Privacy Policy of creative.ch

Data Controller

CREATIVE DIGITAL SAGL
Via Ronchetto 7
6900 Lugano (CH)

Data Controller's email address: [email protected]

Types of Data Collected

The Data collected by creative.ch, either directly or through third parties, includes: last name; first name; phone number; email address; various types of Data; Tracking Tools; usage Data; number of Users; session statistics.

Full details on each type of Personal Data collected are provided in the relevant sections of this privacy policy or through specific notices displayed before the Data is collected.
Personal Data may be voluntarily provided by the User or, in the case of Usage Data, collected automatically while using creative.ch.

Unless otherwise specified, all Data requested by creative.ch is required. If the User refuses to provide this Data, creative.ch may be unable to provide the Service. In cases where creative.ch indicates that certain Data is optional, Users are free to choose not to provide such Data, without this having any impact on the availability or functionality of the Service.

Users who have questions about which Data is required are encouraged to contact the Data Controller.
Any use of cookies—or other tracking tools—by creative.ch or by the operators of third-party services used by creative.ch is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for any third-party Personal Data obtained, published, or shared through creative.ch.

Methods and Location of Data Processing; Methods of Processing

The Data Controller implements appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.
Data processing is carried out using IT and/or telecommunications tools, with organizational procedures and logic strictly related to the specified purposes. In addition to the Data Controller, in some cases, other individuals involved in the organization of creative.ch (administrative, sales, marketing, and legal staff, as well as system administrators) or external parties (such as third-party technical service providers, postal carriers, hosting providers, IT companies, and communications agencies) may have access to the Data; these parties may also be appointed, if necessary, as Data Processors by the Data Controller. An updated list of Data Processors may be requested at any time from the Data Controller.

Location

The Data is processed at the Data Controller’s operational facilities and at any other location where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. For further information on the location of processing, the User may refer to the section detailing the processing of Personal Data.

Shelf Life

Unless otherwise specified in this document, Personal Data is processed and retained for as long as necessary to fulfill the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on Users’ consent.

Purpose of Processing the Collected Data

User Data is collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Access to accounts on third-party services, Contacting the User, remarketing and behavioral targeting, statistics, displaying content from external platforms, tag management, and creation and management of creative.ch.

For detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Details on the Processing of Personal Data.”

Facebook Permissions Requested by creative.ch

Creative.ch may request certain Facebook permissions that allow it to perform actions with the User’s Facebook account and to collect information, including Personal Data, from it. This service allows Creative.ch to connect to the User’s account on the Facebook social network, provided by Facebook Inc.

For more information about the permissions listed below, please refer to Facebook's permissions documentation and Facebook's privacy policy.

The required permits are as follows:

Basic Information

The basic information of a registered Facebook user, which typically includes the following data: ID, name, profile picture, gender, and language, and, in some cases, Facebook “Friends.” If the user has made additional data publicly available, that data will also be available.

Access to Personal Data

It allows access to the User's and their friends' private data.

Details on the Processing of Personal Data

Personal Data is collected for the following purposes and through the following services:

Access to Accounts on Third-Party Services

These types of services allow creative.ch to retrieve data from your accounts on third-party services and perform actions with that data. These services are not enabled automatically; they require the User’s express authorization.

Facebook Account Login (Meta Platforms Ireland Limited)

This service allows creative.ch to connect to the User’s account on the social network Facebook, provided by Meta Platforms Ireland Limited.

Permissions Requested: Access to personal data. Location of Processing: Ireland – Privacy Policy.

Contact the User

Contact Form (creative.ch)

By filling out the contact form with their personal data, the User consents to its use to respond to requests for information, quotes, or any other purpose indicated in the form header.

Personal Data Processed: ZIP code; city; last name; date of birth; email address; country; first name; phone number; various types of data.

Mailing list or newsletter (creative.ch)

When you subscribe to the mailing list or newsletter, your email address is automatically added to a contact list to which we may send emails containing information—including commercial and promotional content—related to creative.ch. Your email address may also be added to this list as a result of registering with creative.ch or after making a purchase.

Personal Data Processed: last name; email address; first name; phone number.

Creation and Management of creative.ch

The main components of creative.ch are created and managed directly by the Owner using the software listed below.

WordPress (self-hosted) (creative.ch)

Creative.ch is developed and managed by the Data Controller using a CMS (Content Management System) called WordPress. Personal Data processed: last name; email address; first name; phone number.

Tag Management

These types of services are used for the centralized management of tags or scripts used on creatives.ch.
The use of these services involves the transmission of User Data through them and, where applicable, the retention of such data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data Processed: Tracking Tools.
Place of Processing: Ireland – Privacy Policy.

Remarketing and Behavioral Targeting

These types of services allow creative.ch and its partners to communicate, optimize, and serve advertisements based on the User’s past use of creative.ch.
This activity is facilitated by tracking Usage Data and using Tracking Tools to collect information that is then transferred to partners who manage remarketing and behavioral targeting activities.

Some services offer a remarketing option based on email address lists.
Generally, services of this type offer the option to disable such tracking. In addition to any opt-out features provided by any of the services listed in this document, the User can read more about how to disable interest-based ads in the section titled “How to Disable Interest-Based Advertising” in this document.

Meta Custom Audiences (Meta Platforms Ireland Limited)

Meta Custom Audiences is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects creative.ch’s activities with Meta’s advertising network.

Users can choose not to use Meta's tracking tools for ad personalization by visiting this opt-out page.

Personal Data Processed: email; Tracking Tools. Location of Processing: Ireland – Privacy Policy – Opt Out.

Statistics

The services included in this section allow the Data Controller to monitor and analyze traffic data and are used to track User behavior.

Google Analytics 4 (Google Ireland Limited)

Google Analytics is a statistics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected to track and analyze the use of creative.ch, compile reports, and share them with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads on its advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is stored in any data center or server. For more information, please refer to Google’s official documentation.

Personal Data Processed: Usage data; number of users; session statistics; tracking tools. Location of processing: Ireland – Privacy Policy – Opt Out.

Meta Ads Conversion Tracking (Meta Pixel) (Meta Platforms Ireland Limited)

Meta Ads conversion tracking (Meta Pixel) is a analytics service provided by Meta Platforms Ireland Limited that links data from the Meta ad network with actions taken on creatives.ch. The Meta Pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and the Audience Network.

Personal Data Processed: Usage Data; Tracking Tools. Location of Processing: Ireland – Privacy Policy – Opt Out.

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can provide the Data Controller with information about traffic and interactions on creatives.ch.

Personal Data Processed: Tracking Tools.
Place of Processing: Ireland – Privacy Policy – Opt Out.

Displaying Content from External Platforms

These types of services allow you to view content hosted on external platforms directly from the pages on creative.ch and to interact with that content.
However, these types of services may still collect web traffic data related to the pages where the service is installed, even when users are not using it.

Font Awesome (Fonticons, Inc.)

Font Awesome is a font styling service operated by Fonticons, Inc. that allows creative.ch to embed such content within its pages.

Personal Data Processed: Usage Data; Tracking Tools. Location of Processing: United States – Privacy Policy.

Google Fonts (Google Ireland Limited)

Google Fonts is a typeface rendering service operated by Google Ireland Limited that allows creative.ch to embed such content within its pages.

Personal Data Processed: Usage Data; Tracking Tools. Location of Processing: Ireland – Privacy Policy.

Information on how to turn off interest-based ads

In addition to any opt-out options provided by any of the services listed in this document, Users can read more about how to disable interest-based ads in the relevant section of the Cookie Policy.

Cookie Policy

Creative.ch uses tracking tools. To learn more, users can review the Cookie Policy.

Additional Information for Users

Legal Basis for Data Processing

The Data Controller processes Personal Data relating to the User if any of the following conditions apply:

the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European data protection legislation; the processing is necessary for the performance of a contract with the User and/or for the implementation of precontractual measures;

the processing is necessary to comply with a legal obligation to which the Data Controller is subject;
the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

The processing is necessary for the purposes of the legitimate interests of the Data Controller or of third parties.

In any case, you may always ask the Data Controller to clarify the specific legal basis for each processing activity and, in particular, to specify whether the processing is based on law, required by a contract, or necessary to enter into a contract.

More information on shelf life

Unless otherwise specified in this document, Personal Data is processed and retained for as long as necessary to fulfill the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on Users’ consent.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes based on the Data Controller’s legitimate interest will be retained until that interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. In addition, the Data Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or pursuant to an order from an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon the expiration of that period, the right of access, erasure, rectification, and data portability can no longer be exercised.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller. Specifically, within the limits provided by law, the User has the right to:

Withdraw consent at any time. The User may withdraw the consent previously given for the processing of their Personal Data.
Object to the processing of their Data. The User may object to the processing of their Data when it is based on a legal basis other than consent.

Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing, and to receive a copy of the processed Data.
Verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.

Request restriction of processing. The User may request that the processing of their Data be restricted. In such cases, the Data Controller will not process the Data for any purpose other than storage.
Request erasure or removal of their Personal Data. The User may request that the Data Controller erase their Data.

receive their Data or have it transferred to another data controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller.
file a complaint. The User may file a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad, including to any international organization governed by international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect their Data.

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are advised that, if their Data is processed for direct marketing purposes, they may object to such processing at any time, free of charge and without providing any reason. If Users object to processing for direct marketing purposes, their Personal Data will no longer be processed for those purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to Exercise Your Rights

To exercise their rights, Users may submit a request to the Data Controller’s contact information provided in this document. The request is free of charge, and the Data Controller will respond as soon as possible—and in any case within one month—providing the User with all the information required by law. Any corrections, deletions, or restrictions on processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of these recipients upon request.

Additional Information for Users in Switzerland

This section applies to Users in Switzerland and, for those Users, supersedes any other information in the privacy policy that may differ from or conflict with it.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of personal data (if any), the retention period, and other information about personal data can be found in the section titled “Detailed Information on the Processing of Personal Data” in this document.

User Rights Under the Federal Act on the Protection of Personal Data

Users may exercise certain rights regarding their data within the limits of the law, including the following:

Right of access to Personal Data;
the right to object to the processing of one’s Personal Data (which also allows Users to request the restriction of the processing of Personal Data, the erasure or destruction of Personal Data, or a prohibition on the disclosure of Personal Data to third parties);
the right to receive one’s Personal Data and to transfer it to another data controller (data portability);
the right to request the rectification of inaccurate Personal Data.

How to Exercise These Rights

Any requests to exercise the User’s rights may be directed to the Data Controller using the contact information provided in this document. These requests are free of charge, and the Data Controller will respond as soon as possible, providing Users with the information required by law.

More information on the "Legal Defense" treatment

The User’s Personal Data may be used by the Data Controller in legal proceedings or during the preparatory stages leading up to such proceedings to defend against any misuse of creative.ch or related Services by the User.
The User acknowledges that the Data Controller may be required to disclose the Data upon order of public authorities.

Specific Information

At the User’s request, in addition to the information contained in this privacy policy, creative.ch may provide the User with additional, context-specific notices regarding specific Services or the collection and processing of Personal Data.

System Logs and Maintenance

For operational and maintenance purposes, creative.ch and any third-party services it uses may collect system logs—that is, files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information Not Included in This Policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact information provided.

Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on creative.ch, as well as—where technically and legally feasible—by sending a notification to Users via one of the contact details on file. Please check this page frequently, referring to the last modified date indicated at the bottom.

If the changes affect processing activities for which the legal basis is consent, the Data Controller will obtain the User’s consent again, if necessary.

Definitions and Legal References

Personal Data (or Data)

Personal data is any information that, directly or indirectly—including in combination with any other information, such as a personal identification number—identifies or makes a natural person identifiable.

Usage Data

This is information collected automatically through creative.ch (including from third-party applications integrated into creative.ch), such as: the IP addresses or domain names of the computers used by Users connecting to creative.ch, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, various time-related details of the visit (such as the time spent on each page), and details regarding the path taken within the Application, with particular reference to the sequence of pages viewed and parameters related to the User’s operating system and computing environment.

User

The individual who uses creative.ch, who, unless otherwise specified, is the same as the Data Subject.

Interested

The natural person to whom the Personal Data relates.

Data Controller (or Controller)

Any natural person, legal entity, government agency, or other entity that processes personal data on behalf of the Data Controller, as set forth in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, agency, or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the measures adopted, including security measures relating to the operation and use of creative.ch. Unless otherwise specified, the Data Controller is the owner of creative.ch.

creative.ch (or this App)

The hardware or software tool used to collect and process Users' Personal Data.

Service

The Service provided by creative.ch, as defined in the applicable terms (if any) on this website/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document is understood to include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are tracking tools that consist of small pieces of data stored in the user's browser.

Tracking Tool

“Tracking Tool” means any technology—such as cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that allows for the tracking of Users, for example by collecting or storing information on the User’s device.

Data Security

We are committed to protecting your personal data by implementing appropriate security measures. Below are some of the measures we take to prevent unauthorized access, disclosure, alteration, or destruction of data:

  1. Encryption

    • We use SSL (Secure Socket Layer) encryption to protect your personal data during transmission between your browser and our servers.
  2. Access Controls

    • We restrict access to personal data to only those employees, agents, contractors, and other third parties who need to know it. These individuals are subject to strict confidentiality obligations.
  3. Information Systems Security

    • Our computer systems are protected by firewalls, antivirus software, and intrusion detection systems.
  4. Data Backup

    • We regularly back up personal data to ensure its availability and integrity.
  5. Auditing and Monitoring

    • We conduct regular audits and monitoring of our security practices and systems.
  6. Staff Training and Awareness

    • We regularly train our staff on data security best practices.
  7. Access and Authentication Policy

    • We implement strict authentication and authorization policies, including multi-factor authentication.
  8. Security Incident Management

    • We have procedures in place to handle any security incident. In the event of a data breach, we will promptly notify the relevant authorities and the affected individuals.

Legal References

This privacy policy is based on various legal frameworks.
Unless otherwise specified, this privacy policy applies exclusively to creative.ch. 

Last updated: January 4, 2024