Privacy Policy

Privacy Policy V-Locker AG (Switzerland)

Privacy Policy V-Locker Services GmbH (EU)


Privacy Policy V-Locker AG (Switzerland)

1. General

This Privacy Policy governs the processing of customer or user data ("User", "You") by V-Locker AG, Sonnentalstrasse 8, 8600 Dübendorf (CHE-135.004.269) ("V-Locker AG", "We").

The protection of Your privacy and Your personal data is important to us and we take it seriously. The following privacy policy informs You about the processing of Your data when using our products and services as well as the V-Locker website and/or the V-Locker App. Our privacy policy does not apply to third-party offers that You can access via links on the V-Locker Website and/or the V-Locker App. Please check directly with the third party providers about their privacy policies.

2. Legal basis of the Data processing

We treat Your data confidentially and in compliance with the legal data protection regulations and this Privacy Policy. The processing of personal data is governed by the Federal Data Protection Act (DSG) of June 19, 1992.

3. Data protection officer

The data protection officer is:

V-Locker AG

Sonnentalstrasse 8

8600 Dübendorf

Switzerland

4. Terms

Personal Data shall be protected against unauthorized processing by appropriate technical and organizational measures.

Processing means any handling of personal data, regardless of the means and procedures used, in particular the acquisition, storage, use, alteration, disclosure, archiving or destruction of data.

5. Processing of personal data

By using the V-Locker Website and/or the V-Locker App, You consent to the processing of Your Personal Data as described below.

We will only process Your personal data to the extent necessary to provide You with one of our products and/or services. We process personal data only with Your consent or if there is a legally recognized justification.

We process personal data only for the duration required for the respective purpose or purposes. If further storage is necessary due to legal and/or other obligations to which we are subject, we restrict processing accordingly.

6. Data security

Personal data is protected against unauthorized processing by appropriate technical and organizational measures.

7. Data collection

For the use of our products and services a registration with personal data is required.

7.1 General data processing when using V-Locker services

7.1.1 Data processing by V-Locker contact

When contacting us via contact form, email, chat, Whatsapp or telephone, we use the information You provide for the purpose of processing the request and for possible follow-up requests. The processing is based on our legitimate interest in being able to answer Customer inquiries.

7.2 Data processing when using the V-Locker website

7.2.1 Privacy Policy V-Locker Website

When using the V-Locker website, the website's privacy policy applies in addition to this privacy policy. This can be accessed at the following address: v-locker.ch/data.

7.3 Data processing when using the V-Locker App

7.3.1 Location service OpenStreetMap

In order to be able to inform You if You are near a V-Locker tower and/or how to get there, we require Your location. For this purpose we use the software "OpenStreetMap" (Open Street Map Foundation (OSMF) United Kingdom). This application is also used to translate geo-locations into addresses and to show You the estimated walking or driving distance to the selected facility (or list of facilities).

OpenStreetMap's privacy policy can be viewed at the following address: wiki.osmfoundation.org/wiki/Privacy_Policy.

OpenStreetMap's Terms of Use can be viewed at the following address: wiki.osmfoundation.org/wiki/Terms_of_Use.

7.3.2 V-Locker Analytics

In order to continuously optimize the V-Locker App, we collect the following technical data, among others:

7.4 Data processing for product information and advertising purposes

7.4.1 New Products, Services or Features

We test new products, services and/or features from time to time. These products, services and/or features may only be made available to certain user groups during the test phase. In order to select test customers, we will need access to Your location data. If you do not want to test new products, services and/or features, You can disable the "Service and Product News" feature in the settings.

7.4.2 Advertising

We send personalized and non-personalized marketing messages.

We send personalized marketing messages about our products and services via email, SMS and/or in-app push notifications. The information sent is based on the respective User profile. The information provided upon creation of the User account as well as automatically collected information, such as:

The personalized marketing messages will only be sent with Your permission. You can withdraw Your permission at any time in the settings of the V-Locker App or by sending an email to dpo@v-locker.ch.

We send non-personalized marketing messages to keep You informed about our products and services. For this purpose, we use the email address or other contact information provided during account creation.

7.4.3 Newsletter

We regularly send Users and interested parties advertising about our products and services and/or the products and services of our partners by e-mail. For this purpose, we use the e-mail address and country data You provided during registation for the newsletters.

When You register for the newsletter, we obtain Your consent as follows: Your e-mail address is identified by the double opt-in process. This means that after the initial registration You will receive a separate confirmation e-mail in which You must agree to receive the newsletters. During the subscription to the newsletter, we register the following information:

The purpose of this procedure is to verify Your registration and, if necessary, to be able to clarify a possible misuse of Your personal data. In the context of the confirmation e-mail, as well as in each subsequent newsletter, we will refer to the revocation option. We use the "Zoho" software for sending our newsletter (see section 7.5). You can find more information about our B2B newsletter at the following address: v-locker.ch/data.

7.4.4 Disclosure of data and withdrawal

The data collected for promotional purposes will not be disclosed to third parties. Your data will be stored as long as the business relationship with us is legally applicable and You have not revoked Your consent to data processing. You can withdraw Your permission by sending an e-mail to dpo@v-locker.ch or by writing to us directly. Each of our notification contains an unsubscribe link, the selection of which is considered as a cancellation.

7.5 Data collection for research purposes

We target users who meet a specific usage criterion (e.g., purchase a certain package) in our App to obtain feedback on our products and/or services. If You meet one of these criteria, we may send You in-app notifications, emails and/or SMS inviting You to participate in our user research initiatives. Participation in our user research initiatives is completely voluntary and only with Your permission.

If You agree to participate in one of our user research initiatives, we may invite You to complete a survey or participate in a recorded conference call with our research team. We may ask You for information such as Your usage habits, age group, industry in which you work, opinions and preferences regarding our third-party services or service, etc. If You decide to participate in a research we will ask if You agree to a video recording of the interview. If You do not, you can tell us and the interview will take place without a video recording. Regardless of the option you choose, we will ask You to sign the letter of agreement electronically.

As a rule, Your data will be kept for three months. It will be deleted after six months at the latest.

We use the software "FindMind", "Zoho" and "Microsoft Teams" to conduct surveys and user interviews.

The companies mentioned above receive personal data exclusively for the purpose of providing their services to us and are contractually obligated to use personal data exclusively these purposes. It is the responsibility of the user to be informed about the privacy policy of these companies.

8. Data Subject Rights

8.1 Right of access

Within the scope of Art. 8 DSG, You have the right to request the information whether Your data been processed. Upon request, V-Locker AG will provide You with all the existing data, including available information on the origin of the data, the purpose and, if applicable, the legal basis of the processing, as well as the categories of personal data processed, the parties involved in the collection and the data recipients. The restriction of the right to information according to Art. 9 FADP remains reserved.

8.2 Right of objection

You can revoke your consent to the processing of Your personal data at any time and without giving the reasons. We will no longer process Your personal data from the time of the revocation unless there are compelling reasons for the processing that are worthy of protection.

We explicitly point out that a restriction or revocation of the processing right may prevent V-Locker AG from providing its contractual services.

To assert your data protection rights, You can contact our data protection officer by e-mail or in writing (see section 3). For all Your requests, we ask to always send proof of Your identity, such as a copy of Your electronic ID.

9. Data processing by third parties

In addition to the service providers mentioned in Section 7.3 and Section 7.5, we have involved the following services for data processing activities:

Your personal information may also be transferred to the following recipients:

Your personal data will only be passed on to third parties if this is permitted or required by Swiss and European data protection law. This is the case if You have expressly consented to the transfer of Your data and / or the transfer is necessary for the performance of the contract. Furthermore, disclosure is permissible under data protection law if the enforcement of regulations of other laws (e.g. criminal regulations) require the disclosure and there is nothing to prevent this disclosure from a data protection perspective. Aggregated and anonymous data on traffic data are also made available to public institutions, such as research centers, cities and municipalities to improve the local traffic situation. Individuals can no longer be derived from this aggregated data. If we transfer data to recipients located outside the European Economic Area ("EEA"), we ensure that either an adequate level of data protection exists at the recipient (e.g. based on an adequacy decision of the EU Commission for the respective country or the agreement of so-called EU standard contractual clauses of the European Union with the recipient) or Your consent to the transfer has been obtained.

10. Disclaimer

All information in our offer has been carefully checked. We make every effort to ensure that the information we provide is up-to-date, accurate and complete. Nevertheless, the occurrence of errors can not be completely excluded, so we can not guarantee the completeness, accuracy and / or timeliness of information. We expressly point out that data transmission on the Internet can have security gaps. A complete protection of data against access by third parties is not possible.

Liability claims arising from direct and/or indirect damage of a material or non-material nature caused by the use of the information provided on the V-Locker website and/or in the V-Locker app are excluded to the extent permitted by law.

We may, at our sole discretion and without notice, modify and/or delete any text on the V-Locker Website and/or the V-Locker App and are under no obligation to update such content. Use of and/or access to the V-Locker Website and/or the V-Locker App is at Your own risk. We assume no liability for any direct and/or indirect damages allegedly caused by visiting the V-Locker Website and/or the V-Locker App.

We assume no liability for the content and availability of third party websites that are accessible via external links of the V-Locker Website and/or the V-Locker App. The operators of the linked sites are exclusively responsible for their content. The publisher thus expressly dissociates itself from all third party content that may be relevant under criminal or liability law or offend common decency.

11. Final provisions

11.1 Legally bound

The original English text of this Privacy Policy is legally binding. The original English text shall take precedence over any translations.

11.2 Amendment of the data protection declaration

We reserve the right to amend this Privacy Policy at any time to ensure that it always complies with current legal requirements or to implement changes to our services in the Privacy Policy. We recommend that You check the privacy policy regularly for possible changes. If Your prior consent is required for a change to our services or for the introduction of a new service, we will inform You accordingly in good time and request Your consent.

11.3 Severability clause

The invalidity or unenforceability of any provision of this Privacy Policy shall not affect the validity of the remaining provisions. An invalid provision will be replaced by a provision that legally and economically comes closest to the original, unenforceable provision.



Privacy Policy V-Locker Services GmbH (EU)

12. General

This Privacy Policy governs the processing of customer or user data ("User", "You") by V-Locker Services GmbH, Quellenstrasse 7a, 70376 Stuttgart, Germany ("V-Locker Services GmbH", "We").

The protection of Your privacy and Your personal data is important to us and is taken seriously by us. The following privacy policy informs You about the processing of Your data when using our products and services as well as the V-Locker Website and/or the V-Locker App. Our privacy policy does not apply to third-party offers that You can access via links on the V-Locker Website and/or the V-Locker App. Please check directly with the third party providers about their privacy policies.

13. Legal basis of the processing

We treat Your data confidentially and in accordance with the legal data protection regulations and this Privacy Policy. The processing of personal data is governed by the EU General Data Protection Regulation (DSGVO).

14. Data protection officer

Data protection officer in the sense of the DSGVO is:

V-Locker Services GmbH

Quellenstrasse 7a

70376 Stuttgart

15. Terms

Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

16. Processing of personal data

By using the V-Locker Website and/or the V-Locker App, You consent to the processing of Your personal data as described below.

We process Your personal data only to the extent necessary to provide one of our products and/or services. As far as and insofar as the DSGVO is applicable, we process Your personal data in accordance with Art. 6 (1) DSGVO:

  1. processing of personal data with the consent of the data subject;
  2. processing of personal data for the performance of a contract with the data subject as well as for the implementation of corresponding pre-contractual measures;
  3. processing of personal data for compliance with a legal obligation to which we are subject under any applicable law of the EU or under any applicable law of a country where the GDPR applies in whole or in part;
  4. processing of personal data in order to protect vital interests of the data subject or another natural person;
  5. processing of personal data to protect the legitimate interests of us or of third parties, unless such interests are overridden by the fundamental freedoms and rights and interests of the data subject. Legitimate interests include, in particular, our business interest in being able to provide our V-Locker Website and/or V-Locker App information security, the enforcement of our own legal claims and compliance with legal obligations.

We process personal data only for the duration required for the respective purpose(s). If further retention is necessary due to legal and/or other obligations to which we are subject, we restrict processing accordingly.

17. Data security

Personal data is protected against unauthorized processing by appropriate technical and organizational measures.

18. Data collection

For the use of our products and services, registration is required by providing personal data.

18.1 General data processing when using V-Locker Services

18.1.1 Data processing when contacting us

When contacting us via contact form, email, chat, Whatsapp or phone, we use the information You provide for the purpose of processing the request and for possible follow-up requests. The processing is based on our legitimate interest in being able to answer User inquiries.

18.2 Data processing when using the V-Locker Website

18.2.1 Privacy Policy V-Locker Website

When using the V-Locker Website, the privacy policy of the Website applies in addition to this privacy policy. This can be accessed at the following address: v-locker.ch/data.

18.3 Data processing when using the V-Locker App

18.3.1 Location Service OpenStreetMap

In order to identify if You are near a V-Locker tower and/or how to get there, we require Your location. For this purpose we use the software "OpenStreetMap" (Open Street Map Foundation (OSMF) United Kingdom). This application is also used to convert geo-locations into addresses and to show You the estimated walking or driving distance to the selected facility (or list of facilities).

OpenStreetMap's privacy policy can be viewed at the following address: wiki.osmfoundation.org/wiki/Privacy_Policy.

OpenStreetMap's Terms of Use can be viewed at the following address: wiki.osmfoundation.org/wiki/Terms_of_Use.

18.3.2 V-Locker Analytics

In order to continuously optimize the V-Locker App, we collect, among other data, the following technical data:

18.4 Data processing for product information and advertising purposes

18.4.1 New Products, Services or Features

We test new products, services and/or features from time to time. These products, services and/or features may only be made available to certain groups of users during the testing period. In order to select test customers, we will need access to Your location data. If You do not want to test new products, services and/or features, You can disable the "Service and Product News" feature in the settings.

18.4.2 Advertising

We send personalized and non-personalized marketing messages.

We send personalized marketing messages about our products and services via email, SMS and/or in-app push notifications. The information sent is based on the respective User profile. The information provided when the customer account was created, as well as automatically collected information such as:

The personalized marketing messages are sent only with Your consent. Consent can be revoked at any time in the V-Locker App settings or via email to dpo@v-locker.ch.

We send non-personalized marketing messages to keep You informed about our products and services. For this purpose, we use the email address or other contact information you provided when while creating User account.

18.4.3 Newsletter

We regularly send customers and interested parties advertising about our products and services and/or the products and services of our partners by e-mail. For this purpose, we use the e-mail address and country data that You provided when registering for the newsletters.

When You register for the newsletter, we obtain Your consent as follows: Your e-mail address is identified by the double opt-in procedure. This means that after the initial registration You will receive a separate confirmation e-mail in which You must agree to receive the newsletter. For the registration to the newsletter, we register the following information:

The purpose of this procedure is to verify Your registration and, if necessary, to be able to clarify a possible misuse of Your personal data. In the context of the confirmation e-mail as well as in each subsequent newsletter, we will refer to the revocation option. We use the "Zoho" software for sending our newsletter (see section 7.5). You can find more information about our B2B newsletter at the following address: v-locker.ch/data.

18.4.4 Disclosure of data and revocation

The data collected for promotional purposes will not be disclosed to third parties. Your data will be stored as long as the business relationship with us is legally applicable and You have not revoked Your consent to data processing. You can withdraw Your consent by sending an email to dpo@v-locker.ch or by writing to us directly. Each of our notification contains an unsubscribe link, the selection of which is considered as a cancellation.

18.5 Data Collection for Research

We target users who meet a specific usage criterion (e.g., purchasing of a certain package) in our App to obtain feedback on our products and/or services. If You meet one of these criteria, we may send You in-app notifications, e-mails and/or SMS inviting you to participate in our user research initiatives. Participation in our user research initiatives is completely voluntary and solely upon Your permission.

If You agree to participate in one of our user research initiatives, we may invite You to complete a survey or participate in a recorded conference call with our research team. We may ask You for information such as Your usage habits, age group, industry in which You work, opinions and preferences regarding our third-party services or service, etc. If You decide to participate in a user interview, we will ask if You agree to a video recording of the interview. If You do not, You can let us know and the interview will take place without video recording. Regardless of the option You choose, we will ask You to sign our letter of agreement electronically.

As a rule, Your data will be kept for three months. It will be deleted after six months at the latest.

We use the software "FindMind", "Zoho" and "Microsoft Teams" to conduct surveys and user interviews.

The above mentioned companies receive personal data exclusively for the purpose of providing their services to us and are contractually obligated to use personal data exclusively for the same purposes. It is the responsibility of the User to be informed about the privacy policy of these companies.

19. Data Subject Rights

19.1 Right of access

You may at any time request information about the personal data we have stored about You, its origin, recipients and/or categories of recipients, as well as the type and purpose of the processing (Art. 15 DSGVO).

19.2 Right of rectification

If the stored personal data is incorrect or incomplete, You may at any time request to complete or correct the data (Art. 16 DSGVO).

19.3 Right of deletion

The personal data processed by us will be deleted or restricted in processing in accordance with Art. 17 and 18 DSGVO. Unless explicitly stated within the scope of this data protection declaration, the personal data stored by us will be deleted as soon as it is no longer required for the intended purpose and the deletion does not conflict with any statutory retention obligations. If the personal data is not deleted because it is required for other and legally authorized purposes, its processing will be restricted, i.e. the personal data will be blocked and not processed for other purposes.

Under certain circumstances, You have the right to block or delete the data we have stored about You. The deletion or blocking of Your personal data will take place as soon as we have checked the conditions for the legitimacy of Your request. If the deletion is contrary to legal or contractual requirements, we can only block Your data instead of deleting it. After deletion of Your data, it is no longer possible to provide information.

19.4 Right of data transfer

You have the right to receive Your personal data in a structured, common and machine-readable format and to transfer this data to another responsible party, insofar as this is technically feasible and does not involve unreasonable effort (Art. 20 DSGVO).

19.5 Right of objection

You may revoke Your consent to the processing of Your personal data at any time and without giving reasons. We will no longer process Your personal data from the time of revocation unless there are compelling legitimate reasons(Art. 21 DSGVO).

19.6 Extended rights in relation to automated data processing

You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning You or otherwise significantly affects You (Art. 21 (1) GDPR). The restrictions pursuant to Art. 22 (2) of the GDPR remain reserved.

We explicitly point out that a restriction or revocation of the processing right may prevent V-Locker Services GmbH from providing its contractual services.

To assert Your data protection rights, You can contact our data protection officer by e-mail or in writing (see section 3). For all Your requests, we ask You to always send proof of your identity, such as a copy of Your electronic ID.

20. Data processing by third parties

In addition to the service providers mentioned in Section 7.3 and Section 7.5, we have engaged services for the following processing activities:

Your personal information may also be transferred to the following recipients:

Your personal data will only be passed on to third parties if this is permitted or required by European data protection law. This is the case if You have explicitly consented to the transfer of Your data and / or the transfer is necessary for the performance of the contract. Furthermore, disclosure is permissible under data protection law if the enforcement of regulations of other laws (e.g. criminal regulations) require the disclosure and nothing prevents this disclosure in compliance with the data protection. Additionally, aggregated and anonymous traffic data is also will be available to public institutions, such as research centers, cities and municipalities to improve the local traffic situation. Individuals can no longer be derived from this aggregated data. If we transfer data to recipients located outside the European Economic Area ("EEA"), we ensure that either an adequate level of data protection applied at the recipient (e.g. based on an adequacy decision of the EU Commission for the respective country or the agreement of so-called EU standard contractual clauses of the European Union with the recipient) or Your consent to the transfer has been obtained.

21. Disclaimer

All information on our Website has been carefully checked. We make every effort to ensure that the information we provide is up-to-date, accurate and complete. Nevertheless, the occurrence of errors can not be completely excluded, so we can not guarantee the completeness, accuracy and / or timeliness of information. We expressly emphasize that data transmission on the Internet can have security gaps. A complete protection of data against access by third parties is not possible.

Liability claims arising from direct and/or indirect damage of a material or non-material nature caused by the use of the information provided on the V-Locker Website and/or the V-Locker App are excluded to the extent permitted by law.

We may, at our sole discretion and without notice, modify and/or delete any text on the V-Locker Website or the V-Locker App and have no obligation to update such content. Use of or access to the V-Locker Website and/or the V-Locker App is at Your own risk. We assume no liability for any direct and/or indirect damages allegedly caused by visiting the V-Locker Website and/or the V-Locker App.

We assume no liability for the content and availability of third party websites that are accessible via external links of the V-Locker Website and/or the V-Locker App. The operators of the linked sites are exclusively responsible for their content. The publisher thus expressly dissociates itself from all third party content that may be relevant under criminal or liability law or offend common decency.

22. Final provisions

22.1 Legally bound

The original English text of this Privacy Policy is legally binding. The original English text shall take precedence over any translations.

22.2 Amendment of the data protection declaration

We reserve the right to amend this Privacy Policy at any time to ensure that it always complies with current legal requirements or to implement changes to our services in the Privacy Policy. We recommend that You check the Privacy Policy regularly for possible changes. If Your prior consent is required for a change to our services or for the introduction of a new service, we will inform You accordingly in good time and request your consent.

22.3 Severability clause

The invalidity or unenforceability of any provision of this Privacy Policy shall not affect the validity of the remaining provisions. An invalid provision shall be replaced by a provision that legally and economically comes closest to the original, unenforceable provision.