Informativa sulla privacy / Linee guida sulla protezione dei dati di Memberly AG

Version from August 2024

1. Introduction
Memberly AG (“Memberly”, “we”, “us” or “our”) takes the protection of your personal data
very seriously. This Privacy Policy describes how we collect, use, share and protect personal
information when you use our customer loyalty app (“App”) and your rights in relation to
that information. This policy is based on the applicable data protection laws in Switzerland,
in particular the Federal Data Protection Act (DSG) and the European Union General Data
Protection Regulation (GDPR), to the extent that they apply.
The contract language is German. Versions of this Privacy Policy in other languages are for
guidance only. Only the German version is authoritative.

2. Responsible Company
The person responsible for processing your personal data is:
Memberly AG
support@memberly.ch

3. Data collected
We collect personal data that is necessary to provide our services. These can include:
- Master data: first name, last name, date of birth, gender
- Contact information: email address, telephone number, postal address
- Usage data: information about your interactions with the app, e.g. E.g. pages visited,
transactions made and loyalty points used
- Technical data: IP address, device type, operating system, app version
- Customer preferences: information about your preferences and interests that you share
with us or that are derived from your usage behavior

4. Purpose of data processing
We use the data collected for the following purposes:
- Provision and management of the app and the associated services
- Personalize the user experience and offer tailored services
- Management and processing of loyalty programs and customer loyalty measures
- Communicate with you about updates, offers or other relevant information
- Improve our products and services by analyzing usage data
- Comply with legal obligations and enforce our Terms of Use

5. Legal basis for data processing
The processing of your personal data is based on the following legal bases:
- Fulfillment of the contract: The processing is necessary to fulfill the contract between you
and Memberly AG.
- Consent: Where necessary, we process your data based on your consent, which you can
revoke at any time.
- Legal obligations: We process your data to comply with legal obligations.
- Legitimate interest: In some cases, we process your data based on our legitimate interest,
in particular to improve our services and communicate with you.

6. Disclosure of data to third parties
Your personal data will only be passed on to third parties if this is necessary to fulfill the
purposes mentioned above, in particular to:
- Service providers who support us in providing the app (e.g. hosting providers, payment
service providers)
- Business partners if this is necessary to fulfill loyalty programs
- Authorities if we are legally obliged to do so

7. Data transfer abroad
If we transfer your data to countries outside Switzerland or the European Economic Area
(EEA), we will ensure that appropriate protective measures are taken, e.g. B. by concluding
standard contractual clauses or on the basis of an adequacy decision by the European
Commission.

8. Data Security
We take appropriate technical and organizational measures to protect your personal data
from unauthorized access, loss or misuse. This includes encryption technologies and access
rights to our systems, which are limited to the minimum necessary.

9. Storage period
Your personal data will only be retained for as long as necessary to fulfill the purposes set
out in this policy or as required by law. After these periods have expired, your data will be
securely deleted or anonymized.

10. Your Rights
You have the right:
- To receive information about your personal data stored by us
- To request correction of incorrect or incomplete data
- To request deletion of your data, provided that there are no legal retention obligations to
the contrary
- to request restriction of the processing of your data
- To object to data processing, in particular to processing based on a legitimate interest
- Receive your data in a structured, common and machine-readable format (data portability)
- To revoke your consent at any time, without this affecting the lawfulness of the processing
carried out based on the consent before its revocation
To exercise your rights, you can contact us using the contact details above.

11. Changes to the Privacy Policy
We reserve the right to change this privacy policy at any time. The current version is
available in the app and on our website. We will inform you of any significant changes in an
appropriate manner.

12. Contact
If you have any questions about this privacy policy or the processing of your personal data,
you can contact us at any time using the contact details above.