Privacy Notice
Privacy notice for the use of the website, last updated 11 December 2023

General information
The purpose of this privacy notice (the “Notice“) is to inform you of the type of personal data we collect through the website (the “Website“), and the online registration platform for “Сlear your mind” free online challenge. The way we process such personal data and how we ensure their safety.
By navigating on the Website or being registered to challenge by a third party, you are deemed to have read and approved this Notice. If you disagree with the Notice, please do not use this Website and do not provide your personal data through the Website.
Please note however that we decline any responsibility for the collection and processing of your personal data by third parties’ websites that this Website may refer to (links) and we therefore invite you to read the corresponding privacy policies when visiting these third party websites. The use of such websites is at your own risk.
The present Notice is subject to change and the latest version is published on the Website and the Portal. Continued use of the Website after a change in the Notice indicates your acknowledgement and acceptance of the processing of your personal data in accordance with the amended Notice.
The services provided on this Website are not intended for individuals below the age of 18. If you are under 18, please do not provide your personal data on this Website.

1. Who collects/processes your Personal Data?
BGS Promotion Sàrl, brands, goods and services promotion Swiss company at rue de la Fontaine 7, 1204 Geneva (“BGS” or “we”) determines the purposes and means of the processing of your Personal Data (as defined below) in the context of the Website as such, acts as data controller.

2. What Personal Data do we collect?
(i) Personal data is all information relating to an identified or identifiable person.
When you navigate on our Website or request our services, we may collect in particular:
a. Information obtained through the use of cookies and other trackers (as described under section 6 below), in particular:
– Your navigation and the frequentation of the Website’s pages;
-Limited personal data connected with your use of the Website, i.e. IP address, browser type, operating systems, websites you visit before and after our Website.
b. What data do we collect using the registration form:
– The application form to register on this Website: first name, last name, email, phone number and job title.
(ii). The above-mentioned information collected as part of your use of the Website, the Portal or your participation in an event is hereafter referred to as “Personal Data“.
We never ask for sensitive data (i.e., personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, genetic data, data concerning your sexual orientation or data relating to criminal convictions and offenses) unless it is required by law. If we need to process sensitive data for other purposes, we will inform you and obtain your explicit prior consent.

3. Why and on which basis do we collect your Personal Data?
We collect your Personal Data:
(i) To perform a contract entered into with you or to take steps at your request before entering into a contract, in particular in order to:
– Answer your queries promptly and efficiently via the contact email address provided on our Website;
– Provide services you requested (e.g., registration to an event we organize.
– Communicate with you with respect to your registration to an event “Сlear your mind” free online challenge including in particular information regarding the organization of the event, a change in the venue or the date.
– Send administrative information, such as change of our terms, conditions and policies.
(ii) To fulfill our legitimate interest, in particular in order to:
– Establish statistics on the Website’s frequentation in order to improve its functioning;
– Establish statistics on registration and participation to our events;Ensure the Website’s security and maintenance (in order to reach this purpose, we use statistical data as far as possible);
– Provide you with information in relation to our services when you registered on the Website;
(iii) To comply with our legal and regulatory obligations;
(iv) Based on your consent for specific processing, such as:
– Providing you regular news and updates about events or activities related to the “Сlear your mind” free online challenge.
If we need to carry out further processing for purposes other than those mentioned above, we will inform you and, where necessary, obtain your consent.

4. With whom do we share your Personal Data?
We may share your Personal Data with third parties in connection with the services we are providing to you (including your registration and attendance to an event) or the functioning of the Website. The recipients of any such information will depend on the services that are being provided. In particular, we may disclose your Personal Data to:
– IT, storage or platform services providers, including to administer the Website;
– Service providers which perform services on our behalf, including marketing, communication or event planning services; Other partners as part of the provision of our services and planification of our events (e.g., our partners and sponsors as part of the organization of our events);
– Local authorities to the extent deemed necessary, in particular for sanitary or security reasons or as required by mandatory laws and regulations;
– Any other person agreed with you.

5. Are your Personal Data transferred outside of Switzerland?
In the circumstances mentioned in Section 4 above, we may transfer your Personal Data to jurisdictions that: (i) ensure an adequate level of data protection for the rights and freedoms of data subjects (e.g., in Portugal, to a service provider in charge of the operation of the Portal; (ii) benefit from adequacy decisions as regards their level of data protection (e.g., adequacy decisions from the European Commission and the Swiss Federal Data Protection and Information Commissioner); or (iii) do not benefit from such adequacy decisions and do not offer an adequate level of data protection. In the latter case, we will ensure that appropriate safeguards are provided, e.g., by using standard contractual data protection clauses established by the European Commission and taking additional protective measures to the extent required.
To obtain details on the applicable safeguards, please contact us at the address provided under Section 9 below.

6. How do we secure your Personal Data?
We value the protection of your Personal Data. Any information we receive from you is handled with industry-standard security means and technologies in order to avoid incidents, such as loss, unauthorized access, improper use, destruction, disclosure or alteration. To all extent possible, all employees are made aware of their obligation to work in strict confidentiality when dealing/processing with your Personal Data.
If you think that the Website is not secure or that there has been unauthorized access to the Website, the Portal or your Personal Data, please contact us at the address provided under Section 9 below.

7. How long do we keep your Personal Data?
The conservation of your Personal Data will not exceed the period of time that is necessary to complete the purpose of its collection (see Section 3 above) and/or to provide the service you requested (which means for instance that, generally speaking, we will not keep your Personal Data after an event you attended, except with your consent), unless a longer period of conservation is required in order to comply with our legal obligations, to resolve disputes or to enforce our agreements.

8. What about your data protection rights?
Subject to the local data protection laws which apply to your situation and other applicable regulations, you have the following rights:
– You may access any Personal Data stored about you in our records and obtain a copy.
– If you consider that any of your Personal Data collected through this Website is incorrect, incomplete or confusing, you may request for the information to be completed or rectified.
– You may also ask us to erase your Personal Data under certain legal conditions (for instance if the Personal Data is no longer relevant with regards to the initial purpose of collection).
– You may object to the processing of your Personal Data, ask us to restrict the processing of your Personal Data or request portability of your Personal Data under certain legal conditions.
– If your consent was required at some point for the processing of your Personal Data, you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
– You have the right to file a complaint with a data protection authority about the collection and processing of your Personal Data by Astghik Switzerland, the competent data protection authority is:
Office of the Federal Data Protection and Information Commissioner FDPIC
Feldeggweg 1
CH – 3003 Berne
If you require further information, or if you wish to exercise the rights listed above, please contact us at the address provided under Section 9 below.

9. Any other questions about your data protection rights?
We take the protection of your Personal Data very seriously. In case of questions/concerns or complaints on this matter, please contact BGS Promotion Sàrl at:
BGS Promotion Sàrl
rue de la Fontaine 7
1204 Geneva

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