1. INTRODUCTION
You have indicated your interest to join the Lan.space AG (“Lan.space” or “we” or “us”) social network, streaming and digital performance platform (website www.Lan.space, the "Platform"), consisting of services, podcasts, software applications, embeddable players, and syndicated ‘widgets’ such as the sale and subscription to courses, creating your profile at Lan.space.org the ability to offer and apply for employment, communications, etc. (collectively, the “Services”). We respect the privacy of the users, subscribers, publishers, members, and others who visit and use the Services (collectively or individually, “you”, “yours”, or “users”) and are committed to protecting your personal data.
2. Purpose of this privacy policy
This Privacy Policy explains what information of yours will be collected and processed by us when you visit or use the Platform, what we do with your personal data within the scope of providing the Services, how you can control the collection, correction and/or deletion of information and how the law protects you.
It is important that you read this Privacy Policy together with any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. This Privacy Policy is incorporated into and is subject to Lan.Space Terms of Service. By using the Services, you expressly consent to the information handling practices described in this Privacy Policy.
3. Controller
The company responsible for personal data is Lan.space AG , with registered offices in Samstagernstrasse 55, Wollerau CH8832, Switzerland ("Data Controller"). To contact the representative from the Data Controller, who is responsible for overseeing questions in relation to this Privacy Policy, you may send an email to: dataprotection@Lan.space.org.
4. Legal Basis for Processing the Personal Data
Collection and processing of your personal data is based primarily in the contractual and/or non-contractual relationship you have with us.
When we send you newsletters and Services or when we use the email you have provided us to contact you individually or to recognize you when you return to visit our website, we are doing so under the informed consent. How we process the information collected by our cookies is based in the informed consent you provide, pursuant to current legislation.
Pursuant to applicable data protection laws, bear in mind that:
Lan.space will cooperate with you in order to ensure compliance with all applicable data protection provisions, e.g. to enable you to exercise data subjects’ rights (i.e. right of access, rectification, erasure, blocking, opposition) and to manage incidents including forensic analysis in case of security breach.
Lan.space is also in compliance with the requirements of the Children’s Online Privacy Protection Act. Whilst the requirements under this law sets an age restriction of 13 years or older, Lan.space stipulates that in order to register and navigate the Platform, you need to be older than 18. Lan.space may use your personal information to verify your age and ensure the enforcement of this restriction.
If information indicated in our Privacy Policy is not provided, we might be unable to process your user registration or use of certain Services available in the Platform.
The Data We Collect about You
In order to register for a user account for the Services and to create your profile in the Platform, we may request the following data about you:
Identity Data: includes first name, last name, company name, nationality, date of birth.
Contact Data: includes billing address, email address and telephone numbers.
Account/Profile Data: includes your username and password and may also include personal information such as your country or city of residence, a photograph, education, work experience, and any other additional information you might want to share in your profile. The profile information helps you make the most out of the Services, like helping other professionals find you and finding business opportunities or projects you might be interested in. However, if you do not want this information to be published, you may leave the profile information fields blank or delete the information already provided.
We do not make decisions based on profiles, beyond personalization of advertisement and for the purpose of the legitimate prevention of Internet fraud.
Financial Data: To buy or subscribe to our Services, we will request your credit card or debit information, including expiration date and CVV. If you are paying with PayPal, we will request the email associated to it. If you are paying with PayU, we will redirect you to that payment platform. If you request an invoice, we will request your invoicing data, if needed.
Transaction Data: We will collect transaction information which includes details about bookings, payments to or from you and other details of products or services you have listed or made available, online or offline, or booked and purchased from us online or offline.
Usage Data: In addition to the information you provide to us directly, we may collect information about your use of the Services. When you visit or use our Services, we register data such as frequency of use, date, time and duration the Services were accessed, and other information about your interaction with content offered through a Service i.e. when you see or click a specific content, your course preferences, projects you are sharing or content you publish. You may provide us information in user submissions you post, stream or include in the Service. If you correspond with us by email, we may retain the content of your email messages and our responses. We may also retain any messages you send through the Service.
Marketing & Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Device and Technical Data: We use information when you log in, when you read our emails, Internet protocol ("IP") addresses and other unique device identifiers, to identify you and register your use in the Platform. We may also use information such as your hardware model, browser type and version, time zone setting, operating system and platform, other technology on the settings of the device you use to access the Service and information stored in cookies and similar technologies that we set on your device.
Location information: We may collect your mobile device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.
Information From Third-Party Sources: We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may obtain information through other platforms, i.e. when you register via Facebook or similar technologies or social media sites. This might include personal texts or images available in an external website.
System Generated Data: The Service automatically creates and stores meta data on basis of the other types of data, e.g., (i) subscription data, like start date, latest invoice date and the result of a mandatory VAT number validation, (ii) issued invoices are stored so that you may access any issued invoices from within the service manager, (iii) definitions of the cookies found when the Service has scanned your website(s), including reports on the result of each scan, (iv) aggregated statistical data such as demographic data for any purpose or data on end user consents.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
6. Purpose of the Processing
We use the personal information you submit to operate, maintain, and provide to you the features and functionality of the Service. More specifically, Lan.space AG, as the Data Controller, will process your personal data for the following purposes:
Please note, aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Following termination or deactivation of your account, Lan.Space may retain your profile information and user submissions for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, we may retain and continue to use indefinitely all information (including user submissions) contained in your communications to other users posted to public or semi-public areas of the Service after termination or deactivation of your account.
7. Your Choices/Options About Your Information
The provision of the Service might entail the use of your personal data, with your express consent, to make available to you personalized advertisement related to our products and services, through emails or other electronic communication means from us or third party collaborators. With the goal of improving our services, please know that personal information regarding your purchases, interests and preferences might be used by Lan.space for the purpose of analysis, user profiling, marketing studies, quality surveys, and improving interaction with our clients.
If you do not want to receive certain type of email communications, you may opt out by simply accessing the Notifications section under Edit Profile to manage your preferences. Opting out may prevent you from receiving email messages regarding updates, improvements, or offers. You may not opt out of Service-related e-mails.
You may, of course, decline to submit personally data through the Service, in which case we may not be able to provide certain services to you. You may update or correct your account information and email preferences at any time by logging in to your account. Likewise, if at any time you would like to unsubscribe from receiving future e-mails, you will be able to cancel your notifications by following the instructions in each notice you receive or you can cancel your account after login by clicking on "Cancel my account".
You can review and correct the information about you that we keep on file by contacting us directly. Please email dataprotection@Lan.space.org with your inquiry.
8. Data Retention Period
We will retain your personal data for as long as we have a valid contractual relationship, and after that, for the period determined by any obligations arisen from the treatment of the data or as established by law:
Data retention for compliance with legal requirements
You cannot require Lan.space to change any of the default retention periods, except for the reasons for erasure pursuant to clause 6.v. but may suggest changes for compliance with specific sector laws and regulations.
Data restitution and/or deletion
No data except Account Data will be retained after the termination of the contract. You may request a data copy before termination. You must not cancel the Service account until the data copy has been delivered, as we otherwise will not be able to deliver the data copy.
9. How We share your Data, Data Recipients
Lan.space does not sell, trade or otherwise transfer to outside parties any personally identifiable information, except to comply with the purposes indicated in this Privacy Policy, it might be necessary to report or release your personal data to third parties for the following reasons:
Business Partners: We may share your information with business partners to provide you with services that you request. For example, if you sign up for a promotion that runs on our Service but that is sponsored or co-sponsored by another company, your information may be shared with that sponsor. Lan.space is not responsible for the privacy practices of these entities.
Business Transfers: In connection with any reorganization, restructuring, merge or sale, or any other transfer of assets, including personal, provided that the receiving party accepts to process your personal information in accordance with our Privacy Policy.
Service Providers: In order to provide services in our name or to help us provide our services. For example, we contract service providers to render marketing, advertising, communication, infrastructure and IT services, to customize and improve our service, to process credit card transactions or other methods of payment, provide customer service, collect debts, analyses and improve data (such as data regarding user interaction with our services), and process and manage satisfaction surveys. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
For efficiency purposes, these partners and providers may be based in the US or other countries or territories outside of the European Economic Area, and might not provide a data protection level comparable to that of your country or the European Union's.
When you accept this Privacy Policy, you are specifically authorizing us to process and report your personal data to the partners mentioned and/or release your personal data to the service providers as processors located outside of the European Economic Area for the purposes described herein and to provide you complete service. When we release personal information when exchanging data with countries outside the European Economic Area and other areas with different data protection laws, we will ensure the information is being transferred in compliance with this Privacy Policy and pursuant to current data protection laws.
Links to Third-Party Sites: Occasionally, we may include or offer third party products or services on our website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. These third party sites have separate privacy policies that are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome feedback about these websites. You should exercise caution, and review the privacy statements applicable to third-party websites and services you use.
Aggregated Data: We also may provide aggregated data about how users are using our Service to third parties.
Information That is Publicly Available: When you create an account on our Platform, some information about your account and your account activity will be provided to other users of the Platform. This may include the date you opened your Lan.space account, the date you last logged into your account, your age (if you choose to make it public), the country and the number of videos you have watched. Any content that you submit to Lan.space may be redistributed through the Internet and other media channels, and may be viewed by other users or the general public. You may also choose to add personal information which may include your name, gender, profile picture or other details, that will be visible to other users. If you choose to add certain features to your Lan.space account page, then these features and your activity associated with these features will be displayed to other users and may be aggregated and shared with your friends or other users. Such shared activity may include your favorite videos, videos you rated and videos that you have uploaded.
Other Parties When Required by Law or As Necessary to Protect Our Users and Services: We may share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Service, our employees or agents or users or to comply with applicable law or legal process, including responding to requests from public and government authorities.
10. Data Protection Rights
As Data Controller, we are committed to respecting the confidential nature of your personal data and guaranteeing the full exercise of these rights. At all times, you will have the following rights:
Right to access: You have the right to confirm whether we are processing your personal data and, if we are, you have the right to obtain a copy of such data and information regarding the processing.
Right to amend/rectify: You have the right to correct errors, modify incomplete or wrong data and guarantee the authenticity of the information that is being processed.
Right to delete: You have the right to request the deletion of your personal data without undue delay, if it were being processed wrongfully or if the end to which it was processed or collected has ceased to exist.
Right to limitation of processing: You have the right to request that the suspension of the processing of your information if it is illegal or the accuracy of the data has been contested.
Right to oppose/object: You have the right to oppose to the processing of your data when it has been used for purposes of direct marketing or when the processing must be terminated due to a personal situation, except when there is legitimate interest, or it is necessary for the exercise or defence of claims.
Right not to be subjected to personalized decisions: You have the right of not being subjected to a decision based solely on the automatic processing of your data, including profiling, with binding legal effects or which affects you, except when necessary for the execution of an agreement, as permitted by the law or if you have expressly authorized it.
Right to transfer: In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
Right to Withdraw consent at any time: You may withdraw your consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
In order to exercise the above referenced rights, please send an email to: dataprotection@Lan.space.org indicating your (i) identity, by sharing your full name and email address used to register or make a purchase at Lan.space, an ID to establish your identity, and (ii) the right or rights you're exercising.
You may also visit the agency overseeing the protection of data in your country to file a claim or request the protection of your rights, if deemed necessary.
The exercise of such rights is free, except when requests are deliberately unfounded or excessive, in which case the individual will be required to bear the processing costs.
11. How We Protect Your Information
Lan.space AG uses commercially reasonable physical, administrative, managerial, and technical safeguards to preserve the integrity and security of your personal information and implement your privacy settings designed to protect against unauthorized use, disclosure or access of personal information. Once we receive your transmission of information, we make reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards as the Internet cannot be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you provide to us and do not accept liability for unintentional disclosure.
Your privacy settings may also be affected by changes to the functionality of our distributors, such as social networks. Lan.space is not responsible for functionality or security measures of third parties.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your password and account information, and for controlling access to communications from us at all times.
In the event that personal information is compromised as a result of a breach of security, Lan.space will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.
12. Information about cookies
We use cookies, small files with information regarding your navigation in this Platform, mainly to enable a better user experience. Please, read our Cookies Policy to know more about the cookies we use, their purpose, and other useful information.
13. Complaints
You may at any time lodge a complaint with a supervisory authority regarding Lan.space AG’s collection and processing of your personal data. In Switzerland, you can lodge a complaint with the National Data Protection Authority.
14. Changes to our Privacy Policy and Your Duty to Inform of of Changes
We keep our Privacy Policy under regular review. We will update this Privacy Policy occasionally and as required by legal, regulatory or operational modifications. We will notify such changes (including the effective date) as required by law. If we change our privacy policies and procedures, we will post those changes on the Platform to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. If you have any questions about this Privacy Policy, the practices of this site, or your dealings with the Platform, please contact us with your inquiry at dataprotection@Lan.space.org.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
15. Notification Procedures
It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Platform as determined by Lan.space in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.
If there are any questions regarding this Privacy Policy you may contact us using the information below.
Lan.space AG
Samstagernstrasse 55
Wollerau CH8832
info@lan.space
Published on [] December 2020
APPENDIX
GRAPHIC ON HOW WE USE & DISCLOSURE YOUR PERSONAL DATA
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new user | (a) Identity (b) Contact |
Performance of a contract with you |
|
To process your purchases including: (a) Manage payments, fees and charges (b) Collect and recover money owed to you or us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing Communications |
(a) Performance of a contract with you (b) Necessary for your and our legitimate interests |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or provide ratings and feedback |
(a) Identity (b) Contact (c) Profile (d) Marketing & Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing & Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website and apps content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing & Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and apps updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about content or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing & Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
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