PRIVACY POLICY

ASMALLWORLD AG of Löwenstrasse 40, 8001, Zürich, Switzerland is the data controller (“ASMALLWORLD” or “ASW” or “we”) and we take your privacy seriously.

If you have any questions about this policy, we can be reached by email at privacy@asw.com.

Alternatively, you can contact us at:

c/o ASMALLWORLD AG

Löwenstrasse 40

8001 Zurich

Switzerland

This privacy policy sets out the basis on which any personal data that we have collected about you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We review this privacy policy regularly. Occasionally we may need to make changes or additions to this privacy policy that may affect how we handle your data. We will post new versions of this privacy policy on our website at www.asmallworld.com (the “Site”), more specifically on our privacy policy page www.asmallworld.com/privacy-policy.

We may also notify you of changes to this privacy policy by email.

This privacy policy was last reviewed and updated on 23 March 2021.

WHAT INFORMATION WE COLLECT, MAY COLLECT, AND HOW WE COLLECT IT

When you apply for an ASMALLWORLD Membership, register as an ASMALLWORLD Member, register as a Basic Account Holder, or make a hotel booking on our Site, we will collect personal information from you, such as your name, email address, country of origin, location, occupation, education, photos, social media accounts and other data you upload or enter into your profile.

This personal data is entered by you during the application or registration process or shared by you through another social media service, in order to become a member of ASMALLWORLD, or apply for membership or use another ASMALLWORLD Service.

We do not store credit card information; this is handled by a third party who fully complies with the Payment Card Industry's Data Security Standard (PCI-DSS).

We may also collect data about your navigation of the Site on an aggregate basis, such as your Internet Protocol Address (“IP Address”), which is identified and logged automatically in our server log files whenever you navigate the Site, your Internet Service Provider (“ISP”), your login frequency, the pages you visited within the Site, and the Internet browser or device you are using while browsing the Site.

When you participate or redeem the Site’s member privileges, special offers, or complete forms for optional promotions, RSVP for events, or participate in contests, surveys, or beta testing, we may require you to submit personal information to the Site, our mobile apps or via email.

You may also voluntarily provide personal information when you send us an enquiry or raise a support request via email. When you contact us, we keep a record of your communication and may use third-party service providers (e-mail marketing providers such as Emarsys, or CRM systems such as Salesforce), to help solve any issues you might be facing in the future.

When you use ASMALLWORLD, you may share your location data with us to optimise your experience on the Site and Apps and inform other members of your upcoming travels. This data is voluntary and is shared with us and other members of the community and may be used to suggest other members to connect to you and you to connect to other members.

Surveys are periodically conducted to collect information to help us improve the Site, our Apps and Services. All information collected through surveys will remain voluntary and confidential, even if we use a third party to help us conduct the survey.

Any information you disclose in public areas of the Site and Apps may become public information. Please exercise caution when disclosing personal information in these areas. We are not responsible for any use by third parties of personal information disclosed by you in public areas of the Site.

In order to facilitate the fulfilment of privileges for Members, you may authorise ASMALLWORLD to provide private data relevant to privilege redemption to privilege partners in question. Your approval will be requested before such data is exchanged. Any such exchange only happens for the fulfilment of Member privileges.

COOKIES

The website www.ASMALLWORLD.com (hereinafter “Site”) uses cookies. We use cookies on the Site and other technologies to recognise you and uniquely identify your browser. This helps us to provide you with a good user experience when you use the Site and also allows us to improve the Site. By continuing to use the Site, you are agreeing to our use of cookies.

WHAT IS A COOKIE?

Cookies are text strings created by a server and stored on the hard disk of a computer or any other device used by the user to have access to the Internet (smartphone, tablet) before being retransmitted to subsequent access of the user to the internet.

Cookies are used to enable certain features (e.g., logging in), to track site usage (e.g., analytics), to store your user settings (e.g., time zone, notification preferences), and to personalise your content (e.g., advertising, language).

Cookies may be stored permanently on your device and have a variable duration (persistent cookies) or may disappear when the browser is closed or have a limited lifespan (session cookies).

Cookies can be installed by the Site you are visiting (first-party cookies) or may be installed by other websites (third-party cookies).

The Site uses first-party cookies, third-party cookies and other similar technologies, as further described below.

WHY WE COLLECT INFORMATION

Information collected may be used to provide and improve our products and service of the Site; for billing, identification and authentication purposes; to analyse the Site usage for statistical purposes; to manage and improve our products and the Site; to deliver administrative and informative notices and communications relevant to your use of our products and the Site; for internal market research; for troubleshooting problems; for detecting, protecting against and preventing fraudulent or other criminal activity; for distribution to third party contractors who provide services to us (such as our email server) who are bound by our privacy restrictions or restrictions at least as restrictive as those set forth in this policy; and to enforce our Terms of Service.

The features of the cookies used on the Site are described in the following table.

TYPES OF COOKIES AND HOW WE USE THEM

Tracking technologies also used are beacons, tags, pixels and scripts, to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

ESSENTIAL COOKIES

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.

PERFORMANCE COOKIES

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all Site users, to help us understand visitor usage patterns, identify and diagnose problems or errors that our users may encounter, and to make better strategic decisions in improving our audience’s overall website experience.

These cookies may be set by the Site you’re visiting (first-party) or by third-party services.

FUNCTIONALITY COOKIES

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, we can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you are visiting ‘us’ (first-party) or by a third-party service.

We use functionality cookies for selected features on our site.

TARGETING/ADVERTISING COOKIES

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests.

Websites may use targeting/advertising cookies to deliver targeted advertising or to limit the number of times you see an advertisement. This helps us improve the effectiveness of our campaigns and the quality of content presented to you.

These cookies may be set by the website you’re visiting ‘us’ (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service.

We use targeting/advertising cookies on our site.

THIRD-PARTY COOKIES ON OUR SITE

We may employ third-party companies and individuals on our websites—for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf.

They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you anonymously on other websites that use the same third-party service.

As we have no control over third-party cookies, they are not covered by ‘our’ ASMALLWORLD AG's cookie policy.

OUR THIRD-PARTY PRIVACY PROMISE

We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.

HOW YOU CAN CONTROL OR OPT OUT OF COOKIES

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.

WITH WHOM WE SHARE

We may disclose your personal information to any company within the ASMALLWORLD group, which means our subsidiaries, our ultimate holding company and its subsidiaries for outsourcing purposes (i.e. where such a member of our group provides services for and on our behalf).

When you submit information to ASW, it is collected, processed and maintained solely by us or by our third-party contractors, those third party contractors being bound by our privacy policy or by restrictions at least as restrictive as those set forth in this policy.

Partners may sponsor special member offers, promotions, privileges or contests that require you to disclose personal information to benefit from them. We will never disclose private member data, including email addresses, to partners without your prior express consent.

Certain partners may require members to opt-in or agree to terms on the partners’ landing pages authorising us to provide member information to the partner in question. We advise you always to check our partners’ privacy policies before submitting information about yourself.

We may disclose your personal information:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
  • to identify, contact or bring legal action against you if you are violating our Terms of Service or other rules or if we believe you are causing injury or interference with the rights of members, the general public or ASW;
  • if we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be some of the transferred assets; and
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements or to protect our rights, property, or safety of our customers, or others.
  • In the event that you raise a payment dispute and your bank or credit card provider requests data supporting your transaction and use of the ASW Service.

OPTING IN OR OUT OF COMMUNICATIONS

By using the Site you are consenting to the terms of this privacy policy and you agree that ASW and its partners (if you have provided the respective partner with your email address or have consented to us giving your email address to the respective partner) may send you communications regarding goods, services, events and other information that may be of interest to you.

You may opt-out of receiving communications from us and/or our partners, and from participating in member surveys at any time by either following the simple unsubscribe process set out in each email, sending us an email at privacy@asw.com or going to your account settings and deselecting the relevant boxes.

You may opt in to receiving communications from us and/or our partners at any time by going to your account setting and selecting the relevant boxes or sending an email to privacy@asw.com.

Please be aware that on certain, rare occasions, we will send emails to communicate important corporate or member messages, like changes in our privacy policy or a receipt of your membership payment. These emails will not have an unsubscribe feature, as they are one-time only communications.

If you supply us with your postal address, you may receive mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please go to your account settings and deselect the relevant boxes or let us know by emailing us at privacy@asw.com.

To ensure removal from any lists, please provide us with your exact name, as it appears in your ASW profile, and address when communicating with us.

WHERE WE STORE/TRANSFER YOUR PERSONAL DATA

Our main servers for registered users and members are based in Switzerland. However, the data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area ("EEA") by us. It may also be processed on our behalf by staff operating outside Switzerland and the EEA who work for us or our suppliers, including but not limited to countries such as the United Kingdom and the United States of America.

By consenting to the collection and processing of your personal data, you agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy.

The transfer, storage or processing of personal information outside Switzerland and the EEA does not diminish your rights and we will take all reasonable steps necessary to ensure that any information that is transferred, stored or processed outside Switzerland and the EEA will be treated securely, in accordance with this privacy policy and with the same level of protection required by the Swiss Federal Act on Data Protection (“Swiss-Act”).

DATA RETENTION POLICY

ASW may retain information submitted by you following application, termination, or deactivation of your Membership, ensuring that you will benefit from communications, and to allow for reactivation of your Membership at a later point in time if you so choose.

If you de-register from all ASMALLWORLD Services, we may retain information submitted by you or collected from you, for such time as is reasonably necessary for backup, archival and/or auditing purposes, to prevent fraud or other criminal activity, or prevent violation of our Terms of Service and for such time as may be required by applicable laws.

We will remove personal information by deleting it from our database if required to do so by law. We will also delete personal information upon your request in line with the right to erasure (‘right to be forgotten’) according to Art. 17 GDPR and similar local and national regulations elsewhere.

According to Art. 16 GDPR (and similar local and national regulations elsewhere), following the right to rectification, we will also rectify inaccurate personal data concerning you id you so choose (For both, please submit your request via e-mail to privacy@asw.com).

We regularly review the way we collect, store and process information, including physical security measures, in order to protect our systems from any unauthorised access.

All of our services are fully encrypted using SSL, and access to any personal information is limited to ASMALLWORLD employees, contractors and agents, to the extent relevant to their job duties (such as processing certain information). Anyone with access to private data is bound by strict confidentiality obligations.

ACCESS TO INFORMATION

The Swiss-Act, GDPR and other local and national regulations give you the right to access personal data held about you. Your right of access can be exercised in accordance with these Acts, subject to any fees that ASW may be permitted to charge you under such Acts (send e-mail request to privacy@asw.com).

NOTIFICATION OF NEW USES

On occasion, we may use personal information for new, unanticipated uses not previously disclosed in this privacy and cookie policy. In such cases, we will notify you of the content and purposes of the change by email.

If you do not oppose such change in writing (by email to privacy@asw.com ) within ten (10) days of the date of the email, the changes will be deemed accepted by you. Any data collection changes will be effective from then on. We will not retroactively collect data for new collection procedures.

This policy became effective on 23 March 2021.