Thank you for visiting https://www.govio.app/ (collectively, “the Site”). The Site is operated for Coded Solution Ltd. (“Coded Solution Ltd.”) under a license and services arrangement with Coded Solution Ltd. (“Coded Solution”, and together with “we,” “ our,” or “us”). This Data Protection Notice (“Notice”) sets out the basis which Coded Solution may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Privacy policy (“Privacy Policy”) together with govio.app’s Cookie Policy below (“Cookie Policy”) set out the basis on which any Personal Information we collect from you (“you”, “your”, or “ customer”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier. Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy then you should not access or use the Site or use the services, functions, or features offered from time to time on the Site (“ Services”).

When you visit our website, the hosting provider of our website, Amazon Web Services (AWS) automatically collects and stores various information in so-called server log files that your browser transmits to us. The information/data mentioned is neither assigned to specific persons nor linked to data from other sources. The following technical data will be recorded by us, as usual with every connection with a web server, without your intervention, and stored by us until automatic deletion after no later than two days:

• Anonymized IP addresses
• Geographical location of IP address

The collection and processing of this technical data is for the purpose of enabling the use of our website, continuously ensuring system security and stability, optimising our website, and for internal statistical purposes. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

• Furthermore, the IP addresses will be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorised use or misuse of the website, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

We collect information about you when you:

• Use the Support Centre on the Site; or
• Correspond with us by phone, e-mail or otherwise.

The Personal Information most often collected and maintained in a customer file includes customer identification, transaction history including records of payments made.

Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:

• Technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.

We use IP addresses to analyze trends, administer the Site, track customer movements, and gather broad demographic information for aggregate use. For systems administration and detecting usage patterns and troubleshooting purposes, our web servers also automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within Coded Solution and their affiliates on a need-to-know basis. We reserve the right to block access for any customer accessing the Site via a proxy service intending to conceal originating identity. This includes access via the Tor anonymity network.

We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

We will process your Personal Information on the following grounds:

• Use the Support Centre on the Site; or
• where it is necessary for us to perform pursuant to your contract with Coded Solution or in your interests; and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interest of our organization to conduct and manage our business to enable us to better serve you and provide you with a secure experience on the Site.

We ensure that we balance any potential impact on you and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Generally we do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies (please refer to our Cookies Policy) or when we send third party direct marketing communications to you via email or text message.

We are committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality. The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You agree that we have the right to share your Personal Information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries including their respective contractors, affiliates, employees or representatives.
• Our service providers, to the extent necessary to supply the Services to you.
• Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us.

We will also disclose your Personal Information to third parties:

• If Coded Solution or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Sale and Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing described in this Privacy Policy. This concerns especially the following receiver(s):

• our websites service providers
• e-commerce provider such as payment solution providers to assist us in the processing of your online payments

They are obliged to protect data privacy to the same extent as we ourselves. If the level of data protection in a given country does not correspond to the Swiss and European data protection level, we contractually ensure that the protection of your personal data corresponds to that in Switzerland and the EU at all times by concluding agreements using the standard contractual clauses and complying with the GDPR.

We use appropriate technical and organizational security measures to protect your stored personal data against manipulation, partial or complete loss, and unauthorized access by third parties. Our security measures are continuously being improved in line with technical developments. Please note that any data transmission on the Internet (e.g. communication by e- mail) is generally not secure and we accept no liability for data transmitted to us via the Internet. Unfortunately, absolute protection is not technically possible. This information does not apply to the websites of third parties and the corresponding links given on our websites. The Foundation assumes no responsibility and liability for these.

You have the right to obtain confirmation from the Foundation as to whether or not personal data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact the responsible person as stated in section 1 of this Privacy Policy.

You have the right to obtain from the Foundation free information about your personal data stored at any time and a copy of this information. Furthermore, you will have access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the Foundation rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority; 
• where the personal data are not collected directly from you, any available information as to their source; and
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

If you wish to avail yourself of this right of access, you may at any time contact the responsible person as stated in section 1 of this Privacy Policy.

You have the right to obtain from the V Systems, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, contact the responsible person as stated in section 1 of this Privacy Policy.

You have the right to obtain from V Systems the erasure of personal data concerning you as soon as possible, and the Foundation shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

• The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;
• The personal data has been unlawfully processed;
• The personal data must be erased for compliance with a legal obligation in accordance with the applicable law to which the Foundation is subject;
• The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If any one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by the Company, you may at any time contact the responsible person as stated in section 1 of this Privacy Policy. The responsible person at the Company shall promptly ensure that the erasure request is complied with as soon as possible.

You have the right to obtain from the Company restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by you, for a period enabling the Company to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and requests instead the restriction of their use instead;
• the Company no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; and/or
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Company override those of the data subject.

If any one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by the Company, you may at any time contact the Company's responsible person. The responsible person will arrange the restriction of the processing.

You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. The Foundation shall no longer process the personal data in the event of the objection, unless the Foundation can demonstrate reasonable grounds for the processing, which override the interests, rights and freedoms of you, or for the establishment, exercise or defense of legal claims. In order to exercise the right to object, you may directly contact the responsible person.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between you and the Foundation, or (2) is not authorized by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between you and the Foundation, or (2) it is based on your explicit consent, the Company shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision. Please note that the Company does not use automatic decision-making but we may use profiling according to these Privacy Policy rules.

You have the right to withdraw your consent to processing of your personal data at any time. If you wish to exercise the right to withdraw the consent, you may at any time directly contact the responsible person as stated in section 1. You may access and verify your Personal Information held by Coded Solution Limited by submitting a written request to: support@codedsolution.xyz

You will not have to pay a fee to access your Personal Information or to exercise any of your other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This Privacy Policy and the use of your Personal Information only applies to the information we collect. You are cautioned that if you disclose Personal Information or personally sensitive data through use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which we have no control. It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. We are not responsible for the privacy statements, policies, terms, conditions, or other content of any Site not owned or managed by Coded Solution.

We take all reasonable endeavors to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Thank you for visiting the Coded Solution Website (collectively, “the Site”). The Site is operated for Coded Solution Limited (“Coded Solution Limited”) under a license and services arrangement with Coded Solution Limited (“Coded Solution”, and together “we,” “ our,” or “us”). This Data Protection Notice (“Notice”) sets out the basis which Coded Solution may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). The Site may use “cookies”. A cookie is a small text file containing a unique identification number that identifies a customer’s browser each time that customer visits a website. The use of cookies is industry standard practice and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Site. You choose to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the ‘Help’ menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit Home or Your Online Choices | EDAA for comprehensive information on how to manage cookies. We set cookies (first party cookies) on web pages, however, where we require additional information, we may also allow other companies to host cookies on our Site (third party cookies). These companies have been carefully selected by us and are required to meet contractual obligations they have with us. The cookies on the Site may be from any of the following categories:

• Strictly Necessary cookies – these are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.
• Functionality cookies – these are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat user of the Site and help us remember your preferences (for example, your choice of language or region).
• Analytical – these record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

We may share information that we collect through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies

If you have questions, comments or concerns about the Privacy Policy, please send us an email to support@codedsolution.xyz