Privacy policy

1. Introduction

Welcome to GoNiña! 1/3 of the world's food production is wasted. This equates to 1.3 billion tons per year and accounts for 10% of global greenhouse gas emissions. We have made it our mission to change this. We offer a platform where suppliers can sell their surplus food to consumers at a reduced price. This Privacy Policy explains how we treat your personal data and how we use cookies, in accordance with the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR).

2. About this privacy policy

In this Privacy Policy (where applicable; available on our Platforms or via the links in Section 3), we explain how we collect and process your data, depending on your relationship with us.

It should be read in the context of any other agreements and terms and conditions in place between us.

Each point set out in this policy should be read in accordance with the relevant laws of the country or jurisdiction under which your data falls.

The main controller of your data is GoNiña AG, UID CHE-499.164.486, with registered office at Zweierstrasse 35, 8004 Zurich, Switzerland.

If you have any problems accessing this Privacy Policy, please email us at privacy@gonina.com.

3. Definitions

To simplify this Privacy Policy, we would first like to explain some key terms:

"App" refers to the GoNiña app, which is available for cell phones and tablets.

"EU" stands for the European Union.

"EEA" refers to the European Economic Area, which includes all EU member states, Norway, Iceland and Liechtenstein.

"Cookie Policy" refers to the Cookie Policy in Section 6.5 of this Privacy Policy, which applies to our users and businesses, where applicable.

"GDPR" indicates the General Data Protection Regulation (Regulation (EU) 2016/679)

"Platform" refers collectively to our website, mobile application and all services and products offered online

"Shops" or "partners" are companies such as supermarkets, bakeries, canteens, restaurants, etc. that use our platform to offer surplus food.

"Wundertüte" stands for the bags that can be reserved in the app, which contain various surplus foods.

"GoNiña" (or "we", "us", "our") refers to our company GoNiña AG, UID CHE-499.164.486, with registered office at Zweierstrasse 35, 8004 Zurich, Switzerland, as well as our affiliated companies worldwide.

"Website" includes all domains under www.gonina.com and www.goniña.com

"User" describes you as a consumer using our platform.

4. Data that we collect from users

4.1 Data required for the use of the app

When you use the app, we collect personal data about you as a user. Without this data, we would not be able to provide all the requested services. This data includes:

Location query : Country and your exact or approximate location, depending on whether you choose to (i) share your location with us or (ii) enter your location manually.

Responses from trusted payment service providers: We do not collect credit card information. However, when you make a reservation in the app, we will collect responses from trusted payment service providers. Depending on the payment method, this may include a subscription ID that is sent to the payment service provider.

Delivery information: When you make a purchase in the app that can be delivered, we collect your name and address to be able to deliver the purchased items to you. If you choose to provide your email address and phone number to receive notifications, we will also collect this data.

We process this personal data because it is necessary for the performance of the contract with you for the provision of the Platform.

With regard to location requests, we process this personal data on the basis of your consent, which you give in the settings of your cell phone or tablet (consent can be withdrawn at any time).

We may also process this personal data on the basis of our legitimate interests in order to provide, improve and develop our platform communicate with you provide, customize, evaluate and improve our advertising and marketing and as further explained in Section 6 of this Privacy Policy. Where required by applicable law, we will ask for your consent before using your personal data for marketing purposes, including sending you direct marketing communications.

4.2 Data you provide to us

You are free to provide us with additional personal data about you. This data may include:

Additional profile information such as: Name, phone number, email, home address, business address , your gender identity, date of birth and information you have given us about your preferences, such as preferred stores, food preferences, other preferred locations and preferred pick-up times.

Other data: such as when you complete a form, when you answer surveys, enter promotions, competitions or prize draws or when you communicate with our customer service team. This may include demographic and eligibility information and health data if you choose to share it with us.

Our legal basis for this processing is our legitimate interest or, where required by applicable law, your consent. Where we rely on your consent for our processing, we will explicitly ask for your consent.

If we do not ask for your consent, we process this personal data because it is necessary for the purposes of the legitimate interests pursued by us in order to provide, improve and develop the Platform communicate with you, including responding to your requests provide, customize, evaluate and improve our advertising and marketing as further explained in Section 6 of this Privacy Policy.

We will never ask or require you to provide us with personal data. However, if you voluntarily submit health data or other special categories of personal data to our customer service team, e.g. information about allergies, we will process this data on the basis of our legitimate interests and to establish, exercise or defend legal claims where necessary.

4.3 Automatically collected data when using the platform

When you use the platform, we will automatically collect some personal data. This may include:

Usage data: such as the pages or content you view, click on or share, clickstream patterns and the time you spend on each website, as well as the searches you conduct, reservations and purchases you make and the services of our app you use.

Log data and device information: such as details about your use of the Platform (including the fact that you have clicked on links to third party applications), IP address, access dates and times, hardware and software information, device type, device event information, unique identifiers (e.g. IDFA and IDFV), crash data and the pages you have viewed or accessed on the Platform and before or after using the Platform.

Cookies and similar technologies: as described in section 6.5.

We process this personal data on the basis of our legitimate interests to provide, improve or develop our Platform provide, customize, evaluate and improve our advertising and marketing as further explained in section 6 of this Privacy Policy.

4.4 Data we collect from third parties

We collect personal data from other sources, such as

Third party services: When you link, connect or log in to the Platform with a third-party service (e.g. Facebook), you instruct the service provider to provide us with profile information, such as your name and email address, which is controlled by that service provider or authorized by you through your privacy settings with that service provider.

We process this personal data on the basis of your consent, which you give when you instruct the third-party provider to send us your profile information.

4.5 Data collected from the recipients of our email communications

GoNiña engages external service providers to send our email communications. These service providers may collect the following data about the recipients of our emails who opens the email (IP address, user ID, email address), when the email is opened (date and time) which links in the email the recipients click on whether the email is received via a mobile device or browser and the links are activated which operating system is used, and Information about which communication/campaign from our side the above refers to.

We receive reports containing the above data from our external service providers. We use this data to analyze which links in our email communication the recipients click on and use this data to shape our future email communication.

We process this personal data on the basis of our legitimate interest in being able to customize future email messages based on the data collected.

5. DATA WE COLLECT FROM OUR PARTNERS, VENDORS AND OTHER BUSINESS CONTACTS

5.1 Data required for the use of the Platform

When you register and create a vendor account to make Wonder Bags available for reservation on the Platform or use our digital solution to manage expiration dates in your store, we collect some personal data about you as a store contact or store owner.

This data includes:

Profile information: Name, email address, phone number, store address, store name, type of store, your role in the store.

Tax and bank information: the VAT number of your business and your bank details.

If you are an individual business owner, we process this personal data because it is necessary for the performance of the contract for the use of the platform by the business.

If you are an employee of the store, our legal basis for processing this personal data is our legitimate interest in being able to provide the Platform.

We may also process the above personal data because it is necessary for the purposes of the legitimate interests pursued by us to provide, improve and further develop the Platform communicate with our partners and app users provide, customize, evaluate and improve our advertising and marketing as explained in more detail in section 6 of this Privacy Policy. Our legal basis for this processing is our legitimate interest or, where required by applicable law, your consent. If we rely on your consent for our processing, we will explicitly ask you for it.

5.2 Automatically collected data when using the Platform

When you use the Platform, we will automatically collect some personal data from your use of the system.

This may include the following:

Usage data: e.g. the pages or content you view, click on or submit, clickstream patterns and the time you spend on each website, as well as the searches, reservations and purchases you make and the actions you take on the Platform,

Log data and device information: e.g. details of how you used the Platform, IP address, access dates and times, hardware and software information, device type, devices, event information, unique identifiers (e.g. IDFA and IDFV), crash data and the pages you viewed or accessed before or after using the Platform,

Cookies and similar technologies: as described in section 6.5.

We process this personal data on the basis of our legitimate interests to provide, improve or develop our Platform provide, customize, evaluate and improve our advertising and marketing as further explained in Section 6 of this Privacy Policy.

5.3 Data collected from our vendors and other business partners

As part of our daily business operations and communication and interaction with our vendors and other business partners, we collect some personal data about you as a vendor or other business partner or as an employee of one of our vendors or partners:

Company contact information: Name, e-mail address, telephone number, company name, address and type of company and your function in the company.

Tax and banking information: your company's VAT number and your bank details if you are a retailer.

If you are a retailer, we process this personal data because it is necessary for the performance of the contract we have concluded with you.

If you are an employee of one of our suppliers or business partners, the legal basis for processing personal data is our legitimate interest in the performance of a contract with your employer.

We may also process the above personal data on the basis of the legitimate interests pursued by us to provide, improve or develop our Platform communicate with you provide, customize, evaluate and improve our advertising and marketing as explained in more detail in section 6 of the Privacy Policy

5.4 Data that you have provided to us

You are free to provide us with additional personal data about you. This data may include:

Email correspondence: data that you submit as part of our email correspondence.

Other data: Data that you provide to us on your own initiative in connection with support requests or other interactions with us.

The legal basis for processing this personal data is our legitimate interest or, where required by applicable law, your consent. If we rely on your consent for our processing, we will explicitly ask you for it.

If we do not ask for your consent, we process this personal data because it is necessary for the purposes of the legitimate interests pursued by us in order to provide, improve and develop the Platform communicate with you provide, customize, evaluate and improve our advertising and marketing as further explained in section 6 of the Privacy Policy.

We will never ask or require you to provide us with special categories of personal data. However, if you voluntarily submit health data or other special categories of personal data to us, we will process this data on the basis of our legitimate interests and to enable us to establish, exercise or defend legal claims. In specific cases where required by applicable law, we may base the processing of personal data on your consent.

5.5 Data that we collect from third parties

We collect personal data from other sources such as:

Third party services: When you log in to the Platform through a third party service provider (e.g. Facebook), you instruct the third party service provider to provide us with profile information such as your name and email address as directed by that third party service provider or as authorized by you through your privacy settings with that third party service provider.

We process this personal data on the basis of your consent, which you give when you instruct the third party provider to send us the above-mentioned data.

We may also collect personal data in the form of your name, contact details and other relevant business information, such as your role and the company you work for, from publicly available sources such as the internet:

Websites, and online directories where we need to contact you for a specific purpose in the course of our day-to-day business operations, or where permitted by applicable law for marketing purposes and where your consent is not required under applicable law. Our legal basis for this processing is our legitimate interest in being able to contact you as part of our day-to-day business operations and to promote our services.

5.6 Data collected from the recipients of our email messages

GoNiña uses external service providers to send our email communications. These service providers may collect the following personal data about the recipients of our emails who opens the email (IP address, user ID, email address) when the email is opened (date and time) which links in the email the recipients click on whether the email is received via a mobile device or browser and the links are activated which operating system is used, and data on which communication/campaign from our side the above refers to.

We receive reports containing the above data from our external service providers. We use this data to analyze which links in our email communications readers click on and use this data to shape our future email communications.

We process this data on the basis of our legitimate interest in being able to design future email messages based on the data collected.

You can unsubscribe from receiving our marketing emails at any time by clicking on the unsubscribe link in our marketing emails or by sending us an email to unsubscribe at privacy@gonina.com.

6. HOW WE USE THE DATA WE COLLECT

6.1 Providing, improving and developing the Platform

We will use some of the personal data we collect about you to provide you with the best possible platform.

For users of our app, this includes:

Creating and managing your account with us and processing your reservations,

Personalizing and customizing your experience based on your interactions with the platform, your search and purchase history, and your profile information and preferences, e.g. by displaying a map or list view of nearby stores and suggesting the most relevant stores,

Performing analysis, troubleshooting and market research,

Performing analytics to provide you with relevant features.

For users of the provider website of our platform, this includes

Creating and managing your store's account with us and processing reservations for wonder bags in your store,

Informing your store about orders, payments and required actions,

Informing users about updates to your store, e.g. cancelations,,

Manage payment to your store for Wonder Bags sold,

Personalizing and customizing your experience based on your interactions with the platform

Performing analytics, troubleshooting and market research,

Performing analytics to provide you with relevant features.

The processing of personal data is carried out in good faith and is proportionate

6.2 Communication with you

We will use some of the personal data we collect about you to communicate with you. This includes:

Responding to your emails and/or support requests,

Sending you notices of a technical or legal nature, e.g. if our policies change or if one of your reservations has been canceled by a business,

Notifications and announcements about us and our products via email, SMS and/or push notifications, if you have opted in to receive such communications.

To the extent permitted by local law, we may send you marketing communications without relying on your consent as a legal basis or relying on your soft opt-in to receive such marketing communications.

6.3 Providing customization, evaluation and improvement of our advertising and marketing

For users:

We will use some of the personal data we collect about you to support our ongoing efforts to raise the profile of food waste as an issue. This may include the following:

Personalizing, evaluating and improving our advertising,

Analyzing preferences to customize our promotional messages, marketing, advertising and other information,

Sending promotional messages, marketing and advertising based on your preferences and advertising on social media through the relevant platforms,

conducting surveys, contests, sweepstakes or other promotional activities or events sponsored or administered by GoNiña or its partners, and inviting you to events and relevant opportunities.

For partners or employees of partners:

We will use some of the personal data collected about you to support our ongoing efforts to establish food waste as an issue. This may include the following:

Personalizing, evaluating and improving our advertising,

Analyzing how you and our other partners use the Platform to customize our promotional messages, marketing, advertising and other information,

Sharing your information with third parties, such as our advertising networks (only if you have allowed marketing cookies on the Platform provider website), to help us identify other individuals and businesses who want to join our mission to reduce food waste,

Sending you promotional messages, marketing and advertising based on your preferences and social media advertising via the relevant platforms

Conducting surveys, promotions or events sponsored or organized by GoNiña or its partners and inviting you to events and relevant opportunities.

6.3.1 Targeted advertising

We ourselves or third-party providers may use your personal data to provide you with targeted advertising when you use our platform or visit other websites. This may involve the use of cookies, clickstream data and other similar technologies. For example, if you search for information related to our services, we or our third-party provider may arrange for an advertisement to appear on other websites you visit with information about our app and our services. This form of advertising, sometimes referred to as "targeted advertising", "behavioral advertising" or "cross-contextual behavioral advertising", allows us and our vendors to know your interests in connection with the placement of a particular ad. We believe that this type of advertising is helpful because it allows you to see advertising that is relevant to your interests.

6.4 Automated decision making

GoNiña uses automated decision-making processes when processing your personal data for some services and products. An example is our fraud prevention and detection efforts on our platform, which are designed to protect our business from fraudulent use of our services and to ensure the confidentiality, integrity, availability and resilience of our platform.

You may request that GoNiña provide information about the nature of the automated decision-making and that we verify that the automated decision-making has taken place correctly.

We may refuse the request where permitted by applicable law, for example, if providing the information would result in the disclosure of a trade secret or would impede the prevention or detection of fraud or other crime. However, in these circumstances we will generally verify that the algorithm and source data perform as expected without error or distortion.

6.5 Cookies and similar technologies

Our website uses cookies and similar technologies to improve the user experience and to provide certain services and functions. A cookie is a small text file that is stored on your computer, tablet or smartphone when you visit a website. You can change your cookie settings in your browser to block or delete cookies. You can find more information about the cookies and similar technologies we use in the table below:

Name: ActiveCampaign
Purpose: Email marketing and automation
Type: Marketing
Duration: 1 year
Source: ActiveCampaign, LLC

Name: Facebook
Purpose: Social media integration and tracking
Type: Marketing
Duration: 90 days
Source: Facebook, Inc.

Name: Firebase
Purpose: App development and analytics
Type: Analytics
Duration: Varies
Source: Google LLC

Name: Google Ads
Purpose: Ad personalization and measurement
Type: Marketing
Duration: 90 days
Source: Google LLC

Name: Google Analytics
Purpose: Analysis of user behavior
Type: Analytics
Duration: 2 years
Source: Google LLC

Name: Google Tag Manager
Purpose: Management of website tags
Type: Necessary
Duration: Session
Source: Google LLC

Name: Instagram
Purpose: Social media integration and tracking
Type: Marketing
Duration: 90 days
Source: Facebook, Inc.

Name: Intercom
Purpose: Customer communication and support
Type: Necessary
Duration: 1 year
Source: Intercom Inc.

Name: LinkedIn
Purpose: Network analysis and advertising tracking
Type: Marketing
Duration: 90 days
Source: LinkedIn Corporation

Name: Sentry
Purpose: Error monitoring and analysis
Type: Necessary
Duration: Session
Source: Functional Software, Inc.

Name: Stripe
Purpose: Payment processing
Type: Necessary
Duration: Session
Source: Stripe, Inc.

Name: Twint
Purpose: Payment processing
Type: Necessary
Duration: Session
Source: Twint AG

Name: Wallee
Purpose: Payment processing
Type: Necessary
Duration: Session
Source: Wallee AG

7. REASONS WHY WE TRANSFER DATA

7.1 Sharing with your consent or at your direction

If you give your consent, we will transfer your personal data as described at the time of consent, for example, when you allow a third party application or website to connect to your GoNiña account or participate in promotions with GoNiña partners or third parties.

If you have opted in to marketing cookies on our Platform, we may transfer your personal data to third party advertising platforms to increase awareness of our Platform and our mission, drive traffic to the Platform or otherwise promote our Platform, as further described in Section 6.3 and Section 6.5 of this Privacy Policy.

7.2 The GoNiña Group of Companies

To assist us in providing, promoting and improving the Platform, we may transfer personal data within our group of companies, which consists of a controlling company and its dependent companies, worldwide. When we transfer personal data within the GoNiña Group, we have put in place appropriate contractual, technical and organizational security measures to protect your personal data in accordance with applicable law.

7.3 Processors

We may transfer personal data to service providers who help us run our business and provide the Platform. These service providers may assist us in fulfilling the purposes set out in this Privacy Policy, including (but not limited to) by

Processing payments for reservations, purchases and refunds on the Platform, hosting software functions that enable the functioning and development of our Platform Provision of hosting services, supporting tools to improve the functionality, availability, resilience and security of the platform, Performing data analysis, Providing evaluations for our ads and campaigns,

Automating the delivery of SMS, emails and ads, such as sending newsletters,

Managing our social media presence and online advertising,

Providing integrated tools that help us provide customer service.

When we engage a service provider to process personal data on our behalf, we ensure that they are contractually obliged to protect your personal data by entering into a privacy policy.

Some of our service providers are based in countries and process your personal data in countries that do not provide an adequate level of protection for personal data under EU/EEA, Swiss and UK law. Where this is the case, we will ensure that your personal data is adequately protected by ensuring that appropriate safeguards are in place in accordance with the law applicable to the transfer of personal data and as further explained in Section 8 of this Privacy Policy.

We use Google's "ReCAPTCHA" tool on our website, which allows us to verify that you are not automated software. For this purpose, this tool analyzes various parameters such as IP address, device information and cursor movement patterns, which may lead to the processing of your personal data. The ReCAPTCHA functions are subject to the current version of Google's data protection provisions and terms of use.

7.4 Third party location collection

We work with third parties who collect location information to provide our Platform and help us with our day-to-day business operations, as described below. These third parties may process personal data for their own purposes as a controller.

If you are a user of our website, we may provide your approximate geographic location (at city level) (subject to your consent as described in section 4.1) to our third party geographic location service provider, Google.

When you make a purchase in the App that can be delivered, we share the delivery address provided with our third-party geolocation provider, Google, to verify the delivery address. Our legal basis for sharing this data is our legitimate interest in being able to verify that the delivery address provided is actually an existing address so that our courier service can deliver your order.

If you are a user of the platform provider website, we share your store's address with our third-party geolocation provider, Google, based on our legitimate interest in seeing where your store is located because it is necessary for the purposes of the legitimate interests we pursue to: provide, improve and develop the Platform communicate with you provide, customize, evaluate and improve our advertising and marketing.

The functions and content of Google Maps are subject to the respective current versions of the following provisions: (1) Additional Terms of Use for Google Maps/Google Earth at https://maps.google.com/help/terms_maps.html; and (2) Google Privacy Policy at https://www.google.com/policies/privacy/. We recommend that you familiarize yourself with these terms before using our services.

7.5 Franchisor (only relevant for franchisees)

If you are a franchisee belonging to a franchise chain, we may transfer the following personal data to your franchisor, depending on the agreement we have with your franchise chain:

Name

E-mail address

Name and address of the business

Data about the use of the platform by your stores (e.g. saved portions, saved wonder bags, )

Data about users' experiences with your business, including reviews transaction data, and

data relevant to the franchisor about the communications and interactions you have had with our customer service team.

If you are an employee of a franchisee, we may share your name and email address relevant to the platform with the franchisor.

Our legal basis for sharing this personal data is our legitimate interest and that of the franchisor to manage your franchise chain agreement with us and the presence of your business on the Platform.

7.6 Public bodies

We may only disclose your personal data to courts, law enforcement, government or public authorities, including the police in connection with criminal investigations, if and to the extent that we are required or authorized to do so by law.

7.7 PR and media agencies

We may transfer your personal data to third parties such as PR, media or other advertising agencies if you have consented to participate in our promotional activities or have entered into a contract with us to participate in such promotional activities. Depending on the circumstances, these PR and media agencies may process personal data either as independent controllers or as processors on our behalf and under our instructions. Where the PR or media agency processes personal data as a processor, our relationship will be governed by a data processing agreement in accordance with applicable law.

7.8 Transfer of business

In the event that we are involved in a bankruptcy, insolvency, merger, acquisition or reorganization, your personal data may be transferred to advisors, counterparties, authorities and other relevant third parties as part of this transaction (e.g. for due diligence purposes). This Privacy Policy will continue to apply to your personal data even if it has been transferred to a new GoNiña entity.

7.9 Disclosure to other third parties

In order to provide you with our services, we may need to engage third party service providers such as freight forwarders or logistics partners to assist us in fulfilling our contractual obligations and to protect our legitimate interest in sending advertising. These service providers have access to personal data solely for the purpose of providing the services on our behalf. We ensure that all third party service providers engaged by us are bound by appropriate data protection and confidentiality obligations.

8. INTERNATIONAL DATA TRANSFER

Any transfer of your personal data by GoNiña from the EU/EEA, Switzerland or the UK to third countries outside these territories will be based on an adequacy decision of the EU Commission or governed by applicable standard contractual clauses and/or binding corporate rules or equivalent appropriate transfer mechanisms, unless you are informed otherwise. All other international transfers of your personal data not originating from the EEA, Switzerland or the United Kingdom will be made in accordance with the relevant international data transfer mechanisms and safeguards applicable to the transfer of your personal data under local law.

You may request a copy of the transfer mechanism for the transfer of your personal data by sending a request to privacy@gonina.com.

9. RETENTION PERIOD

We will retain Personal Data for as long as is necessary or permitted in light of the purpose for which it was collected and in accordance with applicable law. The criteria for determining our retention periods include, but are not limited to

the duration of our business relationship and the provision of our Platform to you, e.g. for as long as you have an account with us or continue to use the Platform,

the existence of a legal obligation applicable to us under which we are required to keep records of your transactions for a certain period of time before we can delete them, and/or

storage is advisable in view of the existing legal situation, e.g. with regard to applicable limitation periods, legal disputes or official investigations.

10. SECURITY

The security of your personal data and our platform is a top priority for us.

We have implemented appropriate technical and organizational (including physical) security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal data we have transferred, stored or otherwise processed.

In addition, we only work with suppliers who implement appropriate technical and organizational security measures in accordance with industry best practices for good IT security.

In the event of a data breach, the data subjects and the Federal Data Protection and Information Commissioner (FDPIC) will be informed within 72 hours.

11. YOUR RIGHTS

If you are a resident of the EU/EEA, Switzerland or the UK, you have the following rights in relation to our processing of your personal data, subject to the conditions and exceptions set out in applicable law:

Right of access: you have the right to obtain access to the personal data that we process about you.

Right to rectification: You have the right to have inaccurate personal data that we hold about you rectified.

Right to erasure: You have the right to have personal data erased. Please note, however, that the exercise of the right to erasure may be restricted under applicable law.

Right to restriction of processing and right to object: You have the right to ask us to restrict the processing of your data and can object to the processing.

Right to data portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format.

Right to object: If the processing of your personal data is based on consent, you have the right to withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Please note that certain personal data may be exempt from the above rights under applicable data protection laws or other laws and regulations.

11.1 Easy access to exercise your rights directly in our app

Our app gives you full control over your personal data. We have integrated "privacy by design" and "privacy by default" on our platforms and have user-friendly features that allow you to exercise your rights directly in the app, e.g. to delete your personal data, as well as an option to obtain a copy of the personal data we process about you. If you wish to exercise your rights directly in the App, please consult your account settings in the App.

You can also:

unsubscribe from our newsletter

request a copy of your data, or

delete your account

by sending your e-mail address to us via privacy@gonina.com.

11.2 Requests and complaints

If the information provided in our App is not sufficient or you wish to exercise rights other than those available directly in the App or as described above, you are welcome to contact us at: privacy@gonina.com.

We will endeavor to respond to your request without undue delay and in any event within one month of receipt. If your request is complex, we may need more time to process it and may extend this period by a further two months.

You always have the right to lodge a complaint with a competent data protection authority - even if you are not satisfied with our response. However, we recommend that you always contact us first so that we have the opportunity to help you with your request.

The contact information for the Federal Data Protection and Information Commissioner (FDPIC), the supervisory authority in Switzerland where GoNiña is headquartered, is as follows:

Website: www.edoeb.admin.ch

Address: Feldeggweg 1, 3003 Bern, Switzerland

12. DATA PROTECTION FOR CHILDREN

Our Platform is intended for users who are 18 years of age or older and we do not knowingly collect personal data from anyone under the age of 16. If we learn that personal data (or other data protected under applicable law) has been collected from a child under the age of 16, we will make all reasonable efforts to delete that data from our databases. If you believe that we might have any Personal Data from or about a child under the age of 16, please contact us using the information in Section 14.

13. CHANGES TO THE PRIVACY POLICY

You can find out about any changes to this Privacy Notice on our website and app. If we make material changes to the Privacy Policy, we will notify you on the Platform or via the email you provided when you registered on our Platform.

14. CONTACT INFORMATION

If you have any questions about the processing of your personal data, please contact our data protection team using the contact details below.

GoNiña AG, Zweierstrasse 35, 8004 Zurich, Switzerland

Company identification number (UID): CHE-499.164.486

E-mail: privacy@gonina.com

Zurich, September 2023, GoNiña AG