Preamble and Acceptance
This Privacy Policy (the “Privacy Policy”) governs your relationship with this website owned by Bey International SA. (the “Website”), which is managed by Bey International SA (“we”, “us”, “our”), with its headquarters at Boulevard Georges-Favon 43, 1204 Geneva.

Please read this Privacy Policy carefully before using the Website. This Privacy Policy explains how information relating to an identified or identifiable person (the “Personal Data”) is collected, used, and protected. Your access to the Website is conditional upon your acceptance of the Privacy Policy and your conduct in accordance with it. By using the Website, you agree to be bound by this Privacy Policy and you consent to our collection, use, and processing of your Personal Data in accordance with this Privacy Policy.

If you do not consent to the terms of this Privacy Policy, please do not use the Website.

1. Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. However, please note that such withdrawal:

– does not call into question the lawfulness of any processing carried out prior to such withdrawal and based on your consent;

– may result in you no longer being able to make use of certain features of the Website.

2. Data Controller

2.1 If you have any questions, please do not hesitate to contact us via team@annabey.com. We will be happy to answer them.

2.2 You may also contact us by post at Boulevard Georges-Favon 43, 1204 Geneva.

3. General Principles

3.1 The information collected on our Website enables us to provide the following services:

(i) links to other websites.

3.2 This Privacy Policy sets out our policies and procedures relating to the collection and processing of Personal Data that you may provide to us by visiting our Website, and/or by using one of the services described in section 3.1 above.

3.3 This Privacy Policy does not apply to services offered offline.

4. Personal Data that We Collect

4.1 We collect Personal Data through the use of cookies and similar technologies. Please see our Cookie Policy, which, for the avoidance of doubt, is incorporated in the Privacy Policy, for further details.

4.2 The Personal Data we collect when you visit the Website may include: your first and last name, email address, and IP address.

5. The Purpose of the Collection of the Personal Data

We use the Personal Data that you provide us with for the following purposes:

(i) to enable you to use the interactive features of the Website when you wish to do so

6. Grounds for processing

6.1 Regarding the use of the Website, we justify the processing of your Personal Data notably on the basis of Article 13 (1) of the Swiss Federal Act on Data Protection (“FADP”).

7. Personal Data Collected by Third Parties (Links to Other Websites)

7.1 This Privacy Policy does not cover how your Personal Data is processed by third parties when we link to their websites. We encourage you to read the privacy policies of other websites you visit.

7.2 Our Website may contain links that take you to other websites, in order to enable you to access the content available on these platforms. When you access another website through our Website, it is the relevant service provider’s responsibility to comply with applicable data protection requirements.

7.3 When you establish a connection to a website, your browser connects directly to the server of the relevant service provider. Through this connection, the website receives the information that your browser has accessed on the relevant page of our Website. This information (including your IP address) is transmitted from your browser directly to the service provider’s server and stored there.

7.4 Please refer to the relevant website’s privacy policy for information in relation to the purpose and scope of the collection of Personal Data by the relevant service provider, the further processing and use of such Personal Data by the relevant service provider, as well as the related rights and settings to enable the protection of your Personal Data.

8. Disclosure of Your Personal Data to Third Parties

8.1 We may provide access to the Personal Data that you have provided to us through our Website to certain independent contractors and affiliated companies to assist us in the operation of the Website. To date, these contractors are as follows:

(i) Sales and Marketing platforms

(ii) Email system provider

8.2 We take all necessary measures to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy and the applicable laws. All our contractual partners undertake to protect the Personal Data by means of procedures similar to ours, unless otherwise provided for in this Privacy Policy.

8.3 The purpose of sharing your Personal Data with the aforementioned third parties is to ensure our business, as well as to maintain and seek to constantly improve our Website, and the services offered to our users. The grounds on which we justify the processing of your Personal Data in this respect are Article 13 (1) and (2) FADP, which authorizes us to process Personal Data when such processing is necessary for the purposes of our legitimate interests.

9. Communication of your Personal Data to the Authorities

9.1 We may need to disclose your Personal Data (including your communications) if we consider it necessary for security reasons, to investigate a potential breach or other violation of this Privacy Policy, and/or to prevent harm to other users of our Website. As a result, we may need to disclose your Personal Data to investigate, respond to, or resolve a complaint or dispute in connection with our Website.

9.2 We may be required to disclose your Personal Data when required to do so by law or when we have a good faith belief that such disclosure is necessary to:

(i) investigate, prevent or take action in relation to potential or actual illegal activities or assist administrative enforcement authorities,

(ii) to execute an agreement between us and you,

(iii) to investigate and defend against a complaint or allegation from third parties,

(iv) protect the security and integrity of our Website or

(v) exercise and protect the rights and safety of our users, employees, or others.

9.3 We shall attempt to notify you of third-party requests for your Personal Data when we believe it is appropriate and technically feasible to do so, except where we are prohibited from doing so by law or an order of authority or where the request is urgent. We may challenge such requests when, in our sole discretion, we consider that the request is formulated too broadly, is too vague, or is unfounded, but we do not guarantee to challenge any request.

9.4 The purpose of sharing your Personal Data with the aforementioned authorities is to meet our obligation under Article 13 (1) FADP, which authorizes us to process Personal Data when such processing is necessary to comply with a legal obligation to which we are subject.

9.5 We do not sell your Personal Data to third parties. We do not share or otherwise make available your Personal Data to third parties, except as otherwise provided in this Privacy Policy.

10. Cross-Border Disclosure of Personal Data

10.1 If, as a result of certain services provided by third parties, we transfer your Personal Data to one of their databases outside the European Economic Area, potentially to a country that does not have a level of protection for personal data comparable to that prevailing in Switzerland or the European Economic Area, unless otherwise provided for in this Privacy Policy, we undertake to enter into an agreement with the third-party service provider to ensure an adequate level of protection for your Personal Data.

11. Protection of your Personal Data and Notification of a Data Breach

11.1 We undertake to use all commercially reasonable means to prevent any exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (including administrative, physical, and technical measures) to deal with unauthorized disclosure or exposure of your Personal Data.

11.2 In the event of an actual or suspected breach of Personal Data, we will

(i) use our best efforts to notify you promptly, where technically feasible, and

(ii) cooperate with you to investigate and resolve the breach, including, but not limited to, providing you with reasonable assistance in notifying affected third parties. We undertake to provide you with access, without delay, and upon reasonable request, to our records relating to the breach of your Personal Data, provided, however, that this does not give you access to records that belong to other users or that could compromise their security.

11.3 In the event of an actual or suspected breach of Personal Data, we undertake to notify the relevant authority under applicable law.

12. Your Rights with Regards to your Personal Data

12.1 Right of rectification: You have the right to obtain the rectification of your Personal Data if it is inaccurate or incomplete.

12.2 Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.

12.3 Right to limit the processing: Within the limits of the law, you have the right to obtain a limitation on the processing of your Personal Data.

12.4 Right to portability of Personal Data: You have the right to obtain a copy of your Personal Data in a structured, commonly used, and machine-readable format.

12.5 Right to Withdrawal of Consent: Within the limits of the law, you have the right to withdraw your consent at any time when the processing of your Personal Data relies on it.

12.6 Right to complain to an authority: You have the right to complain to any competent authority about the collection and use of your Personal Data.

12.7 We may ask you to prove your identity before responding to a request based on the above rights or otherwise related to your Personal Data.

13. Retention of your Personal Data

13.1 We retain the Personal Data you provide to us to the extent required to access and use our Website and its features (such as our newsletter registration forms), as well as to the extent required to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce agreements we have entered into and our internal regulations.

13.2 We reserve the right to store the data in an anonymized form after the deletion of your Personal Data.

14. Security of your Personal Data

We attach great importance to the security of your Personal Data. However, no method of communication over the Internet or method of electronic storage guarantees 100% security. Therefore, although we strive to use commercially acceptable technical and organizational means to protect your Personal Data, we cannot guarantee its absolute security.

15. Personal Data Relating to Children

We do not provide services specifically targeted at children and we do not proactively collect Personal Data from children.

16. Changes to this Privacy Policy

16.1 We may change this Privacy Policy at any time by posting a new version on this page or a deeper page without prior notice. In such an event, you will be notified by a notice on the home page of our Website. By continuing to access or use our Website after the effective date of such change, you agree to be bound by the revised Privacy Policy. If you do not agree to these changes, please do not use our Website.

16.2 We undertake to always treat your Personal Data in accordance with the Privacy Policy in force at the time of collection.

16.3 The new version of the Privacy Policy will be effective on the day of its publication, the date mentioned at the top of this Privacy Policy corresponding to the effective date.

17. Miscellaneous

17.1 Any failure by us to enforce any provision of this Privacy Policy shall not be construed as a waiver of such provision or right.

17.2 If any provision of this Privacy Policy should be held invalid or unenforceable by a judicial authority, the other provisions of this Privacy Policy shall not be affected in any way.

17.3 This Privacy Policy, including the Cookie Policy, constitutes the entire agreement between us and you with respect to the Privacy Policy of our Website. It supersedes and replaces any prior agreement we may have in relation to the privacy policy of our Website.