Effective date: 1 Jan, 2022

​​

939 Privilege Owners Club is a non-profit association based in Switzerland, Canton Zürich (“us”, "we", or "our") which operates the website www.939privilege.club  (the “Website”). We act in the capacity of a data controller with regard to the personal data processed through the Website in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

This privacy policy informs you of our policies regarding the collection, use and disclosure of your personal data when you use the Website and the choices you have associated with that data.
 

Sources of Personal Data

​

We obtain your personal data from the following categories of sources:

• Directly from you. For example, if you submit certain personal data directly to us when contacting us;

• Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect technical information about your use of the Website; and

• From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.

​

Types and Purposes of Personal Data Personal Data

​

While using our Website, we may ask you to provide us with certain personal data that can be used to identify you. We provide an overview of such data below. We respect data minimisation principles. This means that we collect only a minimal amount of personal data through the Website that is necessary to ensure the proper provision of the Website as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this privacy policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases.

​

• Registration of your user account. When you register your user account on the Website, we collect your   first and last names, country, language, email address, interests, and professional category. We use the said information to register and maintain your user account, enable your access to the Website, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer the Website). We keep your personal data until you delete your user account.

• Inquiries. When you contact us by email we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We keep your personal data until you stop communicating with us.

• Comments. When you submit a comment under a blog post, we collect any information that you decide, at your sole discretion, to provide. We do not require any personal data from you. If you decide to reveal your personal data, we will use it to feature your comment and enforce our legal terms. The legal bases on which we rely are ‘your consent’ and ’pursuing our legitimate business interests’ (i.e., to ensure security of the Website and enforce our terms).

• IP address. When you use the Website, we or our third-party analytics service providers (as explained in section 3 below) collect your IP address in an anonymised form. We use your IP address to analyse the technical aspects of your use of the Website, prevent fraud and abuse of the Website, ensure the security of the Website, and tailor the Website for your location. The legal basis on which we rely when processing your IP address is ‘pursuing our legitimate business interests’ (i.e., to analyse and protect the Website). We keep your personal data as long as it is necessary for analytics purposes.

• Cookies. When you browse The Website, we collect your cookie-related data. For more information about the purposes for which we use cookies, please refer to the Tracking & Cookies Data section of this privacy policy. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies).

​

Sensitive data

We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation.  

 

Your feedback

If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.

 

Refusal to provide personal data

If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Website, receive our products and services, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

​

Usage Data

When you access the Website, we may collect certain information automatically, including, but not limited to, the type of device you use, your device unique ID,, your operating system, the type ofInternet browser you use, unique device identifiers, and other diagnostic data (the "Usage Data”).

​

We use the Usage Data for the following purposes:

• To analyse what kind of users visit the Website;

• To examine the relevance, popularity, and engagement rate of the Website;

• To investigate and help prevent bugs, security issues and abuse;

• To develop and provide additional features to the Website; and

• To personalise the Website for your specific technical needs (e.g., to adjust the design and resolution for your device).

• Aggregated and de-identified data

 

If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data and make sure that we have a legal basis for processing it. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

  

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use the Location Datato provide features of, improve and customise our Website.You can enable or disable the Location Data when you use the Website at any time by way of your device settings.

​

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept all cookies, you may not be able to use some portions of our Website. Also, we place a cookie consent banner on the Website that asks you to provide us with your consent for non-essential (analytics and marketing) cookies. If you do not provide your consent, we will use our essential cookies only that are strictly necessary for the functioning of the Website.

​

Examples of cookies that we use include:

• Essential technical cookies that are strictly necessary to ensure the correct functioning of the Website and provide the services requested by you; and

• Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement.

​

Disclosure & Transfer of Data

​

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. The disclosure is limited to the situations when your personal data is required for the following purposes:

​

• Ensuring the proper operation of the Website;

• Ensuring the delivery of the products and services ordered by you;

• Providing you with the requested information;

• Pursuing our legitimate business interests;

• Enforcing our rights, preventing fraud, and security purposes;

• Carrying out our contractual obligations; or

• If you provide your prior consent to such a disclosure.

 

We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this privacy policy and the applicable data protection laws. The data processors that have access to your personal data are:

​

• Our cloud storage service provider WIX located in United States;

• Our marketing service provider Hubspot located in United Stetes;

• Our transactional email service provider Microsoft located in United States; and

• Our independent contractors and consultants.

​​

Disclosure of technical (non-personal) data

Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving The Website, responding to lawful requests from public authorities or developing new products and services.

 

Legal requests

If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

 

Successors

In case the Website is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this privacy policy. We will notify you of any changes of the data controller.

​

Selling personal data

We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your cookies as described in the section Tracking & Cookie Data.

​

International transfers

Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your personal data.

​

Retention Period

​​

Retention of personal data

We store your personal data in our systems only for as long as such personal data is required for its initial purposes described in this privacy policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

 

Retention of the Usage Data

We retain non-personal data pertaining to you for as long as necessary for the purposes described in this privacy policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

 

Retention as required by law

In certain cases, we are required by law to store your personal data for a certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

 

Our Communication with You

 

Newsletters

If we have your email address, we may, from time to time, send you a newsletter informing you about the updated editorial content, latest developments related to the Website and our special offers. You will receive our newsletters in the following instances:

• If we receive your express (“opt-in”) consent to receive marketing messages; or

• If you voluntarily subscribe for our newsletter on the Website; or

• If we decide to send you information closely related to services already used or products purchased by you.

 

Opting-out

You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

 

Service-related notices

If necessary, we will send you important informational messages, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

 

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal pata, we cannot guarantee its absolute security. The security measures taken by us include:

• Access control;

• Secured networks;

• SSL protocol;

• Strong passwords;

• Anonymisation of personal data (when possible); and

• Carefully selected data processors. 

 

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites.

 

Children's Privacy

Our Website does not address anyone under the age of 18 ("Children").

We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us. If we become aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.

 

Your Rights

 

You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

• Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;

• Right to rectification: you can rectify inaccurate personal data that we hold about you;

• Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;

• Right to restriction: you can ask us to restrict the processing of your personal data;

• Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;

• Right to object: you can ask us to stop processing your personal data;

• Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or

• Right to complaint: you can submit your complaint regarding our processing of your personal data.

 

How to exercise your rights?

If you would like to exercise any of your rights, please contact us by email or by post (you can find our contact details at the end of this privacy policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

 

Complaints

If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

 

Non-discrimination

We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

 

Changes to This Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page.

We will let you know via email and/or a prominent notice on the Website, prior to the change becoming effective and update the "effective date" at the top of this privacy policy.

You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this privacy policy, please contact us:

•          By email: direttivo@alfabreraprivilege.com