Legal Notice

** This is a translation of the original text (in French). Only the French version is legally binding **

The website accessible at www.claapp.app (hereinafter referred to as the « Site ») and the CLAAPP mobile application (hereinafter referred to as the « Application ») are operated by 90-52 Sàrl (hereinafter « CLAAPP »), c/o Fiduciaire Rutz-Menger Sàrl, 3, rue de l’Hôpital, 2520 La Neuveville, Switzerland, registered in the commercial register of the Chamber of Commerce of the Canton of Zurich under number CHE-113.545.692.

The company is under the responsibility of the managing director: Pascal O’Neill.

In order to get your questions and comments answered as quickly as possible, please use our contact form or contact us by e-mail at the following address: hello@claapp.app.

The texts and illustrations are protected by intellectual property law. Any use without prior authorisation is prohibited.

Data Protection Statement

** This is a translation of the original text (in French). Only the French version is legally binding **

This Personal Data Protection Policy contains information on the nature of the personal data that 90-52 Sàrl (hereinafter « CLAAPP » or « we ») collects from you (hereinafter the « User » or « you ») and how and for what purposes it processes them. It applies to all personal data collected when using the website accessible at (hereinafter the « Site »), the CLAAP application (hereinafter the « Application ») and more generally the CLAAPP services (hereinafter the « Services »).

Date of last modification: 12/01/2020.

Summary of topics

  • * 1. Data controller
  • * 2. General purposes of data processing
  • * 3. Which data we use and why
  • * 4. Cookies
  • * 5. Social plug-ins
  • * 6. Internet analysis services
  • * 7. Rights of the data subject
  • * 8. Right of opposition
  • * 9. Data security
  • * 10. Transfer of data to third parties
  • * 11. Modification of the personal data protection policy
  • * 12. Contact

1. Data controller

The entity responsible for the collection, processing, and use of your personal data: 90-52 Sàrl
c/o Fiduciaire Rutz-Menger Sarl, 3, rue de l’Hôpital, 2520 La Neuveville, Switzerland
Company identification number: CHE-113.545.692
Tel : +41 77 504 62 94
Email: hello@claapp.app

2. General purposes of data processing

CLAAPP uses your personal data in order to guarantee the functionality of the Site, the Application, and the Services, and to provide the Services and related content. CLAAPP processes personal data in a responsible, accurate, and targeted manner. In doing so, CLAAPP adheres to the requirements of applicable data protection law.

3. Which data we use and why

3.1 Access data

When the User visits the Site, the browser used on the User’s computer or mobile phone automatically sends data to the Site’s server. When the User uses the Application, the Application also automatically sends data to the Application server. This data is temporarily stored in a log file. The following data are collected without your intervention and stored until they are deleted:

  • * Name and URL of the retrieved file.
  • * Date and time of retrieval.
  • * Amount of data transferred.
  • * Notification of successful retrieval (HTTP response code).
  • * Browser type and version.
  • * Operating system.
  • * Referrer URL (i.e. the page previously visited).
  • * Websites called by the User’s system via our Site.
  • * The User’s Internet service provider.
  • * IP address and the requesting provider.

We use this protocol data, without assigning it to you or creating any other form of profiling, in order to perform statistical analyses with the goal of improving the operation, security, and optimisation of our Site and/or Application, but also to determine the extent and nature of the use of our Site and/or Application and Services. On the basis of this data, we may provide personalised and localised content, analyse traffic, search for and correct errors, and improve our services.
This use of the data also constitutes our legitimate interest.
We reserve the right to subsequently check the protocol data if, on the basis of concrete evidence, there is a legitimate suspicion of unlawful use. We store IP addresses in log files for a limited period of time when necessary for security reasons or for the provision of services or billing of a service, for example, if you subscribe to one of our offers. We also record the date of your last visit as part of your User account activity (e.g. when you register, log in, click on links, etc.).

3.2 Data to enable us to fulfil our contractual obligations

We process the personal data that we need in order to fulfil our contractual obligations to you, such as your first name, surname, date of birth, e-mail address, and billing and payment data. In addition, for processing payments and depending on the method and process of payment chosen, we pass on your personal data to banks, payment service providers, financial service providers, and credit card companies. The deletion of this data takes place after the expiry of the statutory retention periods.
The data associated with a User account (see below) will be kept in all cases for the duration of the account’s activity.
We may also use your personal data to verify compliance with the terms and conditions of use and thus to combat fraud.
The legal basis for processing this data is the execution of the contract concluded with you and our legitimate interest in combating fraud.

3.3 User account

When you register, we also need you to provide us with some contact data, such as your first name, surname, address, date of birth, e-mail address, and telephone number, in addition to the access data (username and password).
You can request to unsubscribe and to close your account. After deletion and closure of your User account, we will delete your stored personal data.
The legal basis for the processing of this data is your consent.

3.4 E-mail and other forms of contact (written opinions, contact with customer service)

If you contact us (for example via a contact form or an e-mail), we will process your data to deal with the request or notification and to answer any follow-up questions.
If the data processing takes place for the purpose of carrying out pre-contractual measures taken upon your request, for example if you are already our customer, for the performance of the contract, then the legal basis for the data processing is the performance of the contract.
We will only process further personal data if you consent or if we have a legitimate interest in doing so. A legitimate interest lies, for example, in replying to your e-mail or any other request.

4. Cookies

CLAAPP uses cookies to simplify the use of the Services and to obtain information in order to improve its Services. In particular, we use session cookies to optimise our Site.
A session cookie is a small text file sent by the servers concerned when visiting the Site and stored on your hard drive. This file contains a session ID (identifier) with which various requests from your browser can be assigned to the shared session. These cookies are deleted after closing your browser. They make it possible, for example, to use the shopping cart function on several pages.
We also use a small amount of permanent cookies (also small text files stored on your device) which remain on your device and enable us to recognise your browser the next time you visit. These cookies are stored on your hard drive and are automatically deleted after a predetermined period of time. Their life span is from 1 month to 10 years. Cookies enable us to offer more user-friendly services in an efficient and secure way and, for example, to display information on the page that corresponds to your interests.
Additionally, we use interest-based advertising on our Site using advertising cookies, including retargeting/remarketing technologies from the third-party provider (.). These enable us to display personalised advertising content on third party websites based on the interest you express in our products and services when you visit our Site.
Our legitimate interest in the use of cookies is to make our Site more user-friendly, efficient, and secure and to adapt the information available to your interests in the best possible way and to make your online experience as informative as possible.
Cookies store the following data and information:

  • * Login information.
  • * Language settings.
  • * Search terms entered.
  • * Information on the number of visits to our Site and the use of the individual features of our Site.

When the cookie is activated, it is assigned an identification number and no assignment of your personal data to this identification number will be made. Your name, IP address, or similar data that would allow the cookie to be associated with your account will not be included in the cookie. On the basis of cookie technology, we only receive anonymous or pseudonymised information, for example regarding which pages were visited on our Site.
You can configure your browser in order to be informed in advance about the setting of cookies and decide on a case-by-case basis whether or not to accept cookies in certain cases or in general, or whether cookies should be completely prohibited. This may limit the functionality of websites.

5. Internet analysis services

We use different software solutions to optimise our online offer. Thanks to these software solutions, the use of our Site can be evaluated and valuable information on user needs can be collected in order to continuously increase the usability of the online service and its quality. In order to carry out these analyses, aggregated and anonymous statistical data is collected. This data is non-personal connection and movement data related to the browser used, the number of pages viewed and the number of visits, browsing behaviour and the length of time a visitor spends on a website. During collection and processing, the visitor’s shortened IP address is also taken into account.
The data is evaluated in particular for the following purposes:

  • * Counting of visitors.
  • * Evaluation of areas of a website that are particularly attractive to the visitor concerned.
  • * Evaluation of the origin of visitors in order to optimise the offer.
  • * Managing targeted recommendations.

This procedure uses so-called permanent cookies (see point 4 above). The User can refuse the installation of cookies at any time or only allow them to be saved after explicit confirmation via the browser settings. In addition, the User has the option to prevent the use of the data at any time by choosing the « opt-out » option offered by all deployed solutions. In the event of opposition, however, no specific recommendation can be made.
CLAAPP uses the following software solutions in the above-mentioned sense (a click on the respective provider leads to the « opt-out » option):
Google : http://www.google.com/settings/ads
Google Analytics : https://tools.google.com/dlpage/gaoptout/
Facebook : http://www.youronlinechoices.com/ch-fr/controler-ses-cookies
Note: Opting out is done by means of a cookie. If this cookie is deleted, a new opt-out is required.

6. Rights of the data subject

You have the following rights regarding your personal data. If you wish to exercise these rights, please send your request by e-mail or post, clearly stating your identity, to the address given in point 1. You may:

  • * Request information about your personal data processed by us. In particular, you may request information about the purposes of the processing, the category of personal data, the category of recipients to whom your data are or have been disclosed, the intended storage period, the right of rectification; deletion, limitation of processing or opposition, the right to lodge a complaint, the origin of your data if they are not collected from us, and the existence of automated decision-making, including profiling and useful information on their details.
  • * Request as soon as possible that incorrect personal data be corrected or that incomplete data stored on our servers be completed.
  • * Require the deletion of your personal data stored on our servers, unless the processing of such data is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest, or to establish, exercise, or defend legal rights.
  • * Require the restriction of the processing of your personal data, if (i) you contest the accuracy of the data, (ii) the data processing is unlawful and you object to its deletion, (iii) we no longer need the data, and you need it for the establishment, exercise or defence of legal claims, or (iv) you have objected to the data processing while verifying whether the legitimate reasons pursued by our company prevail over yours.
  • * Receive the personal data you have provided us with in a structured, commonly used, and machine-readable format or require the data to be transmitted to another data controller.
  • * Withdraw your consent once given at any time. Consequently, we cannot continue processing data based on this consent in the future.
  • * Submit a complaint to a supervisory authority. As a general rule, you can contact the supervisory authority of your usual place of residence or work or that of our registered office.

7. Right of opposition

If your personal data are processed on the basis of legitimate interests, you have the right to object to the processing of your personal data, insofar as there are reasons related to your particular situation or if the opposition is directed against direct mail. In the latter case, you have a general right of opposition, which we implement without specifying any particular situation.

8. Data security

We make every effort to ensure the security of your data in accordance with applicable data protection laws and technical possibilities.
The personal data transmitted to us are encrypted. This applies to your orders and also to the connection via your customer account. We use the SSL (Secure Socket Layer) encryption system, but we would like to point out that data transmission over the Internet (e.g. in the case of communication by e-mail) may have security breaches. Complete data protection against access by third parties is not possible.
To protect your data, we implement technical and organisational security measures that we continuously adapt to the state of technological knowledge.
We also do not guarantee that our offer will be available at all times, as disruptions, interruptions, or failures cannot be excluded. The servers we use are regularly backed up with care.

9. Transfer of data to third parties

As a general rule, your personal data will only be used within the framework of use by our company.
However, CLAAPP may pass on your personal data to companies whose services are related to the activities of CLAAPP with the sole purpose of optimising CLAAPP’s services.
Apart from the cases mentioned in this explanation (see in particular point 6), there is no transfer of data to third parties outside Switzerland and the European Economic Area (EEA), and this is not foreseen.

10. Modification of the personal data protection policy

CLAAPP reserves the right to modify this personal data protection policy at any time. The changes will be published on the Site and the Application and will take effect as soon as they are activated.

11. Contact

If you have any questions or concerns regarding data protection, please contact us by sending a message via the contact details mentioned in point 1.