Privacy policy

Changes

Effective date: 22 October 2019


We at Anapaya (“Anapaya Systems AG”) are committed to protecting your privacy and personal information. This statement explains our practices for this web site. 
Anapaya ("us", "we", or "our") operates the Anapaya.net website (the "Service"). 
This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use our Service and the choices you have associated with that data.

In most cases, the provisions of the Federal Act on Data Protection (FADP) including the Ordinance on Data Protection (DPO) apply to the processing of personal data. For some occasional processing, the provisions of the EU General Data Protection Regulation (GDPR) may also apply directly. We therefore draw your attention to the provisions of both the FADP and the GDPR. In each case, the regulations that are provided for by the laws for the respective situation apply. 


Changes To This Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the Service and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

Definitions

Definitions

Controller

Anapaya Systems AG

Hardturmstrasse 253

8005 Zurich

Switzerland

info@anapaya.net

Personal information

Personal Information means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. 

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data processor (or Service providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) 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.

Data subject

Data Subject is any living individual who is the subject of Personal Information.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Information. 

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of data collected

Types of data collected

We collect several different types of information for various purposes to provide and improve our Service to you. Types of data collected:

Personal information

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Information"). Personally identifiable information may include, but is not limited to: 

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking and Cookies data

We use cookies and similar tracking technologies to track the activity on the Service and hold certain information. 

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. 

Examples of Cookies we use:

  • Session Cookies: we use Session Cookies to operate our Service.
  • Preference Cookies: we use Preference Cookies to remember your preferences and various settings.
  • Security Cookies: we use Security Cookies for security purposes.

Do not track

Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “Do Not Track” (“DNT”) option that relies on a technology known as a DNT header, which sends a signal to web sites’ visited by the user about the user's browser DNT preference setting. 

We do not currently commit to responding to browsers' DNT signals with respect our Service, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. 

We take privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. 

Clear Gifs (Web Beacons/Web Bugs)

We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Service by informing us what content is effective. 

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. 

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' Personal Information. If you would like to opt-out of these emails, please see "To Unsubscribe From Our Communications". 

How we use the
information we collect

Compliance with our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy.

Use of personal information

Anapaya uses the collected data for various purposes. In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: 

  • improve your browsing experience by personalising the Service* provide and maintain our Service
  • notify you about changes to our Service
  • allow you to participate in interactive features of our Service when you choose to do so
  • provide customer support* gather analysis or valuable information so that we can improve our Service* monitor the usage of our Service
  • detect, prevent and address technical issues
  • provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information 

Use of navigational usage data

We use Usage Data to operate and improve the Service. We may also use Usage Data alone or in combination with Personal Information to provide you with personalized information about us. 

Retention of data

Anapaya will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information 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. 

Anapaya will 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 time periods. 

Disclosure of data to third parties

For the purposes mentioned above, we may transfer your data to service providers such as [IT providers, payment providers or providers of the tools listed] below. 

In addition, we also transfer data to authorities if we have a legal obligation to do so. 

Transfer of data

It is possible that your data will not only be processed in Switzerland. If the statutory data protection in the relevant recipient country does not correspond to the level of data protection in Switzerland, we will take appropriate measures to ensure that a transfer may take place, e.g. by concluding the standard contractual clauses of the European Union or that another option provided for by law exists, e.g. by us fulfilling a contractual obligation for you or you giving us your consent.

Service providers

Service providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service. 

  • Google Analytics 
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. 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. 
     
    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. 
     
    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ 

Marketing automation

We use marketing automation technologies for personalisation and marketing initiatives within the Service. We and our third-party vendors use cookies for monitoring browsing information and they allow us to collect Personal Information through forms and landing pages. 

  • HubSpot 
    HubSpot B2B Marketing Automation service is provided by HubSpot, Inc. 
     
    For more information on the privacy practices of HubSpot, please visit the Salesforce Privacy & Terms web page: https://legal.hubspot.com/privacy-policy 

Behavioral remarketing

Anapaya Systems AG uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service. 

  • Google AdWords 
    Google AdWords remarketing service is provided by 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/ads

    Google 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 the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ 
  • Microsoft Clarity 
    Personal data is processed when you visit this website. Processed data categories: data for creating usage statistics. Purpose of processing: Anonymization and creation of statistics and analysis of user behavior. The legal basis for processing: Your consent according to Art. 6 (1) a GDPR. Data is transmitted: to the data controller Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. The legal basis for the data transfer to Microsoft Ireland Operations Ltd. is Your consent according to Art. 6 (1) a GDPR. This may also mean a transfer of personal data to a country outside the European Union. The data is transferred to the USA on the basis of Art. 45 GDPR in conjunction with the European Commission's adequacy decision C(2023) 4745, since the data recipient has committed to comply with the data processing principles of the Data Privacy Framework (DPF). To contact the data protection officer by email Microsoft Ireland Operations Ltd.: https://www.microsoft.com/de-at/concern/privacy. The privacy policy of Microsoft Ireland Operations Ltd.: https://privacy.microsoft.com/de-de/privacystatement. 
Communication from
Anapaya

Communication from Anapaya

From time to time we may wish to Communicate with you to inform you about promotions, changes to our services, or to make recommendations that we believe may be of interest to you or your business. We may use your Personal Information to personalise the content contained within these Communications. 

Types of communications

Our Communications fall broadly into the following areas:

  • Special offers and updates:
    We may occasionally send you Communications on products, services, special deals, and promotions.
  • Newsletters:
    We may occasionally send you a periodic email newsletter containing a mixture of topical articles published by Anapaya and other 3rd parties.
  • Educational material, reports and white papers:
    We regularly publish educational content through our Service. This content may consist of webinars, white papers, reports, and best practice guides. We will send you an email containing a link to any content that you request. We may also send you follow-up Communications containing further educational content that we believe may be of interest.
  • Service on-boarding:
    Certain of our services and offerings are complex in nature and require training in order to ensure their best use and adoption. Should you subscribe to any of these services we may send you periodic on-boarding Communications to help you understand more about the service you have procured and to train you in its technical usage and best practices.
  • Service-related announcements:
    We may send you service-related Communications on rare occasions when it is necessary to do so. For instance, if a service we provide you is temporarily suspended for maintenance, we might send you an email message. 
    Generally, you may not opt-out of these Communications, which are not promotional in nature.
  • Customer service:
    Based upon the Personal Information you provide us, we may send you a welcoming email to verify your username and password. We will also communicate with you in response to your enquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes. 
    Generally, you may not opt-out of these Communications, which are not promotional in nature. 

To unsubscribe from our communications

Every marketing email from Anapaya contains instructions on how to opt out of receiving further emails from us. 

  • You may manage the types of Communication we share with you by following the instructions located on the bottom of our e-mails (or by directly visiting our Communications Preference Centre.) 
  • You may unsubscribe from all of our marketing Communications by clicking on the “unsubscribe” link located on the bottom of our e-mails. 

Customers cannot opt out of receiving transactional emails related to their account with us. 

Your rights

Your rights

Anapaya aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. 

Whenever made possible, you can update your Personal Information directly within your account settings section. If you are unable to change your Personal Information, please contact us to make the required changes. 

If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. 

You have the following rights in connection with the processing of your data: 

  • Right to information about what data we store about you and how we process it 
  • Right to rectification of your data 
  • Right to erasure or restriction of your data 
  • Right to object to data processing 
  • Right to data portability, i.e. to request that certain data be handed over in a commonly used format or transferred to another controller 
  • Right to lodge a complaint with a supervisory authority. 

The contact details of the Federal Data Protection and Information Commissioner can be found here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html If you have any questions about data protection or if you want to exercise any of the  rights, please contact us at info@anapaya.net, or by sending us postal mail to The Privacy Officer, Anapaya Systems AG, Hardturmstrasse 253, 8005 Zurich, Switzerland. We will respond to your request to change, correct, or delete your information and notify you of the action we have taken. 

Please note that we may ask you to verify your identity before responding to such requests.

External websites

External websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. This Privacy Policy does not apply to these other websites. We strongly advise you to review the Privacy Policy of every site you visit. 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. 

Children’s privacy

Children’s privacy

Our Service does not address anyone under the age of 13 ("Children"). 

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers. 

Contact us

Contact us

If you have any questions about this Privacy Policy, or our treatment of the information you provide us, please write to us: