Informativa sulla privacy del sito web

Website Privacy Policy V 1.2 2023-04-24

We collect information about you when you use our Website, including browsing and taking certain actions within it.


Means of collection Explanation Personal Data collected
Your use of the Website We keep track of certain information about you when you visit and interact with our Website. This information includes the Usage Data (as defined above in the Section “Personal Data We Collect”).
Device       and       connection information We collect information about your computer, phone, tablet, or other devices you use to access the Website. This information includes the Location Data and Usage Data (as defined above in the Section “Personal Data We Collect”).
How much of this information we collect depends on the type and settings of the device you use to access the Website.
Cookies and other tracking technologies We and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.

This information includes the Tracking and Cookies Data (as defined above in the Section “Personal Data We Collect”).

For more information, please refer to our Cookie Policy.

Other users of the Website Other users of our Website may provide information about you when they submit content through the contact form. This information includes the Contact Details (as defined above in the Section “Personal Data We Collect”).
For example, you may be mentioned in technical support issue opened by someone else. We also receive your email address from other Service users when they provide it in order to invite you to register as a SONECT Shop.
Other partners

We receive information about you and your activities on and

off the Website from third-party

This information includes the Usage Data and Tracking and

Cookies Data (as defined above


partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services          and          online advertisements.

in the Section “Personal Data We Collect”).

For more information, please refer to the Section “Service Providers”.


1                Legal Basis and Purposes

If you are from the European Economic Area (EEA), our legal basis for collecting and using the Personal Data described in this Privacy Policy depends on the Personal Data we collect and the specific purposes for which we collect it:


To perform our contractual obligations or take steps linked to a contract with you or your organisation. To register you as a SONECT Shop as instructed by you.

To provide and administer services as instructed by you. To provide you with customer support.


We may rely on your freely given consent at the time you provided your Personal Data.

To provide you with news, special offers and general information about goods, services and events which we offer (with your explicit consent).

Legitimate interests

We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced.

To provide and maintain our Website, as well as to detect, prevent and address security threats. To analyse, improve, personalise and monitor the usage of our Website and communications. To notify you about changes to our Website and our Privacy Policy.

Public interest

To meet regulatory and public interest obligations.

To maintain records and conduct compliance checks, e.g. anti-money laundering, fraud and crime prevention.


2                Data Retention

We retain your Personal Data only for as long as is necessary following the principle of limitation of the length of the storage, and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We may also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.


In the cases when the terms of data storage are indicated in the legislative regulations, the legislative regulations are applied.

Your Personal Data might be stored longer if:

  • it is necessary in order for us to defend ourselves against claims, demands or action and exercise our rights;
  • there is a reasonable suspicion of an unlawful act that is being investigated;
  • your Personal Data is necessary for the proper resolution of a dispute/ complaint;
  • under other statutory

3                Storage and Data Transfers

We store your Personal Data on our servers in Switzerland.

If you are located outside Switzerland and choose to provide information to us, please be aware that the data protection laws may differ from those of your jurisdiction.

For the purpose to provide you our services we can engage third-party service providers in the EEA. The transfer of Personal Data may be considered as needed in such situations as, e.g.:

  • in order to conclude the contract between you and us and/or to fulfill the obligations under such contract;
  • in cases indicated in laws and regulations for protection of our lawful interests, e.g. in order to bring proceedings in court/other governmental bodies;
  • in order to fulfill legal requirements or in order to realize public

In case your Personal Data is transferred outside the EEA, we will take all steps to ensure that your data is treated securely and in accordance with this Privacy Policy and we will ensure that it is protected and transferred in a manner consistent with the legal requirements applicable to the Personal Data.

This can be done in a number of different ways, for example:

  • the country to which we send the Personal Data, a territory or one or more specified sectors within that third country, or the international organization is approved by the European Commission as having an adequate level of protection;
  • the recipient has signed standard data protection clauses which are approved by the European Commission;
  • special permission has been obtained from a supervisory

We may transfer Personal Data to a third country by taking other measures, if it ensures appropriate safeguards as indicated in the GDPR.

4                Data Disclosure

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation (i.e., if required by law or in response to valid requests by public authorities, such as a court or government agency);
  • To protect and defend our rights or property;
  • To prevent or investigate possible wrongdoing in connection with the Website;


  • To protect the safety of Website visitors or the public;
  • To protect ourselves against legal

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

5                Data Security

The security of your Personal Data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We take reasonable technical and organizational security measures that we deem appropriate in order to protect your stored data against manipulation, loss, or unauthorized third-party access. Our security measures are continually adapted to technological developments.

We also take internal data privacy very seriously. Our employees and the service providers that we retain are required to maintain secrecy and to comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.

Finally, we take all the steps reasonably necessary to ensure that no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your Personal Data.

6                Data Protection Rights

You have certain data protection rights. We will respond to your request without undue delay, at the latest within one calendar month after receipt. Please note that we may ask you to verify your identity before responding to such requests.


Right to get familiar with your Personal Data and how it is processed

You have the right to know about processing of your Personal Data as well as to have the access to your Personal Data and processing. Your right to access may, however, be restricted by legislation, protection of other persons’ privacy and consideration for the Company’s business concept and business practices. The Company’s know-how, business secrets as well as internal assessments and material

may restrict your right of access.

Right to obtain a copy of your personal data You have a right to request a copy of the Personal Data held by us as a data controller, which we will provide to you in an electronic form, except in the cases when the provision of such data may affect and harm rights and freedoms of others.
Right to amendment You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.
Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. This includes cases where you wish to opt out from marketing messages.

However, such consent withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another Legal Basis for the processing. To stop receiving emails from us, please click on the “unsubscribe” link in the email you received from us or contact us at [email protected].


Right to erasure You have the right to request that we delete your Personal Data when it is no longer necessary for the Purposes for which it was collected, or when it was unlawfully processed, however, in certain cases we may not be able to erase all of your Personal Data, due to the fact that we need to store your Personal Data due to a contractual relationship or law.
Right to restriction of processing You have the right to request the restriction of our processing of your Personal Data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial Purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it. It can also pertain to a situation where you object to processing that we base on a legitimate interest. In such case we must verify if our grounds override yours.
Right to portability You have the right to request that we transmit your Personal Data to another data controller in a common format such as Excel, where this is data which you have provided to us and where we are processing it on the Legal Basis of your consent or in order to perform our contractual obligations (e.g. to provide our Services).
Right to object to processing Where the Legal Basis for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate Legal Basis for the processing which override your interests, or if we need to continue to process the Data for the establishment, exercise or defense of a legal claim.
Right to lodge a complaint with a supervisory authority

You have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law.

In Switzerland: Federal Data Protection and Information Commissioner, Feldeggweg 1, CH-3003 Bern

In Lithuania: State Data Protection Inspectorate, L. Sapiegos str. 17, 10312 Vilnius


7                Service Providers

We may employ third party companies and individuals to facilitate the operation of our Website (“Service Providers”), provide the Website on our behalf, perform Website-related services or assist us in analysing how our Website is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


App Provided by Function
Functional Services Providers
Airship Airship Servi ces Ltd

We use Airship in order to improve our Website and detect bugs in our system. To that end, we process Usage Data. For more information, please refer to the Airship Privacy Policy: https://airship.co.uk/privacy-


Amplitude Amplitude Inc

We use Amplitude in order to improve our Website and detect bugs in our system. To that end, we process Usage Data. To find out more about Amplitude,   please   access   their    Privacy   Policy:


Segment Segment.io Inc.

Segment links the anonymous IDs to merge information from the above apps. For more information on Segment, please visit their Privacy

Policy: https://segment.com/docs/legal/privacy/


Marketing Services Providers
MailChim p The    Rocket Science Group LLC

We use Mailchimp to manage email marketing subscriber lists and send emails to our subscribers. For more information on The Rocket Science Group,          please          read          their          Privacy          Policy:


Analytics Services Providers
Google Analytics Google Inc. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google,  please  visit  the  Google  Privacy  &  Terms  web page: https://policies.google.com/privacy?hl=en
Remarketing Services Providers
Google Adwords Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on

https://tools.google.com/dlpage/gaoptout — for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on Google’s privacy practices, please visit   the   Google   Privacy   &   Terms   web page: https://policies.google.com/privacy?hl=en

Facebook Meta Platforms Ireland Limited

You can learn more about interest-based advertising from Facebook by visiting                                                                                        this

page: https://www.facebook.com/help/247395082112892/?helpref= uf_share.

To opt-out from Facebook’s interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive                           Digital           Advertising           Alliance            in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on Facebook’s privacy practices,                           please             visit             Facebook’s             Data Policy: https://www.facebook.com/privacy/explanation.


8                Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.


9                Children’s Privacy

In the European Union the age limit to use the Sonect App is 18. Because of this, also our Website does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

10             Changes to This Privacy Policy

We may update our Privacy Policy from time to time.

We will notify you via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy, but we encourage you to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

11  Cookies

We use cookies and other similar technologies to ensure the stable operations of our website, in order to adapt its content to your needs, to improve the features of our website and to manage advertising campaign based on the interests of our website audience.

For more information regarding cookies, please read our COOKIE POLICY *link*.

12             Contact Us

If you have any questions about this Privacy Policy, please contact us at: In Switzerland:


Dufourstrasse 47 CH-8008 Zürich [email protected]


In European Union:


  1. Goštauto g. 8-227

LT-01108 Vilnius, Lithuania [email protected]


13             Data Protection Officer

Our data protection officer (hereinafter referred to as “DPO) continuously monitors our privacy compliance and communicates with us on data protection matters relevant to the provision of our services. You may contact our DPO regarding all issues relating to our company’s processing of your personal data and the exercise of your data protection rights by sending an e-mail to the address: [email protected]