Privacy Policy
This data protection declaration provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name northlightholding.com. In particular, we provide information about what personal data we process, how and where we process it. We also provide information about the rights of individuals whose data we process.
We may publish additional data protection declarations or other information on data protection for individual or additional activities and operations.
The data protection officer responsible for data protection is:
NorthLight Holding
Dr. Sarwar Pedawi
Fortune Executive Tower 2402 JLT
Cluster T
Dubai, UAE
In individual cases, third parties may be responsible for the processing of personal data, or joint responsibility may exist with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.
2. Terms and legal basis
2.1 Terms
Data subject: Natural person whose personal data we process.
Sensitive personal data: Data relating to trade union, political, religious, or philosophical beliefs and activities, data concerning health, privacy,sphere or ethnic or racial origin, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or persecution, and data on social assistance measures.
Processing: Any handling of personal, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, changing, disseminating, linking, destroying, and using personal data. data.
We process personal data in accordance with Swiss law, in particular the Federal Data Protection Act (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. Type, scope, and purpose of processing personal data
We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the following categories: browser and device data, content data, communication data, meta data, usage data, master data including inventory and contact data, location data, transaction data, contract data, and other data.communication data, meta data, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, insofar as such processing is permissible.
We process personal data with the consent of the data subjects, where necessary. In many cases, we may process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also request consent from data subjects if their consent is not required. consent is not required. We process personal data for the period of time necessary for the respective purpose. We anonymize or delete personal data in particular in accordance with statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties are in particular specialized providers whose services we use.
We may disclose personaldata to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers. Communication
We process personal data in order to communicate with individuals, authorities, organizations, and companies. In doing so, we process in particular data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or using similar tools..
Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals independently. In particular, they must ensure that such data is accurate and may be transferred.
6. Data security
We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without however being able to guarantee absolute data security.
Access to our website and our other digital presence is provided via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn you before visiting a website without transport encryption.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the processing of personal data by secret services, police, agencies, and other security authorities. We also cannot rule out the possibility that a data subject may be subject to targeted surveillance.
We process personal data in principle in Switzerland. However, we may also disclose or export personal data to other countries, in particular for processing or to have it processed there.
We may transfer personal data to all countries on earth and elsewhere in the universe, provided that the law there complies with decision of the Swiss Federal Council ensures adequate data protection.
We may disclose personal data to countries whose laws do not guarantee adequate data protectionprovided that adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example if the data subjects have given their express consent or if there is a direct link to the conclusion or execution of a contract., such as the express consent of the persons concerned or a direct connection with the conclusion or execution of a contract. We will be happy to provide data subjects with information about any guarantees upon request or provide a copy of the guarantees.
8.1 Data protection claims
We grant data subjects all rights under applicable law. Data subjects have the following rights in particular:
- Information: Data subjects may request information about whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data. .
- Correction and restriction: Data subjects may correct inaccurate personal data, complete incomplete data, and have the processing of their data restricted. Data subjects may express their own point of view and request a review by a human being in the case of decisions that are based exclusively on automated processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions).
- Deletion and objection: Data subjects may have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict, or refuse the exercise of data subjects' rights within the scope permitted by law. We can inform data subjects of any prerequisites for exercising their data protection rights. For example, we can refuse to provide information on the grounds of confidentiality obligations, overriding interests, or the protection of other persons, either in whole or in part.or the protection of other persons. For example, we may also refuse to delete personal data, in particular with reference to legal retention obligations, in whole or in part. We may charge a fee for exercising these rights in exceptional cases. We will inform the persons concerned in advance of any costs that may be incurred.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal protection
Affected persons have the right to enforce their data protection claims through legal channels or to file a complaint with a data protection supervisory authority.
TheData protection supervisory authority for private controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).
9. Use of the website
9.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in your browser. Such stored data are not necessarily limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable, in particular, a browser to be recognized when you visit our website again and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing purposes. be used for online marketing. Cookies can be deactivated, restricted, or deleted in whole or in part at any time in your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may not be fully available. We request – at least to the extent required by applicable law – actively seek your express consent to the use of cookies.
For cookies used for success and reach measurement or for advertising, a general objection (“opt-out”) is available for numerous services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
9.2 Logging
We may log at least the following information for each access to our website and our other digital presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time, including time zone, IP address, access status (HTTP status code), Operating system including user interface and version, Browser including language and version, Individual subpages of our website accessed, including the amount of data transferred, last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in logThe information is necessary to ensure that our digital presence is permanent, user-friendly, and reliable. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
10. Notifications and communications
10.1 Consent and objection
You must always consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may use the consent obtained, including IP address and time stamp for evidence and security purposes.
You can generally object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical collection of usage data for the purpose of measuring success and reach. This does not apply to notifications and communications that are necessary in connection with our activities and operations.p>
10.2 Service providers for notifications and communications
We send notifications and communications with the help of specialized service providers.
We use the following in particular:
- Mailchimp: Communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); information on data protection: Data protection declaration (Intuit) including “Country and Region-Specific Terms,” ”Frequently asked questions about data protection at Mailchimp“ (”Mailchimp Privacy FAQs“), ”Mailchimp and European Data Transfers", “Security,” Cookie Policy, “Requests regarding data protection rights”, “Legal provisions”.
11. Third-party services
We use services provided by specialized third parties to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content into our website. When such embedding takes place, the services used collect, for technically compelling reasons, at least temporarily, the IP addresses of users for technical reasons.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to provide the respective service.
We use the following in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in part for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles,“, ”More information about how Google uses personal data,", Privacy Policy, “Google is committed to complying with applicable data protection laws”, “Data protection guidelines for Google products”, “How we use data from websites or apps that use our services”, “Types of cookies and similar technologies Google uses”, “Advertising you can control” (“Personalized advertising”).
12.1 Digital infrastructure
We use services from specialized third parties to provide the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
- Nine Internet Solutions: Managed cloud and container solutions; provider: Nine Internet Solutions AG (Switzerland); Information on data protection: Data protection declaration, “Our commitment to data protection”.
12.2 Map material
We use third-party services to embed maps in our website.
In particular, we use:
- Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific information: “How Google uses location information”.
13. Final notes on the data protection declaration
We have created this data protection declaration using the data[+] protection generator from Data[+] Protection[+] Partner
We may update this data protection declaration at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current data protection declaration on our website.