personal data directly to another data controller.
(d) Business sensitive information
If granting access to your personal data would disclose commercially sensitive information, we may not grant you access to that information. However, we will provide you with the reasons behind our decision.
(e) Use of intermediaries
If we are unable to provide you with direct access to your personal data, we may, where appropriate, use an intermediary to do so.
(f) Correction and deletion of personal data
It is your responsibility to ensure that the information you provide to us is accurate and to update your personal data as necessary. If for any reason you are unable to correct the personal data we hold about you, please contact us using the details provided in section 1(b).
If we decide not to correct your data after receiving your request, we will inform you within one month of the reason for our refusal and the options available to you to object to our refusal.
If you wish to have your personal data erased, please notify us of your request using the contact information provided in Section 1(b). The only circumstances in which we will not take reasonable steps to erase your personal data is if we are required to retain it under another provision of this Privacy Policy, the GDPR, or for other legal reasons. However, the deletion of your personal data may result in the deletion of your account with LaLuz and means that you will no longer have access to our services.
If we correct or delete personal information about you that we have previously disclosed to a third party in accordance with our Privacy Policy, we will take reasonable steps to notify the third party of the correction or deletion and request that they do the same.
(g) Refusal of correction or deletion
If at any time we deny or withdraw access to your personal data or refuse to correct or delete your personal data, we will provide you with the reasons for such denial or refusal.
(h) Restriction of processing
You may request that we restrict or limit the way in which we handle and process your personal data, in which case we will only process your personal data with your consent: for the establishment, exercise or defense of legal claims against us or for the protection of the rights of another person.
(I) Costs
Access to, deletion and correction of your personal data, including all related communications, will generally be provided free of charge.
If your requests are manifestly unfounded or excessive (in particular due to repetition), we may charge you a reasonable fee for providing the information or communication or taking the action requested. If your requests are manifestly unfounded or excessive, we may also refuse your request.
(j) Specific rights of objection
Sometimes it becomes necessary to process your personal data without your consent for the following reasons:
(i) to perform a task carried out in the public interest;
(ii) to exercise a public authority vested in us; or
(iii) where it is in our legitimate interests or the legitimate interests of a third party;
You have the right to object to such use.
If you object to our use of your personal data, we will not use your personal data unless we have compelling legitimate grounds to use it or for the establishment, exercise or defense of legal claims.
Where we have collected your personal data in accordance with this Privacy Policy and we choose to use that personal data for direct marketing purposes (which you consent to), you have the right to object to such use at any time.
If we receive an objection, we will, as soon as reasonably practicable, stop using your personal data for direct marketing purposes.
- Complaints
(a) submit a complaint
If you believe that we have used or disclosed your personal information in a manner inconsistent with this Privacy Policy or otherwise in violation of any applicable law, you should email us at info@laluz.ch.
You also have the right to lodge a complaint with the competent supervisory authority in your jurisdiction. If you are not sure who your competent supervisory authority is, please contact us so that we can help you.
(b) our answer
Within 30 days of receiving your complaint, we will write to you to let you know what action we propose to take in relation to your complaint and give you details of what further action you can take if you are not satisfied with our response.
- Definitions
Company” means LaLuz, which is registered as a self-employed person in Baden, Switzerland.
“General Data Protection Regulation” and “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC “international organization” means an international organization and its subordinate bodies or any other body established by, or on the basis of, an agreement between two or more countries “personal data” means any information relating to an identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, and includes data in the special category of personal data.
” Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Special Category Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your criminal record, genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation.
“Related Website” means any other website owned, operated or controlled by LaLuz.