Data Protection
PRIVACY POLICY
Introduction
Welcome to www.suissecann.com’s Privacy Policy.
SuisseCANN respects your privacy and is committed to protecting your personal
data. This privacy policy will inform you as to how we look after your personal data
when you visit our website or mobile app (regardless of where you visit it from) and
tell you about your privacy rights and how the law protects you.
This privacy policy is designed to be transparent and accessible although some of
the words and phrases used come from data protection regulations, please also use
the Glossary to understand the meaning of some of the terms used in this privacy
policy.
If there is anything within this privacy policy that you do not understand or cannot
access, please contact support@greenconsensus.ch.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how SuisseCANN collects and
processes your personal data through your use of SuisseCANN’s website, including
any data you may provide through this website when you sign up to our newsletter
mailing list or purchase a product or service.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy policy together with any other privacy policy
or fair processing notice 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. This privacy policy supplements the other notices
and is not intended to override them.
This version was last updated on 1 September, 2020.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to
collect or share data about you. We do not control these third-party websites and are
not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual or
a legal entity from which that person or legal entity can be identified. It does not
include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together follows:
“Identity” data includes first name, last name, username (or similar identifier), title,
date of birth and gender.
“Contact” data includes billing address, delivery address, email address and
telephone numbers.
“Financial” data includes bitcoin wallet address and payment card details.
“Transaction” data includes details about payments to and from you and other details
of products and services you have purchased from us.
“Technical” data includes internet protocol (IP) address, mouse tracking, links
clicked, your login data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform and other
technology on the devices you use to access this website.
“Profile” data includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
“Usage” data includes information about how you use our website, products and
services.
“Marketing and Communications” data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share “Aggregated Data” such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your personal data but
is not considered personal data in law as this data does not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data or Technical
Data to calculate the percentage of users accessing a specific website 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.
We do not collect any sensitive 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, social security measures, information
about your health and genetic and biometric data). Nor do we collect any information
about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we
have with you and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a product
or service you have with us but we will notify you if this is the case at the time.
A note on age verification
The products that we sell on our Website are highly regulated and age-restricted. We
are required and committed to preventing sales to anyone under the legal
purchasing age. We will only send you marketing materials and information that
encourage or facilitate a purchase of our products after you have certified that:
● you are a of legal purchasing age for the product you wish to purchase;
● that you wish to be added to our mailing list for the purpose of receiving
transactional offers and advertising from a regulated company; and
● that you understand that providing false information may constitute a violation
of the law.
Before you can make a purchase from a product specific newsletter mailing list, we
will verify your age through questionnaires. We ensure that you qualify to access and
purchase products from our website. Where your data is shared with a third party
company in order to perform an age and identity verification check such data sharing
shall always be done by us in accordance with this policy.
How is your personal data collected?
We use different methods to collect data from and about you including through direct
interactions. You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
● purchase our products;
● create an account on our website;
● subscribe to our publications;
● request marketing to be sent to you;
● enter a competition, promotion or survey; or
● give us some feedback.
● Automated technologies or interactions. As you interact with our website, we
may automatically collect Technical Data about your equipment, browsing
actions and patterns. We collect this personal data by using cookies, server
logs and other similar technologies. We may also receive Technical Data
about you if you visit other websites employing our cookies. Please see our
cookie policy for further details.
● Third parties or publicly available sources. We may receive personal data
about you from various third parties and public sources as set out in our age
verification process as stated in paragraph 4 above.
● Technical Data from the following parties:
● analytics providers such as Google based outside the EU;
● search information providers such as Google.
● Contact, Financial and Transaction Data from providers of technical, payment
and delivery services such as Worldpay and Recurly.
● Identity and Contact Data from publicly availably sources such as Veratad.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:
● Where we need to perform the contract we are about to enter into or have
entered into with you.
● Where it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to sending third party direct marketing communications to
you via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact
us if you need details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out in the table below.
Purpose/Activity
– To register you as a new customer
– To process and deliver your order including: Manage payments, fees and charges; Collect and recover money owed to us
– To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; Asking you to leave a review or take a survey
– To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
– To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.
Promotional offers from us:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we call
this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us
and, in each case, you have not opted out of receiving that marketing.
Third-party marketing.
We will get your express opt-in consent before we share your personal data with any
company outside the SuisseCANN group of companies for marketing purposes.
Opting out.
You can ask us or third parties to stop sending you marketing messages at any time
by contacting us, respectively the third parties, at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.
Cookies.
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that
some parts of this website may become inaccessible or not function properly. For
more information about the cookies we use, please see our cookie policy.
Change of purpose.
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please
contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is required or
permitted by law.
Disclosures of your personal data
● We may have to share your personal data with the parties set out below for
the purposes set out in the table in paragraph 7 above.
● Internal Third Parties (full details of which are included in the Glossary at the
end of this policy). Note that these Internal Third Parties are not necessarily
within Switzerland or the European Economic Area (EEA).
● External Third Parties (full details of which are included in the Glossary at the
end of this policy).
● Specific third parties were such are stated in the table at paragraph 7 above
(purposes for which we will use your personal data), e.g. with age verification
partners.
● Third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set out in
this privacy policy.
● We require all third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit
them to process your personal data for specified purposes and in accordance
with our instructions.
Please note: The products sold on this website are highly regulated by various
governing agencies. It may become necessary to share the information that we
collect in accordance with the terms of this policy with such agencies to comply with
laws, a judicial proceeding, court order, or other legal requests.
Data security
We take the security of your information extremely seriously and employ physical,
administrative, and technological safeguards designed to preserve the integrity and
security of all information collected through our website. Our services support the
industry standard Secure Socket Layer (SSL) encryption which is applied to all data
transmitted so it cannot be read by others. In addition, if you are using a shared
computer to access our website, we recommend that you log out of your account
before ending your browser session. This will also ensure that your account will not
be used by anyone other than yourself.
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are legally
required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see the “request erasure”
legal right below for further information.
In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which case we
may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation
to your personal data. Full details of these rights can be found in the Glossary at the
end of this policy and on the European Commission website here. In summary, these
rights are the right to:
● Request access to your personal data.
● Request correction of your personal data.
● Request erasure of your personal data.
● Object to processing of your personal data.
● Request restriction of processing your personal data.
● Request transfer of your personal data.
● Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your
request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any of
your other rights). This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also contact you to
ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have made
a number of requests. In this case, we will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on
you (both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that we are
subject to.
THIRD PARTIES
External Third Parties
Service providers acting as processors based outside of the EEA who provide IT and
system administration services including cookies/user experience/analytics.
Professional advisers acting as processors including lawyers, bankers, auditors and
insurers based outside the EEA who provide consultancy, banking, legal, insurance
and accounting services.
Tax agencies, tax collectors, regulators and other authorities acting as processors or
joint controllers based in Switzerland who require reporting of processing activities in
certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you
have successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase
your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in the following scenarios: (a) if you
want us to establish the data’s accuracy; (b) where our use of the data is unlawful
but you do not want us to erase it; (c) where you need us to hold the data even if we
no longer require it as you need it to establish, exercise or defend legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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.
Withdraw consent at any time 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.
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