Effective date: 04-24-2023
We (“SONECT, “us”, “we”, or “our”) are committed to protecting your privacy and want you to feel secure when visiting the www.sonect.net website (“Website”).
This page informs you of our policies regarding the collection, use and disclosure of Personal Data when you use our Website or contact us and the choices you have associated with that Data.
|Personal Data||Personal Data means data about a identified or identifiable living individual who can be identified directly or indirectly by reference to an identifier (or from those and other information either in our possession or likely to come into our possession).|
|Data Subject (or User)||
Data Subject is any living individual who is using our Website and is the subject
of Personal Data.
|Data Processor (or Service Provider)||Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.|
- Personal Data We Collect
We collect the following types of Personal Data when you browse our Website.
First and last name
This Usage Data is sent by your browser whenever you visit our Website and may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Website with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so. We use Location Data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by adjusting your device settings.
|Tracking and Cookies Data||
3 How We Collect Personal Data
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.|
This information includes the Tracking and Cookies Data (as defined above in the Section „Personal Data We Collect“).
|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.|
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“.
4 Legal Basis and Purposes
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).
We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced.
To meet regulatory and public interest obligations.
To maintain records and conduct compliance checks, e.g. anti-money laundering, fraud and crime prevention.
5 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
6 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
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.
7 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
8 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.
9 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
10 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.
|Functional Services Providers|
|Airship||Airship Servi ces Ltd||
Segment links the anonymous IDs to merge information from the above apps. For more information on Segment, please visit their Privacy
|Marketing Services Providers|
|MailChim p||The Rocket Science Group LLC||
|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
|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.
11 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.
12 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.
15 Contact Us
Dufourstrasse 47 CH-8008 Zürich [email protected]
In European Union:
SONECT Europe UAB
- Goštauto g. 8-227
LT-01108 Vilnius, Lithuania [email protected]
16 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]
LT-01130 Vilnius, Lithuania