Privacy Policy

PRIVACY POLICY FOR THE VOLTIMUM PLUS PROGRAMME

 

GENERAL

This privacy policy (“Privacy Policy”) informs you about how your personal data ("your data") is processed when you participate in the VOLTIMUM+ Programme, hereinafter “the Programme”. If you use special offers such as on the VOLTIMUM website, the data protection information provided there also applies. Any reference to “GDPR” in this Privacy Policy is a reference to the EU General Data Protection Regulation EU/ 2016/679. Any reference to “you” and “your” is a reference to the participant to the Programme. Any reference to “we” and “us” are references to VOLTIMUM. Any terms in this Privacy Policy used with initial capital has the meaning attributed to them in the Terms and Conditions of the Programme, available through the Voltimum website: https://www..voltimum.com, unless explicitly defined otherwise in this Privacy Policy.

 

1. PERSON RESPONSIBLE FOR DATA PROTECTION

Those responsible for the Programme and this Privacy Policy is Voltimum S.A., Route de Peney 2, 1214 Vernier, Switzerland, as the coordinator of the Programme hereinafter referred to as "VOLTIMUM". The controller (as defined in the GDPR) of your data is VOLTIMUM.

2. YOUR DATA AT REGISTRATION AND PARTICIPATION

2.1 Registration for the programme

If you participate in the Programme, VOLTIMUM requires, among other things, your name, company information and address as well as your account numbers with the Distributors ("basic data"). Your basic data is required for the allocation and redemption of Points. You can provide further data on a voluntary basis ("voluntary data"). VOLTIMUM processes the basic data and voluntary data for your registration and for processing the Programme. To ensure that mail reaches you as reliably as possible, VOLTIMUM can, but is not obliged to, check whether the address data is correct and complete. Only you can update this data on your Account with Voltimum+. VOLTIMUM will share your VOLTIMUM+ Account number with the Distributors of whom you have specified a Distributor’s account number to VOLTIMUM. This is required so that the Distributor can share the necessary data that is required to calculate and allocate the Points (“Transactional Data”) to your account. Other personal data will only be transferred to other Manufacturing Partners or Distributors, hereinafter together referred to as “partner companies” if you have given your express consent (e.g. for VOLTIMUM services on the website of a Distributor).

2.2 Collecting Points

If you purchase from a Distributor and you have either shared your distributor account number with VOLTIMUM or you have shared the VOLTIMUM+ Account number with the Distributor, the Distributor will report your distributor account number and the discount data (i.e. goods/services, price, place and time of the purchase), hereinafter referred to as “Raw Purchase Data”, to VOLTIMUM for crediting, managing and allocating the Points. Your Raw Purchase Data will not be passed on to the other partner companies or to third parties outside the Programme unless explicitly provided in this Privacy Policy, or upon your explicit consent. In order to offer you additional opportunities to collect Points under the Programme, you will receive campaign offerings and/or coupons from the partner companies via the Programme Website. 

2.3 Data flow regarding Redeeming Points

As Motivationdirect is the party operating the redemption of Points for Awards, also Motivationdirect will get access to some of your data for such purpose. If you redeem your points in the VOLTIMUM+ rewards shop, VOLTIMUM will forward your order to MotivationdDirect Sp. Z o.o, ul. Czeczota 31, 02-607 Warsaw, as the operator of the rewards shop. The contractual partner for your rewards order is Motivationdirect, not VOLTIMUM. Further information on Motivationdirect´s privacy policy can be found in the data protection information of the website of Motivationdirect

2.4 Programme information and communication with VOLTIMUM

In view of execution of the Programme VOLTIMUM processes the data from your Application Form, for communication between you and VOLTIMUM and for the collection and redemption of Points, all in accordance with this Privacy Policy.

2.5 Further development of the Programme

In order to offer you the most attractive Programme possible, VOLTIMUM and the partner companies furthermore evaluate your data for planning purposes in the form of anonymous statistics.

2.6 Misuse

VOLTIMUM analyses your data to detect misuse, e.g. breaches of the conditions of participation or attempted fraud. If there is any concrete suspicion, VOLTIMUM may inform the Distributor(s) involved, if any and, if necessary, the criminal prosecution authorities.

2.7 Invoicing by VOLTIMUM

VOLTIMUM also processes your data for the purpose of billing the partner companies for services provided by VOLTIMUM to them.

2.8 Legal basis

The legal basis for the data processing described in this section 2 is Art. 6 para. 1 b) GDPR (fulfilment of contract and pre-contractual measures) and Art. 6 para. 1 a) GDPR (consent, given when applying for participation to the Programme).

3. ADVERTISING AND MARKET RESEARCH

By participating in the Programme, you consent to your data being used for advertising and market research purposes, as described below in this Section 3. Use for advertising purposes, such as advertising planning and success monitoring, and selecting suitable advertising offers selected for you on the basis of your data. Market research purposes means, for example, the determination of criteria on the basis of which such a selection of offers should be made; this is done by evaluating data to identify patterns in usage and purchasing behaviour.

3.1 Your consent

VOLTIMUM, and its partner companies through VOLTIMUM, can send you advertising by post, e-mail, or SMS. This advertising is geared towards your individual interests and is selected by VOLTIMUM and the partner company on the basis of the following data: Your basic data, voluntary data, the Transactional Data generated by the Distributor and the data generated when you use the VOLTIMUM website or the Distributor Website (e.g. which of these communication channels with the Distributor and which of the offers made there were used by you, when and how)

The partner companies and VOLTIMUM each process the data specified in the above paragraph for these advertising purposes and for market research purposes.

3.2 Advertising planning and success monitoring

VOLTIMUM and its partner companies will also process your data for the purposes of advertising planning and success monitoring:

Each partner company can select VOLTIMUM customer numbers available from previous purchases and communicate them to VOLTIMUM as an independent entity in order to have a specific advertisement sent to its owner. VOLTIMUM will send the partner company’s advertising to them in its own name.

In order to monitor the success of a particular advertisement and better plan future advertising measures, VOLTIMUM and the advertising partner companies compare the purchasing behaviour of recipients and non-recipients of the advertisement. For this purpose, VOLTIMUM may transmit your customer number and information as to whether or not you have received a particular advertisement to the partner company concerned.

3.3 Legal basis

The legal basis for the data processing described above in section 3 is Art. 6 para. 1 a) GDPR (consent).

4. E-MAIL

4.1 Sender

By participating in the Programme, you consent to receiving regular e-mails from VOLTIMUM.

4.2 E-mail address

As VOLTIMUM+ is a digital programme, your e-mail address is required. To ensure that the e-mail newsletter reaches you as reliably as possible, VOLTIMUM uses service providers to check the activity and accuracy of the e-mail address. If an e-mail address turns out to be non-existent, we will ask you to update your details.

4.3 Contents

With the e-mails you receive VOLTIMUM coupons and offers, information on the Programme and partner companies as well as advertising directed at you (e.g. extra Point opportunities, special offers, discount campaigns, product and service information). VOLTIMUM e-mails may relate to all goods or services offered by VOLTIMUM or by a partner company.

4.4 Statistical data

We only want to send e-mails that really interest the recipients. VOLTIMUM therefore records how the recipients use the e-mails it sends. To do this, it measures whether and, if so, when they open and read these e-mails. It also measures whether and, if so, when they click on which information in the e-mails. These measurements help VOLTIMUM to understand what information the recipients are (or are not) interested in.

4.5 Personalisation

VOLTIMUM and the partner companies will also use the statistical data for the purposes described in the consent given under Section 3.

4.6 Unsubscribe

You can revoke your consent to receive such e-mails at any time. The easiest way to do this is to use the "unsubscribe" link in every e-mail. Revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

 4.7 Legal basis

The legal basis for the processing of your data described here is your consent, (Art. 6 Para. 1 a) GDPR.).

4.8 Storage period

The e-mails sent are deleted after the expiry of the commercial and tax law retention period mandatorily required in our and your jurisdiction.

5. OPERATION OF THE PROGRAMME WEBSITE

We process your personal data to provide you with the contents and various functions of the website. In particular, the website offers you the following functions:

• Information about the programme
• Collect Points online through training and educational contents
• Search for VOLTIMUM+ partner branches in your area
• Search for brochures from VOLTIMUM+ partners in your area
• Redeem Points in the Awards shop
• Manage your Points account
• View your customer data and change it if necessary
• Further VOLTIMUM+ services

Unless otherwise stated in the following sections, the legal basis for the processing of your personal data within the scope of using these functions is Art. 6 para. 1a (consent) and 1 b) GDPR (fulfilment of contract).

5.1 Data processed by VOLTIMUM

5.1.1 Data from participation in the Programme

If you have an Account, you can log into your customer account on the programme Website. We will then also use your data from your participation in the Programme to display information on the website (e.g. your points balance).

5.1.2 Data entered by you

We process your entries on the Programme Website, for example in the contact form, in order to process and answer your respective enquiries.

5.1.3 Automatically collected data

In order to be able to display the Programme Website, we process the following data in particular:

• The address of the page of the Programme Website you have visited
• The address of the website you visited immediately before (the so-called "referrer")
• Date and time of your visit
• Certain characteristics of your terminal device which your browser automatically transmits to us, such as the operating system, the browser used and the window size of your browser
• The IP address of your terminal device on the Internet.

5.2 Cookies and similar technologies

In addition, we use so-called cookies and similar technologies (hereinafter collectively referred to as "cookies") to operate our website. In the following sections we explain the use of cookies in general. Specific information on individual cookies, including type, purposes pursued, data processed, provider and storage duration, can be viewed in the cookie overview.

5.2.1 Basic information about cookies

When you visit the website, cookies are stored on your end device in accordance with the settings of your browser and are read out again if necessary. This storage usually takes place in a special memory area defined by your browser. Cookies are set either by us (first party cookie) or by third party providers determined by us (third party cookie).

Cookies interact with pixels stored on a website when you call up the website. Pixels are transparent images that are inserted into a website and are loaded during the visit. In addition, we use scripts, especially based on the language Javascript. By loading the pixel or script, we can record the call of a website. We also use web storage (also called DOM storage). Web Storage is a further development of cookie technology and also enables the local storage of data in an area provided by your browser.

We use different types of cookies:

• Session cookies: These cookies are short-lived and are automatically deleted at the end of your browser session. The session usually ends when you close the browser window. Session cookies primarily help us to recognise your browser within the session and thus provide you with certain functions of the websites, for example the shopping basket when redeeming Points.
• Persistent cookies: These cookies are provided with a predefined expiry date and are automatically deleted when this date is reached. The time periods can range from minutes to several years. The cookies with which you can agree (opt-in) or disagree (opt-out) to the setting of cookies have the longest duration (if opted-in). This ensures that the settings defined in the respective browser remain valid as long as these cookies are not deleted manually.

5.2.2 Your possible cookie settings

On the one hand, you have the option of configuring the use of cookies by our website individually for your end device in the cookie settings.

On the other hand, you can also set in your browser whether cookies (especially third-party cookies) may be set at all and - if so - whether all cookies should be deleted at the end of the session without exception. You can also manually delete all or only certain cookies in your browser. In addition, you can configure many browsers so that they automatically delete data stored in the web storage when the session is ended. Alternatively, you can use the incognito mode of your browser.

If you allow cookies only partially or delete them manually before they expire, some functions of our website may not be available or may only be available to a limited extent.

5.2.3 Categories of cookies used by us

We use Technically necessary cookies and Marketing cookies. You can find which cookies we use and their purpose in our cookie overview.

5.3 VOLTIMUM+ Award shop

You will find the VOLTIMUM+ Award shop in the relevant section of the Programme Website.

5.3.1 Data protection officer for the VOLTIMUM Award Shop

The seller and sender of the Awards offered in the Award shop is not VOLTIMUM, but Motivation Direct Sp. z o.o, ul. Czeczota 31, 02-607 Warsaw (hereinafter referred to as "Motivationdirect"). We and Motivationdirect are therefore jointly responsible in some cases. In this respect, we have concluded an agreement which defines who fulfils which data protection obligations. We, or Motivationdirect, will provide you with the essential content of these agreements on request.

5.3.2 Redemption of Points

In order that the contract between you and Motivationdirect regarding your redemption of Points for Awards can be concluded we will forward your application for the conclusion of a contract regarding redemption of Points to Motivationdirect. In doing so we transmit the following data to Motivationdirect:

• the data of your order (name, address, Awards ordered, VOLTIMUM+ account number, number of Points redeemed),
• Your agreement to the general terms and conditions of Motivationdirect.

Motivationdirect processes the data you provide for the purpose of initiating and implementing the contract and subsequently processing your order.

5.3.3 Communication

While your order for Awards is being processed by Motivationdirect, you may receive various e-mails from us. These will inform you on behalf of Motivationdirect about the current status of your order.

If you have any complaints or questions about your order, you can contact the VOLTIMUM Service Centre at any time (online via the contact form at VOLTIMUM+ website or by email). Motivationdirect has commissioned the VOLTIMUM Service Centre to deal with any such enquiries.

To enable us to keep you informed by e-mail and to enable the VOLTIMUM service centre to process your complaints and questions about the Awards order, Motivationdirect will send us the necessary information to process your order. In particular, this includes information on the order, delivery and payment status and on any returns.

5.3.1 Statistical evaluations

In addition, we use the data collected in connection with Motivationdirect´s Award Shop and the data received from Motivationdirect to compile (anonymous) statistics. We delete the raw data used to calculate these statistics after 2 years. Otherwise, the storage periods described in the general information on data protection in the Programme Terms and Conditions apply.

5.3.2 Legal basis

The legal basis for the processing of your data by us as described above in section 5.1, 5.2 and 5.3 ,is Art. 6 para. 1 a) GDPR (consent ).

The legal basis for the processing of data regarding corresponding payments is Art. 6 para. 1 b) GDPR (fulfilment of contract and pre-contractual measures).

5.4 Website analysis

5.4.1 General

We want to design our websites in the best possible way. To do this, we need to understand which of our websites and offers are used by visitors to our website. In order to determine this, we use so-called "tracking" tools that record visitor behaviour. The tracking tools thus enable us to measure the use of our online offers and the effectiveness of our online advertising. With the help of the tracking tools, we collect the following information in particular:

• Which links do online users click on, on other websites to get to our website?
• Which of our pages are visited when, how often and in which order?
• What products are our customers looking for?
• Which links or offers do our customers click on?

From this information we compile statistics that help us to answer the following questions:

• Which pages are particularly attractive for the users of our services?
• Which products interest our customers the most?
• Which offers should we make to our customers?

5.4.2 Collection and evaluation of personal data

To determine visitor behaviour, we use the automatically collected data mentioned in section 5.4.1 above. We can link such data with other data that identifies you as a person (e.g. name, address, etc.).

5.4.3 Google Analytics

The tracking is done with the support of marketing cookies. These are set by the tracking tool "Google Analytics" of the service provider Google Inc, based in the USA, hereinafter referred to as "Google"). Insofar as this service provider receives data in the process, this is always done under our control. Google will use the information collected solely on our behalf for the purposes set out above.

5.4.4 Mautic

The tracking is done with the support of marketing cookies. These are set by the tracking tool “Mautic” and operated by VOLTIMUM. All data in the process is always under our control.

5.4.5 A/B tests

A/B testing means that we may display different website content to different visitors to our website. Website visitors of "Group A" may therefore see different content in their browser than visitors of "Group B". The purpose is to determine which content is better received or which design of our website is more user-friendly.

Whether you belong to "Group A" or "Group B" in an A/B test is decided by chance.

The group to which you belong is stored on your computer in a cookie. Depending on the content of the cookie, your browser will then show you either the "A version" or the "B version" of our website. We record how the use of our website differs between "Group A" and "Group B". However, we store the corresponding usage information exclusively in anonymous form. We only compile anonymous statistics from this information. We need these statistics to make our website as user-friendly as possible.

5.4 Advertising from third parties

5.4.1 General explanation on third-party advertising

VOLTIMUM and its partners companies can place advertisements on our website and other websites on the Internet via various advertising networks.

The aim is to present you with advertising content that is based on your previous surfing behaviour on our website and other websites where the advertising networks are present ("retargeting"). For this purpose, this surfing behaviour is recorded, and the data evaluated for advertising purposes.

5.4.2 Selection of advertising by advertising networks

In order to select the relevant advertising, the advertising networks process the data and use the technologies described in our overview of the cookies and similar technologies used.

In this way, an advertising network can record when you use which online offers with your end device. Using this information, the advertising network selects offers based on your interests and displays them in the form of banners or advertisements on our and other websites.

5.4.3 Advertising networks used on our website

The advertising networks collect and process the data arising in this context on their own responsibility.

The advertising networks used by us are:

• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland Privacy policy: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Please note that the advertising networks involve further sub-marketers. This is done on the basis of criteria that the advertising networks set themselves. For further information, please contact the advertising networks mentioned above.

If you disable personalisation cookies (one of the marketing cookies) on our website, no data will be transmitted to the advertising networks or sub-marketers when you visit our website.

5.5 Contents of third parties

5.5.1. General

The Internet is connected. For this reason, you will not only find our own content on our website. We have also included various third-party contents which either improve the technical functionality or the attractiveness of our website. When you click on such thirdparty content on one of our web pages, your browser automatically establishes a direct connection to the servers of the respective provider and calls up the content there in order to be able to display it to you.

More information on the third parties whose content we have included on our website in the above sense is available with VOLTIMUM upon request.

5.5.2 Google Fonts

We use Google Fonts for an improved presentation of various texts on this website

The provider of Google Fonts for users in the European Economic Area and Switzerland is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

The fonts will be loaded directly from your web browser into a local cache on your device for display on our website and other websites as appropriate. If your web browser does not support Google Fonts or access to Google Fonts is disabled, your browser will attempt to display the text in a default font.

The Google Privacy Policy (https://policies.google.com/privacy) explains how Google uses and processes data.

5.7 Legal Basis

The legal basis for the data processing by us described in sections 5.4 and 5.5, is Art. 6 para. 1 f) GDPR.

6. STORAGE DURATION

Unless stated otherwise in this Privacy Policy, VOLTIMUM stores your basic data and voluntary data for as long as you actively participate in the Programme. They are then deleted, but if there are mandatory retention periods under commercial or tax law, they are only deleted after these periods have expired. Your discount data will be deleted after the relevant mandatory commercial or tax retention period has expired. VOLTIMUM will delete your communication data at the latest 6 years after termination of your participation to the Programme, whether or not upon termination by you or VOLTIMUM of your participation, or after termination of the Programme by VOLTIMUM, or so much earlier or later as required by applicable law. If VOLTIMUM no longer needs your data for the purposes described in this Privacy Policy, VOLTIMUM will no longer process it for other purposes than as required to comply with the commercial or tax law retention obligations, if any.

7. DATA PROCESSING BY OWN DEPARTMENTS AND SERVICE PROVIDERS

Internally, VOLTIMUM processes your data through its relevant departments. VOLTIMUM also uses various service providers (so-called contract processors), e.g. to record paper forms or send information (by post, e-mail etc.). Where necessary, these service providers will also process your data under an agreement with VOLTIMUM. In this case the data will be deleted immediately after the order has been fulfilled. The service providers are carefully selected and monitored by VOLTIMUM.

8. RIGHT OF OBJECTION

If VOLTIMUM processes your data on the basis of Art, 6 1 f) GDPR, you have the right to object if your interest or your fundamental rights and freedom override the legitimate interest of VOLTMUM, or third parties referred to in Section 5.

On request, VOLTIMUM will inform you whether any of your personal data has been stored and, if so, which data. If the legal requirements are met, you have the right to correct, block or delete this data. You also have the right to receive the data you have provided to VOLTIMUM in a structured, standard format from VOLTIMUM. You may transmit this data or have it transmitted to other parties. You also have a right of file complaints, if any, to a data protection supervisory authority.

9. CONTACT

Questions about data protection at VOLTIMUM can be sent to Voltimum S.A., with reference “data privacy”, Route de Peney 2, 1214 Vernier, Switzerland. You can also send questions and comments via our contact form.