Version 1.0, March 2022
The Services are provided by Witty Works AG, Rotwandstrasse 63, 8004 Zürich, Switzerland ("we", "our", or "us").
1 Contact Us
Unless otherwise stated below, the responsible party for the processing of your personal data is Witty Works AG (“Controller”). If you have any queries or require information on data protection at Witty Works, please contact us at: email@example.com.
2 Personal data we collect
We collect the following types of personal data when you use our Services. If you do not wish to provide this mandatory information, subscription to our Services is not possible:
- User account: Contact and login information
- Subscription data: Payment details
- Contact form, email to support: Contact information and content
- Website usage and interaction: Only to the extent that this is necessary to make it possible for you to utilize the Services
- Technical data: Time of access, the IP address, type of browser and operating system
- Location-based data: Country of residence.
To improve our Service, you may also provide us with the following information:
- Analytics: You receive feedback on your input
- Demographic data: Gender and skin tone.
3 How we collect personal data
We collect information about our users when they use our Services, including taking certain actions within it.
- When users register an account on our website.
- When you correspond with us by electronic means.
- When you sign up to receive our newsletter and other marketing material.
- When users submit their data to us.
- When users submit their featured stories to us to be published on our website.
- From third parties, such as social media plugins and third-party cookies.
4 Legal basis and purposes
In short, we use the personal data we collect to provide, analyse and improve our Services. To increase the security of our Services and to give you the best possible experience on Witty Works.
We at Witty Works are constantly working to provide you with the best possible experience of our Services.
To achieve this goal, we use personal data…
Contract: To perform our contractual obligations or take steps linked to a contract with you. In particular:
- To provide and protect our Services.
- To administer, manage and develop our business and Services.
- To recruit.
Consent: We may rely on your freely given consent at the time you provided your personal data. In particular:
- To provide users with news, special offers, newsletters, and general information about goods and services which we offer (requires explicit consent).
Legitimate interests: We may rely on legitimate and/or vital interests based on our evaluation that the processing is fair and reasonable. In particular:
- To maintain and improve our Services.
- To develop new services.
Public interest: To meet regulatory and public interest obligations. In particular:
- To comply with applicable regulations and legislation.
5 Data retention
We retain personal data for so long as it is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements.
6 Data transfers
We and/or the Service Providers referred to in Section 5 may process your personal data may be transferred and thus processed:
- In Switzerland
- In the EU & EEA
- In the USA
We safeguard your personal data per our contractual obligations and applicable data protection legislation when transferring data abroad.
Such safeguards may include:
- the transfer to countries that have been deemed to provide an adequate level of protection according to lists of countries published by the Federal Data Protection and Information Commissioner;
- applying standard data protection model clauses, binding corporate rules or other standard contractual obligations that provide appropriate data protection.
7 Data disclosure
We may disclose your personal data in the good faith belief that such action is necessary:
- To comply with a legal obligation (i.e., if required by law or in response to valid requests by public authorities, such as a court or government agency);
- To protect the security of the Services and defend our rights or property;
- To prevent or investigate possible wrongdoing in connection with us;
- To defend ourselves against legal liability.
8 Data security
We take reasonable technical and organisational security measures that we deem appropriate to protect your stored data against manipulation, loss, or unauthorised third-party access. Our security measures are continually adapted to technological developments.
We also take internal data privacy very seriously. Our employees and the Service Providers that we retain are required to maintain secrecy and comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate.
The security of your personal data is important to us but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We recommend using antivirus software, a firewall, and other similar software to safeguard your system.
9 Your rights
You have the below data protection rights. Please note that we may ask you to verify your identity before responding to such requests.
- Right of access: You have a right to request a copy of your personal data, which we will provide to you in an electronic form.
- Right to amendment: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Right to withdraw consent: If you have provided your consent to the processing of your personal data, you have the right to withdraw your consent. This includes cases where you wish to opt-out from marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you initially consented unless there is another legal basis for processing. To stop receiving emails from us, please click on the 'unsubscribe' link in the email you received.
- Right to erasure: You have the right to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected or when it was unlawfully processed.
- Right to restriction of processing: You have the right to request the restriction of our processing of your personal data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it.
- Right to portability: You have the right to request that we transmit your personal data to another data controller in a standard format such as Excel, where this is data which you have provided to us and where we are processing it on the legal basis of your consent or to perform our contractual obligations.
- Right to object to processing: Where the legal basis for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have a compelling legal basis for the processing which overrides your interests or if we need to continue to process the personal data for the exercise or defence of a legal claim.
- Right to lodge a complaint with a supervisory authority: You have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch/edoeb/en/home.html).
Exercise these rights by emailing to firstname.lastname@example.org or by contacting our EU representative (art. 27 GDPR): Witty Works Deutschland GmbH, Schwalbacher Str 6B, 12161 Berlin Germany.
10 Links to third-party apps and sites
Our Services may contain links to websites or apps that we do not operate. If you click a third-party link, you will be directed to that third party's site or app. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Cookies are files with a small amount of data that are commonly used as a unique anonymous identifier. These are sent to your browser from the website you visit and stored on your computer's hard drive.
Our site uses these cookies to collect information and to improve our Services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Services.
For immediate help in a serious case of urgency, please call us at: +41 44 291 00 22.