Introduction
The Club respects Member privacy and is committed to protecting Member personal data.
This Privacy Policy aims to provide information on how the Club may collect, process and store the personal data of its Members, notably through Member use of our services, website or Premises. This includes any personal data Members may provide when they sign up for our services, purchase products or services, participate in events, or sign up for our newsletters.
Important Information and Who We Are
3.1 Controller
The data controller within the meaning of the Federal Act on Data Protection of 25 September 2020 or, if applicable, the General Data Protection Regulation (Regulation [UE] 2016/679) is NOWHERE SA.
3.2 Contact Details
For any data protection related concerns, you may use the following contact details:
Full name of legal entity: NOWHERE SA
Email address: info@nowheresociety.xyz
Postal address: Route de Frontenex 60, 1207 Geneva (Switzerland)
The Personal Data We Collect
The Club collects and processes personal data (i.e. any data that identifies a person or that allows, together with other information, for the identification of a person), and in particular the following personal data:
Identity data which includes first name, last name, username or similar identifier, marital status, title, date of birth and gender;
Contact data which includes billing address, delivery address, email address, and telephone numbers;
Financial data which includes bank account and payment card details;
Transaction data which includes details about payments to and from Members and other details of products and services Members have purchased from the Club;
Technical data which includes internet protocol (IP) address, Member login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices Members use to access this website;
Profile data which includes Member username and password, purchases or orders made by Member, Member interests, preferences, feedback, and survey responses;
Usage data which includes information about how Members use the Club’s website, products, and services;
Marketing and communications data which includes Member preferences in receiving marketing or newsletters from the Club and its affiliated third parties and Member communication preferences.
Within its services, the Club may collect and process personal data of its Members, any Members’ guests or individuals accompanying them.
How We Collect Personal Data
Personal data are collected by the Club as part of its services before entering into a Member Agreement with the Member and during the lifetime of a membership which exists with the Member.
The Club uses different methods to collect personal data from and about Members, including:
Direct interactions – the Club mainly collects personal data that it obtains from its Members themselves or from related persons (e.g. by filing forms or by corresponding with the Club by post, phone, email or otherwise).
Automated technologies or interactions – As Members interact with the Club’s website, the Club may automatically collect technical data about Members equipment, browsing actions, and patterns. The Club collects this personal data by using cookies, server logs, and other similar technologies.
Third parties or publicly available sources – The Club may receive personal data about Members from various third parties and public sources such as analytics providers, advertising networks, and search information providers.
Other means – The Club may also collect personal data from its Members when they are visiting the Club’s Premises or using its services. §
How We Use Member Personal Data
The Club processes personal data primarily for the purpose of providing, documenting and improving its services or performing any agreement that has been entered into with its Members. The Club also processes Members’ personal data in order to communicate with them, respond to their requests and send them newsletters, offers, information about the Club and invitations to events. Personal data may also be collected by the Club before entering into a relationship with its Members.
If you do not wish to receive newsletters or invitations from the Club, you can unsubscribe at any time by writing to the e-mail address mentioned above under 2.2. Contact Details.
Personal Data are also collected (i) where it is necessary for our legitimate interests (or those of a third party) and (ii) where we need to comply with any legal or regulatory obligation.
Transmission of Personal Data
The Club may transfer personal data in compliance with the applicable law, and in particular it may share personal data with the following third-parties:
The Club staff members, including employees, auxiliaries and contractors who need the data to provide Members with our services.
External third parties service providers who provide notably IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers, tax authorities, regulators, as well as Swiss and/or foreign judicial and administrative authorities, to the extent permitted by Swiss compulsory law.
Third parties with whom we may choose to sell, transfer, or merge parts of our business or our assets.
Transmission of Personal Data Abroad
The Club may transfer personal data to recipients established or domiciled outside Switzerland if there is appropriate data protection comparable to that applied in Switzerland (such as the data protection law applicable in the European Union), or if the recipient concerned has contractually undertaken to provide the Club with equivalent protection.
Data Security
The Club has put in place appropriate security measures to prevent Members personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. The Club limits access to Members personal data to those employees, agents,
contractors, and other third parties who have a business need to know. They will only process Members personal data on the Club’s instructions.
The Club has put in place procedures to deal with any suspected personal data breach and will notify Members and any competent regulator of a breach in accordance with the applicable law.
Data Retention
The Club will retain personal data no longer than is necessary for the purposes for which the data have been collected and are processed, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, the Club applies a policy within the framework of the applicable law governing its activities. The Club is authorized to store and process personal data during a longer period in order to defend its interest, in the event notably of ongoing civil, administrative and/or criminal proceedings.
Member Legal Rights
Each data subject whose personal data is processed by the Club may be entitled to access his data in accordance with article 25 of the Federal Act on Data Protection of 25 September 2020 or, if applicable, the General Data Protection Regulation (Regulation [UE] 2016/679).
If our processing is based on the consent of the data subject, the latter has the right to revoke his consent at any time with effect for the future.
The data subject may also invoke the other rights conferred by the applicable law (notably request correction or erasure of personal data, request transfer of personal data). To exercise these rights, please contact the Club in writing to address mentioned above under 2.2. Contact Details. The Club will process such requests in accordance with the Swiss data protection law or the applicable law, any may also refuse or restrict them in accordance with the statutory provisions.
In addition, the data subject may contact the Swiss Federal Data Protection and Information Commissioner (www.edoeb.admin.ch).
Changes to the Privacy Policy and Member Duty to Inform Us of Changes
This version was last updated on July 6th, 2023.
The Club may amend the content of this Privacy Policy from time to time and at its sole discretion. The current version published on the Club’s website shall apply.
It is important that the personal data we hold about Members is accurate and current. Please keep us informed if a Member's personal data changes during a member relationship with us.
Governing law and Jurisdiction
This privacy policy is governed by and interpreted in accordance with Swiss law and the courts of the Canton of Geneva, Switzerland, shall have exclusive jurisdiction for any disputes relating to this privacy policy.