Privacy Policy

Introduction

I work U play recognises the importance of ensuring the protection and security of privacy and Personal Data. I work U play has drawn up this Privacy Policy in accordance with the strictest criteria for the protection of personal data and the new Swiss Federal Act on Data Protection Act (nFADP).

Registration for I work U play, as well as any request for information from parents or volunteers, is likely to result in the collection of Personal Data concerning them.

The purpose of this Privacy Policy is to inform each parent and volunteer, before they communicate such Personal Data, about the conditions and way in which it is processed by I work U play.

By accepting this Privacy Policy, the parent and volunteer consents to the collection and processing of his/her Personal Data under the conditions and in the manner defined below.

 

  1. Definitions

Capitalised terms have the following meanings:

  • Data Protection Officer: monitors the association’s compliance with data protection requirements and provides the data controller with advice on data protection matters.
  • Personal Data: means any information provided by the parent and allowing the parent to be identified, processed by I work U play under the conditions set out in this Privacy Policy.
  • Privacy Policy: means the principles and commitments set out hereinafter.
  • Regulation: means the new Federal Act on Data Protection (nFADP).
  • GDPR: means Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (known as the “General Data Protection Regulation“).
  • Process / Processing : means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organising, retention, use, restriction, erasure or destruction.
  • Third / Third parties: means any natural or legal person other than I work U play and the parent.
    Breach of Personal Data : means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data.

 

  1. Processing of Personal Data

2.1.    This Privacy Policy is applicable to the Processing by I work U Play, which acts as Data Protection Officer, of Personal Data voluntarily provided by the parent.

Any mandatory information that is partial, inaccurate or missing, makes it impossible for I work U play to provide the services or benefits requested by the parent.

2.2.    The purposes of the processing of the Personal Data provided by the parent through the registration form will be as follows:

  • to process and respond to a request for contact, registration for I work U play or to an event organised by I work U play;
  • after the prior consent of the parent and until such consent is revoked, send any information necessary for the processing of this registration and any information on the activities of I work U play;

Parents are invited to read and accept the Privacy Policy regarding the Processing of Personal Data communicated in the context of a request for registration to I work U play.

2.3.    You will find hereinafter:

  • the object and purpose(s) of the Processing,
  • the persons concerned by the Processing,
  • the categories of Personal Data Processed,
  • the recipients of the Personal Data,
  • the retention period of the Personal Data,
  • the legal basis.

In case of first contact: The person concerned is the parent and the Personal Data processed is : the name, surname, telephone number and email. The Recipient of the Personal Data is I work U play. The retention period of the Personal Data is 3 years and the legal basis is the parent’s consent.

In case of request for registration by a parent at I work U play: The persons concerned are the parents, the child and the person to be contacted in case of emergency. The Personal Data processed is : the address, name, surname, telephone number and email, emergency contact, insurance criminal extract and child’s specific needs. The Recipient of the Personal Data is I work U play. The retention period of the Personal Data is 3 years and the legal basis is the parent’s consent.

In case of registration to an event: The person concerned is the parent and the Personal Data processed is : the name, surname, telephone number and email. The Recipient of the Personal Data is I work U play. The retention period of the Personal Data is 3 years and the legal basis is the parent’s consent.

In case of first contact: The person concerned is the volunteer and the Personal Data processed is : the name, surname, telephone number and email. The Recipient of the Personal Data is I work U play. The retention period of the Personal Data is 3 years and the legal basis is the volunteer’s consent.

In case of request for registration of the volunteer at I work U play: The person concerned is the volunteer. The Personal Data processed is : identification document, insurance and criminal extract. The Recipient of the Personal Data is I work U play. The retention period of the Personal Data is 3 years and the legal basis is the volunteer’s consent.

2.4.    I work U Play undertakes to Process Personal Data only for the purposes described above, to the exclusion of any other purpose. In particular, I work U play does not market or rent Personal Data to Thirds

 

  1. Data Protection Officer

I work U play has appointed a data protection controller to carry out the tasks referred to in the nFADP.

The Data Protection controller can be contacted at the following email address:

Ms. Domitille Pozzana
legal@iworkuplay.com

 

  1. Technical and organisational measures

4.1.   I work U play implements the appropriate technical and organisational measures to ensure the protection of Personal Data and to provide the necessary safeguards for its Processing, in accordance with the requirements of the nFADP.

In particular, I work U play takes all necessary precautions with regard to the nature of the Personal Data communicated to it and the risks presented by their Processing, in order to preserve their security and, in particular, to prevent them from being distorted, damaged, or accessed by unauthorised Third Parties.

4.2.    The technical and organisational measures taken by I work U play are tested, analysed and evaluated, in order to verify their effectiveness.

 

  1. Third Party Requests

I work U play undertakes not to disclose Personal Data to Third Parties without the consent of the parents, except in the event of an administrative or judicial request or injunction or in application of a legal or regulatory requirement.

 

  1. Users’ rights

6.1.   In accordance with the nFADP, the parent has the right to:

  • obtain confirmation as to whether or not Personal Data is being processed and, where it is, access to such Personal Data,
  • rectify Personal Data that is inaccurate and complete it taking into account the purposes of the Processing,
  • obtain the deletion of Personal Data, in particular when:
    • the Personal Data is no longer necessary in relation to the purposes for which it was Processed
    • the Personal Data has been unlawfully processed
    • the Personal Data must be erased to comply with a legal obligation,
  • limit the Processing of their Personal Data, in particular when their accuracy is disputed or the Processing is unlawful,
  • obtain the portability of their Personal Data, i.e., the right to receive the Personal Data, in a structured, commonly used and machine-readable format, in order to transmit them to another data controller, provided that the relevant Processing of Personal Data is carried out using automated (computer) processes.

6.2.    In order to exercise any of their rights, the parent must send a request to the Data Protection Controller:

Ms. Domitille Pozzana
legal@iworkuplay.com

I work U play undertakes to acknowledge receipt of any request made in this respect by a parent and to process it as soon as possible. It also undertakes to notify any recipient of the Personal Data to which it has been communicated with the consent of the Users of any rectification, deletion or limitation of the Processing, unless such communication proves impossible or requires disproportionate effort.

6.3.   In addition, Users have the right to lodge a complaint with a Supervisory Authority, i.e., the Federal Data Protection and Information Commissioner (FDPIC).

 

  1. Confidentiality

I work U play is committed to ensuring that each member of its staff authorised to Process Parents’ Personal Data is subject to strict confidentiality and Personal Data protection obligations, and in particular undertakes to:

  • process only the Personal Data that is strictly necessary to achieve the purposes for which it is collected,
  • ensure that the Personal Data is not Processed for purposes other than those for which it was collected, except in the event of an administrative or judicial request or injunction or in application of a legal or regulatory requirement,
  • take all measures in accordance with usage and the state of the art in order to avoid the misuse or fraudulent use of Personal Data and to preserve the physical and logical security of Personal Data;
  • in the event of termination of his/her duties, return in full the data, computer files and any information medium relating to Personal Data,
  • inform I work U play immediately and by any means whatsoever of any Personal Data Breach of which it becomes aware.

 

  1. Personal Data Breach

8.1.   I work U play will inform each affected parent as soon as possible of any Breach of their Personal Data that may result in a high risk to their rights and freedoms, in accordance with the nFADP. This information shall describe, in particular, the likely consequences of the Breach, as well as the measures taken or contemplated by I work U play to remedy the Breach, including the measures taken to mitigate any adverse consequences of the Breach.

 8.2.   However, the information referred to in Article 8.1 is not necessary if one of the following conditions is met:

  • I work U play has implemented appropriate technical and organisational protection measures and these have been applied to the Personal Data affected by the said Breach,
  • I work U play has taken subsequent measures to ensure that the high risk to the rights and freedoms of Users is no longer likely to occur.
  • It would require disproportionate effort.

8.3.   I work U play will notify the Federal Data Protection and Information Commissioner (FDPIC)  as soon as possible and if possible within 72 hours of becoming aware of it, any Breach likely to result in a high risk to the rights and freedoms of Users.

 

  1. General Provisions

9.1.   If any of the provisions of this Privacy Policy are to be cancelled or declared unenforceable, in whole or in part, under the laws and regulations in force, they will be excluded from this Policy without affecting the validity and enforceability of all its other provisions.

9.2.   This Privacy Policy may be modified by I work U play at any time, in particular due to technical or normative changes.

Last modification, 08.03.2024