Privacy Policy of creative.ch

Data Controller

CREATIVE DIGITAL SAGL
Via Ronchetto 7
6900 Lugano (CH)

Email address of the Data Controller: info@creative.ch

Types of Data Collected

The Data collected by creative.ch, either independently or through third parties, includes: last name; first name; telephone 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 dedicated sections of this privacy policy or through specific information texts displayed before the Data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of creative.ch.

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

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
Any use of Cookies – or other tracking tools – by creative.ch or by 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 other 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.

Methods and location of processing of collected data Methods of processing

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

Location

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller.
The User's Personal Data may be transferred to a country other than that in which the User is located. For further information on the place of processing, the User may refer to the section on the details of the processing of Personal Data.

Retention period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required for the purposes for which it was collected and may be stored for a longer period due to legal obligations or based on the consent of Users.

Purpose of Data Processing

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), identify any malicious or fraudulent activities, as well as for the following purposes: Access to accounts on third-party services, Contact the User, Remarketing and behavioral targeting, Statistics, Displaying content from external platforms, Tag management, and Creation and management of creatives.

For detailed information on the purposes of the 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 collect information, including Personal Data, from it. This service allows creative.ch to connect with the User's account on the Facebook social network, provided by Facebook Inc.

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

The following permits are required:

Basic information

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

Access to private data

Allows access to the private data of the User and friends.

Details on the processing of Personal Data

Personal Data is 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 retrieve Data from your accounts on third-party services and perform actions with them. These services are not activated automatically, but require the User's express authorization.

Access to Facebook account (Meta Platforms Ireland Limited)

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

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

Contact the User

Contact form (creative.ch)

By filling in the contact form with their data, users consent to its use to respond to requests for information, quotes, or any other matter 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)

By registering for the mailing list or newsletter, the User's email address will be automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, 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 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 mentioned below.

WordPress (self-hosted) (creative.ch)

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

Tag management

This type of service is functional to 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, if applicable, 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 enables 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 feature provided by any of the services listed in this document, the User can read more about how to disable interest-based advertising in the section "How to disable interest-based advertising" in this document.

Meta Custom Audience (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 activity 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. 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 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 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 Personal Data to contextualize and personalize the ads of its own advertising 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. To learn more, you can consult 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 tracking (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 tracks 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 provide the Data Controller with 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 it.
This type of service may still collect web traffic data relating to the pages where the service is installed, even when users do not use it.

Font Awesome (Fonticons, Inc.)

Font Awesome is a font style display service managed by Fonticons, Inc. that allows creative.ch to integrate such content into 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 display service managed by Google Ireland Limited that allows creative.ch to integrate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools. Place of processing: Ireland – Privacy Policy.

Information on how to disable interest-based ads

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

Cookie Policy

Creative.ch uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Additional information for users

Legal basis for processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

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, until the User objects ("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 implementation of pre-contractual 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;

processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

However, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing operation and, in particular, to specify whether the processing is based on the law, provided for in a contract, or necessary for the conclusion of a contract.

Further information on storage time

Unless otherwise specified in this document, Personal Data is processed and stored for the time required for the purposes for which it was collected and may be stored for a longer period due to legal obligations or based on the consent of Users.

Therefore:

Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of that contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller 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 the processing is based on the User's consent, the Data Controller may store the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to store 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, Personal Data will be deleted. Therefore, upon expiry 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 regard to the Data processed by the Data Controller. In particular, within the limits provided for by law, the User has the right to:

withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.
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 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 can verify the correctness of their Data and request its updating or correction.

obtain the restriction of processing. The User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.
obtain the erasure or removal of their Personal Data. The User may request the erasure of their Data by the Data Controller.

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.
lodge a complaint. The User may lodge 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 public powers vested in the Data Controller, or to pursue 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 advised that, if their Data is processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any justification. If Users object to processing for direct marketing purposes, their Personal Data will no longer be processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise your rights

To exercise their rights, Users may send a request to the Data Controller's contact details indicated 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 limitations of processing will be communicated by the Data 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 will inform the User of these recipients if requested to do so.

Additional information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other information that may be inconsistent or conflicting in the privacy policy.

Further details regarding the categories of Data processed, the purposes of the processing, the categories of recipients of the personal data, if any, the retention period, and other information about Personal Data can be found in the section entitled "Detailed information on the processing of Personal Data" within this document.

User rights under the Federal Act on Data Protection

Users may exercise certain rights relating to 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 your Personal Data (which also allows Users to request the restriction of the processing of Personal Data, the erasure or destruction of Personal Data, and the prohibition of disclosure of Personal Data to third parties);
the right to receive your Personal Data and transfer it to another data controller (data portability);
the right to request the rectification of incorrect Personal Data.

How to exercise these rights

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

Further information on processing Defense in court

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of any legal proceedings to defend against abuse in the use of creative.ch or related Services by the User.
The User declares that they are aware that the Data Controller may be obliged to disclose the Data by 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 and contextual information 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, i.e., files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details 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 in its possession. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes affect processing operations whose 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, even in connection with any other information, including a personal identification number, identifies or makes identifiable a natural person.

Usage Data

This is information collected automatically through creative.ch (including from third-party applications integrated into creative.ch), including: the IP addresses or domain names of the computers used by the User connecting to creative.ch, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward 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.), etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time details of the visit (e.g., the time spent on each page) and details of the route taken within the Application, with particular reference to the sequence of pages viewed, the parameters relating to the User's operating system and IT 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 refers.

Data Processor (or Processor)

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

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of personal data processing and the tools used, including the 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 Application)

The hardware or software tool through which Users' Personal Data is collected and processed.

Service

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

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be understood to extend to 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 Tools refer to any technology—e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that allows Users to be tracked, for example by collecting or saving 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 personal data during transmission between your browser and our servers.
  2. Access Controls

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

    • We regularly review and monitor our security practices and systems.
  6. Staff Training and Awareness

    • We regularly train our staff on best practices for data security.
  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 incidents. In the event of a data breach, we will promptly notify the relevant authorities and affected individuals.

Legal references

This privacy policy has been drafted on the basis of multiple legislative systems.
Unless otherwise specified, this privacy policy applies exclusively to creative.ch. 

Last modified: January 4, 2024