Privacy Policy

SOLO AMOR AG, Wassbergstrasse 60, 8127 Forch, Switzerland (referred to herein as “SOLO AMOR”, “we”, “us” and “our”) respects your privacy. This Privacy Policy describes what we do with personal information we collect from you through our website www.soloamor.ch (the “Website”), our mobile application (if any) (the “App”) or our social media platforms (our “Social Media Pages”). This Privacy Policy does not apply to job applicants, employees or independent contractors who work for us, nor does it cover the privacy and security practices of social media platforms on which SOLO AMOR has Social Media Pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.

Please take the time to read this Privacy Policy.

SOLO AMOR is the controller responsible for the processing of personal information described in this Privacy Policy. Our contact details are set out in Section L below.

The EU General Data Protection Regulation (“GDPR”) applies to the extent that the relevant processing falls within its territorial scope. References in this Privacy Policy to GDPR rights and legal bases apply only where the GDPR applies. The Swiss Federal Act on Data Protection (“FADP”) applies to processing governed by Swiss data protection law.

We may revise this Privacy Policy from time to time. The current version will be published on our Website and will state the date on which it was last updated. Where required by applicable law, we will provide additional notice of material changes or obtain renewed consent.

A.Information We Collect

The personal information we collect depends on how you interact with us. We may collect the following categories of personal information about you:

• Device Information: When you visit our Website, use our App, interact with our Social Media Pages or online ads, or open our emails, we may learn about your browser, device type, IP address, the name and version of your operating system, the name and version of your browser, the date and time of your visit, the pages you visit, the platform you use, your screen resolution, your time zone, and any search terms you enter while on the Website.
• Location Data: We use various technologies to learn your approximate geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services and how you interact with us.
• Website/App Interactions: We collect information about your interactions with our Website and App, including pages visited, links or buttons clicked, scrolling and navigation behavior and technical interaction data. Where enabled, we may use session-recording technologies to reproduce aspects of a browsing session for troubleshooting, security, usability and analytics purposes. We configure these technologies to exclude or mask payment-card fields, passwords and other designated sensitive input fields.
• Contact Information: We may collect your contact information, including first and last name, telephone number, email address, billing address and shipping address.
• Payment Information: If you make a purchase, payment information required to process the transaction will be collected by us and/or the payment service provider selected by you. SOLO AMOR may receive limited payment-related information, such as payment status, payment method, transaction reference and partial card details. Unless expressly stated at the point of collection, SOLO AMOR does not itself store complete payment-card numbers or card security codes.
• Shopping History & Transactional Data: We keep track of your shopping history with us, including purchases, returns, exchanges and items added to your shopping cart.
• Call and Email Records: If you call, email, text, or chat with our customer service agents, we may keep records of those conversations including information you provide to us in connection with them.
• Demographic Information: We may collect demographic details about our customers such as birthdate, gender, postal code, social media information and profile data and other similar details.
• SOLO AMOR Account Data: If you want to register or have a registered account with SOLO AMOR, we will collect your Contact Information, account authentication information, such as a password stored in protected form, Demographic Information, Preferences, and Shopping History & Transactional Data.
• Social Media Usage: We may receive information relating to visits to and interactions with our Social Media Pages, including aggregated audience statistics and information that you communicate or make available to us through the relevant platform. For certain audience-insight functions, SOLO AMOR and the relevant platform may act as joint controllers to the extent determined by applicable law. The platform’s privacy notice provides further information about its processing and allocation of responsibilities.
• Preferences: We may collect information about your preferences, such as products you may be interested in.
• Inferences: We may draw inferences about any of the information above that may relate to your preferences, or other matters.

We do not intend to collect sensitive personal data through the Website or App unless this is specifically requested and necessary for a stated purpose. Please do not provide health information, biometric information, information about religious or political views, or other sensitive personal data in free-text fields or user-generated content unless we specifically request it for a stated purpose.

B.How Your Information Is Collected

We may collect the information described above directly from you, from third parties we work with, or through cookies or other automated means. These sources may include:

• You: We collect information directly from you, whenever you: make a purchase; contact us with questions or comments, respond to a survey, upload content to our Website, App, or Social Media Pages; create an account; add items to your shopping cart; opt in to text messages; fill out any forms on our Website, App, or Social Media Pages.
• Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, use our App, interact with our Social Media Pages or online advertising, or open our emails.
• Third Parties: We may receive personal information from service providers and business partners, including payment providers, logistics providers, fraud-prevention providers, analytics and advertising partners, customer-service providers and social media platforms. Depending on the source, this may include contact details, transaction and payment-status information, delivery information, fraud-risk indicators, device and interaction data, marketing identifiers and aggregated or inferred interests.
• Social Media Platforms: Social media platforms may share certain information with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings. If you contact us via our Social Media Pages to make a complaint or service request, then we will collect information related to such complaint or service request from the social media platform.
• Cookies: SOLO AMOR uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), web beacons, and other similar technologies to automatically collect information when you visit our Website, use our App, or interact with our emails.

We and our service providers use these technologies to operate the Website and App, remember settings, measure performance, understand usage and, where permitted, provide or measure personalized advertising.

Cookies and similar technologies that are not strictly necessary will be used only after obtaining consent where required by applicable law. You may withdraw or modify your consent at any time through the cookie-preference tool available on the Website. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Advertising and analytics partners may collect information about your use of our Website or App and, subject to your choices and applicable law, combine it with information from other websites, apps or services. Depending on the arrangements, those partners may process information as our processors, independent controllers or joint controllers.

The cookies and similar technologies used may include strictly necessary technologies, preference technologies, analytics technologies and advertising technologies. Their duration may range from the duration of a browsing session to a longer period, depending on their purpose and configuration. Further information about the individual technologies, providers and applicable storage periods is available through the cookie-preference tool on the Website.

C.How We Use Your Information

We process personal information for the following purposes:

• Fulfillment and Account Administration: To process and deliver orders, process payments, provide order and shipping updates, administer customer accounts, facilitate returns and respond to service requests. Where the GDPR applies, the legal basis is performance of a contract or taking steps at your request before entering into a contract. Certain processing may also be necessary to comply with legal obligations.
• Customer and Business Analytics: To understand how customers use our Website, App and communications; measure performance; identify trends; improve our products, services and user experience; and prepare aggregated business statistics. Where the GDPR applies, the legal basis is our legitimate interest in operating, evaluating and improving our business. Where consent is legally required for the relevant technology, the legal basis is consent.
• Personalization: To customize content, recommendations and the shopping experience based on your interactions, preferences and purchase history. Where the GDPR applies, the legal basis is our legitimate interest in providing relevant content, unless consent is required by applicable law.
• Electronic Marketing: To send newsletters, promotional messages and product recommendations where you have requested them or where otherwise permitted by applicable law. Where the GDPR applies, the legal basis is consent or, where legally permitted, our legitimate interest in marketing similar products to existing customers. You may unsubscribe at any time by using the link in the message or contacting us.
• Targeted Advertising and Advertising Measurement: To deliver, personalize, manage the frequency of and measure advertising on our services and third-party services. Where the GDPR applies, we rely on consent where required by applicable law.
• Communications: To respond to questions, complaints, returns, product inquiries and other requests. Where the GDPR applies, the legal basis is performance of a contract, taking pre-contractual steps, compliance with legal obligations or our legitimate interest in communicating efficiently with customers, depending on the context.
• Fraud Prevention, Payment Security and Protection of Rights: To verify transactions, prevent and detect fraud or misuse, protect customers and our systems, enforce our terms and establish, exercise or defend legal claims. Where the GDPR applies, the legal basis is our legitimate interest in preventing fraud and protecting our business and customers, compliance with legal obligations and, where relevant, performance of a contract.
• Legal and Regulatory Compliance: To comply with tax, accounting, consumer-protection, product-safety, customs, sanctions, law-enforcement and other legal requirements. Where the GDPR applies, the legal basis is compliance with a legal obligation.

Where we rely on legitimate interests, those interests include operating and improving our services, protecting our customers and systems, preventing fraud, maintaining records, responding to communications and promoting our products. We assess whether those interests are overridden by the interests or fundamental rights and freedoms of the individuals concerned.

Where the provision of personal information is required by law or necessary to enter into or perform a contract, we will indicate this where appropriate. If the required information is not provided, we may be unable to create an account, process an order, deliver products or respond to a request.

D.Automated Decision-Making and Profiling

We may use automated tools to assess transaction or fraud risk, personalize content or segment audiences for marketing purposes. Unless we inform you otherwise at the relevant time, we do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

If we introduce such decision-making, we will provide the information and safeguards required by applicable law, including meaningful information about the logic involved and the significance and expected consequences of the processing.

E.How We Share Information and for What Purposes

We disclose personal information to the following recipients or categories of recipients where necessary for the purposes described in this Privacy Policy:

• IT, Cloud-Hosting, Cybersecurity, Website-Operation and App-Operation Providers: We engage providers that host, maintain, secure, support and operate our Website, App, databases, systems and other IT infrastructure. These providers may process the categories of personal information described in Section A to the extent necessary to provide their services.
• Payment Processors, Banks, Payment-Card Networks and Fraud-Prevention Providers: We share payment, transaction, contact, device and verification information with payment processors, banks, payment-card networks, fraud-prevention providers and related financial-service providers in order to process payments, verify transactions, prevent fraud, manage chargebacks and comply with applicable legal and regulatory obligations. Certain of these recipients may process personal information as independent controllers in accordance with their own privacy notices.
• Warehousing, Fulfillment, Logistics, Delivery and Returns Providers: We share contact, order, delivery, transaction and returns information with providers that store, package, ship, deliver and process returns of products.
• Customer-Support, Communications, Email, SMS and Survey Providers: We share contact details, communication records, account information, order information and other relevant personal information with providers that assist us with customer service, transactional communications, email and SMS communications, surveys and related support functions.
• Analytics, Session-Recording, Advertising and Social Media Providers: Subject to applicable consent requirements, we share device, browser, interaction, transaction, preference, inferred-interest and marketing information with providers that assist us with analytics, session recording, advertising, campaign measurement, audience creation, personalization and social media activities. Depending on the relevant arrangement, these providers may act as our processors, independent controllers or joint controllers.
• Professional Advisers, Auditors and Insurers: We may disclose personal information to lawyers, accountants, auditors, consultants, insurers and other professional advisers where necessary to obtain advice, manage risks, conduct audits, maintain insurance coverage or establish, exercise or defend legal claims.
• Tax, Customs, Regulatory, Judicial and Law-Enforcement Authorities: We may disclose personal information to tax, customs, regulatory, judicial, law-enforcement and other public authorities where required or permitted by applicable law, legal process or binding request, or where reasonably necessary to protect our rights, property, customers, personnel or other persons.
• Prospective or Actual Purchasers, Investors and Transaction Advisers: We may disclose personal information to prospective or actual purchasers, investors, lenders, transaction counterparties and their advisers in connection with a merger, acquisition, financing, reorganization, sale of assets or shares, insolvency process or other corporate transaction. Such disclosures will be subject to appropriate confidentiality safeguards where reasonably practicable.
• Other Service Providers and Business Partners: We may disclose personal information to other providers and business partners that support the purposes described in Section C, provided that such disclosure is necessary, proportionate and permitted by applicable law.

Some recipients process personal information solely on our instructions and are contractually required to protect it. Others, including certain payment, advertising, analytics, social media and logistics providers, may process personal information as independent controllers under their own privacy notices.

We may also disclose aggregated or anonymized information that does not identify you and is no longer considered personal information under applicable law.

F.International Disclosures and Transfers

SOLO AMOR is established in Switzerland. We and the recipients described in Section E may process personal information in Switzerland, the European Economic Area, the United Kingdom, the United States and other countries in which our service providers operate.

Where personal information is disclosed from Switzerland to a country that the Swiss Federal Council has not recognized as providing an adequate level of data protection, we use a legally recognized safeguard, such as contractual data-protection clauses, and make any necessary Swiss-law adaptations and supplementary assessments or measures. A disclosure may also take place on another basis permitted by the FADP, including an applicable statutory exception.

Where the GDPR applies and personal information is transferred to a country outside the EEA that has not been recognized by the European Commission as adequate, we use an appropriate transfer mechanism, such as the European Commission’s standard contractual clauses, together with supplementary measures where required. A transfer may also be based on another mechanism or derogation permitted by the GDPR.

You may contact us using the details in Section L to request further information about the applicable safeguards or, where legally available, a copy of the relevant safeguards.

G.Your Privacy Rights

Subject to the conditions and limitations of applicable law, you may have the right to:

• request information about and access to personal information concerning you;
• request correction of inaccurate or incomplete personal information;
• request deletion or destruction of personal information;
• request restriction of processing;
• object to processing based on legitimate interests and object at any time to processing for direct-marketing purposes;
• withdraw consent at any time, without affecting processing carried out lawfully before withdrawal;
• receive personal information that you provided to us in a structured, commonly used and machine-readable format, and request its transmission to another controller, where the statutory requirements for data portability are met;
• request human review of a decision based solely on automated processing where applicable; and
• lodge a complaint with a competent data protection authority.

You may exercise your rights by contacting us using the details in Section L. We may request information reasonably necessary to verify your identity and process your request.

For matters governed by Swiss data protection law, the competent federal supervisory authority is the Federal Data Protection and Information Commissioner (“FDPIC”).

Where the GDPR applies, you may also lodge a complaint with the supervisory authority in the EU/EEA country of your habitual residence, place of work or place of the alleged infringement.

H.Retention of Your Personal Information

We retain personal information only for as long as necessary for the purposes described in this Privacy Policy and to comply with legal, accounting, tax, product-safety, fraud-prevention and record-keeping obligations, and to establish, exercise or defend legal claims.

Retention periods vary according to the nature and purpose of the information. In particular:

• invoices, accounting records and related transaction documentation are generally retained for the applicable statutory record-keeping period, which is ordinarily ten years under Swiss law;
• account information is generally retained while the account remains active and thereafter for a limited period required for legal, security and dispute-resolution purposes;
• customer-service correspondence is retained for the period reasonably necessary to resolve the request and address related legal claims;
• marketing information is retained until you unsubscribe, withdraw consent or object, after which limited suppression information may be retained to respect your choice;
• cookie and analytics data is retained for the periods indicated through the cookie-preference tool on the Website; and
• fraud-prevention and security records are retained for a period proportionate to the relevant risk and applicable limitation periods.

At the end of the applicable retention period, personal information is deleted, anonymized or securely archived where continued storage is required by law.

I.Security

We implement and maintain reasonable security safeguards that are appropriate to the size and complexity of our business and the sensitivity of the personal information we collect. Although we use measures to protect your personal information, even the most robust safeguards may not always be able to prevent all breaches of security.

Access to personal information is restricted to persons who require it for their duties, subject to appropriate confidentiality obligations. We review our safeguards in light of technological developments, implementation costs, the nature and scope of processing and the risks to individuals.

J.Information Relating to Children

The Website and App are not intended to facilitate purchases by children, and purchases may be made only by persons who satisfy the eligibility requirements in our Terms and Conditions. We do not knowingly solicit personal information from children for the purpose of allowing them to purchase products.

If we become aware that we have collected personal information from a child in circumstances requiring the consent or authorization of a parent or legal representative, we will take appropriate steps to delete the information or obtain the required authorization.

Where consent is relied upon for an information society service offered directly to a child and the GDPR applies, the age and parental-authorization requirements of the applicable EU Member State will apply.

K.Links to Other Websites

This Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). SOLO AMOR has no influence on whether operators of such Third Party Sites comply with the applicable data protection laws. We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.

L.Contact Us

We welcome your comments and questions. Please contact us at:

SOLO AMOR AG
Attn: Privacy Policy Inquiries
Wassbergstrasse 60
8127 Forch
Switzerland
Email: contact@solo-amor.com