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sugarmillion GmbH, Florastrasse 14, 4500 Solothurn, Switzerland (hereinafter "sugarmillion" or "we") offers visitors to the sugarmillion website (www.sugarmillion.com) (hereinafter "website") the subscription to the sugarmillion newsletter (hereinafter "sugarmillion") the following “Newsletter”).

In the following, in accordance with Articles 13 and 14 of the General Data Protection Regulation (“GDPR”), we provide information on the processing of personal data in the context of newsletter subscriptions.

Further information about the processing of personal data within the framework of the website can be found in the data protection regulations of the sugarmillion website.

A. Name and Contact Information of Controller

sugarmillion GmbH

Florastrasse 14, 4500 Solothurn, Switzerland

Email: contact@sugarmillion.com

B. Contact details of our data protection officer

You can reach our data protection officer under the following contact details:

sugarmillion GmbH

Data Protection Officer

Florastrasse 14, 4500 Solothurn, Switzerland

Email: contact@sugarmillion.com

 

C. Categories and Sources of Personal Data

We process the following (categories of) personal data:

 

Categories of personal data processed Types of personal data within the category Source of personal data (and, if applicable, whether the source is publicly available) Data we collect when you sign up for the newsletter (“Subscription Data”) E-mail address (mandatory), title, first name, last name (optional).

When you register on the website, we also record the country-specific version of the sugarmillion website through which you register for the newsletter.

Log data that is generated for technical reasons when registering and deregistering for the newsletter ("registration and deregistration data") Date and time of the confirmation of the registration in the double opt-in procedure as well as the IP address of the end device used for the confirmation, date and Time of any cancellation of the newsletter. Newsletter Subscribers

Log data that is generated for technical reasons when our newsletter is called up by tracking pixels** contained in the newsletter via the hypertext transmission protocol (HTTP) ("newsletter HTTP data") IP address, date and time of the call, newsletter subscriber data that stored in cookies* in the newsletter subscriber’s browser when our newsletter is called up (“newsletter cookie data”). Unique ID for (re-)recognition of the newsletter subscriber.

Data in usage profiles that we create by analyzing usage behavior in the newsletter when using pseudonyms ("newsletter usage profile data"). Data about the use of the newsletter, in particular calls, frequency of calls and click behavior in called newsletters.

Log data that is generated for technical reasons when you access the sugarmillion website via the hypertext transfer protocol (HTTP) ("website HTTP data") IP address, type and version of your Internet browser, operating system used, the page accessed, the previously visited page (referrer URL), date and time of retrieval.

* Cookies are small text files with information that are placed on the user's end device via the browser when visiting a website. When you visit the website again with the same device, the cookie and the information stored in it can be retrieved. Depending on the storage period, so-called transient and persistent cookies can be distinguished. Transient cookies, also known as session cookies, are automatically deleted when you close your browser. Persistent cookies remain stored on your end device for a certain period of time even after you close your browser.

** Web beacons (also "tracking pixels") are small graphics in HTML emails or on websites that enable log file recording and log file analysis of email or website access

D. Purpose and legal basis for processing personal data

We process the (categories of) personal data mentioned under point C above for the following purposes and on the basis of the following legal bases.

 

If the processing is based on Art. 6 (1) (f) GDPR, we also indicate the legitimate interests pursued by us or a third party.

 

purpose of processing

Provision of the web applications on the website in which you can provide us with data to subscribe to or unsubscribe from our newsletter. Website HTTP data, subscription data, subscription and unsubscription data Art. 6 (1) (f) GDPR hosting service provider newsletter service provider

“Double opt-in” procedure to confirm subscription.

For this purpose, we will send an e-mail message with a request for confirmation to the e-mail address given during registration. A subscription only becomes effective when the subscriber confirms the e-mail address by clicking on the confirmation link contained in the e-mail.

We use the salutation and your name given when registering to address you personally in our newsletter.

Analysis of the usage behavior of newsletter subscribers in our newsletter and on our website and creation of usage profiles when using pseudonyms and subscriber segments based on this for the purposes of personalization and needs-based design of the newsletter. Subscription Data, Newsletter HTTP Data, Newsletter Cookie Data, Newsletter Usage Profile Data, Website HTTP Data, Website Cookie Data, Website Usage Profile Data, Segment Data Art. 6 (1) ( a) GDPR

E. Recipients who receive personal data

For the purposes described under point D above, we use processors who support us in handling our business processes. Specifically, this includes the following service providers or categories of service providers to whom we disclose personal data:

hosting service provider

newsletter service provider

F. Duration for which the personal data will be stored

The duration for which the personal data is stored is listed below or is determined by the following criteria:

(Categories of) personal data

(for details on the respective categories see point C above) Duration for which the personal data is stored / criteria for determining this duration

Subscription data, registration and cancellation data We store this data as long as you have registered for our newsletter. In exceptional cases, we also store this data if and for as long as we are subject to statutory storage or documentation obligations for this data or if this is necessary for evidence purposes.

Newsletter HTTP data, newsletter cookie data, newsletter usage profile data, website HTTP data, website cookie data, website usage profile data, segment data We only store this data for as long as you subscribe to our newsletter have registered. We delete this data as soon as you have unsubscribed from our newsletter.

G. Necessity or obligation to provide personal data and possible consequences of failure to provide such data

The provision of the following personal data is required by law or contract/mandatory or required for the conclusion of a contract:

(Categories of) personal data

(for details on the respective categories see point C above)

Possible consequences of not providing such data

Subscription data In order to receive the newsletter, you must enter your e-mail address when registering. Failure to provide the email address means that we cannot send you the newsletter.

H. Rights of the data subject

I. Information, correction, deletion, restriction, data portability

With regard to the processing of personal data, you have the following rights:

To request information about your personal data from us in accordance with Art. 15 GDPR.

To request us to correct your personal data in accordance with Art. 16 GDPR.

To request us to delete your personal data in accordance with Art. 17 GDPR.

To request us to restrict the processing of your personal data in accordance with Art. 18 GDPR.

The right to data portability according to Art. 20 GDPR.

II. Right to object

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Art. 6 (1) (e) or (f) GDPR (see point D above), to object.

If personal data is processed in order to operate direct advertising (see point D above), you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

III. Right to revoke consent

If the processing is based on Art. 6 (1) (a) or Art. 9 (2) (a) GDPR (see point D above), you have the right to withdraw your consent at any time without affecting the legality of the processing based on the Consent is affected by the processing that has taken place up to the point of revocation.

IV. Right to complain to the supervisory authority

You have the right to lodge a complaint with a supervisory authority in accordance with Art. 57 (1) lit. (f) GDPR.

 

Status: 02/19/2022

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