1. What is this Privacy Statement about and for whom is this intended
This privacy statement (“Privacy Statement”) explains how Salt Mobile SA, Rue du Caudray 4, 1020 Renens (“Salt”, “we” or “us”) processes your personal data (“Data”) and demonstrates our commitment to ensuring the privacy and security of your Data. This Privacy Statement applies to all persons whose Data we process (“you”). It applies to the processing of Data that have already been collected and Data that will be collected in the future. Data processing by Salt may, in particular, affect the following categories of persons: prospects, customers, ex-customers, users of our Apps, visitors of our websites, visitors of our premises, individuals who write to us or contact us in any other way, recipients of marketing communications, participants of prize competitions, business and commercial partners, contact persons at our suppliers, landlords or rental properties and their representatives.
By accessing and using our websites or our services or by contacting us via any available channel you confirm that you understand and accept the processing of your Data as provided in the current version of this Privacy Statement.
The use of our services is governed by our General terms and conditions.
2. How we ensure the security of your Data
It is extremely important to us to protect your Data from unauthorized access, use, copying or other unauthorized actions.
Salt has implemented the appropriate technical and organisational measures in order to safeguard and protect your Data such as logging accesses and access restrictions or encryption of certain Data. We conclude also the respective confidentiality and data processing agreements with our service providers. Your Data is stored and hosted in data centres located in Switzerland. For more information regarding the transfer of Data abroad, please see point 10 below.
3. Who is the controller for processing of your Data and how to contact us
Salt is the controller and is responsible for the collection and processing of your Data.
If you have any questions about this Privacy Statement or about the processing of your Data, please contact us:
By post: Salt Mobile SA, Data Protection, Rue du Caudray 4, 1020 Renens
Via phone: through the customer service:
Salt Mobile, das Abo: 0800 700 700; Salt Home: 0800 700 500; Lidl Connect: 0800 700 123;
4. How your Data is collected
We collect and process the Data you provide us in particular when you visiti our website, when you conclude with us a contract, when you use our services, our Apps or when you communicate with us via any available contact channel (e.g. during registration through forms, as part of an order, by calling us, when participating in a contest or survey, etc.).
We may also receive your Data from third parties, such as companies with whom we cooperate, persons who communicate with us, or public sources. For example, we may receive your Data from the following third parties: persons close to you (e.g. family members, legal representatives), credit reference agencies if we wish to obtain information about your creditworthiness, address dealers, banks for payments, providers of online services (e.g. providers of Internet analysis services), authorities and other third parties in connection with official and judicial proceedings, or public registers such as debt or commercial register.
When you participate in contests organised or sponsored by Salt, the contest’s terms and conditions provide that we will process your Data for marketing purposes. We use your Data during the contest to conduct the competition, select the winners, and distribute the prizes. We subsequently use the Data to communicate Salt related information such as news, promotions and events.
5. Which Data we process
The Data processed by Salt include the following main categories:
• Contact and Identification Data such as your full name, gender, date of birth, home, invoice and delivery address, phone number, e-mail address, language preference, document type and ID, point of contact or representative of a business partner.
• Contractual Data such as the information regarding products and services you purchased including contract type and duration, price plan, or roaming add-on packages.
• Financial Data such as your payment history, your credit rating information or collection proceedings.
• Communication Data with us such as contact forms, e-mails, letters, chats, telephone conversations and Image and Sound Recordings Data such as your calls to Salt’s customer service or video surveillance records in Salt stores or premises.
You will be informed at the start of each telephone conversation if Salt is recording the conversation for purposes such as quality and training. If you don’t want us to record such conversations, you may terminate the call at any time and contact us in another manner.
The use of video surveillance systems in our premises is localized and clearly indicated.
Salt offers you the option to communicate with us via chat. The respective Terms and Conditions of the chat provider apply. Salt processes the content of chats included uploaded files to continuously improve the quality of the chat service.
• Technical Data such as the connection quality on our mobile and fixed networks, visits to our websites, the use of our Apps or other electronic services, IP address, details about your Internet provider, location Data according to your browser, technical details about your device such as device MAC address, your device operating system and language settings, code numbers assigned by cookies, or other tracking technologies. Technical Data alone does not allow us to identify your identity. However, in combination with other data such as user accounts, registration information, or the processing of contracts, we might be able to identify you as a person.
• Telecommunication Data and Usage Data such as telecommunication traffic Data (e.g. call numbers, countries called, duration and date of calls, value-added service numbers) as well as location Data or television habits. We will never record and analyse the content of your personal voice and data communications unless you communicate with Salt or if Salt is legally obliged to do so.
6. Why your Data is processed and for what purposes
We process your Data, as listed in point 5 above, for the following purposes:
6.1. Contract execution and provisioning of third-party services
Salt uses your Data to the extent necessary to provide its products and services.
We use your Data to conclude and to execute the contracts with you and to enable you to purchase third-party services such as mobile and TV add-on packages or value-added services.
6.2. Omnichannel marketing communications
Salt continuously seeks to strengthen our commercial relationship and to enhance your experience as a customer. Salt uses your Data to provide you with relevant communications enabling you to get the most of Salt’s products and services.
For this purpose, we might use different communication channels such as email, correspondence, messaging, telephone or 3rd party channels to achieve this goal.
You can manage your consent for these communications channels at any time in your profile.
6.3. Development and improvement of services and products
Salt continuously seeks to strengthen the portfolio of our products and services (e.g. price plans, options, up-sell packages), and the overall experience of our customers across various channels. We use your Data to better understand customer needs. Generally, we use anonymised Data for these purposes.
You can manage your consent for the development and improvement of services and products at any time in your profile.
6.4. Personalized customer experience
Salt continuously seeks to personalise the experience of our customers with the objective to precisely meet your needs. Salt may process your Data which we may combine with other data in aggregated form in automated way. This processing is also known as “profiling” in technical language.
We might also use your Data, including Telecommunication and Usage Data, to identify affinities regarding your interests, products and services and to present you with relevant information and marketing communications tailored to your needs like interesting services and products as well as relevant location-based information alerts. Generally, we use anonymised Data for these purposes.
You can manage your consent for the personalised customer experience at any time in your profile.
6.5. Compliance with legal obligations
We also process your Data in order to comply with legal obligations (e.g. under telecommunication laws) and to prevent and to detect infringements. This may include receiving and processing complaints, receiving the requests from authorities and courts, complying with court and administrative orders, detecting and investigating misuse. Compliance with statutory requirements may particularly include the disclosure of Data to authorities if we are legally obliged or if we have an objective reason to do so, the fulfilment of duties of information disclosure, or the reporting obligations, for example in connection with obligations under supervisory and tax law, or for the prevention, detection, and investigation of criminal offenses.
6.6. Security and access control purposes
We process your Data for security and access control purposes, for example, for monitoring, inspection, analysis and testing of our IT infrastructures, for system and errors checks, for documentation purposes and in the context of backups. Access control includes, in particular, electronic system access controls (e.g. logging into user accounts) and physical access control (e.g. access to our stores or premises). For security purposes, we may keep access protocols and visitors lists and we use video surveillance.
7. Automated individual decisions
We may automate discretionary decisions about concluding the contract with you when we check your solvency. These decisions are not determined by an individual person but by algorithms. In these cases, we will inform you accordingly in compliance with applicable law.
8. Cookies and web analysis tools
Salt uses “cookie” technology. A cookie is a small data file created by a web server, transferred to, and stored on your computer or other mobile devices when you visit or use our websites.
Most Internet browsers accept cookies automatically. You can always use the settings to instruct your browser to block the cookies or to delete cookies from your computer or mobile device. However, if you decide to deactivate cookies, you will not be able to see certain information or to use some functions designed to improve your visit on our website.
You will find more information in our Cookies statement.
9. Recipients of your Data
We may share your Data with the following categories of recipients:
• Authorities such as offices, courts and other authorities like Federal and Cantonal Prosecution Authorities. Salt may disclose your Data to comply with the applicable law, and to respond to lawful requests from authorities. We may also process your Data to protect and defend our rights, including enforcement of the contract between you and us.
• Third parties like service providers or distribution and marketing partners:
o Salt is outsourcing some of its activities, for example, call centres, customer care, distribution and marketing, IT and network optimization services or installation services
o Salt may transfer your Data to the value-added services providers or our roaming partners (when you make calls abroad)
o Salt may also process your Data and make it available to our service providers as part of the commissioning of debt collection services or for the purposes of checking the creditworthiness of customers
o We might engage third parties for marketing campaigns such as newsletters, satisfaction survey or outbound call campaigns
10. Disclosure of your Data abroad
As explained in point 9, we may disclose your Data to third parties. Not all of our partners and service providers are located in Switzerland. Foreign suppliers and service providers, for example for call centres services, may be located in Europe and in exceptional cases in other countries in the world.
If a recipient is located in a country without adequate level of data protection, we ensure suitable protection in accordance with the applicable law. We require the recipient to undertake to comply with data protection. For this purpose, we apply, among other things, the contractual measures and we use the revised European Commission’s standard contractual clauses.
11. How long we store your Data
We process and store your Data for as long as it is necessary for the purposes for which it was collected, for example for the duration of our contractual relationship, as long as it is necessary to comply with the applicable law requirements and statutory retention periods or for our legitim marketing purposes. For example, to comply with the obligations under the Federal Act on the Surveillance of Postal and Telecommunications Traffic, we retain your connection Data for 6 months, the Financial Data are generally kept for 10 years, your Contractual Data is generally kept for 3 years after the termination of the contract in order to inform you about the new offers from Salt. The period for which your Data is stored is limited to a minimum. If there are no contrary legal or contractual obligations, we will delete or anonymize your Data once the storage or processing period has expired as part of our usual process.
12. Your rights regarding your Data
• You have the right to access and to obtain information in writing about your Data that we process, including about the automated individual decisions
• You can also ask us to provide certain Data in a commonly used electronic format or transfer it to another controller
• You can ask us to correct the Data if it is inaccurate
• You have the right to ask us to delete your Data, if we are not obliged or entitled to continue a storage under applicable law
If you wish to exercise the above-mentioned rights, please contact us in writing by a duly signed letter and a copy of an identification document using the following address:
Salt Mobile SA, Data Protection, Rue du Caudray 4, 1020 Renens
• You are entitled to withdraw your consent to the processing of your Data and/or refuse the processing your Data at any time. You can do so by adjusting your profile
13. Updates and amendments of this Privacy Statement
We can unilaterally update this Privacy Statement from time to time. We recommend you to check regularly if this Privacy Statement has been updated. The most current version will be available on our website.