Privacy Policy
NEW IN SIGNAL
New In Signal GmbH, Baarerstrasse 25, 6300 Zug, Switzerland (hereinafter referred to as “we” or “our company”), as the data controller, hereby informs you of the conditions for the collection and processing of personal data under the Swiss Federal Data Protection Act (FDPA) and the General Data Protection Regulation (GDPR), where applicable.
This Privacy Policy applies to:
• all individuals who access our website at www.newinsignal.com (“Website”);
• individuals who contact us via the contact form available on the Website and/or the email address office@newinsignal.com;
• individuals who choose to subscribe to one of our subscription plans (“Subscribers”);
• individuals who apply for a job in one of our job positions (“Candidates”),
• individuals who give their explicit consent for direct marketing.
Please read this Privacy Policy carefully to understand our approach and practices regarding your personal data and how we will process it.
1. Identity and Contact Details of the Controller
Data Controller:
New In Signal GmbH
Baarerstrasse 25, 6300 Zug, Switzerland
Email: office@newinsignal.com
2. Data Protection Officer
Currently, we do not have a designated Data Protection Officer. If you have any questions or concerns regarding data protection, please contact us using the details provided above. We will designate a Data Protection Officer in compliance with legal requirements if and when necessary.
3. Personal Data We Collect
Personal data refers to any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect personal data directly from you when you decide to voluntarily share them with us:
• Information you choose to share with us in your inquiry through our contact form on the Website or by other means;
• Information you share with us when registering an account;
• Information you choose to share with us as a Candidate during the application process for a job position with us;
• Information you choose to share with us when selecting one of the three subscription plans;
• If you contact us directly or send an inquiry to office@newinsignal.com or any other email available on the Website, or share information with us through social media, we may receive information about your name, email address, your title or employer’s name, the content of the messages or attachments you provide, or any other information you choose to share with us.
Categories of personal data collected include:
• Contact Details: Name, email address.
• Subscription Information: Information related to your subscription(s) with us (Subscription timestamp (the date and time when you subscribed), Subscription status (a flag indicating whether you are subscribed or unsubscribed), Unsubscribe timestamp (the date and time when you unsubscribed), information about your consent to direct marketing (Consent timestamp: The date and time when you consented to receiving our marketing materials; Consent status: A flag indicating whether you consented to receiving our marketing materials or not; Consent withdrawn timestamp: The date and time when you have withdrawn your consent; Source of consent: How you gave consent (through the CTA button, form, etc.)).
• Payment Information: If you choose to subscribe to one of a paid versions of subscription plans, your payment details (including credit card information) will be collected securely through our third-party service provider, STRIPE. All payment information is processed in compliance with applicable data protection laws and is secured using industry-standard encryption protocols.
• Address: if you choose one of the paid subscription plans, STRIPE might require a billing address for certain card payments, especially to verify transactions for fraud prevention (using Address Verification System, AVS). This information, if collected, will be used only and exclusively for the purpose of securing payment through STRIPE. This information will not be used for any purpose other than ensuring the functioning of the payment.
• Phone number: if you choose one of the paid subscription plans, for some transactions or services (e.g., higher-risk payments or certain regulations in specific regions), STRIPE may choose to collect your phone number to enhance security or for customer communication purposes. This information may be collected only and exclusively for the purpose of securing payment through STRIPE. This information will not be used for any purpose other than ensuring the functioning of the payment.
• Job Candidate Data: We collect personal data from job candidates through the form available in the Careers section of our website or by receiving CVs sent directly to our email address. This data may include contact details, professional experience, education, and any other information candidates choose to provide. The collected data will be used solely for the purpose of recruitment and assessment of candidates for potential employment opportunities.
If you contact us through the Careers page during the application process for any advertised job position, the data we may collect about you as a job candidate may include resumes or CV documents, academic records, employment history, job-related information, and references. To assess your qualifications, we may collect and process your personal data such as your name, date of birth, residence, phone number, and email address, as well as other data you have provided that are necessary to properly evaluate your qualifications. This information is forwarded to the appropriate hiring managers and persons involved in the recruitment process to decide whether and which candidate to invite for an interview. We collect additional information if the candidate is invited to the interview (or similar) stage and beyond. Such information includes interview notes, evaluation results, feedback, and details about the employment offer. If you provide us with additional personal data during the application process, we commit to processing it in accordance with this Privacy Policy, as well as legal provisions and internal regulations.
4. Purpose of Data Collection
The personal data we collect is used for the following purposes:
• Account Creation: To allow you to create and manage your account with us. The legal basis for processing personal data related to account creation and management would be the performance of a contract. When you create an account, you are essentially entering into a contractual relationship with us to access and use our services. The processing of your personal data is necessary to fulfill this contractual obligation, which includes creating the account, managing it, and providing access to the services offered under the subscription plan.
• Subscription Management and Providing our Services: To manage your subscription(s) and provide access to our services. The legal basis for processing personal data related to your subscription to our services and subscription management would be the performance of a contract.
• Customer Support: To respond to inquiries and provide customer support. The legal basis for processing personal data related to customer support would be the performance of a contract
• Direct Marketing: To send you newsletters and marketing communications, including promotions and offers related to our services. The legal basis for processing personal data to send you newsletters and marketing communications is your explicit consent.
• Recruitment: To evaluate job candidates for employment opportunities within our company. The legal basis for processing personal data for recruitment purposes is your explicit consent.
• Responding to your inquiries: If you send us an inquiry via the contact form on our website, we will process your data based on our legitimate interest to respond to your request.
5. Methods of Data Collection
We collect your data through the following methods:
• Contact Forms: Information is submitted through contact forms on our Website.
• Account Sign-Up: Information is provided when you sign up for an account.
• Subscription Forms: Information is submitted through subscription forms on our Website.
• WooCommerce API: We utilize the WooCommerce API tool to facilitate the processing of subscriptions and payments for our services. This tool helps ensure a seamless user experience while managing your account and subscription details.
• Emails: Information is collected when you send us an email, including your email address and any other details you provide in the communication.
• Cookies: We use cookies to collect data about your interaction with our Website, including preferences, browsing behavior, and session information, in order to improve user experience and analyze Website performance.
• Stripe: Payment information is collected and processed securely through Stripe when you make a purchase or subscription payment on our platform. This includes details necessary for completing the transaction, such as payment method and billing information.
6. Cookies and Tracking Technologies
When you visit our Website, we may automatically collect certain personal data from your device. Specifically, the information we collect automatically may include details such as your IP address, device type, unique device identification number, browser type, and broad geographic location (e.g., location at the country or city level). We may also collect information about how your device interacts with our Website, including the pages you accessed and the links you clicked on.
Collecting this information allows us to better understand the visitors coming to our Website, where they are coming from, and what content on our Website interests them. This information is primarily collected using “Cookies” and similar tracking technologies.
We use cookies and tracking technologies to optimize your website experience. This includes the use of third-party services such as Google Analytics, which helps us analyze website traffic and improve our services. Google Analytics collects information such as IP addresses, page views, and time spent on our site. You can learn more about how Google Analytics collects and processes data by visiting their privacy policy.
You can control cookies through your browser settings, and you have the option to opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
More information about which cookies we use and how we process your data collected through cookies can be found in our Cookie Policy
7. Legal Basis for Processing
The legal basis we use for processing your data are:
• Your consent: (Article 6(1)(a) of GDPR and Article 31(1) of the FDPA). Consent must be freely given, specific, informed, and unambiguous for direct marketing under Article 7 of GDPR.
• The necessity for the performance of a contract to which you are a party: (Article 6(1)(b) of GDPR and Article 31(2)(a) of the FDPA). For example, the provision of your data is a requirement necessary to enter into a contract (subscription). If you do not provide this information, we may not be able to fulfill the subscription service.
• Legitimate interests pursued by our company, including processing personal data in direct connection with the conclusion or performance of a contract: (Article 6(1)(f) of GDPR and Article 31(2)(c) of the FDPA).
If we process your data based on legitimate interests, we will inform you of what those interests are.
8. Consent Management
We are committed to ensuring that you have clear choices regarding your data.
You have the right to withdraw your consent for the processing of your personal data, including data collected for recruitment purposes, direct marketing, and the use of non-essential cookies at any time. To do so, you can follow these simple steps:
1. Withdraw your consent for direct marketing: Click on the “Withdraw my consent” link at the bottom of any subscription or other email you receive from us. This will take you to a confirmation page where you can easily confirm your decision to withdraw your consent and after that we will not send you any marketing materials and promotions.
2. Contact Us Directly: If you prefer, you can withdraw your consent by contacting us at office@newinsignal.com. Simply state that you wish to withdraw your consent for the processing of your personal data, including recruitment data, and we will promptly process your request.
3. Manage Cookie Preferences: To manage your cookie preferences, use the cookie banner located at the bottom of our website . This banner allows you to:
o Change Your Preferences: Click on the banner to access the cookie settings, where you can adjust your preferences for different types of cookies.
o Withdraw Consent for Non-Essential Cookies: You can specifically withdraw your consent for the use of non-essential cookies. Please note that essential cookies, which are necessary for the functioning of our website, cannot be disabled.
Once you withdraw your consent, we will stop processing your personal data for the purposes you initially consented to, including recruitment purposes, unless we have other legal grounds for processing your data. Additionally, your updated cookie preferences will be reflected in your experience on our website.
If you have any questions or need further assistance regarding the withdrawal of consent for personal data or cookies, please feel free to contact us at office@newinsignal.com
9. Data Retention Period
We do not retain your personal data longer than necessary to fulfill the purpose for which they were collected, or longer than the period for which we have your consent or other legal basis for processing data.
We retain Candidate data until the specific purpose of processing has been exhausted, or until consent is withdrawn.
If you have submitted your resume with the intention of applying for a specific published job advertisement, we will process your data from that resume until the expiration of the relevant competition.
If you submitted your resume with the intention of being employed by us but outside a specific job competition, we will process your resume data until the expiration of a future competition for a suitable position, but no longer than 12 months from the date you submitted your resume.
If you have given us consent to store your data in the candidate database and process it for future job openings, we will process your data until the purpose is fulfilled or until you withdraw the consent you have given.
10. Recipients of Personal Data
Your data may be shared with:
• Our third-party service provider, Stripe Payments Europe, Limited, which manages our paid subscription services. Stripe is located in Ireland and ensures adequate protection of your data.
• Google Analytics, which helps us analyze website traffic and improve our services. Google Analytics processes data in accordance with its privacy policy.
• Facebook Inc., which may use your data to help us analyze the effectiveness of our marketing efforts and improve user engagement. Facebook processes data according to its privacy policy.
• Other third parties only where you have given explicit consent, it is required by law, or it is necessary to fulfill a contractual obligation related to your subscription(s).
11. Direct Marketing
If you give your explicit consent for direct marketing, we may use your email address to send you marketing communications, including promotions and offers related to our services. You may also receive important updates and announcements from us regarding your subscription.
Withdrawing your Consent for Direct Marketing: You can easily withdraw your consent for direct marketing at any time. To do so, simply click on the “Withdraw my consent” link provided at the bottom of any subscription or other email you receive. This link will direct you to a confirmation page where you can confirm your decision to withdraw your consent. You may also withdraw your consent by contacting us directly at office@newinsignal.com, and we will promptly remove you from our mailing list.
Upon consent withdrawal, your email address will be removed from our mailing list, and you will no longer receive marketing communications from us. However, please note that you may still receive transactional emails related to your subscription or account.
By consenting to receive marketing materials from us, you acknowledge that you understand your rights regarding your data, including the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
12. International Data Transfers
Your data may be transferred to third countries (i.e., outside the European Economic Area) through our third-party service providers, such as Stripe, Google Analytics, and Facebook Inc. We implement appropriate safeguards under GDPR and FDPA, including standard contractual clauses, to ensure adequate protection of your data.
13. Your Rights
Under the GDPR and FDPA, you have the following rights:
• Right to Access: You have the right to request information on how your data is processed.
• Right to Deletion: You can request the deletion of your data.
• Right to Rectification: You can correct inaccurate or incomplete data.
• Right to Restriction of Processing: You may request the restriction of data processing.
• Right to Data Portability: You can receive your data in a machine-readable format.
• Right to Object: You can object to the processing of your data at any time.
• Right to be Informed: You have the right to be informed about the collection and processing of your personal data.
• Right to Withdraw Consent: You can withdraw consent for the processing of personal data when consent is the basis for processing.
• Right to Lodge a Complaint: You have the right to file a complaint with the competent authorities if you do not receive a timely response or are not satisfied with the response.
If you wish to exercise any of these rights, please contact us by filling in this Request and sending it to our email office@newinsignal.com.
Response Deadlines
In accordance with Article 12 of the GDPR, we will respond to your request without undue delay and, in any case, within one month of receiving your request. If necessary, due to the complexity or number of requests, this period may be extended by a further two months. In such a case, you will be informed of the extension and the reasons for the delay within one month of your request.
14. Right to Lodge a Complaint
If you believe your rights have been violated, you have the right to complain to the competent supervisory authority in the EU or with the Swiss Federal Data Protection and Information Commissioner. You can file a complaint through their website: FDPIC Complaint Form.
15. Automated Decision-Making
We do not engage in automated decision-making, including profiling, that significantly affects you.
16. Further Processing
If we intend to further process your data for a purpose other than that for which the personal data were collected, we will provide you with information on that other purpose before further processing.
17. Children’s Data
If our services target children or if we may inadvertently collect data from children, we will implement measures to obtain parental consent as per Article 8 of GDPR.
18. Data Breach Notification
In the event of a data breach that poses a risk to your rights and freedoms, we will inform you without undue delay, as required by GDPR Article 33 and FDPA Article 30.
19. Additional Information
In cases where your data is collected from third parties or when we disclose your data, we will inform you of:
• The categories of personal data processed.
• The identity of the recipient(s) or categories of recipients to whom your data is disclosed.
• The State or international body to which your data is disclosed, if applicable, and the guarantees in place under Swiss law.
If we collect your data from other sources, we will provide you with the above information no later than one month after receiving the data or at the time of disclosure.
20. Contact Information
If you have any questions or concerns regarding the processing of your data or wish to exercise any of your rights, please contact us at: office@newinsignal.com.
21. Effective Date
This Privacy Policy is effective as of November, 2024. It will remain in effect until it is updated or replaced. We encourage you to review this policy periodically for any changes.