Privacy Policy
Status: 31.05.2023.
This policy applies to the companies that are part of Aplauz Financial Services Ltd. (including Aplauz NL B.V. and Aplauz CH GmbH).
The reference to Aplauz (including “we”, “us” or “our”) includes those companies and all relevant group affiliates.
References to “you” in this notice are to the individual who is accessing or applying to use the Services (as defined below) either on your own account or on behalf of a business.
At Aplauz, we take the protection of personal data seriously. We understand that your privacy is important to you, and we are committed to collecting, using, and protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP). This privacy policy explains how we collect, use, and protect your personal data. It also explains your rights under the GDPR, and how you can exercise those rights. If you have any questions or concerns about this policy, please do not hesitate to contact us.
This introduction states Aplauz’s commitment to privacy and compliance with the GDPR and FADP. It also explains the purpose of the policy and how it covers the personal data collection and usage, as well as the rights of the individuals and how they can exercise them. It also encourages the users to contact the company if they have any questions regarding the policy.
The trust of our customers is very important to us. We respect your personal data and privacy.
In the following policy, we provide information about the collection of personal data when using:
• Aplauz websites’ services and features provided when you access Aplauz websites, portals, pages or payment pages (such as, but not limited to https://aplauz.com/, including any country versions and sub-domains) (hereinafter “website”) and/or
• Aplauz Mobile Application and/or
• Aplauz’s products and services (including, but not limited to Aplauz vouchers), and/or
• any ways or means of communication between you and Aplauz such as, but not limited to, email, telephone, web chat, website/portal.
Together these are all referred to in this notice as “Services”.
Please note that Aplauz provides services to both individual consumers and businesses (such as Aplauz’s merchants and distributors) and this privacy policy applies to both and should be read and interpreted accordingly.
Identity of the controller for processing personal data
Aplauz is the controller for the personal data we process, unless stated otherwise.
• For the EU: Aplauz NL B.V., Keizersgracht 555, 1017 DR Amsterdam, the Netherlands
• For Switzerland: Aplauz CH GmbH, Zugerstrasse 77, 6340 Baar, Switzerland
Contact
You can address your data protection concerns to:
• For the EU: Data protection officer of Aplauz NL B.V, Keizersgracht 555, 1017 DR Amsterdam, the Netherlands or dataprivacy@aplauz.com
• For Switzerland: Data protection officer of Aplauz CH GmbH, Zugerstrasse 77, 6340 Baar Switzerland or datenschutz@aplauz.ch
Personal data
We collect and process personal and non-personal information relating to you.
Personal data is any information that relates to an identified or identifiable individual, also known as a data subject, and it is information that can be used to uniquely identify a single person, either directly or indirectly. This includes information such as (but not limited to) a person’s name, address, email address, or IP address, as well as any other information that can be used to identify a person. Under GDPR and FADP, organizations like Aplauz are responsible for ensuring that personal data is collected, processed, and stored in a manner that is compliant with data protection regulations.
We may also collect and process non-personal information, or may anonymize personal information in order to make it non-personal. Non-personal information is information that does not enable a specific individual to be identified, either directly or indirectly.
Collection of data during informational use of Aplauz website
When you use the website for informational purposes only, that is, when you do not register or otherwise provide us with information, we do not collect any personal data, except for the data that your browser sends to enable you to visit the Website.
These are:
Collection of personal data during use of Aplauz services (including Aplauz websites: newsletter, downloads, contact form, marketing campaigns and promotions, etc.)
When you use any of Aplauz websites to be in contact with our team, submit a form, register for our newsletter or download content, such as a whitepaper, personal data can be collected and stored in our Customer Management Systems, such as but not limited to HubSpot and Drip, in order to follow up with your request. We will use the data for the sole purpose of processing your request and only with your explicit consent.
We also collect and process:
• your IP address when using Aplauz payment pages.
• your name, last name, company email address and company phone number in the context of Aplauz sales and/or business discussions.
Collection of personal data during use of Aplauz Mobile Application
Aplauz Mobile Application enables consumers to easily store, access and use their Aplauz vouchers. In order to provide this service and also for legal and regulatory purposes, Aplauz needs to collect specific personal data as follows:
For identification purposes during account creation:
• First Name, Middle Name, Last Name
• Email address
• Mobile Phone Number
• Date of Birth
• Biometric Data (only locally stored on Mobile Phone secure storage)
• Location Data (only locally stored on Mobile Phone secure storage) for the sole purpose of “Find the nearest store” functionality within the app and help pre-filling “Country of Residence” during the Identification process. We will always seek to notify you and obtain your consent if it is our intention to collect real-time location information for any other purposes.
We may use your First Name, Middle Name, Last Name, telephone number and email address for marketing purposes.
For verification purposes, for users that are willing or are required to perform a full “Know Your Customer” (KYC) process:
• All personal data collected during the account creation process; and
• Document ID – front and back side image
• Document ID number
• Face image/video
• Full Address
• Gender
We will use the above information for regulatory purposes, including our own due diligence checks, fraud and risk management.
We will always seek to notify you and obtain your consent if it is our intention to make use of this information for any other purposes than the above indicated.
Processing purposes and legal basis
Data processing is carried out in particular to analyse the internet traffic on our services, to maintain and monitor the performance of our services, to improve the functionality of our services and for advertising purposes. We may also use your personal information to contact you, to provide you a service or to keep you up-to-date about our services and promotions, as per your request.
The lawful basis we rely on for processing of your data depends upon the relevant data gathered and processing purpose.
| Purpose | Lawful basis |
|---|---|
| Collection of data during informational use of Aplauz website | Consent |
| Collection of personal data during use of Aplauz services (including Aplauz websites: newsletter, downloads, contact form, marketing campaigns and promotions, etc.) | Consent |
| Collection of personal data during use of Aplauz Mobile Application | As necessary for the performance of a contract (our terms and conditions applicable to your use of our services) and In order to protect our legitimate interests (for instance in relation to the processing of your biometric data) |
If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive a marketing promotion to use Aplauz vouchers), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and do not require such a basis. A given consent can be revoked at any time, but this has no effect on data processing that has already taken place.
DATA CATEGORIES AND DATA ORIGIN
We process the data that is generated when you use our services, websites and mobile application or the data that is provided by you (for example, when you register for a specific service (newsletter, to receive a voucher etc.)).
Recipient (data disclosure)
In the course of our business activities and purposes, we also disclose personal data to third parties where permitted and necessary for your proper use of the services and/or required by law. This concerns in particular the following data recipients:
• Companies of the Own Solutions Group (including Aplauz NL B.V. and Aplauz CH GmbH);
• Service providers of Own Solutions Group companies, including the companies mentioned in this Privacy Policy and contractors (e.g., IT providers, digital marketing agencies such as Double LLC, a Wyoming limited liability Service Provider with registration number EIN38-4040251), and marketing tools such as HubSpot, Drip and Coupon Carrier);
• Online retailers where you use your Voucher to purchase their goods and/or services, which may be subject to similar identification and verification requirements as us;
• Third parties within the framework of the fulfilment of Aplauz’s legal and/or regulatory obligations towards authorities or institutions (such as, but not limited to, National or EU regulators, Law Enforcement Authorities, National or European Banks and Auditors).
Under no circumstances do we sell any data to third parties or share it for the purposes of direct marketing.
International Transfers
Some of the above recipients are in the EEA area and Switzerland, but they can also be abroad. In particular, you must expect your data to be transferred to all countries in which the Own Solutions Group is represented by group companies, branches or other offices and to other countries in Europe and the USA where the service providers we use are located or operate. These countries may have data protection standards that are different to (and, in some cases, lower than) those of the territory in which you reside and therefore courts, law enforcement and other authorities in these countries have the right to access your information in certain situations.
If we transfer data to a country without adequate legal data protection, we will ensure an adequate level of protection as required by law by means of appropriate contracts. We partner with data processors who are third parties who provide elements of services for us. We have contracts and agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
We will not share your information with any third parties for the purposes of direct marketing by such third parties. If we are required to disclose your information by a judicial, governmental or regulatory authority, acting within its legal authority, we will comply and share only the Information we are obligated to provide.
USE OF COOKIES
We typically use “cookies” and similar tracking technologies on our websites to identify your browser, device and tracks the activity on our websites and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our service. Throughout this policy, when referring to “cookies”, we implicitly also refer to similar tracking technologies such as “web beacons”. The technologies we use may include:
• Cookies are small text files that are stored on your hard disk in accordance with the browser you are using and through which certain information is transmitted to the party that sets the cookie (in this case us or third parties). They are used to make the Internet offer as a whole more user-friendly and effective and to analyse the surfing behaviour of the website visitors. We use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.
• Web Beacons. Certain sections of our websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
This website uses the following cookies.
Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time. Transient cookies are automatically deleted when you close the browser. These include in particular the session cookies. These store a so-called Session-ID, with which different requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to the website. The session cookies are deleted when you log out or close the browser.
In accordance with applicable law, we may store cookies on your device if they are technically necessary for the operation of the website. For other types of cookies, we need your permission, which you can give by clicking on the corresponding fields in the pop-up button. You can configure your browser settings to your liking and refuse to accept third-party cookies or all cookies. However, we would like to point out that you may not be able to use all the functions of this website.
If you are logged in to a social network such as Meta (incl. Facebook and Instagram) or Google services, a cookie may be placed on your device so that you are recognized when you view content on our websites. These cookies allow you to share content on social media through the share settings and may allow the social networking site to track your activity. See the privacy and/or cookie policy on the relevant social networking site for more information and options.
This website uses the so-called “Facebook / Meta Pixel” of the social network “Facebook” by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Meta) for the following purposes:
• Tracking of visitor activity on Aplauz website and Aplauz promotions via Aplauz landing page. Due to the marketing tool used (Facebook / Meta Pixel), your browser automatically establishes a direct connection with the Facebook server as soon as you have agreed to the use of cookies requiring your consent. Through the integration of the Facebook / Meta Pixel, Facebook receives the information that you have called up the corresponding website of our internet presence or clicked on an advertisement from us. If you are registered with a Facebook service, Facebook can assign the visit to your account.
The processing of this data by Facebook takes place within the framework of Facebook’s data policy. Special information and details about the Facebook pixel and its functionality can also be found in the Facebook help area.
This website also makes use of the so-called “Google Analytics”. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our websites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page https://policies.google.com/privacy
OTHER TOOLS
Marketing Promotions on the website
We may occasionally run promotions. Your data (first name, last name and email address) will be processed and stored by a data processor on our behalf or by ourselves for the purpose of the promotion. You will only be contacted once to send you the promotion code or send you further information about new promotions or marketing information if you have given your consent. The personal data will be deleted if they are no longer needed for the purpose for which they were collected, which is to evaluate the success of the promotion.
Newsletter
We are happy to inform you about current topics concerning Aplauz and our products via our newsletter. To send a newsletter we need your name and e-mail address. You can enter both in the fields provided. After you have sent this data, you will receive an e-mail from us to the e-mail address you have provided, in which you must click on a confirmation link to verify the e-mail address you have provided.
Your data will only be used and stored by us for the purpose of sending the newsletter.
You can unsubscribe from the newsletter at any time and thus object to the further use of your data. You can unsubscribe from the mailing list at the end of a newsletter.
In our newsletters and other marketing e-mails, we also include, in part and to the extent permitted, visible and invisible image elements, the retrieval of which from our servers enables us to determine whether and when you have opened the e-mail, so that we can also measure and better understand how you use our offers and tailor them to you. You can block this in your e-mail program.
To send our newsletters, we use the application such as “HubSpot”, a service of HubSpot, Inc., Cambridge, MA 02141, United State. Further information of their data protection and compliance can be found by clicking the following links: HubSpot Private Policy and GDPR Compliance.
CONTACT FORM
If you fill out a contact form or send us an e-mail or other electronic message, your details will only be stored for the purpose of processing the enquiry, possible related further questions and will only be used within the scope of the enquiry.
Duration of data storage
Unless otherwise stated, we store usage data or other personal data for as long as we deem it necessary or appropriate to comply with applicable laws, or for as long as we deem it necessary for the purposes for which it is processed. We delete your personal data as soon as they are no longer needed. We are required under applicable law to retain your personal data for 5 years after the last transaction for you has been carried out.
Data security
We have technical and organisational security procedures in place to maintain the security of your personal data and to protect your session data and personal data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure or access. These are adapted to the current state of the art. However, you should always be aware that there are inherent security risks in transmitting information via the Internet and other electronic means, and that we cannot guarantee the security of any information transmitted in this way.
Rights of the data subject
You are entitled to the following rights, depending upon our reason for processing your information:
• Right of access – you have the right to ask us for copies of your personal information.
• Right to rectification – you have the right to ask us to rectify information you think is inaccurate or incomplete.
• Deletion – you have the right to ask us to erase your personal information, provided we are not bound to retain such information following applicable laws.
• Right to object to processing –
• Restriction of processing – you have the right to ask us to restrict the processing of your information.
• Data transferability – you have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.
Furthermore, you have the right to object at any time to the processing based on your consent or our legitimate interests.
You also have the right to pursue your claims through the courts or to lodge a complaint with the competent data protection authority. According to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities:
• For the EU, click here
• For Switzerland, the competent data protection authority is the Federal Data Protection and Information Commissioner, click here
Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, if we have an overriding interest in doing so (insofar as we are entitled to invoke this) or if we need them for the assertion of claims.
The exercise of such rights usually requires that you clearly prove your identity, where your identity is otherwise not clear or cannot be verified (e.g., by means of a copy of your identity card). To assert your rights, you can contact us at:
• For the EU: dataprivacy@aplauz.com
• For Switzerland: datenschutz@aplauz.ch
Amendment of the Privacy Policy
We may change this Privacy Policy at any time without notice. If we have stored your email address as part of any previous contact, we will provide you with a notification of such changes by sending you a notice to your contact details. The current version published on our website applies. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means if we update it.