The General Data Protection Regulation(GDPR) is a European Union regulation that standardizes the rules for the processing of personal data by private companies and public bodies throughout the EU. This is intended to ensure the protection of personal data within the European Union on the one hand and to guarantee the free movement of data within the European Single Market on the other.
The regulation replaces Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data, which dates back to 1995.
Privacy policy
This privacy policy applies to Lubag AG
Should any contradictions arise between this data protection declaration and the otherwise applicable contractual or business terms and conditions of Lubag AG, the provisions of this data protection declaration shall take precedence.
Data protection is a matter of trust and your trust is important to us. We respect your personality and privacy. We also want to ensure that your personal data is protected and processed in accordance with the law.
It is important to us that you consent to the processing of your personal data. This privacy policy provides you with comprehensive information about our data processing methods. And you decide whether you want your personal data to be processed.
This privacy policy covers both historical and future personal data. If you consent to the processing of your personal data, we will not only process the personal data collected from you in the future in accordance with this privacy policy, but also your personal data already stored by us.
When we refer to the processing of your personal data in this privacy policy, we mean any handling of your personal data. These include, for example:
- The collection,
- Storage,
- Administration,
- Utilization,
- Transmission,
- Announcement or
- Deletion of your personal data.
We collect personal data in order to offer our customers better services. We are convinced that focusing our activities on the wishes and needs of our customers should make the tasks of everyday life easier for them. Better services can be:
- Optimization of our locations so that they are always close to you
- Alignment of the product range with customer needs
- Personalization of customer communication so that you find offers that match your wishes and receive less advertising overall
- Simplification of processes, such as purchases or bookings, so that you reach your destination faster
1. how do we protect your personal data?
We have technical and organizational security procedures in place to protect the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access. However, you should always be aware that the transmission of information via the Internet and other electronic means involves certain security risks and that we cannot guarantee the security of information transmitted in this way.
2. how long do we store data?
We will retain your personal data for as long as we deem necessary or appropriate to comply with applicable laws or as long as it is necessary for the purposes for which it was collected. We delete your personal data as soon as it is no longer required and in any case after the maximum retention period prescribed by law has expired.
3. what rights do you have with regard to your personal data?
You have the right to assert your data protection rights at any time and to obtain information about your stored personal data, to correct or supplement your personal data, to object to the processing of your personal data or to request the deletion of your personal data. You will find the contact details in section 4 below. In this context, we reserve the right to correspond with you electronically (in particular by e-mail).
4. how can you contact us?
If you wish to assert your rights in relation to your personal data or have questions or concerns regarding the processing of our personal data, you can contact us as follows: Information/contact information. We will endeavor to answer your questions or concerns as soon as we receive them.
5. who is the owner of the data collection?
We are legally obliged to inform you of the owner of the data collection containing your personal data. The owner of the data collection is Lubag AG.
6 When do we collect personal data?
We collect your personal data whenever we have contact with you. The situations in which we have contact with you are varied. For example, we collect your personal data in the following circumstances:
- You visit our stores or other premises;
- You purchase our goods or services in our stores or via our website;
- You take part in our courses, seminars or training sessions;
- You are using a service from our customer service department;
- You register a product or service purchased from us;
- You order and use one of our customer cards or loyalty cards;
- You receive a newsletter or other advertising about our goods and services;
- You are taking part in a competition or prize draw;
- You become a member of one of our customer loyalty programs;
- You take part in one of our market research campaigns or opinion polls;
- You use or communicate with us or third parties via our websites, apps for mobile devices or offers on internet platforms, multimedia portals or social networks;
- You communicate with us by telephone, fax, e-mail, voice messages, text messages (SMS), picture messages (MMS), video messages or instant messaging;
- Your cell phone connects to the WLAN provided by us in our branches;
- You come into contact with us at special occasions such as events, advertising events, sponsoring events or cultural and sporting events.
7 What personal data do we collect?
The personal data collected is just as diverse. On the one hand, we collect personal data that you make available to us. On the other hand, we collect personal data that is collected automatically or manually when you contact us, such as
Personal data
- Surname and first name;
- Birthday and age;
- Gender;
- Residential address;
- Household size;
- Shopping habits;
- Information on purchasing power;
- Customer and purchasing preferences;
- Delivery address;
- Billing address;
- Credit card and account information;
- Language preferences;
- Telephone number(s);
- E-mail address(es);
- Identification numbers of your technical devices;
- Customer and loyalty card numbers;
- Information on subscribed newsletters or other advertising;
- Consent to receive advertising;
- Online customer account information (including opening date, user names, profile pictures);
- Memberships within our business division;
- Photo and video recordings of visits to our stores or other premises.
Customer activity data
- Contract data (including contract date, contract type, contract content; contractual partner; contract term; contract value; claims asserted under the contract);
- Purchase information (including date of purchase; place of purchase; time of purchase; type, quantity and value of goods and services purchased; shopping cart; abandoned shopping cart; means of payment used; paying agent; purchase history);
- Customer service information (including returns of goods, complaints, warranty cases, delivery information);
- Session data relating to visits to our Internet pages, apps for mobile devices or offers on Internet platforms, multimedia portals or social networks (including duration and frequency of visits, language and country preferences, information about browser and computer operating system, Internet protocol addresses, search terms and search results; ratings given);
- location-based data when using mobile devices;
- Information on accumulated loyalty points for customer and loyalty cards;
- Communications via telephone, fax, e-mail, voice messages, text messages (SMS), picture messages (MMS), video messages or instant messaging;
8 Why do we process personal data?
We process your personal data for various purposes. These purposes can be summarized in different groups. In particular, we may process your personal data in whole or in part for one or more of the following purposes:
8.1 Processing purposes in connection with our range of goods and services
- Provision and sale of our goods and services;
- Processing of orders and contracts, including dispatch of order and dispatch confirmations, delivery confirmations, delivery and invoicing;
- Organization and implementation of courses, seminars or training sessions;
- Organization and implementation of customer services;
- Organization and implementation of loyalty card programs;
- Organization and implementation of market research and opinion polls;
- Verification of customer creditworthiness.
8.2 Processing purposes in connection with customer communication
- Provision, administration and implementation of customer communication by post and via electronic means of communication;
- business communication by post and by telephone, fax, e-mail, voice messages, text messages (SMS), picture messages (MMS), video messages or instant messaging;
- Evaluation of the use of our offers via telephone, fax, e-mail, voice messages, text messages (SMS), picture messages (MMS) or instant messaging such as: Type of use, frequency and duration of use, exact location of use.
8.3 Processing purposes in connection with special activities and events
- Organization and implementation of competitions or prize draws, including notification and publication of the winners via our Internet pages, apps for mobile devices or our offers on Internet platforms, multimedia portals or social networks;
- Organization and implementation of special occasions such as events, advertising events, sponsoring events, cultural and sporting events.
8.4 Processing purposes in connection with the analysis of customer behavior
- Optimization of the locations and product range in our stores. This is done through individualized and personal, but also anonymous and group-related recording and evaluation of historical and current customer and purchasing behavior in our stores or other premises – including the creation and analysis of location data, movement profiles and shopping basket analysis;
- Individualized and personal or anonymous and group-related recording and evaluation of historical and current customer and purchasing behavior when using the offers on our Internet pages, apps for mobile devices or on Internet platforms, multimedia portals or social networks;
- Individualized and person-related or anonymous and group-related identification, classification and analysis of current and potential customer needs and interests;
- Individualized and person-related or anonymous and group-related classification and analysis of customer behaviour and customer potential;
- Statistical evaluation of customer behavior on the basis of anonymized customer data;
- Linking the new personal data collected about you with the personal data already collected by us or other Migros Group companies in the past;
- Linking the personal data we collect about you with the personal data collected about you by other Migros Group companies (including as part of bonus programs) or with publicly available data and data acquired from third parties outside the Migros Group in order to improve our database and analyze customer behavior. The enrichment of profiles with third-party data includes, for example: Data from the Federal Statistical Office, calendar data or geodata.
8.5 Processing purposes in connection with direct marketing
- Simplification of processes – such as purchases or bookings – and use of findings from the analysis of customer behavior for the continuous improvement of all goods and services offered;
- Avoidance of unnecessary advertising through insights from the analysis of customer behaviour for individualized and personalized direct marketing;
- Sending individualized and personalized advertising by post or by telephone, fax, e-mail, voice messages, text messages (SMS), picture messages (MMS), video messages or instant messaging;
- Individualized and personalized adaptation of offers and advertising on our websites, apps for mobile devices or on our channels on internet platforms, multimedia portals or social networks.
9. to whom do we pass on your personal data?
We may pass on your personal data to other companies/partners of Lubag AG for the purposes stated in this data protection declaration. The companies/partners of Lubag AG may process your personal data in particular for individualized and personalized analyses of customer behavior and for direct marketing activities in their own interest. Within the company, employees only have access to your personal data insofar as this is necessary for the performance of their work.
We may also disclose your personal data to other partners of Lubag AG or to third parties outside the company Lubag AG in order to use technical or organizational services that we require for the fulfilment of the aforementioned purposes or our other business activities. Our service providers are contractually obliged to process personal data exclusively on our behalf and in accordance with our instructions. We also oblige our service providers to comply with technical and organizational measures that ensure the protection of personal data. If the service providers are located in countries in which the applicable laws do not provide for a level of protection of personal data comparable to Swiss law, we will contractually ensure that the service providers concerned comply with the Swiss level of data protection.
We may also disclose your personal data if we believe it is necessary to comply with applicable laws and regulations, in legal proceedings, at the request of the competent courts and authorities or due to other legal obligations in order to protect and defend our rights or property.
10 How do we use cookies?
We also use so-called cookies on our Internet pages. These are small files that are stored on your computer or mobile device when you use one of our websites. We would also like to provide you with comprehensive information about our use of cookies.
10.1 Why do we use cookies?
The cookies we use initially serve to ensure the functions of our website – such as the shopping cart functionality. In addition, we use cookies to customize our website to your wishes and to make your surfing experience with us as comfortable as possible. We also use cookies to optimize our advertising. Cookies enable us to present you with advertisements and/or special goods and services that may be of particular interest to you based on your use of our website. Our aim is to make our website as attractive as possible for you and to present you with advertising that matches your areas of interest.
10.2 Which cookies do we use?
Most of the cookies we use are automatically deleted from your computer or mobile device at the end of the browser session (so-called session cookies). For example, we use session cookies to save your country and language preferences and your shopping cart across different pages of an Internet session.
We also use temporary and permanent cookies. These remain stored on your computer or mobile device after the end of the browser session. When you visit one of our Internet pages again, it will automatically recognize which entries and settings you prefer. Depending on the type of cookie, these temporary or permanent cookies remain stored on your computer or mobile device for between one month and ten years and are automatically deactivated after the programmed time has expired. They serve to make our Internet pages more user-friendly, effective and secure. Thanks to these cookies, for example, you will be shown information on the site that is specifically tailored to your interests.
The cookies stored on your computer or mobile device may also originate from partner companies. These may be other Lubag AG companies or companies outside Lubag AG. These cookies enable our partner companies to target you with advertising that may actually be of interest to you. The cookies of the partner companies remain stored on your computer or mobile device for between one month and ten years and are automatically deactivated after the programmed time has expired.
10.3 What data is stored in the cookies?
No personal data is stored in the cookies we use. The cookies we use cannot be assigned to a specific person. When a cookie is activated, it is assigned an identification number.
10.4 How can you prevent the storage of cookies?
Most Internet browsers accept cookies automatically. However, you can instruct your browser not to accept cookies or to prompt you before accepting a cookie from a website you visit. You can also delete cookies on your computer or mobile device by using the corresponding function of your browser. If you decide not to accept our cookies or the cookies of our partner companies, you will not see certain information on our Internet pages and will not be able to use some functions that are intended to improve your visit.
11 How do we use log files?
Every time you access our website, certain usage data is transmitted to us by your Internet browser for technical reasons and stored in log files. This involves the following usage data: Date and time of access to our website; name of the website accessed; IP address of your computer or mobile device; address of the website from which you came to our website; amount of data transferred, as well as the name and version of your browser.
The analysis of the log files helps us to further improve our Internet services and make them more user-friendly, to find and rectify errors more quickly and to manage server capacities. Based on the log files, we can determine, for example, at what time the use of our Internet offers is particularly popular and provide the corresponding data volume to ensure the best possible use for you.
12. how do we use web analysis tools?
In order to constantly improve and optimize our website, we use so-called tracking technologies. Web analysis tools provide us with statistics and graphics that give us information about the use of our Internet pages. Data about the use of a website is transmitted to the server used for this purpose. Depending on the provider of a web analysis tool, these servers may be located abroad. For the most frequently used web analysis tool, Google Analytics, this data is transmitted including abbreviated IP addresses, which prevents the identification of individual devices. Google complies with the data protection provisions of the “Swiss-U.S. Privacy Shield” agreement and has registered with the U.S. Department of Commerce for the “Swiss-U.S. Privacy Shield” (information on the Swiss-U.S. Privacy Shield can be found at https://www.privacyshield.gov/Swiss-US-Privacy-Shield-FAQs). The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. A transfer of this data by Google to third parties only takes place due to legal regulations or in the context of order data processing.
If other web analysis tools are used within Lubag AG, the data collection process is basically the same.
You can prevent the collection of data generated by cookies and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link(http://tools.google.com/dlpage/gaoptout). You can find more information on Google Analytics and data protection at http://tools.google.com/dlpage/gaoptout or http://www.google.com/intl/de/analytics/privacyoverview.html.
13 How do we use social plugins?
Our websites use social plugins, e.g. from Facebook, Twitter or Google+. The plugins are marked with the provider’s logo and can be, for example, “Like” buttons or a Twitter button or Google+ button.
When you access our Internet pages that contain such a plugin, your browser establishes a direct connection with the provider’s computers. The content of the plugin is transmitted directly to your browser by the offering site and integrated into the website. By integrating the plugins, the provider receives the information that you have accessed our website. If you are logged in to the provider at the same time, the provider can assign the visit to your profile. If you interact with the plugins – for example, by clicking the “Like” button or leaving a comment – the corresponding information is transmitted directly from your browser to the provider and stored there.
If you do not want the provider to collect data about you via our website, you must log out from the provider before visiting our website. Even when you are logged out, the providers collect anonymized data via the social plugins and set you a cookie. This data can be assigned to your profile if you log in to the provider at a later time.
If a login is offered via a social login service – e.g. Facebook Connect – data is exchanged between the provider and our website. With Facebook Connect, for example, this can be data from your public Facebook profile. By using such login services, you consent to the transfer of data.
The purpose and scope of the data collection and the further processing of your data by the provider as well as your rights in this regard and setting options to protect your privacy can be found in the provider’s data protection information.
- Facebook Ireland Ltd. or Facebook Inc.: http://de-de.facebook.com/policy.php
- Google Inc.: http://www.google.de/intl/de/privacy/plusone/
- Twitter Inc.: http://twitter.com/privacy
If you do not want the providers to collect data about you via these cookies, you can select the “Block third-party cookies” function in your browser settings. Then the browser does not send cookies to the server for embedded content from other providers. With this setting, other functions of our website may no longer work.
Date 23.05.2018
Version 1.1
