1. Introduction

Below we inform you, among other things, about who is responsible for processing your data, which data we collect in connection with your visit to our website and the use of our services, for what purposes we process this data, and to whom we may pass on this data. Furthermore, we inform you about the duration of the processing of your data, the legal basis for the processing (if such is necessary), as well as about the rights you have with regard to the processing of your data in relation to us. This privacy policy applies to all your data that we already have or that will be available to us in the future. Please note that we may adjust the privacy policy from time to time. The version published on our website at any given time applies.

 

Personal data means any information relating to an identified or identifiable person (hereinafter “personal data”). This particularly includes information such as name, address, telephone number, email address, and, in some cases, IP addresses and device IDs. The term data, in this privacy policy, encompasses not only personal data but also non-personal and anonymized data. Processing means any handling of data, regardless of the means and procedures used, in particular collecting, storing, using, modifying, disclosing, archiving, or deleting data (hereinafter “processing”).

 

If you provide us with personal data of other persons, please ensure that these persons are aware of this privacy policy and only share their personal data with us if you are authorized to do so in accordance with applicable data protection law.

2. Name and address of the person responsible

Responsible for the data processing in accordance with this privacy policy is:

Acro Ghana

Oberer Quai 32a, 2503 Biel/Bienne, Switzerland

077 913 37 82

adu.adjei@acroghana.ch

3. Categories of processed data

When visiting our website, using our services, and contacting us, we collect certain data. In principle, we collect this data directly from you. The personal data that we process may include the following data:

  • Data collected when visiting our website or using our services.
    This includes, among other things, the IP and MAC address or device ID of the device used, cookies, pages accessed and search terms entered by you, entries in dialog fields, ratings, time and duration of visits, clicks, referrer/exit URL, information about the time of use, browser and device type, operating system used, internet service provider, and amount of data transferred.
  • Data exchanged during or in connection with contact with us,
    e.g., communication by letter, telephone, email, contact form, etc. (in particular name, contact details, gender, marital status, date of birth, job title, photo, employees, language, payment information).
  • Data provided when subscribing to a newsletter or downloading files
    (e.g., software), in particular email address and name.
  • Data provided when creating a customer account for online shopping and in connection with orders placed,
    in particular username, password, selected payment method, and delivery address.
  • Data relating to offers and concluded contracts
    (e.g., contract date, type, content, product, parties, duration, value, amendments, payment details, contact details, contact persons, billing and correspondence addresses, customer feedback, cancellations, disputes, etc.).
  • Data provided when using the comment function,
    in particular email address, the username chosen by you (if you do not post anonymously), and your IP address.
  • Data provided when participating in competitions, surveys, and similar activities.

 

The above data does not necessarily constitute personal data in every case. As a rule, we cannot assign data that arises from the use of our services without registration (e.g., for a newsletter or online shop) to any individually identifiable person. In individual cases, however, this may be possible in combination with other data. We would like to point out that the information provided in connection with the use of the contact form or the comment function may include particularly sensitive data (such as health data) and that you have voluntarily provided this to us.

4. Processing purposes

We will process personal data, insofar as permitted under applicable law, in particular for the following purposes:

 

  • Initiation, conclusion, performance, and processing of contracts.
  • Offering, further development, and improvement of our services; development of new services; operation, maintenance, optimization, and ensuring the security of our services and infrastructure.
  • Administration of users of our services, identity verification, log-ins, and other authentication processes.
  • Maintenance, administration, and development of our customer relationships; communication with customers and third parties; promotions, advertising, and marketing; offering tailored services and relevant content.
  • Quality control and preparation of statistics.
  • Compliance with legal and regulatory obligations and internal rules; enforcement of legal claims; civil, administrative, and criminal proceedings; handling complaints; prevention of abuse; investigations; and responding to requests from authorities and official bodies.

5. Legal Basis

We use personal data for the above purposes on the basis of the following legal grounds, where such a basis is required under applicable data protection law:

  • Performance of a contract.
  • Compliance with legal obligations.
  • Consent granted to us or to third parties.
  • Legitimate interests pursued by us or by third parties, in particular:
    • Provision and delivery of services.
    • Advertising and marketing.
    • Maintaining contact and communication with users.
    • User administration, identity verification, and log-ins.
    • Compliance with legal and regulatory obligations; enforcement of legal claims; civil, administrative, and criminal proceedings; handling complaints; investigations; and responding to requests from authorities.

6. Publication and Sharing of Data

We can publish and share data as follows:

 

Order data processor

We can engage third parties to provide certain services (e.g., in the area of IT, operation of applications, administration, shipping, etc.) and to process and store data (so-called “data processors”). Data processors may have access to personal data and process it on our behalf. In doing so, we oblige the processors to comply with data protection law and to process data only in the way we do ourselves. Data processors who receive personal data may be located in any country, in particular in Switzerland, Germany, Israel, and the USA.

 

Contractual partner

We can share data with contractual partners (for example, sales partners, service providers, financial companies, etc.). This happens, for example, to fulfill contractual obligations, to offer certain services, for collection and marketing purposes, for analyzing usage and operating our services, systems, and infrastructure, and for payment processing. Potential recipients can also include buyers or prospective buyers of business units, companies, or parts thereof. Contractual partners may have access to personal data and process it for their own purposes (for example, to fulfill a contract or to meet their own legal obligations). They are themselves required to comply with applicable data protection laws. Contractual partners who receive personal data may be located in any country, particularly in Switzerland, in EU and EEA countries, and in the USA.

 

Transfers to authorities

In certain situations, we may disclose data to authorities, government offices, and other third parties. We do this in cases where we are officially or formally requested to do so, or where we determine that we are obligated to.

7. Retention period

We store personal data as long as it is necessary for the purpose for which we collected it. Certain personal data is also subject to legally binding retention obligations of ten or more years, which we take into account. We may also store personal data for at least the duration of the applicable statute of limitations, which in many cases is five or ten years. Personal data generated in connection with the use of our services (e.g., records, logs, analyses, etc.) and that is not subject to such retention or limitation periods is generally deleted earlier, as soon as we no longer have an interest in processing it. Data can also be retained in anonymized form for longer periods. Subject to an explicit contractual agreement, we are not obligated to retain data for a specific duration on your behalf.

8. Data Security

We apply appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties. Our security measures are continuously improved in accordance with technological developments.

9. Your Rights (Data Subject Rights)

Every data subject has the right to obtain information about the personal data concerning them.
Furthermore, they have the right to request the rectification, deletion, and restriction of the
processing of personal data relating to them, as well as to object to such processing.

The exercise of such rights generally requires that the data subject clearly prove their identity.
If the processing of personal data is based on consent, the data subject may withdraw this consent at any time.

In certain cases, the data subject has the right to receive the data generated through the use of
online services in a structured, commonly used, and machine-readable format, which enables further use and transfer.

Requests relating to these rights must be addressed to the address mentioned above.
We reserve the right to restrict the rights of the data subject within the framework of the applicable law
and, for example, not to provide complete information or not to delete data.

Please also note that the deletion of your personal data may result in services no longer being available
or only being partially available.

 

Every affected person has the right to lodge a complaint with the competent data protection authority. In the case of a controller in Switzerland, this is the Federal Data Protection and Information Commissioner. For a controller in the Principality of Liechtenstein, it is the Data Protection Office Liechtenstein.

10. Cookies, web analysis and tracking tools

Every data subject has the right to obtain information about the personal data concerning them.
Furthermore, they have the right to request the rectification, deletion, and restriction of the
processing of personal data relating to them, as well as to object to such processing.

The exercise of such rights generally requires that the data subject clearly prove their identity.
If the processing of personal data is based on consent, the data subject may withdraw this consent at any time.

In certain cases, the data subject has the right to receive the data generated through the use of
online services in a structured, commonly used, and machine-readable format, which enables further use and transfer.

Requests relating to these rights must be addressed to the address mentioned above.
We reserve the right to restrict the rights of the data subject within the framework of the applicable law
and, for example, not to provide complete information or not to delete data.

Please also note that the deletion of your personal data may result in services no longer being available
or only being partially available.

 

Every affected person has the right to lodge a complaint with the competent data protection authority. In the case of a controller in Switzerland, this is the Federal Data Protection and Information Commissioner. For a controller in the Principality of Liechtenstein, it is the Data Protection Office Liechtenstein.

11. Integration of third-party offers

We integrate services and content from third parties on our websites that may enable you to interact with third parties (e.g., YouTube videos or online payments via payment service providers). Any data provided may be forwarded to these third parties for processing and execution of the respective service or may be processed directly by them.

Please note that the terms of use and privacy policies of these third parties apply to their data processing activities.

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