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PRIVACY POLICY STATEMENT (PPS)
1. Introduction and Basics
Tirreno Technologies Sàrl (hereinafter Tirreno) is a Switzerland
Limited Liability Company under Swiss law with its registered office
in Prilly (Switzerland). Tirreno attaches great importance to the
responsible, legally compliant and transparent handling of data.
Privacy is also a matter of trust and your trust is important to us.
We respect your personal and privacy sphere.
This Privacy Policy (hereafter "Statement" or "PPS") describes how we
process your personal data as a "user" of the products and services
provided by Tirreno.
We use the following terms in this PPS:
Tirreno = Tirreno Technologies Sàrl, Prilly, Switzerland
Statement, PPS = Privacy Policy Statement
Aggregate data = generic term for personal data and other data.
Personal data = all storable information and data relating to a
specific or identifiable person.
Users = natural and Legal persons
Third parties = external persons and others Companies
EU-GDPR = European General Data Protection Regulation.
API = Application Programming Interface.
APP = application for use on mobile communication devices.
Site = Website.
2. Purpose of the privacy policy
Our privacy policy statement explains:
- what data we collect and for what reason;
- how we use this data;
- what choices we offer, including how data and aggregate data
can be accessed and how they can be updated.
We have tried to make it as simple as possible, but we cannot entirely
do without technical terms. Therefore, if you are unfamiliar with
terms such as cookies, IP addresses and browsers, local storage,
session storage, you should first read about these techniques and key
terms (see EU-GDPR, terms, description of technical IT terms).
This PPS explains the procedures used of Tirreno and does not
constitute a document that binds Tirreno or third parties.
3. Scope of the privacy policy
The declaration applies to all offers and services of Tirreno;
regardless of the way (website, apps, e-mail API, etc.) or the
technical (computer, mobile phone, IoT, etc.) form of use. The
declaration applies and is part of the contract if it is listed in
the contract document as part of the contract or if it is referenced
in the applicable general terms and conditions (GTC).
If there are any contradictions between this declaration and the
terms and conditions, the provisions of this statement take
precedence. If you already use Tirreno products and services, this
declaration also refers to personal data collected by you in the past
and already stored by Tirreno, which we can link to and process with
personal data collected in the future.
4. Consent form
Before using our services, please read our terms of use; the privacy
policy.
Explicit APPROVAL STATEMENT: The user hereby agrees that for the
purpose of providing general and personalised products and services in
accordance with the terms of use and the privacy statement for his
personal data will be collected and processed, in particular via the
Internet, whereby the processing may also be carried out by third
parties.
This consent can be changed at any time by writing to Tirreno or
directly online. The revocation does not affect the legality of the
data processing until then.
By creating a user account on www.tirreno.com you expressly confirm
that you have reached the age of 18. At a younger age, the consent or
consent of the parents is required. The age limit may be lower in
different states.
Your use of this website or our apps, whichever change is made,
constitutes your consent to the collection of personal collection
information that you disclose when using this website or our apps.
Please read this privacy policy regularly. You can access the latest
version of this Privacy Policy from the Website at any time, the
validity of which is stated below.
5. Terms, description of IT-technical terms
Personal data is all information and aggregated data relating to a
specific or identifiable person. In addition to your contact details
such as name, telephone number, address or e-mail address, this also
includes other information that you provide, for example, when using
our services, registering, placing an order or participating in
promotions or surveys and the like. The personal data also includes
the IP address of your device, which we register when you visit our
website or APP and with other aggregate data such as the pages viewed
and reactions to offers displayed on our websites or APP or similar.
Users are natural persons as well as legal entities, which are
represented by the persons acting for them.
Browsers are special computer programs for displaying web pages on
computer or mobile screens.
Cookies are short text snippets that are sent to your browser by a web
page you visit. Cookies can store any aggregate data, such as your
login, your language or other settings.
Local storage or session storage is storage within your browser.
Similar to cookies, aggregate data can be stored and stored here.
Unlike cookies, this aggregate data is not automatically sent to our
servers. Collection data in the localstorage remain stored
indefinitely, the sessionstorage is emptied at the end of a session
(for example, closing the browser).
An IP address is a numeric address in computer networks. It is
assigned to devices connected to the Internet, making the devices
addressable and accessible. The outwardly visible IP address often
belongs to a router, which makes individual devices such as computers
or smartphones unidentifiable.
6. When will personal data and other aggregate data be collected?
Tirreno will need to collect and process personal data about you in
order to provide these services, depending on the products or services
provided to you. This happens especially if you:
- visit our website;
- use one of our apps;
- register for one of our services;
- sign up for an promotions, competitions or special events;
- purchase one of our online services or otherwise be in a
contractual relationship;
- participate in a survey;
- send us an e-mail or otherwise communicate.
In the event that you do not give Tirreno the full consent and
permission to collect and process the personal data, Tirreno reserves
the right not to offer any part of the website, functionality in our
apps, or certain products and services, or only to a limited extent.
This applies in particular if the corresponding personal data are
indispensable for the relevant products and services of the Tirreno.
Tirreno collects and processes aggregate data to provide the best
possible products and services to all its users. This begins with the
detection of basic parameters, such as the language you want to use,
identifying the devices you are using, your location, the products and
services that you are calling, and other ways of using the site.
The aggregate data collected and processed by Tirreno is not
necessarily personal data. Tirreno collects and processes in
particular the following types of aggregate data:
- data that you provide to us (in the form of personal data);
- data we receive from your use of our services, such as:
- device-related data (type and type of device used);
- protocol data (information transmission, etc.);
- location-related data (location or location identifiers,
etc.);
- unique application numbers (software versions, purchase
numbers, etc.);
- local storage (in the browser or similar);
- cookies and similar technologies;
- etc.
7. Type of personal data collected
Depending on the products or services that Tirreno provides, personal
data about you will be collected and processed. These include:
- personal data such as name, age, date of foundation, e-mail or
IP address, postal address or company address, telephone
numbers, as well as collecting data about your gender,
occupation, interests etc. as well as other property
information regarding a natural or legal person;
- details of our mutual business relationship and the products and
services you use;
- if necessary, records of telephone calls, e-mails,
correspondence between the Tirreno and you;
- financial information, including a summary of payments and
transactions and aggregate data relating thereto in relation to
the business relationship; customer or account number, also for
accounting purposes.
8. Use of collected data and personal data
Tirreno uses the collected data and personal data to provide,
maintain, protect and improve services, as well as to develop novel
products or to provide customized content and services.
Tirreno uses your personal data for the following purposes, among
others:
- to preserve and protect your user account;
- to respond to your comments and questions;
- to alert or register you for special events, offers or
services;
- to send you regular information or data;
- to show you services and information tailored to your
interests and profile;
- to pass on individual data to third parties (see "Disclosure of
personal data to third parties", § 10) where they are needed in
order to offer you the desired service.
When you contact Tirreno, we record your communication to help you
solve any problems you may encounter. Notification of your use of our
services, including notices of changes or improvements, may be made
using your email address.
Data collected through cookies and other technologies improves your
overall user experience and the quality of our services. For example,
storing your preferred language setting allows us to display our
services in the language of your choice.
We can collect personal data about you by installing our own markers
on your computer. These markers are commonly referred to as "cookies"
and allow us to identify you using a computer-generated distinctive
code.
By providing you with a unique identifier, we are able to create
databases based on your previous decisions and preferences.
In addition, Tirreno may use technologies that track your use of this
website or our apps, such as which page you are viewing and the links
you use. These aggregated data about your use of this website or one
of our apps are called "click-stream data" and help us to determine
what is important to you and what is not. It helps us to decide what
content and features are desired and which ones to discard. It also
helps us to determine if our website and apps are easy to use or if we
should redesign certain pages and hyperlinks.
You can refuse such "cookies" without further ado. Your computer is
usually set up so that you can adjust the settings and blockage of
cookies to your liking. In your browser you will find more aggregate
data. We point out that this refusal can lead to significant
limitations of the functions of our services and expressly disclaims
any responsibility for the associated loss of benefits, data and
other restrictions.
Tirreno processes personal data on its own servers, sometimes with
the involvement of third-party servers. Therefore, it is not excluded
that personal data is processed on servers outside your country of
residence. In this case Tirreno considers the relevant legal
provisions.
With your permission, we use the aggregate data to inform you about
new Tirreno services and offers. As part of the registration, you
have the opportunity to inform us whether or not you wish to receive
announcements and actions.
9. Duration of storage of aggregate data and personal data
Tirreno will only retain personal data for as long as necessary to
fulfill the purpose for which it was collected or in accordance with
legal, regulatory or internal regulations.
We use criteria based on legal and functional requirements to set
reasonable time limits for the storage of your personal data, which
depend on the purpose of the data, such as: e.g. statutory provision
for the storage of transactions, proper account management,
facilitation of client relationship management and reaction to the
assertion of legal claims, etc.
10. Processing and disclosure of personal data to third parties
Tirreno does not disclose personally identifiable information to
companies, organizations or individuals outside of Tirreno, except in
the following cases:
With your consent:
- If Tirreno provides you with products and services, personal
data may be disclosed to third parties acting on your behalf or
otherwise involved in the transaction (depending on the type of
product or service you use).
- In some cases, personal data is passed on to external, trusted
contractors who provide services to the Tirreno, such as: IT
and hosting service providers, marketing service providers,
communications and printing services providers, collection
agencies, search services, debt collection service providers,
anti-fraud agencies, credit rating agencies and other
contractors. To protect your personal data, Tirreno ensures
compliance with Tirreno data security standards by these
contractors.
This is done on the basis of our instructions and in accordance with
our privacy policy and other appropriate confidentiality and security
measures.
If any of your personal data contains sensitive personal data that you
consider ineligible for disclosure, please let us know in writing,
specifying the exact nature of the information, protection needs, and
disclosure restrictions to ensure that we take the necessary
precautions.
For legal reasons:
- Tirreno will disclose personal data to companies,
organizations or individuals if we reasonably believe that
access to, or use of, storage or disclosure of this information
is reasonably necessary;
- to comply with applicable laws, regulations or legal procedures
or comply with an enforceable regulatory order.
- to enforce applicable terms of use, including investigating
potential violations.
- to detect, prevent, or otherwise combat fraud, security
deficiencies, or technical issues.
- to protect the rights, property or safety of Tirreno, our users
or the public from harm, to the extent permitted or required by
law.
- Tirreno may disclose non-personally identifiable information to
the public and third parties, such as publishers, advertisers,
or related trend research sites.
- in a business merger, acquisition, or sale of assets where
Tirreno participates, Tirreno will ensure the confidentiality
of any personal data and notify the affected users before any
personal data is transmitted or becomes subject to any other
privacy policy.
10.1 Product-specific use and processing of data and personal data
The following third-party services are used by Tirreno:
Fastmail: Tirreno uses email services from Fastmail Pty Ltd.
Paddle: In case you purchase our services via our website (without
contacting sales) please note that we’re using Paddle (Paddle.com
Market Limited), our Merchant of Record, to process your order. Here’s
their privacy policy. https://www.paddle.com/legal/privacy
Notes: the links may be modified by the providers as necessary,
without changing the privacy policy of Tirreno.
10.2 International transfer of personal data
The third parties referred to in paragraph 10 above may also be
established outside the European Union. In this case, Tirreno requires
that these third parties take appropriate measures to protect personal
data, which are set out in a binding legal agreement, unless the
European Union has determined that the country in question ensures an
adequate level of protection. A copy of these actions is available
from the Tirreno Data Protection Officer.
10.3 Links etc. on third party websites
The Tirreno website and apps may contain links to other websites or
services. When you visit these services, we are not responsible for
their privacy practices and how they treat personal data. In addition,
we may authorize third parties to provide registration-based services
through our site (such as payment services), and we will clearly
disclose this to you. Tirreno is not responsible for the actions and
decisions of these third parties and you should review that party's
privacy policies before giving them personal collection information
make available.
11. Privacy of children
Tirreno is committed to protecting the safety and privacy of young
people using the Internet. We do not knowingly collect personal
collection information about children and will delete it immediately
should we be notified of any abuse. In case of doubt, we recommend
that parents check the privacy policy of our and all linked sites.
12. Access to and updating of personal data
Tirreno strives to give you access to your personal data to the
technically possible reasonable extent. If these data are inaccurate,
we will provide you with options to update or remove them quickly -
unless we must retain this information for legitimate business or
legal purposes.
We strive to provide our services in a manner that protects personal
data from accidental or willful destruction. For this reason, we may
not immediately delete any duplicate pieces of personal data that you
have deleted from our services from our active servers and may not
remove that personal data from our backup systems, e.g. if we keep
records of payments and previous orders, which must be kept according
to corporate accounting policies.
You have the right to demand from the Tirreno the correction of
incorrect personal data that we collect and process. If we process
your personal data with your consent, you have the right to revoke
this consent at any time. Please also note that the revocation of your
consent has no effect on the lawfulness of the processing before the
revocation that took place with your consent.
If you are not satisfied with individual aspects of the processing of
your personal data, please write us with your complaints. We will work
with you to find a solution.
13. Notification and approval of changes
Tirreno is constantly improving and adding new features and functions
to the services. These constant improvements as well as changes in
legislation or changes in technology also require regular changes to
this Privacy Policy Statement (PPS).
Tirreno reserves the right to update or change this PPS at any time
without notice. We will notify you of changes to the PPS by posting an
updated or modified version of this PPS on this site. For your
benefit, we may, if necessary, alert you to this by temporarily
posting a message on our website should the PPS change.
Security note:
We have taken appropriate technical and organizational measures to
prevent unauthorized or unlawful access to the personal data you have
provided to us. Because we cannot guarantee complete data security for
email or instant messaging communication or similar means of
communication, we recommend choosing a secure transmission alternative
for highly confidential personal data.
14. Status of the Privacy Policy Statement
This privacy policy statement was last revised on 22 October 2024.
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