Privacy and Data Protection Policy

1. Introduction

This privacy and data protection policy describes the rules applicable to information processed by Indigo Suisse SA, a limited company under Swiss law, with its registered office at rue de Genève 31, CH-1003 Lausanne, identification number CHE-376.721.926. (hereinafter referred to as the “Company”), in its capacity as data controller.

The use of the website https://ch.parkindigo.com/ (hereinafter the “Site”), requires the acceptance by the user (hereinafter the “User”) of this Privacy Policy and the cookie policy.

This Policy describes how we handle personal data collected by the Company. The User is invited to read this document carefully to know and understand our practices regarding the processing of the User’s personal data by the Company.

2. Person responsible for the processing

The data controller is Indigo Suisse Holding SA, rue de Genève 31, 1003 Lausanne, Switzerland.

Phone: +41 21 329 0616

Email : indigo.dpo.ch@group-indigo.com

The representative of the data controller in the European Union is: Ronan Pichard.

3. Glossary

Cookies: A cookie is a small text file containing information that is downloaded to the User’s computer or mobile device when he/she visits a website or mobile application; they are used to recognize the User’s terminal when he/she re-accesses a previously used website or application.

Personal Data: means any information relating to an identified or identifiable natural person.

Partners: Refers to the service providers and subcontractors involved in the implementation of the Service.

Social Networks: refers to the social networks on which we are present, namely: Twitter, Facebook, Instagram, LinkedIn.

Services: refers to the services marketed by the Company and available on the Site.

Site: shall designate the Internet site published by the Company and available at the following address: https://ch.parkindigo.com/

Terminal: refers to the hardware equipment (computer, smartphone, tablet, etc.) that you use to consult or view the Site.

4. Protection of your Personal Data

4.1 What Personal Information do we collect?

We may collect the following data about you:

4.1.1 Data that you voluntarily provide to us in connection with our Services

We collect the Personal Data that you voluntarily communicate to us via a contact form or a collection form on the Site, before or during the execution of the Services (for example the purchase of a subscription). This is the following data (the mandatory data of the form concerned are followed by an asterisk (*)):

• Full name (*)
• Company name (*)
• Email address (*)
• Postal address (*)
• Telephone (*)
• Registration of the vehicle used (*)
• Message to us

The compulsory or optional nature of the data you provide us with is also indicated at the time of collection by a mention or an asterisk (*).

4.1.2 Personal Data that we collect automatically when you use our Services and purchase services

We also collect and process the following Personal Data relating to the execution of the contract, the follow-up of the customer relationship, the transactions carried out and the payment of our invoices:

• Transaction number
• Type of service subscribed
• Price
• Place, date and time of purchase
• Terms of payment
• Unpaid balances (apparent in invoices)

4.1.3. Personal Data that we collect automatically when you use the Site

When you use our website, the servers of our service provider temporarily record each session in a log file. The following technical data is collected.

• IP address of the requesting computer
• Date and time of access
• Internet page that immediately preceded the connection and, if applicable, the keyword searched
• Name and URL of the accessed file
• Searches performed (schedule, general site search function, products, etc.)
• Operating system of your computer (provided by the user agent)
• Browser used (provided by the user agent)
• Type of device in case of access from a mobile phone
• Transfer protocol used

4.1.4 Personal Data that we automatically collect when using our car parks

Indigo processes personal data when a customer enters a car park and his or her number plate is read and associated with a parking ticket (hourly customers), or with a means of access (season ticket holders).

This processing optimizes the management of hourly customers by associating the license plate and the parking ticket (determination of the parking time, particularly in the event of lost or stolen ticket).

For subscribers, the combination of the license plate and the means of access (generally a badge) ensures contactless entry and exit. For this category of customers, the processing of personal data from the number plate is legally required for the execution of the rental contract and ensures access to our car parks in accordance with the conditions of use in force.

Data relating to number plates are kept for 24 hours and then anonymised in a short cycle (entry with exit) or for a maximum of 31 days in the case of a short cycle (entry without exit). Finally, subscriber data is kept for 6 months.

We would also like to inform you that all our car parks are under video surveillance for the protection of people and property.

4.2 Data provided to us by our Partners

We may receive Personal Information about you from our Partners.

4.3 Other frameworks for processing Personal Data

We also collect and process the necessary Personal Data:

• to carry out loyalty-building, canvassing, studies, surveys and promotional activities,
• the organisation and smooth running of games, lotteries and other commercial and promotional operations, such as the date of participation, the answers given and the nature of the prizes offered.

5. For what purposes is your Personal Information used?

Your Personal Data is collected and processed to enable you to access and use the Services.

It is also processed for the following purposes:

• the management of your requests to exercise your rights as described below;
• the execution of the Service and the management of the commercial relationship, customer service, etc;
• the management of your messages on our Site, as well as on our pages hosted on the Social Networks;
• the verification of transactions and more generally the fight against fraud;
• management of unpaid bills and litigation;
• the safety of people and the protection of property and facilities (e.g. vandalism) and the prosecution of abuses (e.g. parking without payment).
• the organization of contests, commercial lotteries or other promotional operations;
• the realization of studies, surveys of actions of development of customer loyalty, prospecting and sales promotion;
• the elaboration of statistics, analyses and marketing/commercial studies;
• the realization of operations of solicitations and commercial prospecting;
• the performance of technical operations on our databases (qualification, enrichment, deduplication, etc.).

6. What are the legal bases for processing Personal Data?

We process your Personal Data for the above purposes, as appropriate, on the following legal bases:

• The processing of Personal Data is necessary for the performance of a contract with you;
• You have given your consent to the processing of your Personal Data;
• The processing of Personal Data is necessary for the performance of a legal obligation; or
• We have a legitimate interest in processing the Personal Data we collect in order to achieve the purposes described in Section 5 above.

7. Storage of Personal Data

We only process and store your Personal Data for as long as the purpose of the processing in question makes it necessary or there is another legal basis (e.g. legal retention periods).

The Personal Data relating to the management of our contractual relationship will thus be kept for ten years from the end of the contract, which corresponds to the legal limitation period. In case of litigation, the data will be kept for the duration of the procedure.

Personal Data relating to prospects are kept for three years from the date of collection and your consent. At the end of this period, the Company may contact you again to find out if you wish to continue receiving commercial solicitations. Otherwise we will irreversibly delete or anonymize your Personal Data.

Your IP address will be kept for one year after your visit to the Site, after which it will be scrambled and your entire journey will become irreversibly anonymous.

Concerning the recordings of your telephone calls received or made, the calls we record are kept for three months from the time they occur.

The video surveillance recordings made in our car parks are kept for a maximum of 96 hours, provided that no harm is done to persons or property within this period.

8. Who are the recipients of your Personal Data?

We may share your Personal Information with the following persons and/or entities:

• Group employees.
• Duly authorized service providers and subcontractors (in particular technical service providers, payment services, analytical solutions). The Company may transfer temporarily and securely to service providers and subcontractors certain Personal Data that are necessary for the operation, animation, and maintenance of our Site, to ensure the sending of emails that you have chosen to receive, and/or the execution of the Services, the smooth running of your order, the realization of the service, and to conduct satisfaction surveys. When Personal Data is communicated to service providers and subcontractors, we ensure that they present sufficient guarantees as to the implementation of appropriate technical and organisational measures so that the processing meets the legal requirements and guarantees the protection of the rights of the persons concerned.
• The Company may transfer temporarily and securely to third parties certain Personal Data that are necessary for the operation, animation, maintenance of our Site, to ensure the sending of emails that you have chosen to receive, and / or the execution of the Services, the smooth running of your order, the realization of the service, and to conduct satisfaction surveys, etc..
• With your express prior consent, we may also transmit all or part of your Personal Data, in aggregate or not, to commercial partners, who may use it for their own purposes and in particular for commercial purposes and/or direct advertising.

If the User wishes to access the Site through a connection service provided by our business partners, their privacy policies are also enforceable against you. The Company has no control over the collection or processing of data by our business partners on their own site.

• In the event that the Company or all or part of its assets are acquired by a third party, the Personal Data in its possession will be transferred to the new owner.
• Finally, we may be legally obliged to disclose your Personal Data to the competent authorities. In particular, in the case of a legal dispute or an order from a public authority.

Personal Information is only provided for the purpose for which it was collected. Under no circumstances do we sell or rent your Personal Information to third parties for marketing purposes.

9. Transfer of your Personal Data abroad

As part of the performance of the Services, we may transfer some of your Personal Data to third parties, in a secure manner, for the purposes defined above, to companies located in countries outside Switzerland and/or the European Union. We undertake to implement all the appropriate guarantees for the security of such transfers.

Therefore, you are informed that for the above purposes, your Data may be transferred outside Switzerland and the European Union in the following manner:

We will only transfer your Personal Data outside of Switzerland or the EU if adequate data protection is provided.

In particular, we assure you that we take appropriate measures and safeguards to maintain a level of confidentiality and security of your Personal Data in the context of such transfers, by requiring in particular that all our subcontractors and service providers implement all appropriate technical and organisational measures, on an ongoing basis, in order to secure the Data processed and thus ensure an adequate level of protection.

10. Social networks

We have a presence on Social Networks, including our dedicated pages on LinkedIn, Instagram and Twitter.

We remind you that access to these Social Networks requires your acceptance of their contractual conditions including provisions relating to the Regulation on Personal Data for the processing carried out by them.

To learn more about the protection of your Personal Data when browsing these Social Networks, we invite you to consult their respective privacy policies, available at the links below:

• LinkedIn: http://fr.linkedin.com/legal/cookie-policy
• Instagram: https://help.instagram.com/519522125107875
• Twitter: https://twitter.com/privacy
• Facebook: https://www.facebook.com/ladefense.fr

11. Cookies

A cookie is a small text file containing information that is deposited on your Terminal when you visit a website or mobile application; they are used in particular to recognise your Terminal when it re-accesses a website or application you have already used. Cookies are often used to make sites work better or to improve their operation, as well as to provide us with certain technical information.

We use cookies to improve your online experience and to better understand how you use the Site. Cookies also allow us to better target ads that appear online to your interests.

Cookies may be stored on your Terminal for varying periods of time. Some cookies are “session cookies”, which means that they are only present while your browser is open. They are automatically deleted when you close your browser. Some cookies are “persistent cookies”, which means that they are retained when you close your browser. These cookies allow us to recognize your Terminal when you open your browser to browse our Site again.

11.1 What is the purpose of the Cookies on our Site?

11.1.1 The Cookies we issue

Subject to your settings, when you connect to our site, we may install various cookies on your terminal.

These are:

• “Necessary cookies”:
  they are essential to provide you with the Services available on our Sites and to use some of their features, in particular to access certain secure areas (Personal Account). Without these cookies, tools necessary to meet the needs of the Service (creation and access to Personal Account, registration of bank details) could not be provided.
• “Technical cookies”:
  these are used throughout your browsing experience to facilitate and execute certain functions. They allow us, for example, during the period of validity of the Cookie concerned, to memorise the answers given in a form, to recognise the browser of your Terminal, or even your preferences with regard to the language or the presentation of our Site.

The cookies we issue are used for the purposes described in this Policy, subject to the settings you make as a result of the browser settings you use when visiting our Site.

Your consent, concerning the cookies deposited via our Site, has a maximum life span of thirteen (14) months. Thus, at the end of the thirteen (14) months, we will ask for your consent again when you connect to our Site or Application. In addition, you have the possibility at any time to manage the cookies that we apply directly via the following link.

11.1.2 Cookies issued by our Partners

Due to third-party applications integrated into our Site, certain Cookies may be issued by our Partners allowing them, during the period of validity of their Cookies, to collect browsing information relating to the browsers consulting our Site.

These are:

• Web analytics cookies: These cookies are used to collect information about how you use our Site. We use this information to generate reports and to help us improve our Site, make it more user-friendly and ensure that it functions properly. These cookies collect information in an anonymous form about your activity on our Site, including the pages you visit and the web page that led you to our sites. These cookies are always set by our sites or third party domains.
• Third party or social network integration cookies: These cookies are used to integrate third party features on our Site. Cookies in this category may be set by third parties and include, but are not limited to, cookies set by social networks.

At any time you may prevent the collection of information about you via these third-party cookies by clicking on the corresponding links (see “Your choices regarding cookies” below).

The issuance and use of Cookies by these Partners is subject to their own privacy policies. We inform you of the purpose of the cookies we are aware of and how you can make choices about them.

11.2 Your choices regarding cookies

You may choose to accept or decline cookies. However, refusing cookies will not allow you to benefit from all the features of our Site.

You can set your cookie preferences using the cookie acceptance tool available on the Site “Managing your cookie preferences“, or by changing your browser settings so that our Site’s cookies cannot be placed on your Terminal. To do this, you must follow your browser’s instructions (generally accessible in the Help, Tools or Browser Edition sections):

• For Firefox
• For Internet Explorer
• For Google Chrome
• For Safari
• For Opera

Below you will find the list of cookies that we deposit on your device via our Site. Clicking on these links will take you to the Partners’ websites, their practices and the choices they offer you regarding cookies:

You can also access an online cookie management tool. This will allow you to manage the cookies placed on your electronic terminals. To do so, you can click on the following link.

12. Personal data of minors

The Services are intended for adult customers. Thus, the Company does not intend to collect Personal Data from minors under the age of 18.

However, if it should happen that, without our knowledge, such Personal Data has been collected and processed without obtaining the authorization of the holder of parental responsibility for the minor in question, we will take all necessary measures to delete such Personal Data as soon as possible.

If you are the holder of parental responsibility for a minor under the age of 16 and are aware that we have collected and processed data about them, you can contact us at: indigo.dpo.ch@group-indigo.com

13. What are your rights regarding your Personal Data?

13.1 Revocation of your consent to the processing of Personal Data

Some processing of Personal Data is only possible with your consent. You can revoke a previously granted consent at any time by sending us a simple e-mail. This revocation does not affect the legality of the data processing carried out up to the moment of revocation.

13.2 Access, rectification and deletion

In accordance with the applicable legal provisions, you have the right to know and have access to the data stored about you, its origin, recipient and purpose of processing at any time free of charge and, if necessary, to correct, block and delete it. However, we will only delete your personal data if we are not required to store it in whole or in part for commercial or legal purposes (e.g. to provide after-sales service for the services you have ordered or if we are required by law to keep copies of certain accounting documents).

If necessary, please send any request by post or e-mail, making sure that your identification is possible and unequivocal, to Ronan Pichard, Indigo Suisse Holding, rue de Genève 31- 1003 Lausanne.

13.3 Appeals to the supervisory authority

In the event of a data protection violation, you have the right to appeal to the Federal Data Protection Commissioner (http://www.edoeb.admin.ch).

14. Update of the Privacy Policy and Personal Data Protection

The Company may update this Privacy Policy at any time. We advise you to consult this page regularly to be aware of any changes or updates to our Privacy Policy.

15. Contact

For any question, comment or complaint aimed at improving our Privacy Policy, the User may contact the Company by mail Indigo Suisse – Rue de Genève 31 – 1003 Lausanne or by email indigo.dpo.ch@group-indigo.com:

Updated on 04/03/2024