WEBSITE AND SOCIAL MEDIA PRIVACY POLICY
Last updated on April 16, 2018
Welcome, and many thanks for visiting our website or dedicated pages on social media! Our mission is to provide information about our company, our services, our team and new developments related thereto. We also aim at providing you with platforms allowing you to keep in touch with the Clinique La Prairie and use contact forms for any questions and comments you may have.
Please take a moment to read the following Privacy Policy which explains how your personal data will be collected, used and protected. When visiting our website or dedicated pages on social media, you are agreeing to this Privacy Policy, therefore do not hesitate to contact us at digital@laprairie.ch should you have any questions, we will be happy to provide more details. If you do not consent to the terms of this Privacy Policy, we kindly ask you not to use our website or dedicated pages on social media.
As indicated in Section 4.11 below, we will not sell your personal data to third parties. We will not share or otherwise make available your personal data to third parties except as provided in this Privacy Policy.
In any event, we will process your personal data in compliance with medical ethics and our duties based on medical secrecy.
1. GENERAL PRINCIPLES
1.1. Our website, available at www.laprairie.ch or www.cliniquelaprairie.com (our "Website") and our dedicated pages on social media, (i) provide users with information about the services offered by our company (including news and content about health and wellness, as well as more detail about our team of doctors), and (ii) contain various channels to get in touch with us (contact forms, link to social media account, personalized offer messages, online diagnostic Revelator, etc).
1.2. This Privacy Policy lays out our policies and procedures surrounding the collection and processing of any information that identifies you, such as your name, your address, e-mail address, date of birth, log-ins, device information, or your IP address, which you may for instance provide to us when:
- Subscribing to our newsletter via our footer or pop-in
- Filling out our online contact forms
- Filling out our “Personalized Offer” form (pop-in)
- Using our online diagnostic tool
- Filling out our Press room user information
- Filling out your personal account
1.3. This Privacy Policy applies only to our Website and and dedicated pages on social media. It does not apply to any offline service offered by our company. Please further note that if you follow us on social media, information you provide will also be subject to the privacy policy of operator of the social media platform.
1.4. If you use our Website or follow us on our dedicated pages on social media, you consent to the collection and processing of your Personal Data under this Privacy Policy (and possibly other documents referenced in this Privacy Policy). Please note that you have the right to withdraw you consent at any time, it being however specified that such withdrawal will not affect the lawfulness of processing based on your consent before its withdrawal.
2. PERSONAL DATA WE COLLECT
A. PERSONAL DATA YOU PROVIDE TO US
2.1.We may collect Personal Data from you when you visit our Website our dedicated pages on social media. We may log in particular usage data when you view or click on content. We use to this end cookies and similar technologies to identify you and log your use.
2.2. We further collect Personal Data from you when, on our Website, you fill out a contact form, subscribe to our newsletter via a footer or pop-up window, reply to a message making a personalized offer (pop-in), use our personal diagnostic tool, provide user information for press room, provide user information for personal account. In this respect, we collect the Personal Data you provide to us, including medical data.
B. PERSONAL DATA COLLECTED ABOUT YOU FROM OTHER SOURCES
2.3. We may collect Personal Data about you from other sources, such as Personal Data you make available on social media. We may also collect information about your location through tools such as Google Analytics.
3. HOW AND WHERE WE STORE YOUR PERSONAL DATA
3.1. We are taking data protection issues seriously and, in order to make our Website available to you, we have chosen to store your Personal Data on Infomaniak servers in Switzerland.
3.2. We use the services of some third-parties, some of which are operated outside Switzerland or the European Economic Area. We may thus transfer your data to one of these third-parties’ databases outside Switzerland or the European Economic Area, potentially including countries which may not have an adequate level of protection for your Personal Data compared with that provided in Switzerland or the European Economic Area. In such event and unless provided otherwise in this Privacy Policy, we enter into agreements with such third-parties ensuring an adequate level of protection for your Personal Data. By providing us with your Personal Data, you agree that we may transfer, store and process your Personal Data outside Switzerland or the European Economic Area – in particular in the USA – and acknowledge that governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
4. OUR USE OF YOUR PERSONAL DATA
A. SERVICES PROVIDED TO YOU
4.1. We will use your Personal Data in the first place to authorize access to our Website, to make the functionalities of our Website available to you, to offer you additional functionalities, and to contact you.
4.2. We may use identifiers such as cookies so that our Website or our dedicated pages on social media can remember you and provide you with the information you are most likely to need.
4.3. Moreover, we may communicate your Personal Data, in particular any medical data you would provide us with through our Website or our dedicated pages on social media, to the competent doctors and centers within Clinique La Prairie in order to have such data added to your medical records.
B. MARKETING PROVIDED TO YOU
4.4. We may use your Personal Data to send you marketing information, in an electronic or paper format, which is related to the information available on our Website or our dedicated pages on social media and which we think may be of interest for you.
4.5. In this connection, we may use identifiers such as cookies so that we can build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our Website or dedicated pages on social media, you do not miss offers and information that might be of interest for you (online targeted advertising).
4.6. In order to send you marketing information in an electronic format, we may use the services of Campaign Monitor, a third-party U.S. based company (https://www.campaignmonitor.com), which may thus be provided with your Personal Data.
4.7. You may opt out from receiving any such information by sending an email to digital@laprairie.ch. Upon receipt of your request, we will promptly notify you by email that your request is being handled. Please note that it may take up to ten days to have your request fully processed. You may therefore receive marketing information during this period of time.
C. USE FOR INTERNAL PURPOSES
4.8. We use your Personal Data and information gained through cookies and similar technologies to improve the Website or our dedicated pages on social media, to compile statistical information about use of our Website or our dedicated pages on social media and to produce aggregate insights that do not identify you. For example, we may use your Personal Data to generate statistics about the demographic distribution of visitors on our Website. This helps us improve the services we offer.
4.9. In connection with the above, we use Google Analytics, which is a service offered by Google Inc. (“Google”), that generates detailed statistics about a website's traffic and traffic sources. Google Analytics uses cookies stored on your computer and your IP address (unless anonymized by use of the appropriate settings) to help analyze how users use our Website. According to Google, Google (i) may transfer this information to third parties in case of a statutory obligation or if a third-party processes data on behalf of Google, and (ii) under no circumstances, Google will combine or associate your IP address with other data stored at Google. We have not entered into an agreement ensuring an adequate level of protection for your Personal Data with Google within the meaning of Section 3.2 above. You hereby agree that we may use the services provided by Google Analytics.
4.10. We may also use your Personal Data (including your communications) if we think it’s necessary for security purposes, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Website or our dedicated pages on social media. Hence, we may use your Personal Data to investigate, respond to and resolve complaints and issues relating to our Website or our dedicated pages on social media.
D. NON-DISCLOSURE OF YOUR PERSONAL DATA
4.11. We will not sell your Personal Data to third parties. We will not share or otherwise make available your Personal Data to third parties except as provided in this Privacy Policy.
5. ACCESS TO YOUR PERSONAL DATA BY THIRD PARTIES
A. IN GENERAL
5.1. As noted above, we may compile usage statistics relating to our Website or our dedicated pages on social media based notably on your Personal Data. We may publish those statistics or share them with third parties in an aggregated form so that they do not include your Personal Data.
B. CONTRACTORS AND AFFILIATES
5.2. We may give certain independent contractors and affiliates access to the Personal Data you made available to us through our Website or our dedicated pages on social media. Those contractors and affiliates assist us with the operation of our Website or our dedicated pages on social media as well as data management and marketing activities. All those contractors and affiliates are required to sign contracts in which they promise to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.
C. CHANGE IN CONTROL OR SALE
5.3 .We may also share your Personal Data, subject to a confidentiality agreement, as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.
D. LEGAL DISCLOSURES
5.4. It is possible that we will need to disclose your Personal Data about you when required by law or if we have a good faith belief that disclosure is necessary to (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Website or our dedicated pages on social media (such as by sharing with companies facing similar threats); or (v) exercise or protect the rights and safety of our users, personnel, or others.
5.5. We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment and technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
6.MANAGEMENT OF YOUR PERSONAL DATA
A. PRELIMINARY NOTE
6.1. We will manage your Personal Data in compliance with the provisions set out in this Section. Please however note that we may have to comply with certain legal requirements, in particular requirements under Swiss medical law in relation to medical data you would make available to us, which may differ from the provisions of this Section.
B. PROTECTION OF YOUR PERSONAL DATA
6.2. We exercise commercially reasonable efforts to prevent unauthorized exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (comprising administrative, physical, and technical safeguards) for managing unauthorized disclosure or exposure of your Personal Data.
6.3. In the event of a data breach, or in the event that we suspect a data breach, we will (i) do our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach, including without limitation by providing reasonable assistance to you in notifying injured third-parties. We will give you prompt access to such records related to a data breach as you may reasonably request; provided such records shall be our confidential information, and we shall not be required to provide you with records belonging to, or compromising the security of, other users.
6.4. In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.
C. ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA
6.5. Whenever we process your Personal Data, we take reasonable steps to ensure that your Personal Data is kept accurate and up-to date for the purposes for which it was collected.
6.6. We will provide you with the ability to object to the processing of your Personal Data if such processing is not reasonably required for a legitimate business purpose as described in this Privacy Policy or our compliance with law.
6.7. You can access and change your Personal Data by sending an email to digital@laprairie.ch.
D. RETENTION OF YOUR PERSONAL DATA
6.8. We retain the Personal Data you provide to the extend necessary to provide you access to and use of our Website or our dedicated pages on social media and of their functionalities (like for instance our newsletter).
E. DELETION OF YOUR PERSONAL DATA
6.9. You may request the deletion of your Personal Data at any time, subject to any retention obligations imposed on us.
6.10. Upon request by you made within 30 days after your request for deletion of your Personal Data, we will make your Personal Data available to you for export or download in a commonly accepted format. We remain free not to accept any specific format required by you for the export or download of your Personal Data or to accept any such format at your cost.
6.11. After such 30-day period, we will have no obligation to maintain or provide any Personal Data, and will thereafter delete or destroy all copies of your Personal Data in our systems or otherwise in our possession or control.
6.12. We may retain de-personalized (anonymous) information after the deletion of your Personal Data.
7. AMENDMENT OF THIS PRIVACY POLICY
7.1. We may change this Privacy Policy at any time by posting a new version on this page or on a successor page, without prior notification. However, we will always handle your Personal Data in accordance with the Privacy Policy that was in effect at the time of collection.
7.2. The new version will become effective on the date it's posted, which will be listed at the top of the page as the new effective date.
8. ANY QUESTION OR COMPLAINT ?ANY QUESTION OR COMPLAINT?
8.1. Should you have questions or complaints regarding this Privacy Policy, please contact us online. You can also reach us by physical mail at Clinique La Prairie, service Marketing Digital, rue du Lac 142, 1815 Clarens-Montreux, Switzerland. Please further note that you have the right to lodge a complaint with a supervisory authority should you consider that your Personal Data is not processed in accordance with this Privacy Policy or in compliance with applicable regulations.
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