This privacy policy informs you about how SOMMI; (hereinafter collectively "we", "us", "our"), when using our website and mobile application (hereinafter collectively "offers") as well as in conjunction with third party services, processes your personal data, whom we may share your data with, and what rights you have with regard to the use of your data.

We may provide you with additional data protection statements if we consider this to be useful. Such additional privacy statements supplement this privacy policy and must be read in conjunction with it.

We always process your personal data in accordance with applicable data protection law (including the Swiss Data Protection Act, "nDSG" and, where applicable, the EU General Data Protection Regulation, "GDPR"; hereinafter collectively "applicable data protection law").

"Personal data" means any information relating to an identified or identifiable natural person or, where protected by the nDSG, legal entity. This may include but is not limited to, your first name and surname, postal address, email address, date of birth, telephone number as well as data about the use of our website or app, purchases made or digital contracts concluded, which of our offers are used, as well as your preferences. This privacy policy also uses the phrase "your data" for this purpose. Information that cannot be directly or indirectly associated with your person, i.e. not with your identity, is generally not personal data.

„Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of your data.

Please note that third party websites that can be accessed through our offer provide information about their data processing in their own data protection statements. We do not accept any responsibility or liability for the data protection compliance of these third parties and recommend that you consult the data protection statements of these third party websites.

1. Who is responsible for processing your data?
SOMMI is responsible for the processing of your data collected or received in the context of our offers or as provided by third party services or processed for other purposes as defined in this privacy policy.

2. How do we collect your data?
We collect your data directly from you or receive your data from third parties, such as companies associated with us, authorities, consultants, our service providers or from publicly accessible sources.

3. Scope purpose, and legal basis of the processing of your data
We process your data when you use our offers, cooperate with us or otherwise contact us.

In principle, we process your data for the following purposes:
●    To fulfil and process contractual or legal obligations;
●    to verify access authorization and manage the user account (if any);
●    to inform you about updates or changes to our offers or events, as well as in the event of adjustments to our GTC, data protection declarations;
●    to combat fraud and abuse;
●    to develop and maintain customer relationships;
●    for our marketing purposes as well as third parties, i.e. all sales-promoting measures, e.g. newsletters, telephone, online advertising, SMS and push notification for market research, conducting analyses and surveys, as well as for statistical purposes;
●    to design and improve our offers in line with demand;
●    to evaluate user behaviour.

In the following, we have summarised in detail which data we process within the scope of our offers, what we process it for, and on which legal basis we perform this processing.

3.1 Visiting our offers (log files)
If you use our offers without providing any further information, the technology we use automatically logs general technical visit information in so-called log files. This includes but is not limited to the IP address of the device used from which the visit is made, details of the browser type, the Internet service provider and the operating system used, reference/exit pages, and the time and duration of the visit.

This information is collected and processed for the purpose of enabling the use of our website and APP (connection establishment), ensuring and increasing the security and stability of our systems and offers, analysing the use of our offers and services, collecting general demographic information, and enabling the optimisation of our offers, as well as for internal statistical purposes. An identification of the user does not take place. Likewise, no connection is made between this automatically collected information and personal data stored by us. However, the automatically collected information and personal data stored by us may be linked if you already have a registered user account with our app or use certain functions of our website as a guest, such as our contact form or our enquiry function. This information may be linked in order to analyse the use of our offers and services, to collect general demographic information and to enable the optimisation of our internet offer.

3.2 Registration of a user account
In order to use our offers and/ or services of the digital contracts or access-protected areas, you must register and set up a user account. This requires the entry of certain personal data. This concerns for example

●    gender
●    First and last name
●    date of birth
●    your username
●    Your e-mail address
●    Your password
●    Language preferences

With your confirmation at the end of the registration process for the recording and modification of your user account details, you guarantee the correctness of the information you have entered.

We use the data to process and fulfil the administration of our digital contracts, to check the plausibility of the data entered, i.e. to establish, structure the content of, process and amend the contractual relationships concluded with you via your user account and, in the case of chargeable services, for proper invoicing. Accordingly, we process your data in this context in accordance with the applicable data protection law.

3.3 Use of our services as a registered user
During the use of the offers by registered users, we collect data for statistical reasons to enable the smooth functioning of the offers as well as for the analysis and optimisation of our offers and services. In this way, we collect data on your use our digital contracts and which functions and which advertising you view. It is in our legitimate interest to optimise, develop and improve our services in accordance with applicable data protection law.

If you use our offer as a registered user, relevant data may be visible to other registered users. Such data will only be shown to other registered users in anonymised and/or aggregated form.

3.4 Use of mobile applications
If you use our mobile applications with a mobile device and you have activated the transmission of your GPS signal data to third parties in the settings of your mobile device, we may collect information about the location of your mobile device (longitude, latitude, horizontal accuracy) using GPS signal data.

We use location data to enhance your user experience by displaying location-based online advertising and other location-based digital content (such as location-based weather and news) to you through the mobile app(s) on your mobile device. We will ask for your consent under applicable data protection law before collecting your location data for these applications.

Even after you have given your consent, you have the option to withdraw your consent or to deactivate or object to the collection, processing and disclosure of your location data at any time. If you do not want to receive location-based online advertising and content, you can either opt-out of access to your location or disable location services in the settings of your mobile device at any time. To disable location services, please follow the device manufacturer's instructions: for Apple devices: https://support.apple.com/de-ch/HT207092, for Android devices: https://support.google.com/accounts/answer/3467281?hl=de.

3.5 Obtaining our free service (digital contract)
If you enter into an agreement / digital contract with other registered users via our app, the provision of data such as gender, username and date of birth is mandatory. Additional data (e.g., first and last name, telephone number) may also be required, as this may be necessary for the performance of the digital contract between two parties, in accordance with applicable data protection law.

3.6 Contacting customer service or via contact form
If you contact our customer service, we may process your contact details (such as gender, first and last name, email address) and the content of the conversation in order to respond to your enquiry. This is in our legitimate interest in terms of the applicable data protection law to provide you with professional information and to process your enquiry correctly.
If you fill out a contact form on our offers, we process the personal data provided (such as gender, first and last name, email address and the content of the enquiry). This is also in our legitimate interest to provide you with professional information and to process your enquiry correctly (in accordance with applicable data protection law).

3.7 User surveys, interviews and market research
If you voluntarily participate in a user survey, interview or other market research activity conducted by us, we will collect personal data from you, such as your gender, first and last name, date of birth and other information requested as part of the survey. We use the information you provide only to improve the user experience and to further develop our product, which is a legitimate interest of ours (under applicable data protection law). The results of the surveys consist of aggregated and anonymous data only.

3.8 Marketing and analysis purposes
When you register for one of our offers, we may also use your data for personalised advertising measures by us and by companies affiliated with us and by third parties. Personalised advertising includes, in particular, advertising by means of digital advertisements on our offers, by e-mail, such as e-mails with general information or of an advertising nature (newsletters), by telephone, text messages, picture messages and on instant messaging services. At the end of each e-mail sent by us, you will find a link that allows you to unsubscribe from the newsletter at any time. You can also unsubscribe from the newsletter at any time by sending an e-mail to info@sommi.io.
We will only send you newsletters if they relate to similar offers or if you have expressly consented to them. Otherwise, the delivery of personalised content and advertising, e.g. on our portals or portals of companies affiliated with us, is in our legitimate interest under applicable data protection law to offer you our products or services that may be of interest to you and to optimally market our offers. If prior consent is required, in particular for the processing of your data by companies associated with us, we will obtain this in advance.
For this purpose, we may continuously use various analysis tools to link user-specific historical and future data that we have and to analyse, aggregate, pseudonymise and anonymise user behaviour across all offers. To improve our database, we may use publicly available data or data from third-party providers. The findings from your use of our offers can be used within the framework of the analysis of user behaviour at other participating companies. Such data processing is always carried out with pseudonymised or anonymised data. You can object to the processing of your data at any time by adjusting the default settings of cookies.

3.9 Anti-fraud, litigation and legal processing obligations
We may also process your data that we collect and process in accordance with sections 3.1 to 3.9 for the purposes of fraud prevention or in the event of litigation, which is in our legitimate interests under applicable data protection law to protect our business and to enforce or pursue any claims we may have. We may also process your data to comply with our legal obligations in accordance with applicable data protection law.

4. Profiling and personality profiles
Within the scope of the stated purposes, it is possible that personality profiles are created and/or profiling is carried out. If personality profiles are to be shared with third parties, we will obtain your express consent in advance.

5. Sharing your data with third parties
We work with or engage other companies or individuals to process and store data in accordance with this privacy policy. These may be companies in the cloud storage industry, contracted data processors of ours, or other third parties. These third parties may have access to your personal data or usage data, but only to the extent necessary to perform the tasks assigned by us or to fulfil the purposes described in this privacy policy. We reserve the right to disclose your data on the basis of mandatory legal obligations.

5.1 Transfer to service providers
In addition, we will pass on your data to third parties insofar as this is necessary for the performance of the contract in accordance with applicable data protection law. For this purpose, we may pass on the necessary data to other service providers, such as hardware and software providers. These service providers use your data exclusively for order processing and not for any other purposes. Insofar as this is necessary for the purposes mentioned previously, the transfer may also take place abroad, for example to ensure the fulfilment of the digital contract. For more information on transfers abroad, see chapter 7.

5.2 Sharing with other third parties
If you click on integrated offers from third parties or use integrated contact forms from third parties, we may pass on your data in accordance with the offer or contact form. In addition, we may pass on your data to third parties if they wish to place personalised advertising or adverts on our offers. Furthermore, your data may be passed on to third parties if we offer a joint offer with a third party.
We may disclose your information to domestic and foreign law enforcement agencies and courts to combat fraud and abuse or if we otherwise suspect criminal activity.
Apart from the disclosure of your data described above, we will only disclose your data if you have either given your express consent in accordance with applicable data protection law, if there is a legal obligation to do so, or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship, which represents an overriding interest of ours.
In the event of a sale, merger or other reorganisation of some or all of SOMMI's assets, personal data may be transferred, sold or otherwise shared with third parties as part of that transaction or reorganisation.
Your personal data will not otherwise be disclosed, transferred, or sold to third parties unless it is necessary for the performance of a contract you have entered into with us or you have expressly consented to it.

6 Use of cookies, tracking and analysis tools as well as plug-ins and other integrations of third-party offers
6.1 Cookies
Cookies help to make your visit to our offers easier, more pleasant and more meaningful, as well as to ensure the functioning of our offers and portals and serve to provide you with interest-based advertising. Cookies are information files that your web browser automatically stores on the hard disk of your computer when you visit our website. In principle, our range of digital contracts services can also be used without accepting cookies, although individual functionalities may then be restricted.
When you use our website, the cookies we use can collect and store usage data such as the IP address of your device, pages visited, browser used, date, time, etc. These data do not allow any conclusions to be drawn about you. This data does not allow any conclusions to be drawn about your person, unless you are logged into your user account.
Cookies are stored in a text file on your computer when you close your browser and are retrieved the next time you access the web server. Cookies neither damage the hard drive of your computer nor do they transmit personal user data to us.
We use cookies, for example, to recognise you after a first visit to our websites, offers or portals, whereby you are not recognised as a user, but only the computer or mobile device used or the browser used. In addition, we use them to track who has visited our offers and portals and to deduce how often certain pages or offers are visited, which parts of the portal are particularly popular and to generally ascertain how the portal is used. We use other cookies to enable you to move freely around our portal and use its functionalities, including accessing restricted areas, navigating efficiently between different pages, and storing preferences. With the use of cookies, the options or choices you have made can also be used as settings to make your visit to the portal more convenient. In general, the use of cookies serves to improve our services and make them more effective and secure. However, cookies are also used to collect information in order to offer you advertising that may be of interest to you. Finally, our cookies help to tailor online advertisements more closely to your possible interests and thus reduce the display of advertisements that may not be of interest to you or may be of little interest to you.
Most internet browsers automatically accept cookies. However, you can configure your browser at any time so that no cookies are stored on your computer or a message always appears when you receive a new cookie (visit the corresponding settings in your browser). You can also delete cookies on your computer or mobile device by using the corresponding function of your browser.
You can decide at any time whether or not you wish to benefit from targeted advertising tailored to your possible interests. However, opting out does not mean that you will no longer receive online advertising. It simply means that the adverts you see on websites are not tailored to your presumed interests and may therefore be less relevant to you.
Most of the cookies we use are temporary session cookies that are automatically deleted from the computer or mobile device at the end of the browser session. However, we also use permanent cookies. These remain stored on the computer or mobile end device after the end of the browser session. Depending on the type of cookie, these permanent cookies remain stored on the computer or mobile device for between one month and ten years and are only automatically deactivated after the programmed time has expired.

6.2 Tracking and analysis tools
The use of our digital offerings is also measured and evaluated by means of various technical systems, mainly from third-party providers such as Google Analytics. These measurements can be both anonymous and personal. It is possible that the collected data will be passed on to third parties for processing by us or the third-party providers of such technical systems.
We use Google Analytics, a service provided by Google Inc. This means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymised by means of IP anonymisation so that an allocation is not possible. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when visiting this website: http://tools.google.com/dlpage/gaoptout?hl=de.

6.3 Plug-ins and other integrations of third-party offers
Our website is linked to third-party functions and systems in a variety of ways, for example by integrating plug-ins from third-party social networks such as Facebook, Google+, YouTube or Twitter in particular.
If you have a user account with these third parties, it may also be possible for these third parties to measure and evaluate your use of our website. In the process, further personal data, such as IP address, personal browser settings and other parameters may be transmitted to these third parties and stored there. When using a social login service such as Facebook Connect, the provider may transmit to us personal data such as your name, email address and profile picture that they have stored about you. We have no control over the use of such personal data collected by third parties and accept no responsibility or liability. We refer you to the detailed further information linked above in this regard. Information on the collection and use of data by third-party providers can be found in the data protection notices of the respective third-party providers.

7. Transfer of personal data abroad
We may also transfer your personal data to third party companies or contracted service providers abroad, in particular in Europe, Asia and the USA, if this is appropriate for the data processing described in this privacy policy. These are obligated to data protection to the same extent as ourselves. If the level of data protection in a country does not correspond to that in Switzerland, we ensure by contract that the protection of your personal data corresponds to that in Switzerland at all times. We ensure this by concluding EU model clauses or other contracts approved by the Swiss Federal Data Protection and Information Commissioner with the commissioned service providers.

8. How long do we store your data?
We only store your data for as long as is legally necessary or necessary for the purpose of processing, in particular to ensure and fulfil the digital contract and its compliance with legal obligations.
In the case of analyses of your data, we store your data until the analysis is completed or you have objected to further processing. If we store data on the basis of a contractual relationship with you, this data remains stored as long as the contractual relationship exists, as long as limitation periods for possible claims or legal or contractual retention obligations exist.
The contents of the contact form and the subsequent e-mail correspondence must be stored by us for six months by law.
We then aim to anonymise the data so that we can continue to use it for statistical purposes. If this is not possible for any reason, the data will be deleted if we no longer need your data for the stated processing purposes and are also no longer legally obliged to retain it.

9. How do we protect your data?
We take suitable technical and organisational precautions to conscientiously protect your data from loss, destruction, falsification, manipulation, or unauthorised access. We operate and or use secure data networks that comply with the applicable technical standards. Our security measures are continuously adapted and improved in line with technological developments.
If you register with us as a user, access to your user account is only possible after entering your personal username and password. You should always treat payment and access information confidentially and close the browser window when you have finished communicating with us, especially if you are using a shared computer.
Our team and the service companies commissioned by us have been obliged by us to maintain confidentiality and to comply with the provisions of data protection law.

10. What rights do you have with regard to your data?
According to applicable data protection law, you have the following rights:
Right of access:
You have the right to know at any time whether and which of your personal data we process. Right to correct your data: You are entitled to have your personal data corrected at any time if you notice that we are processing incorrect data about you.
Right to delete your data:
If the processing of your data is no longer necessary because, for example, you no longer have a contractual relationship with us or you no longer agree to the processing of your data, you may request the deletion of your personal data. We will delete your personal data, provided that we have no other obligation (e.g. legal obligation to retain data) or no overriding interest (e.g. in connection with legal proceedings) in continuing to retain or process your personal data for a certain period of time. In this case, we keep your data exclusively for these purposes and do not process them in any other way. Deletion of your personal data may mean that you can no longer obtain or use the services you have registered for.
Right to restrict or block the processing of your data:
You have the right to restrict or block the processing of your data at any time, provided that we have no other obligation to retain and process your data for a certain period of time.
Right to have your data returned:
Subject to certain conditions, you are entitled to have us disclose your personal data to you or to a third party designated by you in a commonly used format or to have us disclose your data to you in a commonly used format.
Right to object:
You can object to the processing of your data for marketing and analysis purposes as well as the disclosure of your data at SOMMI in accordance with section 3.9 at any time by sending an e-mail to info@sommi.io.
Such an objection does not preclude the collection of personal data altogether, but only for marketing and analysis purposes and for the transfer of your data within SOMMI in accordance with chapter 3.9.
In addition, you can object to any data processing based on a legitimate interest of ours by sending an e-mail to info@sommi.io if you can demonstrate reasons arising from your particular situation.
Right to withdrawal of your consent:
You always have the right to withdraw your consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for those specific purposes unless we have another legitimate interest in doing so. Withdrawing your consent will not affect any data processing that was carried out prior to the withdrawal.
Right to complain to a supervisory authority:
In addition, you have the right to lodge a complaint regarding data processing with the competent supervisory authority, which in Switzerland is the Federal Data Protection and Information Commissioner. You can do this at the supervisory authority at your place of residence, place of work or the place of the alleged data protection violation. You can exercise your rights at any time by sending written notification and proof of your identity to the address below.
Please use the e-mail account with which you have registered with us. This will enable us to verify your identity. In addition, we reserve the right to verify your identity by means of a copy of your passport, a copy of the front and back of your ID card or a copy of your Swiss driver's licence or by other means. We may correspond with you in connection with your contacting us to exercise your rights.
Please note that the granting of your rights may in part be refused or restricted for legal reasons or on the basis of data protection law. We will inform you of the reasons for our decision where legally required or permitted.

11. How can you contact us?
If you have questions about the processing of your data, would like to request information, or would like to request the deletion of your data, please contact our data protection officer by sending an e-mail to info@sommi.io.
The contact details of our data protection officer are as follows:
SOMMI, c/o Marcel Schopfer, Chrüzacherstrasse 4, 8340 Hinwil, Switzerland.

12. Changes to this data protection declaration
The current data protection statement published on our offers applies at all times.
We adapt this data protection declaration in each case to the current status of measures relating to the use and protection of personal data. Any significant changes to the data protection declaration will be communicated to registered users by e-mail to the e-mail address provided during registration or by means of a corresponding notice in a suitable place after logging into the user account.
Please re-read this Privacy Policy at regular intervals so that you are always up to date on what we do with your personal data and how you can exercise your rights.

Status: 20 September 2023