Privacy Policy

Last updated: 1 January 2020

This privacy policy describes our policies and procedures on the collection, use and disclosure of data obtained through your access to and use of the services available on the mobile applications and the Website (the ‘App/Website’) operated by Brame Ltd. (‘Brame’).

Which Data We Collect

    1. In order to enter this website, you are expected to provide personal data, such as your name, username, password, personal contact details (address, zip code and location and email address), date of birth, gender, details about your lifestyle and activities (including underlying GPS data) and similar data (the ‘Data’).

How Your Data is Collected

    1. We collect Data that you provide to us either directly through the App/Website, or third party devices or apps you connect with your account. We also collect information about your interactions within the App/Website as part of our continuous effort to improve the user experience.

How We Protect and Use your Data

    1. When using the App/Website you consent to the collection, transfer, modification, storage, disclosure and other uses of the Data. Irrespective of the country in which you reside or from where you access to the App/Website, the Data may be used by Brame and/or in Switzerland or any other country of operation.

    2. You authorize Brame and/or to de-identify your Data and subsequently to copy, process, use, publicly disclose and distribute the Data in anonymized form for academic and statistical purposes. Such anonymized Data shall no longer be considered as personal data.

    3. You authorize Brame to receive, review and store technical data (including crash reports) retrieved from the devices you are using to access the App/Website.

    4. We restrict access to the Data to those Brame employees or other parties who need access to such Data in order to provide the services. We maintain appropriate physical, electronic and procedural safeguards to protect your Data, including firewalls, individual passwords and encryption and authentication technology, and take all other necessary and adequate administrative, organizational, technical, personnel and physical measures to safeguard the same against unauthorized or unlawful processing and use, accidental loss or destruction or damage, theft, disclosure or modification and to ensure its integrity. Please note, however, that Data transported over an open network, such as the Internet or email, may be accessible to anybody. We cannot guarantee, and are not responsible for, the confidentiality of any communication or information transmitted via such open networks. When disclosing any Data via an open network, you should consider that it is potentially accessible to others, and consequently, may be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. Even if both the sender and recipient are located in the same country, data may be transmitted via such networks to other countries regularly and without controls, including countries that do not afford the same level of data protection as Switzerland. Your Data and Information may be lost during transmission or may be accessed by unauthorised parties. We do not accept any liability for direct or indirect losses as regards the security of the Data and Information during its transfer via Internet.

    5. Brame may use the Data for marketing purposes and may sell, rent or otherwise make available any Data submitted by users to any third parties. Brame may use the Data to contact users with respect to all matters related to the user’s activity on the website, including but not limited to sending motivational e-mails and reminders.

How Your Data is Shared

    1. The concept of the App/Website includes the disclosure of the Data provided by you and accessible via the App/Website to other users or third parties.

      Cookies and Similar Technologies

      Like many websites, we use ‘cookie’ technology to collect additional website usage data and to improve the website, but we do not require cookies for many parts of our services. Most Internet browsers automatically accept cookies. However, you have the option of using your browser software to stop accepting cookies or to warn you before accepting a cookie from the websites you visit. However, if you disable or choose not to accept cookies, some of the functionality of the website may be impaired or you may not have access to areas of the website that require this type of identification. When using mobile applications, Data may be stored and processed temporarily on your mobile device. By accessing mobile applications operated by Brame you agree to the transfer and temporary storage of Data.

      Google Analytics:

      We use Google Analytics on our public website to help us understand things like how long a visitor stays on our websites, what pages they find most useful and how they navigate through our site. To learn more about Google Analytics and how to opt-out visit this Google webpage: link.

      Facebook for Developers:

      For some of our applications we have implemented a simplified login method. We use Facebook for Developers (formerly Facebook Connect) to enable login using your existing Facebook Login.

How Long Your Data is Stored

    1. We store your data for as long as necessary for the purposes for which they are processed.

Your Rights

    1. You have the right to be informed by us on any processing of your Data and obtain a copy of our Data (right of access). If you are affected by incorrect or incomplete Data, you may request rectification or completion of any relevant data (right to rectification). You may request the deletion of your Data (right to erasure) or a temporary restriction of processing in certain cases (right to restriction of processing). You may object to the processing of your Data (right to object) and you have the right to receive your Data in a structured, commonly used and machine-readable format or have your Data transferred to another data controller if technically feasible (right to data portability).

    2. Your rights are subject to limitations necessary (a) to satisfy any applicable law, regulation, legal process or governmental request; and (b) in connection with any legal proceedings (including prospective legal proceedings), obtaining legal advice or otherwise establishing exercising or defending legal rights.

Disclosure of Data

    1. We reserve the right to disclose Data to the extent we reasonably believe it is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms, including investigations of a potential violation thereof, (iii) detect, prevent or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or to (v) protect the rights, property or safety of Brame its users and the public.

Additional Points

    1. Please note that Brame uses encryption software that may be subject to export control regulations.

    2. The App/Website may contain links to App/Websites or materials that are not operated by Brame. Such other App/Websites are not subject to this Privacy Policy and Brame is not responsible in any way for the content or accuracy of such App/Websites or for the policies applied to the treatment of personal data and information. Connecting to or otherwise accessing such App/Websites is at your own risk. We recommend that you read the policies used by these App/Websites, and check how these App/Websites protect your personal data and information and whether they are trustworthy.

Updates to this Privacy Policy

    1. We may revise this Privacy Policy from time to time. The most current version is always available on our App/Website (https://www.brame.ch). The revised Privacy Policy shall become effective from the date of publication on the App/Website. Should these changes be substantial, we will provide you with notice and, where required by applicable law, obtain your consent. This notice will be provided by email or by publication on the App/Website.

Data Controller and Data Protection Officer

    1. In case you are dissatisfied with any aspect of processing of your Data, we would like to understand how we can solve this issue. Please contact us at:

      Brame Ltd.
      Neuhofstrasse 10
      CH-8834 Schindellegi
      Switzerland

      The data protection officer is located at the same address and can be contacted by mail or sending an email to info@brame.ch.

      For EU residents a contact in the EU has been established at:
      Julius Lutz
      Schlosssteig 5
      6800 Feldkirch
      info@brame.ch

      You also have the right to contact the data protection supervisory authority in your country of residence.

Jurisdiction

This Privacy Policy shall in all respects be governed by Swiss substantive law. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the seat of Brame and you consent to such jurisdiction of and venue in such courts and waive any objection as to inconvenient forum.

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