Model L’Heritage

Privacy policy

In this Privacy Policy we want to inform you how and why we collect and further process your personal data, and what rights you have in this area. The term “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data.

When processing your personal data we follow legal regulations, especially the Swiss Data Protection Act (DPA) and the EU General Data Protection Regulation (GDPR) as applicable. Personal data protection is important to us, therefore we follow the strictest security standards when processing personal data. In particular, we take appropriate technical and organizational security measures which shall protect personal data from unauthorized access.

We recommend that you read this Privacy Policy carefully and ensure that you understand it. If you provide us with personal data from third parties, please ensure that you are allowed to do so, the personal data provided is correct and that respective persons are aware of this Privacy Policy.

1. Controller of your personal data
   1. The controller of data processing as described in this Privacy Policy is Oppidum Bunkers GmbH, Hertensteinstrasse 51, 6004 Luzern (hereinafter the “Company” or “we”). If you have any data protection related questions or concerns you can notify us using the following contact details: compliance@oppidum.ch .
2. Collection and processing of personal data
   1. The Company processes personal data that it obtains from its business partners as well as other individuals in the context of the business relationships with them and/or that it collects from users when operating the website www.oppidum.ch (hereinafter the “Website”) or other applications. Such personal data includes your name and contact details, professional information, identification and background information, financial information, bank details, your interests, data in connection with the use of our Website (e.g., IP-address, MAC (Media Access Control) address of your smartphone and computers, information regarding your device, cookies, date and time of your Website-visits, localization data) and/or any other information relating to you which you may provide to the Company. As far as legally permissible, the Company may obtain personal data from publicly accessible sources (e.g., public registries, internet) and/or third parties (e.g., other business partners of the Company, public authorities).
3. Purpose of data processing and legal grounds
   1. The Company primarily processes personal data in order to conclude, process and perform on contracts with its business partners in connection with the products and services we provide, the products and services we procure from third parties, in connection with the operation of the Company’s Website or other applications (regarding the use of the Website and cookies, please see our separate cookie policy on our website) as well as to comply with applicable legal obligations.
   2. Moreover, the Company may process personal data in our legitimate interest in compliance with applicable laws and regulations and where appropriate.
   3. If we require your consent to process your personal data, we will process your personal data within the scope of and based on this consent. You can withdraw your consent at any time, but such withdrawal does not affect the processing of data prior to withdrawal (please also see below Para. 6.2).
   4. In particular, the Company processes personal data for the purposes state below:
      - for the communication with our business partners and the administration of our business relationships;
      - to provide and improve our services to our business partners;
      - to carry out background checks, such as KYC (Know Your Customer), anti-money laundering, conflict and reputational checks;
      - to comply with legal and regulatory obligations, e.g., establishing, exercising or defending claims in legal disputes and administrative proceedings, filling complaints and reports with public authorities (e.g., criminal complaints, anti-money laundering reports);
      - to ensure our business operations (incl. the operation of our Website and other applications);
      - for market and opinion research;
      - to analyse your behaviour and preferences (i.e., profiling) which helps us to tailor our business messages to your specific interests and needs;
      - advertising and marketing (we may contact you with newsletters, publications, updates, offers, event invitations etc. if we have obtained your prior consent or have obtained your contact details from you in connection with the provision of our services and you have not opted out from receiving such marketing communication respectively. If you do not longer wish to receive such marketing communication you will have the choice of opting out of receiving such communication at any time).
4. Transfer of personal data
   1. In the context of our business activities and in line with the purposes of the data processing listed in Para. 3 above, the Company may transfer personal data to third parties. In particular, such third parties include other group companies of the Oppidum Group and the Company’s service providers, suppliers, subcontractors. Moreover, the Company may be required to provide personal data to public authorities such as courts, regulatory authorities, government and law enforcement agencies according to applicable laws and regulations.
   2. The Company may transfer personal data to third parties located abroad, including to countries that do not provide for an adequate data protection level according to Swiss laws. If the Company transfers personal data to a country without adequate data protection level, we ensure an appropriate level of protection as legally required by way of using appropriate contracts or binding corporate rules or based on the statutory exceptions of consent, performance of contracts or for the establishment, exercise or defence of legal claims.
5. Retention of personal data
   1. The Company processes and retains personal data for the following retention periods:
      - as long as it is necessary for the purposes for which the personal data is collected;
      - as long as the Company has a legitimate interest to retain your personal data (e.g., in relation to legal and regulatory proceedings or IT security);
      - as long as it is required to comply with legal obligations and/or under applicable legal retentions periods.
6. Your rights
   1. You have the right to request information about whether and how we process your personal data and to receive a copy of your personal data.
   2. You have the right to rectification or deletion of your personal data and to restrict or object to the Company’s processing of such data. If you have given your consent to data processing you may withdraw your consent. Please note, however, that in the event that you restrict or object to the processing of your personal data or withdraw your consent, the Company may still be able to continue the data processing to the extent required or permitted by applicable laws and regulations.
   3. You have the right to lodge a complaint in relation to the Company’s processing of your personal data with the local data protection authority. In Switzerland the competent data protection authority is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/).
7. Amendments to this Privacy Policy
   1. 7.1 The Company may amend this Privacy Policy without prior notice at any time. You will always find the current version of this document on our Website and are advised to check the same from time to time.

Cookies Policy

1. Introductory information
   1. This Cookie Policy is for users of the website www.oppidum.ch (hereinafter the “Website”).
   2. The owner and operator of the Website is Oppidum Bunkers GmbH, Hertensteinstrasse 51, 6004 Luzern (hereinafter “we” or the “Company”).
   3. If you use the Website, your personal data may be collected in the form of cookies under the terms and conditions stated below.
2. What are cookies?
   1. Cookies are small data files that the visited web page sends to your browser which stores them in your computer and normally serves to distinguish individual users. Cookies usually contain a maximum amount of data e.g., IP address, MAC (Media Access Control) address, behaviour of the visitor to the web page, time spent on the web page, assessment of adverts from which the user learned of the web page and the subject of his search before arriving at the web page. Cookies also help to remember your activities and preferences for a certain amount of time so you do not have to enter them again when you return to the web page or move from one web page to another.
3. What do we use cookies for?
   1. Cookies help to make the search of the Website effective, to develop it and display advertising messages. Cookies especially serve to:
      a) Ensure the proper functionality of our Website, so that your actions when filling in the forms and in the client section are as predictive as possible;
      b) ensure a secure login, verify users, prevent the fraudulent use of login credentials and protect user data from being accessed by unauthorised parties;
      c) retain the login data of our customers, so they do not have to enter them each time;
      d) ensure the appearance of the Website in terms of the preferences and requirements of the visitors;
      e) analyse the visitor rate, behaviour, preferences and interests of the users;
      f) offer adverts to users of all our partners.
4. How long do we store cookies?
   1. The Website uses the following types of cookies in terms of their processing:
      a) Session cookies are cookies that are part of only one session, i.e. the time when you enter a web page until such time when you close the web browser.
      b) Persistent cookies – these are cookies, which we store for no more than 12 months and serve to identify the return of the device of the identified MAC address to the Website. But the device may also have more MAC addresses in which case the cookies are the same.
   2. Types of cookies according to their function:
      The Website uses the following types of cookies in terms of their function:
      a) Essential – these are cookies essential for the function of the Website or for providing services requested by the user.
      b) Statistic – these are cookies providing information on where the visitor is browsing from, what tracking device was used, how much time was spent on the Website, way of using the Website, the visitor’s behaviour.
      c) Marketing – collect information for the purpose of adapting the offered adverts to the interests of the customer, interconnection of social media networks, display of the offers of third party advertisers, assessment of the effectiveness of advertising across websites, reporting the steps of the user on the Website, clicking on a partner’s or advertiser’s advert.
5. Google Analytics
   1. The Website may use Google Analytics provided by Google LLC, USA. Google Analytics measures and evaluates the use of the Website on an anonymous basis by using tracks and reports on the manner in which our Website is used. Google Analytics does this by placing cookies on your computer or other device. These cookies collect information about the number of visitors to the Website, the pages visited and the collection information about the number of visitors to the Website, the pages visited and the time spent on the Website. This information is aggregated and not personally identifiable.
6. Consent and its withdrawal
   1. We can use statistic and marketing cookies only with your consent. Consent to the use of cookies is voluntary and you can change or withdraw it at any time here. If you do not give your consent to the processing of cookies, you can also prevent their processing by making a change to the settings in your browser as set forth in chapter 10 of this document. In case that you decide not to give or withdraw your consent, we shall not send you personalised content and/or less relevant adverts will be displayed to you.
   2. You will find a list of third parties to whom data from cookies may be forwarded in case you give your consent such as for the purpose of marketing here.
7. How to keep cookies under control?
   1. Most browsers automatically accept cookies, unless the browser is configured differently. You can manage cookies in your web browser by blocking some and allowing others. But be careful as if you block some cookies, you may not be able to make full use of some functions of our Website and with the complete ease that cookies provide. It may also be that some functions of our Website may not work properly for you. You will find the instructions for how to configure cookies in the most commonly used browsers in the chapter 10 of this document.
8. Further information
   1. Should you have any queries, contact us using the following contact details: compliance@oppidum.ch.
9. Amendments to this Policy
   1. The Company may amend this Cookies Policy without prior notice at any time. You will always find the current version of this document on our Website and are advised to check the same from time to time.
10. Instructions for how to configure cookies in the most commonly used browsers

    Browser	Disabling Cookies	Deleting cookies
    Internet Explorer	1. Click on the top right-hand corner on …, select “Settings” (cog wheel icon). 2. Click on “Internet Options”. 3. In the “Personal Data” bookmark select “Advance Setup”. 4. Set “Block” cookies and confirm.	1. Click on the top right-hand corner on …, select “Settings” (cog wheel icon). 2. Click on “Internet Options”. 3. In browsing history click on “Delete” and confirm.
    Google Chrome	1. Click on the top right-hand corner on …, select “Settings”. 2. Select “Extensions” and “Privacy and Security”. 3. Select “Site Settings” and “Cookies and Site Data”. 4. Option “Allow sites to store and track cookies” change the settings to “Block” and confirm.	1. Click on the top right-hand corner on …, select “Settings”. 2. Select “Extensions” and “Privacy and Security”. 3. Select “Clear browsing data”. 4. Confirm.
    Microsoft Edge	1. Click on the top right-hand. corner on …, select “Settings”. 2. Select “Data Protection”. 3. Select “Block all Cookies“. 4. Confirm your Settings.	1. Click on the top right-hand corner on …, select “Settings”. 2. Select “Data Protection”. 3. Select “Clear Browsing” . 4. Confirm pre-defined list to clear.