What does this statement cover?

This statement is intended to specifically inform you about the processing of your personal data in connection with the use of a “No Cash” bracelet. We provide you with information on the categories of personal data we process, the purpose of their processing, any transfers to third parties, and how you can exercise your rights.

Paléo Arts & Spectacles (hereinafter “Paléo”) pays particular attention to the protection of your privacy and personal data. We are committed to transparent processing of your personal data in accordance with legal requirements on data protection, in particular the Federal Data Protection Act (LPD).

Who processes your personal data?

The data controller is:
Paléo Arts & Spectacles
Rte de St-Cergue 312
CH – 1260 NYON
Switzerland

What personal data do we collect?

By using the “No Cash” bracelet, you have the option of creating a user account on our online platform to check the remaining balance on your bracelet, top it up online, or request a refund of any remaining balance in your favour at the end of the event.

By creating a user account on the online platform and depending on the chosen functionalities, personal data concerning you is collected and processed, such as your login information, name, surname, email address, and the history of transactions made. If you top up your bracelet or request a refund online, information pertaining to the payment and refund methods is processed (e.g. the phone number if you use TWINT or your IBAN).

However, if you do not create a user account, no personal data is collected.

For what purposes is your personal data collected and used?

The personal data that we collect in connection with the use of the “No Cash” bracelet is only processed to provide you with the online services you choose, namely consulting your (historical) information and options for topping up or refunding your balance.

Less frequently, this data may be processed to respond to assistance requests from you or to handle any oppositions, disputes, or other forms of litigation.

Finally, anonymised data is used for statistical purposes to continuously improve our services.

What are the legal bases or justifications for processing your personal data?

The processing that we carry out in the context of the use of “No Cash” bracelets is mainly justified by:

• your consent when you decide to create a user account and use the online services offered by our platform;
• our legitimate interests when these are predominant, in particular for processing undertaken to handle any oppositions, disputes, or other forms of litigation, and for statistical purposes to improve our services;
• a legal obligation or to comply with an official request ordered by an authority.

Can I withdraw my consent?

You are free to withdraw your consent at any time and therefore to request the deletion of your user account. We will then cease processing your personal data based on this consent, unless it can be retained for another legitimate purpose based on another legal basis than your consent.

You can modify or delete your account directly via your account settings.

To whom can your personal data be communicated?

Your personal data is intended for Paléo’s authorised personnel and its subcontractors and service providers involved in maintaining the smooth running and security of the online platform.

If you use the top-up and/or refund functions, your information will also be transmitted to the relevant financial and/or banking intermediaries.

Our service providers and the partners mentioned are obliged by law, or by contractual obligations, to comply with legal provisions relating to data protection.

Less frequently, your personal data may be transmitted to competent administrative or judicial authorities if they make an official request or in order to fulfil our legal obligations.

Is your personal data transferred abroad?

We make every effort to ensure that your personal data is processed in Switzerland.

However, we do rely on providers whose services involve the transfer of data abroad. In cases where maintaining processing in Switzerland is not possible, we prioritise countries in the European Economic Area and countries offering an adequate level of protection.

Where and for how long is your personal data stored?

We process and store your personal data as long as necessary to meet our contractual and legal obligations, to achieve the purposes for which the data is processed, or for the duration of your consent. Once your personal data is no longer necessary to achieve the aforementioned purposes, it is deleted, as far as possible, or anonymised.

Criteria influencing the storage period include the applicable legal framework, the need for us to have access to this information, the fulfilment of initial or extended goals, the safeguarding of legitimate interests, as well as imperatives arising from internal organisational or technical processes.

How do we protect your personal data?

We take the necessary technical, organisational, and legal measures to safeguard the security and confidentiality of your personal data. These measures are aimed at reducing risks on our websites and applications, protecting our IT infrastructure, and carefully selecting our service providers.

What are your rights regarding the processing of personal data?

Regarding your personal data, you are entitled to:

• request information about your personal data that we process as well as a copy of such data;
• request correction or completion of incorrect or incomplete data;
• request deletion of your data, unless a legal basis or our legitimate interest requires or allows us to retain your data;
• request restriction of processing of your data, if the law permits;
• notify us at any time that you revoke your consent to data processing for which your consent was requested;
• notify us at any time of your objection to the processing of your personal data for promotional and advertising purposes;
• notify us at any time of your objection to any other processing, unless, for example, a legal basis or our legitimate interest requires or allows us to continue processing;
• request your data in a portable format when processing your data is done automatically, based on your consent or a contract;
• request to express your viewpoint in case of automated individual decision-making and to have the decision reviewed by a human being;
• address a supervisory authority (in this case, the PFPDT) regarding data protection when you wish to contest how we process your data or your request to exercise your rights, or to file a complaint.

We will inform you of any conditions or restrictions that may apply to the exercise of your rights.

You may exercise your rights by contacting us directly at the following email address: protectiondesdonnees@paleo.ch or at the postal address mentioned above (section: “Who processes your personal data?”).

We reserve the right to request additional data to identify you, in particular by means of a copy of a valid ID. To facilitate the processing of your request, we also ask you to specify precisely which right(s) you wish to assert and to what extent.

When can this statement be updated?

This statement may be updated at any time. The published version constitutes the most recent version and prevails.

It replaces all previous statements or those contrary to this statement.