Last updated March 29, 2020

KomunIKON (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile applications or website (collectively the “Applications”). Please read this Privacy Policy carefully.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATIONS OR WEBSITE.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Applications after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Applications or make payments, including any in-game virtual items, which may also collect and use data about you.  We are not responsible for any of the data collected by any such third party.

In the course of its activity and for the purposes of providing the Services (as defined in our General Terms of Use), KomunIKON is required to collect and process the personal data of its users (hereafter referred to as the “Users”).

This privacy policy, implemented by KomunIKON, is intended to provide the Users with a summary and overview of the processing of personal data carried out by KomunIKON.

In the course of its activity and for the purposes of providing the Services (as defined in our General Terms of Use), KomunIKON is required to collect and process the personal data of its users (hereafter referred to as the “Users”).

This privacy policy, implemented by KomunIKON, is intended to provide the Users with a summary and overview of the processing of personal data carried out by KomunIKON.

KomunIKON attaches particular importance to the respect for the privacy of the Users and of the confidentiality of their personal data, and is thus committed to processing the data in compliance with the applicable laws and regulations, and in particular Law No. 78-17 of 6 January 1978 relating to Information Technology, Data Files and Civil Liberties (hereafter referred to as the “Data Protection Act”), and 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 (hereafter referred to as the “GDPR”).

Definitions

Personal data: any information relating to an identified or identifiable natural person, that is, a person who can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to that person.

Processing of personal data: any operation or any set of operations relating to personal data, whatever the process used, and in particular the collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as locking, erasure, or destruction.

Cookie : a cookie is a piece of information placed on the hard drive of Internet users by the server of the site they visit. It contains several pieces of data: the name of the server which installed it, an identifier in the form of a unique number, and possibly an expiry date. This information is sometimes stored on the computer in a simple text file that a server accesses to read and save pieces of information.

Data Controller – DPO

The data controller for the processing of the personal data referred to herein is KomunIKON, an association based in Neuchâtel, Switzerland 

KomunIKON has appointed a Data Protection Officer who can be contacted at the following address: privacy@komunikon.com.

Data collected

KomunIKON collects data from Users in order to make the Services for which they have subscribed to the platform available to them.

The mandatory or optional nature of the data provided (in order to complete the Users’ registration and to render the Services) is indicated at the time of collection by an asterisk.

In addition, certain data is collected automatically as a result of the User’s actions on the site (see the paragraph on cookies).

Purposes

The personal data collected by KomunIKON during the provision of the Services is necessary for the performance of the contracts concluded with the Users, or to allow KomunIKON to pursue its legitimate interests while respecting the rights of the Users. Certain data may also be processed based on the Users’ consent.

The purposes for which KomunIKON processes data are the following:

commercial and accounting management of the contract;

management of customer acquisition and marketing activities;

detection of malicious behaviour (fraud, phishing, spam, etc.);

the improvement of the Users path on the site;

more generally, any purpose referred to in Loi fédérale sur la protection des données (LPD) of 19 june 1992, creating a simplified standard for the automated processing of personal data relating to the management of users and prospects.

Recipients of the data

The personal data collected is intended for KomunIKON’s commercial and accounting departments. It may be transmitted to KomunIKON’s subsidiaries, or to third-party data processors which KomunIKON is authorized to use within the context of the performance of its Services.

In this context, personal data may be transferred to an EU or non-EU country. KomunIKON implements guarantees ensuring the protection and security of this data, in compliance with applicable rules and regulations.

KomunIKON does not transfer or rent personal data to third parties for marketing purposes without the express consent of the Users of KomunIKON.

In addition, personal data may only be disclosed to third parties for purposes other than marketing in the following cases:

with their authorisation;

at the request of the competent legal authorities, upon judicial request, or in the context of a legal dispute.

Data retention period

To satisfy its legal obligations or in order to have the necessary elements to assert its rights, KomunIKON will be able to retain the data under the conditions established by applicable rules and regulations.

Thus, personal data collected by KomunIKON relating to the identity and contact details of its Users is retained for a maximum period of two years after the termination of the contractual relationship for Users that are customers, or from their collection by the data controller or the last contact from the Users that are prospects, for the data relating to the latter.

The termination of the contractual relationship is understood as the express termination of the contract by the User, or the non-use of KomunIKON Services for a period of five years.

Rights of Users

In accordance with applicable rules, the Users have the right to access and rectify their personal data, which enables them to rectify, complete, update, or delete data that is inaccurate, incomplete, ambiguous, or outdated, or whose collection, use, communication, or storage is prohibited.

The Users also have the right to request the limitation of the processing, and to oppose on legitimate grounds the processing of their personal data. The User may also communicate instructions on the fate of their personal data in the event of their death.

Where applicable, the User may request the portability of their personal data or, where the legal basis for the processing is consent, withdraw their consent at any time.

The Users may exercise their rights by sending an email to privacy@komunikon.com or a letter to:

KomunIKON

CH2000 Neuchâtel

These requests shall be processed within a maximum period of 30 days.

The Users may unsubscribe from the KomunIKON newsletter or marketing emails by following the unsubscribe links in each of these emails.

In the event of a dispute, the Users may file a complaint with the Préposé fédéral à la protection des données et à la transparence PFPDT https://www.bk.admin.ch/bk/fr/home/chancellerie-federale/organisation-de-la-chancellerie-federale/prepose-federal-a-la-protection-des-donnees-et-a-la-transparence.html

The Users may access detailed information on the use of their personal data, in particular concerning the purposes of the processing, the legal bases enabling KomunIKON to process the data, its storage period, its recipients, and, where applicable, its transfer to a country outside the European Union as well as the related compliance guarantees put in place for such transfers. To do so, the User can send their request by email to privacy@komunikon.com.

Cookies

For more information about how KomunIKON handles cookies, please visit our cookie policy page.

Security

KomunIKON has taken all necessary precautions to preserve the security of personal data and, in particular, to prevent it from being accessed by unauthorized third parties, distorted, or damaged.

These measures include the following:

All persons having access to the data will have to sign a confidentiality agreement in which s/he agrees to hold in the strictest confidence, and take all reasonable precautions to prevent any unauthorized use or disclosure of confidential information, including the personal data collected by KomunIKON.

Data transmitted over unsecured communication channels is subject to technical measures designed to make such data incomprehensible to any unauthorised person.

Any questions about the security of the KomunIKON website can be directed to info@komunikon.com.

Modification of the Privacy Policy

KomunIKON reserves the right to change this Privacy Policy to comply with changes in the applicable laws and regulations.

The Users shall be notified of any changes made to this policy via our website or by email at least thirty days prior, when possible, to their entry into force.

Contact

Any questions about KomunIKON’s Privacy Policy can be directed by email to privacy@komunikon.com or by mail to:

KomunIKON 

CH2000 Neuchâtel