This privacy statement for myfreelap.com and app.freelap.com, services provided by Freelap SA, explains how we process your data when you use our websites and mobile applications (MyFreelap Legacy and MyFreelap), or in any other context.
For these platforms, we are responsible for processing your personal data and ensuring that such processing complies with applicable law. We comply with the applicable data protection regulations.
“Personal data” refers to any information relating to the personal or material circumstances of an identified or identifiable natural person. This means information that can be linked to you and provide details about you. In this data protection statement, this information is also referred to as “your data”.
“Processing” refers to any operation performed on your data, including its collection, recording, management, use, transfer, disclosure or deletion.
Please note that the information below may be amended at any time. We therefore recommend that you consult this privacy statement regularly. Third-party websites accessible through our platforms are not subject to the principles set out in this statement. We accept no responsibility for the data protection practices of third-party websites.
Below, you will find information about the types of personal data we collect and store when you visit our platforms, how we use this data and the parties to whom we may disclose it, where applicable. You will also find information about your rights concerning our use of your data.
1. Scope and purpose of personal data processing
a. When visiting our platforms
If you use our digital services without providing any additional information, the web server technology we use automatically records general technical browsing data in log files.
This data may include the IP address of the device used to access the platform, information about the browser type, internet service provider and operating system, the digital services accessed, referring and exit pages, and the date and duration of the visit.
The purpose of collecting and processing this information is to :
- Enable the use of our websites and establish a connection
- Ensure and improve the security and stability of our systems and services
- Analyse the use of our services
- Collect general demographic information
- Optimise our online services, including product improvements, marketing activities and targeted advertising
- Compile internal statistics
Users are not identified during this process. As a general rule, the information collected automatically is not linked to the personal data stored by us.
An exception may apply if you already have a registered user account on one of our platforms. Further information concerning the processing of personal data belonging to registered users can be found in Sections 1.b and 1.c below.
We may use personal data that you have voluntarily disclosed for marketing or analytical purposes. Further information regarding the processing of personal data for marketing or analytical purposes can be found in Section 2.
If you access our platforms using a mobile device, we will request your permission before determining your precise location using GPS or other technologies.
When you visit our platforms, we also use cookies and analytical tools such as Google Analytics. Please refer to Sections 7 and 8 of this privacy statement for further information.
b. When creating a user account
Registration and the creation of a user account are required to use our personalised services or access protected areas.
To create an account, you may be required to provide certain personal data, including :
- Your email address, which may also be used as your username
- A password
- Information relating to newsletter subscriptions or other marketing communications
- Your preferred language
- Other information that may be required depending on the context and the service concerned
In addition to the information identified as mandatory for the use of a particular digital service, you may voluntarily provide and save further personal data.
We use this data to provide and manage our digital services and to verify the plausibility of the information supplied. We may also use it to establish, define, perform and amend the contractual relationship associated with your user account.
Any contributions submitted through the relevant functions of our platforms for sharing with other users will not be disclosed or made publicly available. This also applies to your username or any pseudonym you may have selected for this purpose.
By confirming the creation or modification of your user account information, you confirm that the information you have provided is accurate.
c. When using a platform as a registered user
When a registered user accesses one of our platforms, we collect data for statistical purposes, to ensure that the platform operates correctly and to analyse, optimise and personalise the use of our services.
This may include information about how you use our digital services and which functions you access.
Further information regarding the processing of this personal data can be found in Section 2.
2. Direct marketing and online advertising
Following your registration on one of our platforms, we may also use your personal data for personalised advertising purposes.
This includes the personalisation of advertising by email, such as newsletters containing general or promotional information, as well as the delivery of personalised content and advertising on our platforms.
For this purpose, we may automatically analyse information available to us regarding your behaviour as a user of our platforms. This allows us to avoid sending you advertising that is irrelevant to your interests.
3. Disclosure of data to third parties
The personal data you provide to us is not sold, rented or exchanged outside Freelap SA.
4. Right of access, rectification, deletion and complaint
You may exercise your data protection rights at any time and request information about the personal data we process concerning you.
You may also request the rectification, restriction or deletion of your personal data at any time by contacting us in writing and providing proof of your identity at the following address : contact@freelap.ch
To prevent or reduce the collection of personal data, you must follow the steps described in Section 7 concerning the deactivation of cookies. Please note that this may prevent you from using some of the services you have requested.
You also have the right to lodge a complaint regarding the processing of your personal data with the competent supervisory authority. You may contact the supervisory authority responsible for your place of residence, your place of work or the location where the alleged data protection violation occurred.
5. Retention period for your personal data
We retain your personal data only for as long as required by law or necessary for the purpose for which it is processed.
For analytical purposes, we retain your data only until the analysis has been completed.
If we retain your data in connection with a contractual relationship, we keep it only for the duration of that relationship and, where applicable, until the expiry of any statutory limitation periods for potential claims in our favour, or for any longer period required by law or contractual provisions.
6. Data security
We implement appropriate technical and organisational security measures to protect the personal data stored by us against accidental, unlawful or unauthorised manipulation, deletion, alteration, access, transfer or use, as well as against partial or total loss.
Our security measures are continuously reviewed and improved in line with technological developments.
However, we cannot guarantee absolute data security and accept no responsibility for data loss or for the disclosure or use of data by unauthorised third parties where this occurs beyond our reasonable control.
If you register with us as a user, access to your user account is protected by your personal password.
We also take data protection within our organisation very seriously. Our employees and the employees of service providers acting on our behalf are bound by confidentiality obligations and are required to comply with applicable data protection legislation.
7. Cookies
Cookies help us organise your visit to our websites and make it easier, more enjoyable and more relevant.
Cookies are files containing information that your web browser automatically stores on your computer’s hard drive when you visit our website.
Cookies do not damage your computer’s hard drive and do not directly provide us with users’ personal data.
We use cookies, for example, to determine how frequently certain pages or services are viewed, which sections of our platforms are particularly popular and how our platforms are used.
We also use cookies to allow you to browse our platforms freely and use their functions, such as accessing protected areas.
Cookies may also remember the choices and settings you have selected to improve your experience when visiting our platforms.
In general, cookies help us improve our services and make them more efficient and secure.
Most web browsers accept cookies automatically. However, you can configure your browser so that cookies are not stored on your computer or so that you are notified whenever a new cookie is received.
Our digital services can generally be used without cookies. However, some functions may be restricted or unavailable.
8. Tracking and analytical tools
The use of our digital services is measured and analysed using various technical systems, primarily those provided by third parties such as Google Analytics.
These measurements may be carried out anonymously or may involve identifiable data.
The data collected may be transferred to third parties for processing on our behalf or processed by the third-party providers of these technical systems.
One of the analytical tools we use is Google Analytics, a service provided by Google.
The data collected may be transferred to and processed on Google servers in the United States. However, IP addresses are anonymised through an appropriate process so that they cannot be directly associated with an individual.
Google will therefore not associate the IP address transmitted by your browser through Google Analytics with other data held about you.
You can prevent Google Analytics from collecting and processing your data by installing Google’s opt-out browser add-on. This will prevent your data from being collected during future visits to this website :
https://tools.google.com/dlpage/gaoptout?hl=en
9. Legal basis
We process your personal data only in accordance with applicable data processing principles and where a valid legal basis exists.
Such a legal basis may arise when processing is necessary to prepare or perform a contract with you.
We also have a legitimate interest in continuously improving our services and adapting them to your needs. This is necessary to develop and finance our services and to ensure their security.
Where required, we consider that our legitimate interests prevail, provided that your fundamental rights and freedoms do not override those interests.
Where you have given your consent to the processing of your personal data, that consent also constitutes a legal basis for the processing.
10. Contact
If you have any questions concerning data protection on our website, wish to obtain information about your personal data or request its deletion, please contact the person responsible for data protection by email at : contact@freelap.ch
11. Updates and amendments to this privacy statement
The development of our website or the implementation of new technologies may make it necessary to amend this privacy statement.
Any significant amendments will be communicated to registered users by email, using the email address provided during registration, or through an appropriate notification displayed after users log in to their account.
Version : 10 January 2025