1. General
1.1 Scope and purpose
neotralo App AG (hereinafter neotralo) is aware of the importance of complying with the General Data Protection Regulation (GDPR) and relies on data processing that complies with the law in the area of data protection, as well as open communication with its customers and transparency with regard to the handling of personal data. With this data protection declaration, we would like to inform you about data processing at neotralo and explain data processing procedures. The purpose of data protection is to protect the personality and the fundamental rights of the person concerned when processing personal data by neotralo.
1.2 Terms
Neotralo understands personal data to be all information that relates to an identified or identifiable natural person; A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
Neotralo understands special categories of personal data to be personal data that reveal racial and ethnic origin, political opinions, religious or ideological beliefs, trade union membership, as well as the processing of genetic data, biometric data to clearly identify a natural person, Health data or data relating to the sex life or sexual orientation of a natural person.
Profiling is any type of automated processing of personal data which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, to analyze or predict the economic situation, health, personal preferences, interests, reliability, behavior, location or change of location of this natural person.
Health data refers to personal data that relates to the physical or mental health of a natural person, including the provision of healthcare services, and from which information about their state of health emerges.
Neotralo understands processing to mean any process or series of processes carried out with or without the help of automated processes in connection with personal data, such as collecting, recording, organizing, arranging, storing, adapting or changing, reading out, querying, using, disclosing by transmission, dissemination or any other form of provision, comparing or linking, restricting, deleting or destroying.
Customers are all natural persons who have a service relationship with neotralo. It is irrelevant whether the private or corporate customers have a contractual relationship with neotralo.
Suppliers are all independent natural persons who have a contractual relationship with neotralo
of the contractual service that the supplier or neotralo has to provide.
Interested or potential customers are natural persons who are interested in neotralo's products.
Legitimate or public interest exists when alcuris justifies the data processing on the basis that there is a legitimate interest of neotralo or a legitimate public interest. neotralo has a legitimate interest if neotralo's interest in data processing outweighs the interests or fundamental rights and freedoms of the person concerned. A public interest in data processing exists if the interest in data processing for the public outweighs the interests of the data subject.
1.3 Legal basis
neotralo processes data in accordance with the GDPR, the Data Protection Act and the applicable special legislation. neotralo looks for the best insurance solutions for private customers and corporate customers in the areas of health and accident insurance, life insurance as well as other property and liability and legal protection insurance.
Data protection legislation does not apply to legal entities. The data of legal entities is accordingly excluded from this data protection declaration. This does not apply to the data of natural persons within a legal entity if they are affected by data processing by neotralo.
2. Processing purposes
2.1 Generally
As part of its activities, neotralo processes personal data of its customers, suppliers, service providers or potential customers (domain). Data processing is a central activity for neotralo in order to fulfill its mandate as an insurance advisor. Data minimization and thus proportionate data processing is a fundamental requirement that neotralo sets for itself.
2.2 Use of website and app
When accessing the neotralo website and app, your internet browser automatically transmits data for technical reasons, even when using or viewing the website and app for purely informational purposes, in order to ensure correct display as well as stability and security. The following data is stored separately from other data that you may transmit to neotralo:
? IP address
? Date and time of access
? Access status / http status code
? Browser type/version/language
? Operating system used
? URL of the previously visited website
? Amount of data transferred in each case
? Website from which the request comes
? Browser
? Operating system and its interface
? Language and version of the browser software
This data is stored in particular for technically necessary reasons. In addition, neotralo stores this data for a limited time in the event of unauthorized access or
Attempts to access the servers lead to the derivation of personal data. The legal basis for the processing of your data described in this section is the protection of neotralo's legitimate interests in accordance with Article 6 Paragraph 1 Letter f of the GDPR.
2.3 Registration, creation and login of a user account In order for you to be able to use all the advantages of the neotralo website and app, you must register and therefore enter certain personal data. Providing all data is voluntary. However, without entering this data, full use of the website and app is not possible. The following data is collected:
? name and first name
? address
? E-mail address
? Telephone number (landline and/or mobile number)
? Birth details (date, place, birth name)
This data is required to calculate your personal offer and, if you decide on the offer, to conclude and implement the insurance contract. The legal basis for processing is, in particular, your consent (Art. 6 Para. 1 lit. a GDPR).
2.4 Offer calculation
If you have an offer calculated via the neotralo website or app, personal data will be requested from you. It is about:
? name and first name
? address
? E-mail address
? Telephone number (landline and/or mobile number)
? Birth details (date, place, birth name)
This data is required to calculate your personal offer and, if you decide to accept the offer, to conclude and implement the contract. The legal basis for processing is the implementation of (pre-)contractual measures and the protection of legitimate interests (Art. 6 Para. 1 lit. b and f GDPR).
2.5 Conclusion of the insurance contract and during the insurance contract relationship
If you conclude an insurance contract through neotralo, only the data you provide or the data passed on to third parties with your consent will be used. The conclusion and implementation of an insurance contract would not be possible without the processing of your data. If you apply for insurance coverage, the information you provide will be required to conclude the contract and to assess the risk to be assumed. If the insurance contract is concluded, this data is used to implement the contractual relationship, e.g. B. used for policy or invoicing. In particular, these are:
? Name and full address details
? Landline phone number and/or mobile phone number
? E-mail address
? Birth details (date, place, birth name)
All data you provide will be used exclusively for the following purposes:
? to conclude and fulfill an insurance contract with us as well as contract administration and claims settlement, as described in the insurance conditions
? for sending advertising, unless you have objected to this. neotralo allows you to object to the sending of data at any time and without further costs when collecting data and with each advertising email/newsletter
The legal basis for this processing is, in particular, (pre-) contractual measures, your consent and the protection of legitimate interests (Art. 6 Para. 1 GDPR).
In the course of your insurance contract, all types of insurance-relevant information may also be used. If the use of special types of personal data is necessary, this data will only be collected and used if or to the extent that you have consented to this. neotralo obtains your consent in accordance with Article 9 Paragraph 2 Letter a in conjunction with Article 7 GDPR. If statistics are created using the data categories specified in Article 9 Paragraph 2 Letter a of the GDPR, this is only done for the purposes stated in Article 9 Paragraph 2 Letter j of the GDPR. A lack of consent may result in the insurance contract not being concluded or being terminated.
2.6 mediation
neotralo brokers insurance contracts (hereinafter referred to as “brokerage”) and/or manages and manages existing contractual relationships. For this purpose, your data will be processed by you as part of data recording, implementation of pre-contractual measures, consulting documentation, contract application or
-conclusion, communication with the product providers and contract support requires the data provided. Your data will be collected, processed and used for contract-related advice and processing and will be transmitted by us for this purpose to providers requested by us (such as insurance companies, comparison platforms) and stored and used by them to review the application. The associated collection and use of your data is necessary to fulfill the contract with you.
2.7 e-mail
You can contact us using the email addresses provided on the neotralo website. If you send us an email, neotralo collects, stores and uses your email
? names
? Email address and the
? Content of your message
Processing will only take place to the extent necessary to process your request and correspond with you. The data collected serves the sole purpose of processing your request. The data collected during the sending process is necessary to prevent misuse of the function and to ensure the security of our systems. The legal basis is Article 6 Paragraph 1 Letter f GDPR.
2.8 General data processing operations
As the business develops, the structure of the company changes as the legal form changes and subsidiaries, parts of the company or components are founded, bought or sold. In such transactions, customer information may be shared along with the portion of the business being transferred. Whenever personal data is passed on to third parties, care will be taken to ensure that this is done in accordance with this data protection declaration and the applicable data protection law.
2.9 Legal requirements
neotralo processes your data to fulfill legal obligations such as: B. regulatory requirements and/or commercial and tax retention obligations. The legal basis for this processing is the respective legal regulations in conjunction with Article 6 Paragraph 1 Letter c GDPR. If neotralo wishes to process your data for a purpose not mentioned above, you will be informed in advance in accordance with the legal provisions.
3. Rights of the persons affected
3.1 Right to information
All persons affected by data processing carried out by neotralo have the right to request confirmation as to whether personal data about them is being processed. If data is being processed, alcuris provides the following information:
? the processing purposes
? the categories of personal data that are processed
? the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular
Recipients in third countries or international organizations
? if possible, the planned period for which the personal data will be stored or, if this is not possible, the criteria for determining that period
? the existence of a right to rectification or deletion of personal data concerning you or to restriction of processing by the controller or a right to object to this processing
? the existence of a right to lodge a complaint with a supervisory authority
? if personal data is not collected directly from the data subject, all available information about the origin of the data
? the existence of automated decision-making including profiling in accordance with Article 22 paragraphs 1 and 4 GDPR and ? at least in these cases? meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject
? In the case of the transfer of personal data to a third country or an international organization, information about the appropriate guarantees in accordance with Art. 46 GDPR, which are related to the transfer
? a copy of the personal data that is the subject of processing
Section 3.11 applies to the exercise of rights.
3.2 Right to rectification
All persons affected by data processing carried out by neotralo have the right to immediately request that incorrect personal data concerning them be corrected. In addition, does every data subject affected by data processing carried out by neotralo have the right to have incomplete personal data completed, taking into account the purpose of the processing? also by means of a supplementary declaration? to demand.
Section 3.11 applies to the exercise of rights.
3.3 Right to deletion
All persons affected by data processing carried out by neotralo have the right to request that neotralo delete the personal data concerning them immediately if one of the following reasons applies:
? The personal data is for the purposes for which
they were collected or otherwise processed are no longer necessary
? The data subject withdraws their consent on which the processing was based in accordance with Article 6 paragraph 1 letter a or Article 9 paragraph 2 letter a GDPR and there is no other legal basis for the processing
? The data subject objects to the processing in accordance with Article 21 Paragraph 1 of the GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing in accordance with Article 21 Paragraph 2 of the GDPR
? The data processed was processed unlawfully;
? The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject
Section 3.11 applies to the exercise of rights.
3.4 Right to restriction of processing
All persons affected by data processing carried out by neotralo have the right to request neotralo to restrict processing if one of the following conditions is met:
? If the accuracy of the personal data is disputed by the data subject, the processing activity must be restricted for the duration of the clarifications that neotralo carries out to ensure accuracy
? The processing of personal data is unlawful, but the data subject does not demand deletion, but rather restriction of processing
? if neotralo no longer needs the personal data, but the data subject still needs the data to assert, exercise or defend legal claims or
? If the data subject has lodged an objection to the processing, the processing will be stopped until it is clear whether the legitimate reasons for data processing by neotralo outweigh them
? If processing has been restricted, may the personal data be used? apart from storing them? may only be processed with the consent of the data subject or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest
A data subject who has obtained a restriction on processing will be informed by neotralo before the restriction is lifted.
Section 3.11 applies to the exercise of rights.
3.5 Obligation to notify in connection with the correction or deletion of personal data or the restriction of processing
neotralo will notify all recipients to whom personal data has been disclosed of any correction or deletion of the personal data or a restriction on processing, unless this proves to be impossible or is prohibited
involves disproportionate effort. neotralo informs the data subject about these recipients if the data subject requests this.
Section 3.11 applies to the exercise of rights.
3.6 Right to data portability
All persons affected by data processing carried out by neotralo have both the right to receive the personal data concerning them that they have provided to neotralo in a structured, common and machine-readable format and the right to this personal data to another controller if the processing is based on consent or on a contract and the processing is carried out using automated procedures. The data subjects have the right to have the personal data transmitted directly to another person responsible, to the extent that this is technically feasible.
Section 3.11 applies to the exercise of rights.
3.7 Right to object
All persons affected by data processing carried out by neotralo have the right to object to data processing under certain circumstances based on their personal situation
Section 3.11 applies to the exercise of rights.
3.8 Automated decisions in individual cases and profiling
Is the data subject subject to automated processing based on the performance of a contract, a legal obligation or based on the data subject's express consent? including profiling? If this decision is subject to and has legal effect on the person concerned, the person concerned has the right to have a person intervene on Neotralo's part, explain the decision and the person concerned has the right to express their own point of view and to contest it of the decision is granted.
Section 3.11 applies to the exercise of rights.
3.9 Right to withdraw consent
Any consent to data processing given to neotralo can be revoked under certain circumstances. Revocation is as easy as granting consent. In special cases, such as a power of attorney or a right to inspect the data by a third party, neotralo requires the revocation of consent in writing. The lawfulness of data processing until consent is revoked remains unaffected.
Section 3.11 applies to the exercise of rights.
3.10 Right to complain to the supervisory authority
In addition to the rights vis-à-vis neotralo, you also have the right to contact a data protection authority directly.
3.11 Reporting point for the exercise of the rights of those affected
To exercise these rights, we ask you to contact alcuris directly at «info@neotralo.ch» Report to. For paragraphs 3.1. until
3.6 we ask you to send us a written request and proof of identification (copy of identity card, passport). alcuris needs this to ensure that no data is incorrect
changed or deleted. The application and the copy of the identification card will be retained for 10 years from the relevant financial year.
4. Data recipient
neotralo does not disclose any data to unauthorized third parties and only processes personal data in a third country if the data protection regulations are met. Neotralo also does not transmit any data to an international organization.
As part of its activities and in compliance with the GDPR, neotralo has certain data processing operations carried out by third parties.
5. Cookies on neotralo websites
5.1 What are cookies?
A cookie is a small text file that is sent from the website (for example www.neotralo.ch) to the browser you are using (Firefox, Internet Explorer, etc.) and stored on the hard drive of your computer, smartphone or tablet (hereinafter referred to as End- called device).
On the one hand, there are session cookies that are deleted as soon as you close your browser; on the other hand, there are permanent cookies that remain stored on your device for a specific or indefinite period of time even after the browser is closed.
Session cookies are used to ensure that you can navigate undisturbed when you visit the website or that you do not have to enter information that you have entered into the website twice (that is, the website recognizes you if, for example, you visit a subpage of www.neotralo.ch call).
The website also uses permanent cookies. These serve in particular to ensure that the website remembers your settings the next time you visit and can show you relevant information that matches your interests (for example in which language the website should be displayed).
neotralo also differentiates between first-party and third-party cookies. First-party cookies are placed by neotralo when you visit our website. Third-party cookies are created by a website other than the neotralo website you are currently visiting. For example, neotralo could have integrated a “Like” button from Facebook on the websites. This “like” will set a cookie that can be read by Facebook. Such a cookie is called a third-party cookie. An advertiser can use such third-party cookies to log your visits to all pages on which their advertising is displayed. Not only on the neotralo website, but also on third-party websites using so-called “re-targeting”. Third-party advertisements are displayed on the website with content that you were interested in on our website. If you would like to prevent this, you can block third-party cookies directly in your browser or manage them via our cookie consent manager.
5.2 Which cookies are used at neotralo?
Strictly necessary cookies
Strictly necessary cookies are cookies that are essential for the proper operation of neotralo's websites. These cookies cannot be switched off by the neotralo system. In the
Normally, the cookies are set based on your surfing behavior on the neotralo website, including when you make certain settings on the website or fill out forms on the website. It is possible to block this type of cookies through your browser settings. Certain parts of the website may then no longer work.
Cookies for statistical and analytical purposes
Cookies for statistical and analysis purposes allow neotralo to count access and movements on the website, so that neotralo can continually improve the website performance. These cookies help neotralo to track individual visits to the subpages of the website and to determine which pages are accessed most often and which pages are accessed less often. All of the information collected using these cookies is stored in aggregated form and anonymously for neotralo. If you refuse the use of these cookies, neotralo can no longer determine when you and other visitors have accessed the website. This may restrict the future development of the website and impair its user-friendliness.
Functional cookies
Functional cookies allow neotralo to provide extended functions such as videos and live chats on the website. These cookies are set either by neotralo itself or by third parties (e.g. YouTube or the provider of the chat module) who provide the corresponding functions and which neotralo has integrated into their website. If you reject the use of these cookies, it may be that all or some of these additional functions on the alcuris websites no longer work or no longer work properly.
Targeting cookies
These cookies are used by neotralo's advertising partners on the neotralo website. The cookies only identify the browser and your device (computer, smartphone or tablet) with which you accessed our site. Our advertising partners can use these cookies to create a profile about your interests and use this to show you advertising that is relevant and interesting to you on other third-party websites. If you reject the use of these cookies, you will no longer be able to receive interesting and relevant offers on the Internet.
5.3 Which data is not processed with cookies?
The cookies that neotralo uses do not contain any personal data that personally identifies you. Based on the cookies we use, no information such as name, telephone number, postal and email address, banking relationship or credit card information or any other personal data is passed on to us. However, in some cookies the IP address you use is stored in an anonymized (shortened) form. neotralo does not use cookie data to identify individual people.
5.4 What data processing takes place using cookies? The cookies (according to section 5.2) are used by neotralo for different purposes. neotralo uses cookies in particular to make it easier for you to navigate the website, to support you in filling out forms (e.g. customer inquiries, premium calculators, competitions, etc.), to facilitate the use of the website and the products offered on it and Analyze services and show you offers that are interesting and relevant to you. You can view more specific information about individual cookies in the cookie settings.
5.5 Refusal of the use of cookies
If you would like to restrict or generally prohibit the use of neotralo cookies, you have the option of using our cookie consent manager. In addition, you can use the Internet browser to make general settings so that all cookies are generally accepted, you are notified when a cookie has been set up or the acceptance of all cookies or third-party cookies is refused. Consent can be revoked at any time in the consent manager or by deleting the cookies. Information and instructions on setting options or deleting cookies can be found in the help menus of the respective browsers.
If you restrict or completely prevent the use of cookies, it may be that certain services tailored to your person cannot be provided on the website. In addition, you may no longer be able to use certain interactive functions of our website.
5.6 Which third-party cookies does neotralo use? Third-party cookies can process data for their own purposes. The purpose and scope of data collection by the service provider as well as your related rights and setting options to protect your privacy can be found on the provider's website. Depending on the provider's legal regulations, the state can also inspect the data upon request. neotralo itself has no influence on how the data is processed by the providers.
Facebook pixels
neotralo uses Facebook Pixel to provide website visitors with meaningful and targeted information. Facebook Pixel is JavaScript code provided by Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA). The Facebook pixel is stored on the neotralo website. Once you have given your consent to the use of cookies for advertising purposes, the Facebook pixel sends data to Facebook. The transferred data enables Facebook to compare the data with an existing Facebook account. If a Facebook user is logged in, their visit to the page is automatically assigned to the user account.
The possible further processing of the data by Facebook cannot be controlled by neotralo. Information about Facebook's data usage, processing and setting options can be found here:
Privacy Policy: www.facebook.com/policy.php Setting options for advertising preferences: www.facebook.com com/ds/preferences/?entry_product=ad_settings_screen.
By using Facebook Pixel, neotralo only receives access to data in anonymized form. It is not possible for neotralo to draw conclusions about the identity of website visitors.
Google
neotralo uses cookies from Google Inc. (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043) on its websites. You can find information about data usage by Google, settings and objection options directly on the Google websites:
? www.google.com/intl/de/policies/privacy/partners (“Use of data by Google when you use our partners’ websites or apps”)
? www.google.com/policies/technologies/ads (“Use of data for advertising purposes”)
? www.google.de/settings/ads
(“Manage information Google uses to show you advertising”)
Google Ad Manager
neotralo uses Google Ad Manager to optimize its advertising. When you visit the neotralo website, the following cookies (Google DV360, Google Ads Remarketing Tag and Google Ads Conversion Tags) are sent to the browser. Depending on your browser settings, cookies are stored for 30 days. These cookies are used to record the activities and the number of accesses to the neotralo website. neotralo only processes the data to optimize your offer strategy and to evaluate campaign performance. At the same time, the data is assigned to an existing Google account.
Further information about the use of data by Google Inc. can be found here:
Remarketing data Conversion data
Google Analytics
neotralo uses Google Analytics, a web analysis service from Google LLC (“Google”), based on its interests (ie the interest in the analysis, optimization and economic operation of the alcuris online offering).
Google uses the information on behalf of neotralo to evaluate the use of neotralo's online offering, to compile reports on the activities within this online offering and to provide other services associated with the use of this online offering and internet usage. Pseudonymized usage profiles can be created for you from the processed data.
neotralo only uses Google Analytics with activated IP anonymization. This means that your IP address will be shortened by Google within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
You can also deactivate Google Analytics by downloading and installing the add-on available at the following link tools.google.com/dlpage/gaoptout?hl=dehttps:// tools.google.com/dlpage/gaoptout?hl=de.
LinkedIn
Furthermore, neotralo uses LinkedIn Insight Tag from LinkedIn (EU: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, USA: LinkedIn Corporation 1000 W. Maude Avenue, Sunnyvale, CA 94085). LinkedIn Insight Tag helps neotralo record the activities of visitors on the neotralo website. neotralo only processes the data to optimize its offer strategy and to evaluate campaign performance. At the same time, the data is assigned to an existing LinkedIn account.
Further information about how LinkedIn uses data can be found here: LinkedIn Insight Day
Permaleads
neotralo uses the advertising analysis tool Permaleads Connect from Permagroup GmbH (Permagroup GmbH, Neue Allmendstrasse 44, 8703 Erlenbach, CH). Permaleads Connect collects peripheral data (such as IP address, time of access, user behavior, etc.) from legal entities. This data is used neotralo for
provided for marketing purposes. Further information about Permaleads' privacy policy can be found here: www.permagroup.ch/permaleads/dsgvo/.
5.7 Scope / changes / additions to these conditions
This Cookie Policy forms an integral part of the Privacy Policy. The cookie policy can be supplemented or changed by neotralo at any time. You can change your consent to the use of cookies at any time (cookie consent manager).
6. Duration of data storage
Data will be stored at neotralo for as long as the purpose, a legal basis or another justification legitimizes this.
The maximum retention period is determined based on the following criteria:
? Is the personal data still needed?
? Is there a legal obligation that requires data to be retained for a certain period of time?
? Should the data be stored for a certain period of time for evidentiary purposes (the limitation periods are crucial)?
? Does the purpose justify further retention of data?
Special categories of personal data that are stored in paper form are only disposed of professionally and in accordance with data protection regulations by a service set up for this purpose. Data stored on an electronic data carrier will be irretrievably deleted before it is disposed of. The data carriers are destroyed.
7. Final provisions
7.1 applicability
If customers, suppliers, service providers and potential customers enter into a business relationship or any other relationship with neotralo (regardless of whether this is based on a written contractual agreement or not), this data protection declaration applies.
7.2 Access to privacy policy
This data protection declaration is always publicly accessible on the al-curis website and can be accessed by the data subjects at any time «https://bit.ly/3Qhq7jC» can be viewed.
7.3 Severability clause
If individual provisions of this data protection declaration are invalid, the remaining provisions will not be affected.
7.4 Applicable Law and Jurisdiction
The law applicable to this data protection declaration is Liechtenstein law. Swiss law applies analogously to persons domiciled exclusively in Switzerland. Complaints can be directed to the responsible data protection office.
Zurich, 4 July 2022 neotralo App AG
