Privacy Policy of creative.ch

Data Controller

CREATIVE DIGITAL SAGL
Via Ronchetto 7
6900 Lugano (CH)

Holder's email address: info@creative.ch

Types of Data Collected

Among the Data collected by creative.ch, either independently or through third parties, are: last name; first name; phone number; email; 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 dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such Data.
Personal Data may be freely provided by the User or, in the case of User Data, automatically collected during the use of creative.ch.

Unless otherwise specified, all Data requested by creative.ch is mandatory. If the User refuses to communicate them, it may be impossible for creative.ch to provide the Service. In cases where creative.ch indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who have any doubts as to which Data is mandatory are encouraged to contact the Data Controller.
Any use of Cookies - or other tracking tools - by creative.ch or the owners of third party services used by creative.ch is for the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through creative.ch.

Method and place of processing of collected Data Processing methods

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties involved in the organization of creative.ch (administrative, sales, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Location

The Data is processed at the Owner's operational headquarters and at any other location where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User's Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.

Retention period

Unless otherwise stated in this document, Personal Data are processed and kept for the time required by the purpose for which they were collected and may be kept for a longer period due to any legal obligations or based on the consent of Users.

Purposes of the Processing of Collected Data

The User Data is collected to enable the Owner 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), detect any malicious or fraudulent activities, as well as for the following purposes: Accessing 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.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section "Personal Data Processing Details."

Facebook permissions required by creative.ch

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

For more information on the following permissions, refer to the Facebook permissions documentation and Facebook's privacy policy.

The required permits are as follows:

Background information

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and language of location and, in some cases Facebook "Friends". If the User has made additional Data publicly available, the same will be available.

Access to private data

Allows access to User's and friends' private data.

Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services:

Access to accounts on third-party services

These types of services allow creative.ch to take Data from your accounts on third-party services and perform actions with them. These services are not activated automatically, but require your express permission.

Facebook Account Login (Meta Platforms Ireland Limited)

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

Permissions required: Access to private data. Place of processing: Ireland - Privacy Policy.

Contacting the User

Contact form (creative.ch)

The User, by filling out the contact form with their Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.

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

Mailing list or newsletter (creative.ch)

By registering for the mailing list or newsletter, the User's email address is automatically added to a contact list to which email messages containing information, including information of a commercial and promotional nature, relating to creative.ch may be sent. The User's 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; first name; phone number.

Creation and management of creative.ch

The main components of creative.ch are created and managed directly by the Owner making use of the software mentioned below.

WordPress (self-hosted) (creative.ch)

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

Tag management

This type of services is functional for the centralized management of tags or scripts used on creative.ch.
The use of these services involves the flow of User Data through them and, where appropriate, their retention.

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

This type of service allows 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 that handle remarketing and behavioral targeting activities.

Some services offer an email list-based remarketing option.
Generally, services of this type offer the ability to disable such tracking. In addition to any opt-out feature provided by any of the services listed in this document, the User can read more about how to turn off interest-based advertisements in the appropriate "How to turn off interest-based advertising" section in this document.

Custom audience of Meta (Meta Platforms Ireland Limited)

Meta's Personalized Audiences is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that links creative.ch's business with Meta's advertising network.

Users can opt-out of Meta's Tracking Tools for ad personalization by visiting this opt-out page.

Personal Data Processed: email; Tracking Tools. Place of processing: Ireland - Privacy Policy - Opt out.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve 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 for the purpose of tracking and examining the use of creative.ch, compiling reports, and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize ads in its ad network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. You can learn more about this in Google's official documentation.

Personal Data Processed: Usage Data; number of Users; session statistics; Tracking Tools. Place of Processing: Ireland - Privacy Policy - Opt Out.

Meta ads conversion monitoring (Meta pixel) (Meta Platforms Ireland Limited)

Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms Ireland Limited that links data from the Meta ad network with actions taken within creative.ch. The Meta pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data Processed: Usage Data; Tracking Tools. Place of processing: Ireland - Privacy Policy - Opt out.

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is a statistics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner information about traffic and interactions on creative.ch.

Personal Data Processed: Tracking Tools.
Place of processing: Ireland - Privacy Policy - Opt out.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of creative.ch and interact with them.
This type of service may still collect data about web traffic 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 style display service operated by Fonticons, Inc. that allows creative.ch to integrate such content within its pages.

Personal Data Processed: Usage Data; Tracking Tools. Place of processing: United States - Privacy Policy.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows creative.ch to integrate such content within its pages.

Personal Data Processed: Usage Data; Tracking Tools. Place of processing: Ireland - Privacy Policy.

Information on how to turn off interest-based advertisements

In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to turn off interest-based advertisements in the appropriate section of the Cookie Policy.

Cookie Policy

Creative.ch makes use of Tracking Tools. To learn more, Users can consult the Cookie Policy.

More information for users

Legal basis for processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

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 need for 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 legislation on the protection of Personal Data; the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;

processing is necessary to fulfill a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;

processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Additional information on shelf life

Unless otherwise stated in this document, Personal Data are processed and kept for the time required by the purpose for which they were collected and may be kept for a longer period due to any legal obligations or based on the consent of Users.

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 such contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User's consent, the Controller may retain Personal Data longer until that consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller. In particular, to the extent permitted by law, Users have the right to:

Revoke consent at any time. The User may revoke the consent to the processing of his/her Personal Data previously given.
object to the processing of his/her Data. The User may object to the processing of his or her Data when it takes place under a legal basis other than consent.

access to their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
verify and request rectification. The User may verify the correctness of his/her Data and request that it be updated or corrected.

obtain restriction of processing. The User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
obtain the deletion or removal of its Personal Data. The User may request the deletion of his/her Data by the Data Controller.

Receive their Data or have their Data transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller.
bring a complaint. The User may propose a complaint to 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 formed by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect their Data.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reasons. If Users object to processing for direct marketing purposes, Personal Data are no longer processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. The request is free of charge and the Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, deletion or restriction of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller shall notify the User of such recipients if the User so requests.

More information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in the Privacy Policy.

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" within this document.

Users' rights under the Federal Data Protection Act

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 deletion or destruction of Personal Data, and the prohibition of 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 erroneous Personal Data.

How to exercise these rights

Any requests to exercise the User's rights may be addressed to the Controller through the contact details provided in this document. Such requests are free of charge and the Controller will respond as soon as possible, providing Users with the information required by law.

More information about treatment Defense in court

The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of its possible establishment for the defense against abuse in the use of creative.ch or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

Upon the User's request, in addition to the information contained in this privacy policy, creative.ch may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

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

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

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, when technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will re-collect the User's consent, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information collected automatically through creative.ch (including by third party applications integrated into creative.ch), including: the IP addresses or domain names of the computers used by the User who connects with creative.ch, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User's operating system and computer environment.

User

The individual using creative.ch who, except where otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data refers.

Processor (or Manager)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set forth in this privacy policy.

Data Controller (or Owner)

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

creative.ch (or this Application)

The hardware or software tool by which Users' Personal Data are collected and processed.

Service

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

European Union (or EU)

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

Cookie

Cookies are Tracking Tools that consist of small portions of data stored within the User's browser.

Tracking Tool

Tracking Tool means any technology - e.g., cookies, unique identifiers, web beacons, embedded scripts, e- tags, and fingerprinting - that enables 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 taking appropriate security measures. Some of the measures we take to prevent unauthorized access, disclosure, alteration or destruction of data are described below:

  1. Cryptography

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

    • We restrict access to personal information only to employees, agents, contractors, and other third parties who have a need to know. These individuals are subject to strict confidentiality obligations.
  3. Protection of Information Systems

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

    • We regularly perform backups of personal data to ensure their 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 multifactor authentication.
  8. Safety Incident Management

    • We have procedures in place to handle any security incidents. In the event of a data breach, we will promptly notify the appropriate authorities and data subjects.

Legal references

This privacy policy is prepared on the basis of multiple legislative orders.
Unless otherwise specified, this privacy policy covers creative.ch only. 

Last modified: January 4, 2024