Privacy Policy
Article 1: Preamble
The purpose of this Privacy Policy is to inform users of the website:
- how their personal data is collected. Personal data refers to any information that can identify an individual user. This may include, but is not limited to, their first and last name, age, postal or email address, location, or IP address;
- the rights they have regarding their personal data;
- the person responsible for processing the personal data collected and processed;
- the recipients of such personal data;
- the website’s policy regarding cookies.
This Privacy Policy supplements the Legal Notice and the General Terms of Use, which are available to users at the following address: https://www.aspug.ch/politique-confidentialite
The processing of personal data is governed by the following principles:
- Personal data must be processed lawfully, fairly, and transparently in relation to the data subject.
- It must be collected for specified, explicit, and legitimate purposes (see Article 3.1 of this Policy) and not further processed in a manner that is incompatible with those purposes.
- It must be adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
- It must be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that inaccurate personal data, having regard to the purposes for which it is processed, is erased or rectified without delay.
- It must be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it is processed.
- It must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, through appropriate technical and organisational measures.
Processing is lawful only if, and to the extent that, at least one of the following conditions applies:
- the data subject has given consent to the processing of their personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the data controller is subject;
- processing is necessary to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
- processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data, particularly where the data subject is a child.
Article 3.1: Data Collected
The personal data collected as part of our activities includes:
- membership applications;
- registrations for training courses.
The collection and processing of this data serve the following purposes:
- displaying the “Our Members” page;
- managing the members’ area;
- issuing training certificates and invoices.
Article 3.2: How Data Is Collected
When you use our website, no personal data is collected automatically.
Personal data is collected only through forms completed by users. The data is stored by the data controller under appropriate security conditions.
Article 3.3: Data Hosting
The website aspug.ch is hosted by:
Infomaniak Network SA
Rue Eugène-Marziano 25
1227 Geneva
Switzerland
Article 3.4: Disclosure of Data to Third Parties
Personal data is not disclosed to third parties.
Article 4.1: Data Controller
Personal data is collected by ASPUG-PP, a professional association established under Articles 60 et seq. of the Swiss Civil Code, whose registered office is located at its General Secretariat.
The Data Controller can be contacted as follows:
- by email: secretariat@aspug.ch
Article 4.2: Data Protection Officer
The Association’s Data Protection Officer is the ASPUG-PP Committee.
If, after contacting us, you believe that your data protection rights have not been respected, you may submit a complaint to the Swiss Federal Data Protection and Information Commissioner (FDPIC).
Any user whose personal data is being processed may exercise their rights under the Swiss Federal Act on Data Protection (LPD).
Article 8 – Data Security (LPD)
1. Data controllers and processors must ensure an appropriate level of security for personal data by implementing suitable technical and organisational measures proportionate to the risks involved.
2. These measures must be designed to prevent any breach of data security.
3. The Federal Council establishes the minimum requirements for data security.
The publisher of the aspug.ch website reserves the right to amend this Privacy Policy at any time to ensure compliance with applicable legislation.
Any such amendments shall not affect actions carried out on the website prior to the changes, which remain governed by the Privacy Policy in force at the time of the relevant action and as accepted by the user.
Users are encouraged to review this Privacy Policy each time they use our services, without the need for formal notification of any updates.
This Privacy Policy, originally issued on 1 January 2024, was last updated on 13 March 2025.
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