POLITICALL AG Privacy Notice

We, PoliticAll AG ("POLITICALL", "we"), are a company with our registered office at Metallstrasse 6, 6300 Zug, Switzerland, who run the political discussion Platform PoliticAll.com ("Platform"). We give our all to create a space that values the freedom of expression.

This Privacy Notice describes how we collect and process your personal data when you use our Platform. Data protection and security are very important to us. We are committed to processing your personal data responsibly and in compliance with legal requirements. We value our commitment to freedom of expression and responsible data processing by not selling your data to any third parties for advertising purposes.

If you transmit or disclose data about other persons (e.g., your contacts) to us, we assume that you are authorized to do so and that this data is correct. By submitting data about third parties, you confirm this. Please also make sure that these third parties have been informed about this Privacy Notice. The Swiss Data Protection Act ("SDPA") is applicable to and complied with by POLITICALL. To the extent that the General Data Protection Regulation of the European Union ("GDPR") is applicable to data processing by POLITICALL, the GDPR principles will be adhered to.

1. Collection and processing of personal data

Personal data we collect and process in order to make the Platform available

You can visit the Platform and access publicly posted contents on activities from our registered members (Members) without telling us who you are. Members may select their account to be private in which case their profile information – including their posts and comments on the Profile page – is visible only to members accepted by the admin.

For both Members and non-members alike – as with any connection with a webserver – the server of our webhosting provider logs and temporarily stores certain technical data. Such data includes the IP address and operating system of your device, the date and time of access, the URL you visited, the type of browser you use and the geographic region from which you access the Platform. Our third-party service providers and we require this data for technical reasons to make the Platform available to you and to provide you with the best possible user experience.

We use cookies, tags and similar technologies. Cookies are text files that are downloaded to your computer or mobile device when you visit a website or online platform. Some of the cookies we use are necessary ("necessary cookies") in order to make available certain features of the Platform and to display it in your preferred language. Necessary cookies cannot be deactivated.

Personal data we collect and process in order to administrate, analyze, individualize, improve and secure the use of the Platform, to communicate with you and to protect our rights

With your permission, our third-party service providers (CloudSigma, Hotjar, Google, Sentry and Hubspot) and we also use cookies, which do not qualify as necessary cookies. Such may be (i) performance cookies to analyze the use of the Platform and to optimize our services and/or to enhance the usability of the Platform and/or (ii) marketing cookies to provide you with our personalized direct marketing inside of our Platform (in form of e-mail newsletters) and outside of the Platform. If you do not allow performance cookies, the website will be displayed less personalized. If you do not allow marketing cookies, the direct marketing you receive from us will not be tailored to your preferences (e.g., e-mail newsletter will not be sent at a time matching your preferences).

With your permission, we use Google Analytics, a web analytics service provided by Google LLC. If you access the Platform in the European Economic Area (EEA) or Switzerland, Google Ireland Limited is the provider of Google Analytics and controller in relation to the processing of personal data in connection with Google Analytics. Google Analytics uses cookies to collect the information that is required to evaluate and create reports on the use of the Platform and to provide other services that support our analysis and improvement of the use of the Platform.We use Google Analytics with IP anonymization. This means that your IP address will be shortened in Switzerland or the EEA. Only in exceptional cases, will the full IP address be transmitted to a Google server in the USA and shortened there. Accordingly, Google only stores the information collected via cookies in anonymous form and processes it in aggregated form. Google may be able to draw conclusions about your identity based on the data collected, create personal profiles and link this data with your Google account, if you have one. You should assume that this processing takes place if you consent to the use of performance cookies. Information about data protection with Google Analytics can be found here [https://support.google.com/analytics/answer/6004245] and if you have a Google account, you can find more details about Google's processing here [https://policies.google.com/technologies/partner-sites?hl=en]. You can alter your settings for these optional cookies at any time with effect for the future by clicking on Settings > Privacy > Cookies [https://politicall.com/en/settings/privacy/].

Finally, it is possible that we integrate elements from other social networks and other platforms operated by third parties on our website, especially social media ("plugins"). However, we do this in such a way that they are deactivated by default. As soon as you activate them (e.g., by clicking on the "share" function), the social networks and other platforms can determine that you are on our website. If you have an account with the social networks and other platforms, the social networks and other platforms can assign this information (your visit of our website) to you. The social networks and other platforms process this data on own responsibility.

We may evaluate personal aspects relating to you automatically ("profiling") based on your data for the purposes set out in this Section 1, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes (e.g., we may combine behavioral and preference data) in order to better understand you as a person (e.g., when to best send you our newsletter). In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.

If you create a profile on the Platform and join our political discussion community as a Member, you will be asked to provide us with the following information, which we will collect and process mainly for the purposes put in brackets:

1. Sign up

In the sign-up process, we ask you to provide your:

  • username (for identification and communication)
  • e-mail address (to validate your account and to notify you about your posts, comments, other activities and your eventual inactivity on the Platform)
  • current age (to assure the minimum age of 16 years for members)
  • location (for identification and to provide you with more personally relevant content).

2. My Profile

The My Profile section of the Platform lists your full name or your nickname, your location, the date of the creation of your account and your short description of yourself (Profile). Your Profile is visible to all Members (and only to members for whom you have accepted the follow request in case you set your profile settings to a private Profile). You can choose how detailed you wish your location to be disclosed in your Profile: You can provide your entire address or just your country of residence. The Platform will provide you with location choices.

Additionally, you may let us and other Members know about your political motto and interest.

Your Profile also lists (i) your posts and comments, (ii) which Members you follow or are followed by and (iii) the activities and interest tags (Tags), like your interest in specific activities you select. We store and process these Tags to provide you with more relevant content.

To be able to properly address you in our communication with you (including newsletters), we will ask you to reveal your gender to us as part of the completion of your profile.

3. Activities on the Platform

We collect and store the content you upload or enter when using the tools that facilitate organization and management of activities on the Platform. You can post content and comment other Member's posts. Non-members can only see content you posted publicly on activities. Members can see and interact with any other Member's public profile and activity.

Personal data we collect and process in order to allow invitations to discussions

We allow our Members to invite their contacts to join a specific discussion by providing us with their contact's e-mail address. As such a contact of a Member we will use your e-mail address to see whether you are already a Member. If you are not, we will delete your e-mail address immediately. If you are a Member, we will forward invitation to you, unless you object to receive any invitations. You can do so at any time and free of charge (see our contact details in clause 6).

2. Processing Principles and Legal Basis

We process your personal data responsibly, as necessary for the purposes set forth in this Privacy Notice or otherwise communicated to you, and in accordance with applicable laws. We are committed to create a space that values the freedom of expression.

We primarily use the collected personal data in order to make the Platform available, and provide our services in accordance with our contractual obligations to you, as well in order to comply with our legal obligations. In addition, we may process your personal data in particular to analyze and improve your use of the Platform (e.g., speed up search results), optimize, promote and personalize our services or to provide you with personalized suggestions and offers by us and to pursue our or our Partners' legitimate interests. We do not sell your data to third parties for advertising purposes.

However, we may also ask you for your consent to the processing of your personal data for certain purposes (e.g., our e-mail newsletter). If you have consented to certain processing activities, we will process your personal data within the scope of and based on such consent, unless we have another legal basis for this processing (e.g. legal obligation, performance of a contract or our third party's legitimate interest), or no longer need one. You may withdraw your consent at any time with effect for the future.

3. Data Security and Storage Limitation

We apply adequate technical and organizational security measures, commensurate with the level of known risk, in order to protect the confidentiality and integrity of your personal data.

We store your personal data only for as long as this is necessary to fulfill the purposes set forth in this Privacy Notice, to protect the integrity of the Platform and the interests of other members of the Platform, or to comply with our legal requirements. Personal data stored in the form of cookies will be deleted within 12 months (after the last refresh of the relevant cookie), provided that such data is not subject to any regulatory retention requirements. You may delete your personal data posted or shared on the Platform yourself in accordance and within the limits of the General Terms and Conditions. We store technical data for 6 months. We store your account data until [5] years after deletion of your account or 10 years after your last activity. Data of communication between you and us, we usually keep for 13 months after our last exchange. E-mails in personal mailboxes and written correspondence are usually kept for at least 10 years. Chats are usually kept for 2 years.

4. With whom we share your personal data

In connection with the services provided on the Platform or to comply with legal and/or regulatory obligations, it may be necessary to share your personal data (i) with third-party service providers (e.g., our third-party IT service provider); (ii) social networks and other platforms (e.g., Facebook) and/or (iii) with regulatory authorities. These parties are not all located in Switzerland. Your data may therefore be processed both in Europe and in the USA; in exceptional cases, in any country in the world. Relevant third-party service providers to whom we may share your personal data are currently: CloudSigma, Hotjar, Google, Sentry and HubSpot.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the European Commission's standard contractual clauses, which can be accessed here, here and here,unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exemption. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

5. Your rights regarding your personal data

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, to profiling carried out for direct marketing purposes and to other legitimate interests in processing.

Provided that the applicable data privacy regulation provides such rights, you have the right to access or receive certain information regarding the personal data we process, and to receive a copy of this data in a commonly used electronic form. Further, you may have (based on applicable data protection laws) a right to (i) the portability of your personal data; (ii) have your personal data rectified or object to the processing of your personal data in whole or for specific purposes (e.g., newsletter); (iii) ask us to restrict processing or to delete your personal data; (iv) withdraw consent, where our processing is based on your consent (v) or on request receive further information useful for the exercise of these rights.

Please note, however, that your rights are subject to exceptions or derogations. Where legally permitted to do so, we may refuse your request to exercise these rights. We may need to further process and retain your personal data to perform a contract with you or your company or organization, to comply with legal obligations or to protect our own legitimate interests or the rights of others. However, you have a right to lodge a complaint with a competent supervisory authority. You can find a list of authorities in the EEA here: [https://edpb.europa.eu/about-edpb/board/members_en]. You can reach the Swiss supervisory authority here: [https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html].

6. Controller / Contact

PoliticAll AG, with registered office at Metallstrasse 6, 6300 Zug, Switzerland, is the controller in relation to the data processing described herein. If you have any queries about data protection at POLITICALL or if you would like to exercise your data protection rights, please write to Farida Benbalit at contact@politicall.com.

We have designated an EU representative, as the EU GDPR may govern some of our data processing activities on or in connection with the Platform. You can contact our EU representative at [legal@politicall.com].

7. Amendments of this Privacy Notice

We may amend this Privacy Notice at any time without prior notice. The current version published on the Platform shall apply.

Last updated: February, 2022