This bookaclass privacy policy, informs you how we, whether you use our websites and mobile applications (hereafter also "digital offers" or "portals")) or in any other way. With regard to these portals, we are responsible for the processing of your personal data and the compatibility of the processing of data with the applicable law. In this way, we comply with the current rules on the protection of personal data.

"personal data" means any element relating to the personal or material circumstances of an identified or identifiable natural person. This means that this is information that can be attributed personally to you and can say something about you. In these data protection provisions, the term "your data" is also used for this purpose. "Processing" means any processing of your data, in particular the collection, storage, administration, use, transmission, disclosure or deletion of your data.

Please note that the following versions can sometimes be modified. It is therefore recommended that you consult this data protection statement on a regular basis. Third-party websites that can be accessed through our portals are not subject to the principles set out here. We take no responsibility for compliance with data protection by third-party websites.

Below we inform you about what personal data we collect and store when you use our portals and how we use this data, as well as to whom we can transmit this data if necessary. You also receive information about your rights to us in connection with the use of your data:

Scope and purpose of the processing of personal data

a. when you visit our portals

If you use our digital offers without further guidance from you, the web server technology we use automatically records the general technical information of visiting in the so-called log files. This includes, among other things, the IP address of the device used from which the visit was made, information on the type of browser, the Internet service provider and the operating system used, on which digital offers were downloaded from our site, the reference/exit pages, the time and duration of the visit.

This data is collected and processed to allow the use of our websites (establish a connection), ensure and increase the security and stability of our systems and offers, analyze the use of our offers and services, collect general demographic information and allow the optimization of our website (in particular, but not exclusively, product improvements, marketing measures, specific advertising for target groups, etc.), as well as for internal statistical purposes. The user is not identified. Similarly, no link is established between this automatically collected information and the personal data we store. However, there may be an exception to this basic rule if you already have a registered user account on one of our portals. With regard to the processing of the personal data of registered users you will find further detailed information in the following sections 1.b and 1.c.

If you send a message to third parties (e.g. a publisher) through a corresponding function of our portal, this message can be stored by us. You can also get free services on our portal. All personal data (e-mail address, telephone number, etc.) that you provide to us when you use a free service or by sending a possible message can be used by us,for example, for marketing and analysis purposes. More detailed information on the processing of personal data for marketing and analysis purposes can be found in paragraph 4 below.

The information you publish on our portal may be published by us on other platforms and other media (such as newspapers), if necessary in different forms.

In addition, on our portals we use cookies and analysis tools (e.g. Google Analytics). Please refer to paragraph 9 and paragraph 10 of these data protection provisions.

b. when you register a user account

For personalized services or restricted areas, or to process requests and manage subscriptions, you may be required to register and create a user account. This requires the entry of some personal data. This applies, for example:

● Your email address, which can also be used as a username

● Password

and, depending on the context, further information, where appropriate, such as:

● First and last name

● Address (full postal address, zip code, city)

● phone number

● Date of birth

● Sex

● Information about subscribed newsletters or other forms of advertising;

● language preferences

In addition to the information marked as mandatory for the use of a specific digital offer, the user may voluntarily enter and store additional personal data.

We use the data to process and manage our digital offers, to verify the plausibility of the data entered, or to substantiate, structure the content, process and modify the contractual relationships concluded with you regarding your user account and, in the case of paid services, to correctly issue invoices.

If you post contributions (comments, photos, videos, etc.) to be shared with other users using the appropriate functions of our portals, these can be published by us and therefore made accessible to the general public. This also applies to your username or any other nickname you have chosen for this purpose. We would like to point out that such data, once published on the Internet, can continue to be recovered by third parties, for example through search engines, even in the event of deletion or anonymization initiated by you or us.

By confirming that you have completed the registration process for collecting and modifying the data of your user account, you guarantee the correctness of the content of the data entered.

c. when you use a portal as a registered user

During the use of the portal by registered users, we collect data for statistical reasons in order to allow the good functioning of the portal and for the analysis, optimization and customization of the use of our offers and services. We collect data on how you use our digital offerings, in particular what functions and advertisements you use and how. Further information on the processing of this personal data can be found in paragraph 1.d and the following paragraph 4.

If you use our portal as a registered user, the statistical data may be visible to other registered users and registered and evaluated by us.

d. in case of purchase of a paid service

If you buy a product on our site, or purchase a paid service, specifying data such as first and last name, address (full postal address, ZIP code, city) and any other data is mandatory, because we need it for the elaboration of the contract with you. If you choose an online payment option such as credit card or PayPal to purchase a paid product or service, payment is made through the respective provider's online payment system. In this case, the processing of personal and payment data takes place directly through the provider of the respective payment system. We do not know and do not store your payment details. The data protection rules of the respective provider of the online payment system apply in this case.

If you are registered and have a user account, we may store your data in your user account for the next purchase/conclusion of the contract.

In any case, we retain all information about your current and past purchases and contracts, i.e. products, services, number of products and services per purchase, amount of payment. We have the right to use this information for marketing and analysis purposes.

Further information for marketing and analysis can be found in paragraph 4 below.

e. in case of participation in lotteries, competitions (events)

We use the information you provide to organize and conduct events and to notify and/or publish winners on our portals, through direct notification or on social networks. If you have authorized us to do so, we may use your data in accordance with paragraphs 2 and 4 and also transmit it in accordance with paragraph 3.

f. for user surveys and market research

We use the data you provide solely to improve the user experience and further develop our products. The results consist exclusively of aggregated and anonymous data. If you have consented, you can also be contacted by other affiliates (see here for a full list of all these companies), for example to participate in surveys of other users.

Direct marketing and online advertising

With your registration or visit as a guest on our site, we may also use your personal data for personalized advertising measures. This concerns both the personalization of advertising by e-mail, such as emails with a general information or advertising character (newsletter), by telephone, mail, fax, text messages, images and instant messaging services, as well as the provision of personalized content and advertising on our portals. For this purpose, we may automatically evaluate known information about your usage behavior on our portals in order to prevent you from receiving inappropriate advertising. These operations are described in paragraph 4.

When you register for a user account, registration also happens automatically for one of our newsletters and your email address can also be used for our advertising purposes until you delete from the corresponding newsletter. At the end of each email sent there is a link to delete from the newsletter at any time.

You can also cancel your newsletter subscription at any time by sending an email to customersupport@bookaclass.net. You can unsubscribe at any time.

We are authorized to entrust to third parties the technical processing of advertising and advertising measures for ourselves and we are authorized to transmit your data for this purpose (see paragraph 3 below).

Communication of data to third parties

We work with other companies or individuals and commission other companies or individuals to process and store data. They may have access to your personal data or usage data, but only to the extent necessary to perform their functions.

We may use and transmit the information collected from you and data about you or your user account collected as part of our usage measurements referred to in the point for evaluation, improvement and design based on the needs of our services, for customer support, for customization and for marketing purposes.

In addition, we transmit your data to third parties to the extent that this is necessary for the execution of the contract. For this purpose, we may transmit the necessary data to transport companies, banks and other service providers. These service providers use your data solely for order processing and not for further purposes. To the extent that this is necessary for the purposes referred to in the previous period, the transfer may also be made abroad, for example to allow the delivery of the goods. For more information on transfers abroad, see paragraph 5.

The personal data you provide to us will not be sold, rented or marketed by us.

Without prejudice to the information described above, we will disclose your personal data only if you have expressly consented, if there is a legal obligation to do so or if this is necessary to assert our rights, in particular to assert the rights deriving from the contractual relationship.

In the event of the sale, merger or other reorganization of some or all of our company's assets, personal data may be transferred, sold or otherwise shared with third parties as part of such transaction or reorganization.

If we perform an advance service, for example in the case of an on-account purchase, we may obtain credit information from a credit agency based on mathematical-statistical procedures in order to safeguard our legitimate interests. For this purpose, we transmit the personal data necessary for the assessment of credit to a credit agency and use the information received on the statistical probability of non-payment to decide on the establishment, execution or termination of the contractual relationship. The solvency report may contain probability values (valuation values) calculated on the basis of scientifically recognised mathematical-statistical procedures and which include, among other things, the address data in their calculation. Their interests worthy of protection shall be taken into account in accordance with the provisions of the law.

Processing of personal data for marketing and analysis purposes

Bookaclass aims to continuously improve the digital offer offered to you and to make it more suitable for your needs and safer.

For this purpose, the historical and future data specific to the user at our disposal can be continuously linked through various analysis tools and the user's behavior can be analyzed, aggregated, pseudonymized and anonymized in all offers. To improve our database, we may use public data or third-party data. The results of using our services can be used and exploited by other participating companies as part of the user behavior analysis. This processing of data takes place mainly with pseudonymous or anonymized data. The processing is aimed in particular at sending personalized advertising pursuant to paragraph 2 or displaying on one of our portals and improving the security of our portals.

Transmission of personal data abroad

We are also authorized to transfer your personal data to third-party companies (contracted service providers) abroad, if this is appropriate for the data processing described in this data protection statement. These are obliged to the same extent that we ourselves are obliged to protect data. If the level of data protection in a country does not match that of Switzerland, we contractually guarantee that the protection of your personal data always corresponds to that of Switzerland. We guarantee this through one or more of the following measures:

● concluding EU standard clauses with contracted service providers, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

● for the existence of binding enterprise standards (BCRs) recognised by a European data protection authority among contracted service providers, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en

Right of access, rectification, cancellation or appeal

You have the right to assert your rights in the protection of personal data at any time and to ask about what personal data about you is processed by us. You can also have your personal data rectified, blocked or deleted at any time, subject to written communication and proof of identity at the following address:

customersupport@bookaclass.net

We reserve the right to correspondence with you in this context.

Please note that even after your request to block or delete your personal data, we will still have to retain a part of it as part of our legal or contractual obligations (e.g. for billing purposes) and in this case we will retain your personal data only to the extent necessary for this purpose. In addition, the deletion of your personal data may prevent you from receiving or using the services to which you have registered. In certain circumstances, you have the right to disclose your personal data to you or to third parties designated by you in a common format.

You may object at any time to the processing of your data for marketing and advertising purposes, in accordance with sections 2 and 4 by e-mail.

This objection does not completely exclude the collection of personal data. At the following link you can prevent us from collecting your usage data. The opposition simply excludes the possibility that the personal data collected cannot be processed anonymously for marketing purposes and that for this purpose they can be forwarded to other companies and analyzed by them. In order to completely exclude or at least reduce the collection of personal data, it is necessary to follow the steps referred to in paragraph 10 relating to the deactivation of cookies. As a result, you may no longer be able to continue receiving or using the purchased services. In addition, you have the right to lodge a complaint with the competent supervisory authority regarding the processing of data. You can do this by contacting the supervisory authority of your place of residence, workplace or alleged data breach.

Retention period of your personal data

Your data will only be stored for the time legally necessary or appropriate for the purpose for which it was processed. For analysis, we store your data until the analysis is complete. If we store the data on the basis of a contractual relationship with you, this data will be kept at least for the duration of the contractual relationship and for the entire limitation period of any claims by us or legal or contractual retention obligations.

Data security

We use appropriate technical and organizational security measures to protect your personal data stored with us from manipulations, deletions, alterations, accesses, disclosures or un intentional, illegal or unauthorized uses, as well as from partial or total losses. Our security measures are continuously adapted and improved in line with technological developments. We take no responsibility for data loss or for their knowledge and use by third parties.

If you register with us as a user, access to your user account is possible only after entering your personal password. You should always treat your payment and login information confidentially and close the browser window when you have finished communicating with us, especially if you share your computer with others.

We also take internal data protection very seriously. Our employees and the service companies we have appointed have been obliged by us to secrecy and to comply with data protection rules.

Cookie

Cookies help make your visit to our website easier, more enjoyable and more meaningful. Cookies are information files that your web browser automatically stores on your computer’s hard drive when you visit our website.

Cookies do not damage your computer's hard drive and do not transmit users’ personal data to us. We use cookies, for example, to track who has visited our portal and to determine how often certain pages or offers are visited, which parts of the portal are particularly popular and, in general, to determine how the portal is used. We use other cookies so that you can move freely within our portal and use its features, for example when accessing protected areas. Such cookies may also be necessary to use’shopping carts' or payment functions. Using cookies, you can also use the options or decisions you have selected as settings to make your visit to the portal more convenient. In general, the use of cookies serves to improve our services, to make them more effective and secure. However, cookies are also used to collect information in order to offer you advertisements that may be of interest to you. Most Internet browsers automatically accept cookies. However, you can configure your browser at any time so that no cookies are stored on your computer or a message always appears when you receive a new cookie.

In principle, our digital offers can also be used without accepting cookies, although individual features may be limited.

Tracking and analysis tools

In addition, the use of our digital offers is measured and evaluated through different technical systems, mainly from third-party providers such as Google Analytics. These measures may be anonymous or personal. It is possible that the collected data may be transmitted to third parties by us or by third-party suppliers of such technical systems for processing. The most frequently used analytics tool is Google Analytics, a service provided by Google Inc. In this way the collected data can be transmitted to a Google server in the United States, where IP addresses are anonymized through IP anonymization, so recognition is not possible. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data. The collection and processing of this data through Google Analytics can be countered by setting an exclusion cookie that prevents the future collection of your data when you visit this website:

http://tools.google.com/dlpage/gaoptout?hl=en

Location information

If you use our mobile applications with a mobile device (a list of all relevant mobile applications can be found here),), we can use GPS signal data to collect information about the location of your mobile device (latitude and longitude, horizontal accuracy).

We use location data to improve your user experience by viewing location-based online advertising and other location-based digital content (weather and news; viewing approximate user locations) on your mobile device through the mobile application or applications (see here for a list of all relevant mobile applications). If required by law, we will ask for your consent before collecting your location data for the applications mentioned.

In this regard, we may use the services of other companies within and outside Bookaclass ("contractual data controllers"). We ensure that the protection of your data is guaranteed throughout the processing process by selecting the persons responsible for processing orders and by means of appropriate contractual agreements.

Even after giving consent, you have the option to deactivate the collection, processing and forwarding of your location data at any time. If you don't want to receive location-based online advertising and content, you can deny access to your location or turn off location services in your mobile device settings at any time. To disable location services, follow the instructions of the device manufacturer:

- for Apple devices: https://support.apple.com/en-us/HT202074

- for Android devices: https://support.google.com/ads/answer/2662922?hl=en

Legal bases

We process your personal data only within the framework of the data processing principles and in the presence of a legal basis. This legal basis applies to the start-up and execution of our contract. If not, we are interested in continuously improving our offers, adapting them to your needs and showing you ads that may interest you. This is a necessity to further develop and finance our offers and to ensure the safety of our offers. We assume that our interests prevail. If you have consented to the processing of data, this is valid.

Contact persons

If you have any data protection questions on our website, would like to request information or request the deletion of your data, please contact our data protection law contact person by sending an email to customersupport@bookaclass.net

Our data protection officer's contact details are as follows:

Bookaclass

Data Protection Officer

Riva Paradiso 2

6900 Lugano

Updating and upgrading data protection legislation

Due to the development of our website or the implementation of new technologies,you may need to change this privacy policy. Registered users will be informed of any material changes to the data protection provisions by e-mail to the email address specified at the time of registration or by means of a corresponding note at an appropriate time after logging in to the user account.

You can also recall and print the applicable data protection rules on our website at any time.

The original privacy policy is in Italian. Translated versions serve only for better comprehensibility. In the event of a dispute, the Italian text prevails.

December 1st, 2020