PURE’S PRIVACY POLICY

This privacy policy (“Privacy Policy”) applies to the use of the website https://pure.app/ in its entirety, including all of our subpages, associated sites or pages (“Website”), and the PURE mobile and web app, which is accessible through browser on mobile phone, tablet computer and personal computer (“App”) (collectively, “PURE”), are operated by Online Classifieds AG, Steinhauserstrasse 74, 6300 Zug, Switzerland, CHE-274.401.166 (“we”, “us”, “our”).

We are responsible for all information relating to an identified or identifiable natural and, where applicable, legal person (“Personal Data”) that we collect, process, and use during your use of PURE. We care deeply about protecting your privacy. We are committed to handling your Personal Data in accordance with applicable laws and to making PURE a service that people love and trust.

This Privacy Policy outlines how we process your Personal Data both in connection with PURE and otherwise.

1. What Personal Data do we collect?

a. When visiting the Website and/or App

When you visit the Website or App, we can process the following categories of Personal Data from you:

• Technical data: IP address, operating system, date and time of access, country from which PURE is accessed, browser type, referrer URL, log-in data, device type;
• Tracking data: see section 4 below.

b. When using PURE

When you use PURE, you voluntarily provide us with certain information. When you create an account, add information to your user profile, or interact with us you make the choice to share information personal to you with us. In this way, we can process the following categories of your Personal Data:

• Identity data, including email, date of birth, gender, details about your bio, preferences;
• Account data, including User ID; 
• Transactional data, including information about the application process, contract content, contract management and execution;
• Financial data, including billing and payment information;
• Sexual identity data, including sexual orientation and sexual preferences;
• Pictures, videos, audio and text messages sent when communicating with other users that are processed in order to secure and operate services and keep our user community safe;
• Pictures and videos that you upload, publish or provide in any other way. In order to add this kind of content, you first have to give us permission to access your photo album/gallery and/or your camera;
• Your insights into our products and services, responses and testimonials your provide us when you participate in surveys, market studies or answering questions;
• Information that is used for participation in different contests, events and promotions we provide;
• Location data, including geographical position, time identifier;
  PURE is designed to help you engage with other users located nearby to you. We use your location data (e.g., by using the GPS on your mobile device) to enable the intended functionality of PURE. This will be enabled only if you explicitly give us permission to access your location. You can disable this at any given time by changing the location permissions on your device or in the browser. Please keep in mind that when you use PURE, other users can view your location data and they may use it for purposes you did not intend, or disclose it to individuals or entities outside of our control and without our and your knowledge. The information you provide may be subject to abuse, misuse, and monitoring by others, and you share this information at your own risk.
• Usage data, including activity data, online interactions with us and with other users;
• If you contact our customer support team, we collect the information you give us during the interaction.
• Photographic image of you and your form of identification that can confirm the date of your birth when appealing our decision to revoke your license, any authorization to access and/or use PURE and terminate your account for failure to comply with our rules on minimum required user age (see more here).

We receive most of your Personal Data directly from you. To the extent permitted by applicable law, we can also obtain your Personal Data from publicly available sources or from public authorities and other third parties (e.g., service partners, internet analysis services).

2. How do we use your Personal Data?

We can use your Personal Data for the following purposes:

• Business relationships: Establishing, administrating, and processing of contractual relationships, including the creation and management of a user account that allows you to make full use of PURE;
• Ensuring the core functionality of the business and PURE: Maintenance, provision, improvement, and monitoring of PURE;
• Security and access control: Monitoring, analyzing, and testing of networks and IT infrastructures, system and error checks, documentation, security copies, and communication of security updates;
• Market and opinion research: Monitoring and analyzing your use of PURE, using statistical data for scientific and analysis purposes, further developing the offers we provide on PURE, administering focus groups, determining user demographics, and conducting market studies and surveys;
• Advertising and marketing, including promotional offers, events, and contests;
• Compliance with laws and regulatory recommendations and directives: Know your customer (KYC) clarifications, fulfillment of disclosure, information and reporting obligations, fulfillment of archiving obligations, and the prevention, detection, and clarification of criminal acts;
• Safeguarding legal claims: Assertion, enforcement, and defense of legal claims.

3. What legal basis do we rely on when processing your Personal Data?

We process your Personal Data based on the following legal bases:

• Performance of contractual obligations: It is necessary for us to process your Personal Data to provide PURE to users and thus carry out our obligations under the terms and conditions of PURE (e.g., create user account, receive payments);
• Legitimate interests: It is necessary to process your Personal Data to pursue our legitimate business interests, provided that your rights and freedoms do not override these legitimate interests, which include but are not limited to the protection of PURE and enhancing the functionality and efficiency of PURE;
• Compliance with applicable laws and regulations: It is necessary to process your Personal Data to comply with our legal obligations (e.g., accounting, tax, and other statutory data retention obligations);
• Your consent: If you choose to provide us with Personal Data that may be considered sensitive in certain jurisdictions, such as your sexual identity data, you are giving us consent to process that Personal Data in accordance with this Privacy Policy. We may explicitly ask for your consent to collect specific Personal Data such as your precise geolocation, to transfer your Personal Data to countries without an adequate level of data protection, or to use your Personal Data for certain specific reasons (e.g., direct marketing). You may withdraw your consent at any given time by contacting us as stated in this Privacy Policy.

4. Online tracking and analysis

a. Cookies

We use and may allow others to use cookies and similar technologies on PURE to recognize you and/or your device(s). You may read our cookie policy (see here) for more information on why we use them and how you can have better control over their use.

b. Analytics

We use analytics and research technologies on PURE to collect information about how visitors use PURE. For the analytics technologies that we use on our web platforms, you may read our cookie policy (see here) for more information on why we use them and how you can better control their use.

c. Log files

When using PURE, general access data is stored in a log file for the creation of statistics. We use this data for statistical and technical evaluations in anonymized form, for example to optimize the server infrastructure, to determine on which days there are particularly many accesses, or to draw conclusions about possible improvements to the user interface and functionalities. A personal evaluation of this data does not take place.

5. Social networks

There are links on our Website to our profiles on the following social networks:

• Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA 94025, USA please find more information about data protection here.
• Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, please find more information about data protection here.
• TikTok Inc., 5800 Bristol Parkway Culver City, Los Angeles, CA 90230, USA, please find more information about data protection here.

If you click on the social network icons, you will automatically be redirected to our profile on the corresponding social network.

When you open a link to one of our profiles, a direct connection is established between your browser and the server of the relevant social network. This provides the network with the information that you have visited PURE with your IP address and accessed the link. If you access a link to a network while logged into your user account on the network in question, the content of PURE may be linked to your user account on the network, i.e., the network may link your visit originating from PURE directly to your user account on the social network. If you want to prevent this, you should log out from your account before clicking on the corresponding links. In any case, an association takes place when you log in to the relevant network after clicking on the link.

6. What Personal Data do we share with third parties?

We may transfer your Personal Data abroad to third parties that may be located in any country in the world (in particular in other countries in Europe, Hong Kong, and the USA). These countries may have different laws about data processing and, as the case may be, data protection laws that have been deemed inadequate by competent authorities to protect your privacy rights.

The data recipients are obliged to protect your Personal Data in accordance with the agreed contractual obligations and the applicable data protection laws. If the level of data protection in a country does not correspond to the Swiss or European level, we will contractually ensure that the protection of your Personal Data always corresponds to the level in Switzerland or the EU. For this purpose, we agree with the third parties on the EU standard clauses and, if necessary, implement additional technical and organizational measures.

In particular, we may disclose your Personal Data to the following categories of recipients:

• Service providers: We work with trusted service providers that process your Personal Data on our behalf or under joint responsibility (e.g., providers of telecommunications systems, email, database, hosting, outsourcing, payment, user verification, advertising, marketing, analytics, anti-spam, anti-fraud services). These service providers may also use your Personal Data for their own purposes. Service providers provide information about their independent data processing in their own privacy statements.
• Buyers or merger partners: In connection with an actual or potential restructuring of part or all of our business or our assets or any rights or interests therein, we may disclose your Personal Data to potential buyers or merger partners or sellers and their advisors.
• Government agencies: We may disclose your Personal Data to governmental agencies, courts, and other authorities, both domestic and foreign, if we are legally obligated or entitled to do so or if we deem it necessary to do so in order to protect our interests.

7.  What Personal Data do we receive from third parties?

By signing in PURE using your Facebook account you give permission to Facebook to share your email address, name and your profile picture with PURE. You have an option to manually opt-out of permission to allow Facebook sharing your email address with PURE, however this is only possible when an email is associated with your Facebook account.

By signing in to PURE using your Apple ID you give permission to Apple to share your Apple login, your name and your email with PURE. Apple is offering an option to hide your email, so you can keep your email address private but still receive messages from the App. To enable this, Apple will create a random email address, link it to your account on PURE and allow your personal email to stay private.

By signing in to PURE using your HUAWEI ID you give permission to HUAWEI to share with PURE your profile picture, your nickname or anonymised phone number/email address if no nickname is set, to link your HUAWEI ID and to share your email address. HUAWEI allows you to manually opt-out of sharing the email address.

By signing in PURE with your Google Account you give permission to Google to share your name, email address, language preference and  with PURE.

Compiled data will be used in order to form your account on PURE. You can always manually withdraw your permission to access the data above by removing the PURE app from the Facebook settings, your Google account or from your Apple ID or by canceling authorization for HUAWEI ID. Data provided at the set up of the account using any of these third party services will still be accessible to PURE, even after you withdraw permission on these third party services. In order to remove our access to this data you will have to delete your PURE account. Your rights regarding, and setting options for protecting your privacy, can be found in the privacy notices of the providers:

• Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA; please find more information about data protection here.
• Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; please find more information about data protection here.
• Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA 94025, USA please find more information about data protection here.
• Huawei Device Co. Ltd., 9 Canton Road, Tsim Sha Tsui, Kwloon, Hong Kong; please find more information about data protection here.

8. How long do we retain your Personal Data?

We only retain your Personal Data for as long as it is needed for the purpose for which it was originally collected or as we are required to retain it under applicable laws and regulations or contractual agreements.

9. How do we secure your Personal Data?

We use appropriate technical and organizational security measures to protect Personal Data from loss, misuse, or alteration. Our employees and the service providers commissioned by us are contractually obliged to maintain confidentiality and to comply with the provisions of data protection law.

However, it is not possible for us to guarantee the absolute security of Personal Data. In this context, please note that data transmitted over an open network such as the Internet or an email service is openly accessible. We cannot guarantee the confidentiality of messages or content shared over these networks. Thus, Personal Data sent to us via open networks will not be subject to the same security measures as Personal Data contained within PURE.

10. Your rights

You have the following rights:

• Access: You have the right to access your Personal Data. This gives you the opportunity to check what Personal Data we process about you and that we process it in accordance with the applicable data protection regulations.
• Rectification: You have the right to have inaccurate or incomplete Personal Data rectified and to be informed of the rectification. In this case, we will inform the recipients of the data concerned of the adjustments made, unless this is impossible or involves disproportionate effort.
• Deletion: You have the right to have your Personal Data deleted under certain circumstances.
• Restrict processing: You have the right, under certain conditions, to request that the processing of your Personal Data be restricted.
• Data portability: You have the right, under certain circumstances, to obtain from us, free of charge, the Personal Data you have provided to us in a readable format.
• Lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a competent supervisory authority about the way in which your Personal Data is processed.
• Withdrawal: You have the right to withdraw your consent to the processing of your Personal Data at any time, free of charge, and without giving any reason by contacting us at the address provided in this Privacy Policy. Processing activities conducted with your consent in the past, prior to you revoking consent, do not become unlawful as a result of your revocation.

Please note that the above-mentioned rights are not absolute. These rights are subject to exceptions and their applicability is largely dependent on the legal basis we rely on in each case and the various circumstances of each specific request.

11. Children's policy

Users who are not at least 18 years old or older when explicitly required by applicable state laws (referred to as “minor/s” hereafter) are not permitted to use PURE. We do not knowingly collect Personal Data from minors.

We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children not to use PURE and thus not to provide Personal Data on PURE. If you have reason to believe that a minor has provided Personal Data to us, please contact us immediately and we will endeavor to delete that data from our databases.

12. Changes to this Privacy Policy

We may change this Privacy Policy to address changes in the legislation or on PURE. Changes to this Privacy Policy will take effect automatically after they are first posted on the Website or App.

13. Contact

If you would like to exercise any of your rights or if you have feedback, comments, or questions about data protection or this Privacy Policy please contact us by email at [email protected] or by mail at alternatively provided postal address.

We also have a selected Data Protection Officer that can be contacted by email at [email protected]. 

Alternatively, you can write to:

Online Classifieds AG
Steinhauserstrasse 74
6300 Zug
Switzerland