Notice: This privacy policy only applies to the website. If you are interested in the privacy policy of our app, please follow this link.

Introduction

At iTrain GmbH, we respect your privacy. We believe that the less we know about you, the better; that is why we aim to limit the information we collect to the minimum necessary. The purpose of this privacy policy (“Privacy Policy”) is to inform you in detail what personally identifiable information or personal information we collect from you when you use our application, how we use such information, and the choices you have regarding our use of, and your ability to review and correct, the information.

We reserve the right to change this policy, which we will do through online posting. We use your data solely to provide you with services in which you enroll.

For purposes of this Privacy Policy, the terms iTrain GmbH, “we,” “us” and “our” refer to the company iTrain GmbH; the terms “Application“, “Service” and “Product” refer to the iTrain software and related services; and “You” refers to you, as a user of the application as applicable.

Who We Are

iTrain GmbH is a Swiss company located in Seefeld 4/5, 8716 Schmerikon. We comply with the Swiss Federal Act on Data Protection (“FADP”) and the European General Data Protection Regulation (“GDPR”). The European Union acknowledges, that Switzerland has an adequate level of data protection.

Processing of Personal Data

We process personally identifiable information in compliance with Swiss law. Furthermore, if the GDPR is applicable, we process personal data in accordance with the following provisions:

  • Art. 6(1)(a) GDPR: You have given clear consent for us to process your personal data for a specific purpose.
  • Art. 6(1)(b) GDPR: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Art. 6(1)(c) GDPR: The processing is necessary for us to comply with the law (not including contractual obligations).
  • Art. 6(1)(d) GDPR: The processing is necessary to protect someone’s life.
  • Art. 6(1)(f) GDPR: The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or your fundamental rights and freedoms.

What Information We Collect and How We Use It

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). We collect solely information that is necessary to provide you with our services and to improve our product. Personally identifiable information may include, but is not limited to:

Cookies

We use cookies (a small text file sent by your computer each time you visit our site) or similar technologies to record data or to collect and store information when you visit this site. Many browsers default to accepting cookies. You may be able to change this setting in your browser, and you can also clear your cookies. Check your browser’s help function to learn more about your cookie setting options. – Legal basis Art. 6(1)(f) GDPR

We may use the following types of cookies:

  • Advertising and analytics
  • Essential cookies
  • Functionality cookies
  • Social Media cookies
  • Advertising cookies

Please see below for your choices on cookies in the use of advertising.

  • To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us.
  • We might also use a pixel tag, which is a small graphic file that allows us and third parties to monitor the use of the site and provide us with information based on your interaction with the site. These tags may collect the IP address from the device which you loaded the page, and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, and the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.
  • Other data technologies may be used that collect comparable information for security and fraud detection purposes.

Usage Data

We may collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. – Legal basis Art. 6(1)(f) GDPR

Analytics

We use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. – Legal basis Art. 6(1)(f) GDPR

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on or by clicking [ga-optout text=”here”]. Opting-Out prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

Email Newsletter Subscription (Optional)

To inform our users about new features and releases, we provide a newsletter for which you can subscribe with your email address.

We use MailChimp to manage our newsletter and other email lists. MailChimp provides us with data concerning your email activity, that is, the place, date and time where and when you open our messages, the device type you are using, and your interactions with our messages such as clicking a link. – Legal basis Art. 6(1)(a+f) GDPR

You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of the newsletter. If you don’t want us to track your email activity, you can click the preferences link at the end of the newsletter. It will take you to your newsletter preferences, where you can opt out from email activity tracking. You can also email privacy@itrain.ch to update or unsubscribe your email address, to request that we delete your email address, or that we stop tracking your email activity.

Where We Store Your Data

Usage Data and Device Information

The usage data and device information are stored on servers hosted by Hostfactory.

Analytics

Analytics data is stored on Google servers.

Email Newsletter Subscription (Optional)

Your email address and activities are stored on servers hosted by MailChimp.

Customer Support Emails

For customer support and email services, we use Hostfactory as email provider. This means that every email you send to us will be stored at Hostfactory.

How Long We Store Your Data

We store your data for as long as Swiss law requires, or as is necessary for the fulfillment or the initiation of a contract, or as long as we claim legitimate interests. After the expiration of that period, the corresponding data is routinely deleted or completely anonymized. Statistical and diagnostic data is generally never deleted.

Your Privacy Rights (Under GDPR)

  • Right to Access: You can request iTrain GmbH to provide you with information on how we collect, use, and store your personal information, and to provide you with a copy of your personal information we store. – Legal basis Art. 15 GDPR
  • Right of Rectification: You can request that we correct inaccurate information about you. – Legal basis Art. 16 GDPR
  • Right to Erasure: You can request that we delete information collected about you, given that we are not required by law to preserve it, that it is not necessary for contract fulfillment and that we can still identify your records. – Legal basis Art. 17 GDPR
  • Right to Data Portability: If requested, we will provide you all data under our control in common, machine-readable formats. If requested, we will provide you with instructions to obtain your data, in cases where we do not have direct access. – Legal basis Art. 20 GDPR
  • Right to Object: You can object to the processing of your information in certain cases, as well as request that iTrain GmbH does not use your personal information for direct marketing purposes. – Legal basis Art. 21 GDPR

Data Processors

Depending on the usage of our services your personal data might be processed by the following services:

MailChimp

Email marketing service provided by The Rocket Science Group LLC, USA.

Personal Data: Email Address
Country of Data Processing: USA

MailChimp complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland, respectively. MailChimp, including The Rocket Science Group LLC and its wholly-owned US subsidiaries, has certified that it adheres to the Privacy Shield Principles. Furthermore, MailChimp is committed to compliance with the General Data Protection Regulation. To learn more, check out their Privacy Statement.

Google Analytics

Web analytics service offered by Google LLC, USA, that tracks and reports website traffic.

Personal Data: Usage Data and Device Information
Country of Data Processing: USA

Google complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland, respectively. Google, including Google LLC and its wholly-owned US subsidiaries, has certified that it adheres to the Privacy Shield Principles. Furthermore, Google is committed to compliance with the General Data Protection Regulation. To learn more, check out their Privacy Statement.

Hostfactory

Hosting service provided by Hostfactory, Switzerland.

Personal Data: Usage Data and Device Information
Country of Data Processing: Switzerland

Check out their Privacy Policy.

Contact for Data Privacy

If you have any questions regarding your personal data as well as your privacy rights, please contact

iTrain GmbH
Seefeld 4/5
8716 Schmerikon
Switzerland

Email: privacy@itrain.ch

Contacting You

We may use your contact information to communicate with you about our product, diagnostic data and error reports, provide support, and send you other information such as product updates and announcements. You can opt out of news and announcements by unsubscribing from our newsletter.

Breach Notification

If the confidentiality of customer data is breached, we recognize our responsibility to our customers and to the public to disclose the nature of the risk and provide a transparent account of the events without undue delay. At a bare minimum, we must inform the applicable supervisory authorities as required by law and regulation. – Legal basis Art. 33 GDPR

Consent for Underage Enrollment

Those under the age of 16 may not use the services without the consent or authorization of their parent or legal custodian.