Data protection declaration
- About us
Les Bains de Lavey SA is a business that offers a trilogy of “well-being, relaxation and health” with a very special touch encouraging emotion and escape. Les Bains de Lavey SA focuses on complete customer satisfaction through its various services with the Baths and 36° water, the Wellness area, and its hotel and restaurants, all in an impeccable environment in terms of hygiene, quality of services, reception and security.
- Basic principles of data processing
This data protection declaration describes how we process personal data, in particular what personal data we collect and for what purposes. It also sets out the sharing of data, the retention period, and your rights. Personal data (hereinafter also referred to as data) means any information relating to an identified or identifiable natural person. The notion of data processing should be understood as dependent on the situation, and includes any operation relating to personal data, whatever the means and processes used, in particular the collection, conservation, use, modification, communication, archiving or destruction of data.
We collect and process personal data in order to carry out our professional tasks in accordance with legal and contractual provisions. The collection, processing and use of personal data are subject to the legal provisions in force in Switzerland1 and, where applicable, in Europe2.
We collect personal data in a transparent manner and in compliance with the principles of proportionality and finality. Data is only processed to the extent and for the duration necessary to fulfil our tasks and obligations.
- Purpose of collecting and processing personal data
We process personal data which is necessary to ensure the sustainability, security and reliability of our offer. This namely includes the following objectives:
- Management and administration of contractual relationships with customers, collaborators, suppliers, etc.
- Management of contacts and communication in the context of service provision;
- Use of the website and authentication of registered users for certain parts of our website;
- Guarantee of security, compliance with legal obligations and exercise of claims;
- Sending invitations and organising events;
- Marketing activities and sending newsletters;
- Statistical collection/analysis;
- What personal data do we process?
- 1 Contact data and general master data
Depending on the purpose of data processing, the customer segment and service areas, we collect different types of personal data, including, in certain circumstances, sensitive data.
At a minimum, we process the following personal data for all contacts, interlocutors, contractual partners and customers:
- Surname, first name, email address and, where applicable, gender, address, telephone number, title, date of birth, nationality, profession, title, OASI number, bank account number, marital status,
- Electronic and written (e-mail) correspondence.
Furthermore, depending on the purpose of data processing, the customer segment and service area, we collect and process additional data in accordance with the descriptions set out in the following paragraphs.
- 2 Data for e-mail campaigns and newsletters
For sending information about events, publications, etc. (for marketing purposes) as well as for sending newsletters, we process the following personal data:
- Contact data and general master data according to ch. 4.1;
This data is necessary for the provision of the service, for communication and for the management of our customer base. Information relating to marketing, e-mail
campaigns and newsletters is also subject to statistical analysis in order to constantly improve our services.
You can at any time object to the use of your personal data for marketing purposes or unsubscribe from the newsletter.
- 3 Data for the organisation and running of events
The following personal data is processed for the organisation and running of events:
- Contact data and general master data according to ch. 4.1;
For online events, the data referred to in section 4.5 is also processed.
The first name and last name, may be disclosed to other participants if, for example, a person has expressed interest in an event on social networks (Facebook only). You may also be photographed or filmed during events, however your consent will be requested if you are clearly recognisable in any image taken by our staff.
This data is processed for the organisation of events, networking and marketing purposes. We need the images for internal documentation of the event, for inclusion in a newsletter or on our website and social media networks, for writing reports and, where appropriate, to inform our members about the event. Participants have the opportunity to let the photographer know, before or at the time of photographs being taken, that they do not wish to appear in said
images.
- 4 Data related to direct communication (telephone, e-mail or chat, online meetings, video conferences and/or webinars, etc.)
The online meetings, video conferences and/or webinars that we organise are carried out with Microsoft Teams / Zoom / Skype / Google Meet, etc. For direct communication by telephone, e-mail, chat or through a collaboration platform, we, and if necessary our corresponding service providers, may process the following personal data:
- Contact data and general master data according to ch. 4.1;
- Other personal data contained in the email;
- Communication data such as IP address, time and duration of communication;
- Video conference recordings, if necessary;
We process this personal data to provide and improve our services to our customers and other interested third parties.
- 5 Employee data
Instead of being included in the general data protection declaration, this information could also be included in an additional annex to the employment contract or in an internal directive.
The declaration must, however, include information concerning the application file.
The following data is processed for employee management:
- Contact data and general master data according to ch. 4.1;
- Data relating to social insurance / OASI number;
- Information about children;
- Information about the position within our company, such as date of hire, position, salary, employment contract;
- Informations relatives à la candidature telles que lettre de motivation, CV, certificats de travail, diplômes, évaluation des entretiens d’embauche, références ;
- Financial information and bank details;
- For employees taxed at source: confession, residence permit, information on other professional activities, income acquired as compensation and information about the partner;
- Information on the periodic review interview;
- Recording time and leave;
- Information on illnesses, accidents, maternity or paternity leave, military service or civil protection;
Application files that do not result in employment are deleted/destroyed at the end of the application procedure, unless we have obtained permission to retain them.
The data is used for proper processing in the field of human resources, for the execution of the contractual relationship (employment contract) and is mainly provided by employees.
- 6 Suppliers and other contractual partners
We process the following personal data for business partners who perform services or deliveries for us:
- Contact data and general master data according to ch. 4.1;
- Financial information such as bank details;
- Information available in the contract (such as data on responsible employees, advisors, information on the service provided, etc.);
We process this data for contract execution and in application of legal retention periods under commercial and tax law. If our contractual partners have access to our personal data as part of carrying out their work [e.g. IT companies], we enter into a corresponding subcontracting agreement with them.
- 7 Use, improvement and control of the website, other electronic channels
- 7.1 Server log files
Our website can be used without the need to disclose extensive personal data. However, the server collects information about the user on each visit. These are temporarily saved in server log files. However, it is not possible to attribute this information to a specific person. Log files contain the following information:
- date, time of access and quantity of data,
- browser used and the operating system,
- provider’s domain name,
- the page from which you arrived on our site (referrer URL),
- search query,
- IP address.
The collection of this data is necessary for technical reasons: it serves the stability and security of the website and is used to analyse the use of the website and improve it. It also allows for precise monitoring in the event of suspicion of the illegal use of our website.
- 7.2 Cookies
Our website uses cookies and similar technologies. If your device settings allow it, we use cookies and similar tools to provide you with an optimal browsing experience on our website.
Cookies are text files that are stored on your computer and which allow your use of the website to be analysed or to fill in forms or to log in to the online store automatically. They facilitate our website display and help you navigate our site. Cookies collect data such as:
- IP address,
- the website from which you are visiting us,
- the type of device you are using,
- how you use our search function (known as the Search-Log),
- the different actions you take when you receive the newsletter.
You will find further information on the use of cookies in the information relating to the use of web analysis tools (sections 7.1 and 7.2).
It is also possible to visit our website without cookies, by setting the browser to prevent the storage of cookies. However, this setting may restrict possibilities for using the website.
Under no circumstances do we use cookies to install malware or spyware on your computer.
Full details of our cookie policy can be found on our dedicated web page https://www.bains-lavey.ch/fr/politique-en-matiere-de-cookies/
- 9 Guarantee of security, compliance with legal obligations and exercise of claims
We may process the above-mentioned personal data in order to guarantee security and assert your rights, if necessary, and, for this purpose, forward them to third parties such as courts or offices.
- Data capture, retention period, security measures
- 1 Data capture
As a general rule, we obtain the personal data mentioned in section 4 directly from you from the moment you access one of our services.
We also use publicly available information in the media and online to the extent that this is part of a particular case (e.g. as part of an application, when selecting teachers and speakers), as well as data relating to the use of the website
(see section 4.8).
- 2 Retention period
We retain personal data for as long as it is necessary for the purposes for which it was collected, for legal or contractual retention periods, and for as long as we have an overriding interest in retaining it. The data is then deleted.
- 3 Data security
We take appropriate technical and organisational security measures to protect personal data against unauthorised access and misuse. These measures include IT and network security solutions, access restrictions, encryption of data carriers and their transmission, instructions, training and checks.
The data is saved in the applications and software we use.
If third parties have access to our data, special measures, which are governed by the subcontract (see section 8), are taken.
- Social media networks
Our website, www.bains-lavey.ch, uses share buttons to allow you, by clicking, to use third-party social plug-ins, e.g. Facebook, Twitter and LinkedIn. We therefore enable visitors to our website to share content on the respective social media networks. When you click on a share button, usage data is transmitted to the corresponding social media provider.
The plug-ins are identified by the provider’s logo. The content of the plug-in is transmitted directly to your browser by the provider and linked to the website. By linking the plug-ins or opening the corresponding channel via the link, the provider receives the information that you have visited our website. If you are connected to the service provider at the same time, the service provider can associate the visit with your profile. If you interact with the plugins, e.g.
by clicking on the button or leaving a comment, the corresponding information is transmitted directly from your browser to the service provider where it is saved.
We (additionally) refer to our respective social media networks through links. This is only a static referral to the channel concerned. When you connect to our social media networks, we receive information that is stored in your profile (contact information) and possible information on the profiles of your friends.
You will find the purpose and scope of the data collection and the further processing of your data by the provider, as well as your related rights and setting options to protect your privacy relating to the data protection information providers.
- Third-party tracking technologies and tools
- 1 Google Analytics
This website uses “Google Analytics”, a website analysis tool from Google Ireland
Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses “cookies”, i.e. text files which are stored on your computer and which enable your use of the website to be analysed. The information generated by the cookies about your use of our website is generally transferred to and stored on a Google server in the United States. We draw your attention to the fact that this site uses Google Analytics with the extension “anonymizeIp();” to ensure the anonymous capture of IP addresses (IP masking).
If you activate the anonymisation of your IP address on our website, this address will be shortened by Google in Switzerland, in member states of the European Union (EU) and other state parties to the Agreement on the European Economic Area. This means that no identification of your identity is possible.
Only in exceptional cases will the full IP address be transmitted to a Google server in the USA where it will be shortened. On behalf of the operator of this website, Google will use this information to analyse your use of the website, compile reports on website activity, and provide us with other services relating to the use of the website and the internet.
You can prevent the storage of cookies by setting your browser accordingly. However, we would like to point out that in this case not all functions of our site may be fully available.
In addition, you can prevent the transfer to Google of data generated by cookies and data relating to your use of the website (including your IP address), as well as the processing of this data by Google, by downloading and installing the plug-in browser available.
You can also prevent the collection of data by Google Analytics by installing an opt-out cookie which will prevent your data from being recorded the next time you visit our website: deactivate Google Analytics.
Further information on this can be found at
https://marketingplatform.google.com/about/analytics/terms/us/ and on data protection at
https://marketingplatform.google.com/about/.
- 2 Newsletter mailings
The newsletters contain “web beacons”, namely one-pixel files which are extracted when the newsletter is opened. As part of this extraction, technical data, such as information about the browser and your system, as well as your IP address and the time of the consultation, are collected.
This information is used for the technical improvement of services based on technical data or target groups and your reading behaviour depending on the viewing location (identifiable by IP address) or access times. For statistical purposes, a record is also taken of whether the newsletter is opened. In this case, the day, time and links consulted are recorded. For technical reasons, this information may be assigned to the corresponding recipient. However, we only use this information to identify the reading habits of our users, adapt the content and thus improve the newsletter.
The sending service provider may use the recipient's data in the form of a pseudonym, i.e. without associating them with a user, in order to optimise or improve its own services, e.g. for the technical optimisation of sending and determining the layout of the newsletter or for statistical purposes. However, it does not use the data of the recipients of our newsletter for its own account nor transmit it to third parties.
- 3 Ad personalisation
We use cookies for ad personalisation, with advertising or marketing cookies.
- 4 Use of plugins
- 3.1 Facebook plugin
Our website uses social plugins from the social network Facebook, operated by “Facebook” (Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). These plugins can be identified by the Facebook logo or the words “Facebook social plugin” or “Facebook Social Plugin”.
If you visit a page of our website that contains such a plugin, your browser establishes a direct link to the Facebook servers. The plugin content is transmitted directly by Facebook to your browser and linked to the page. Via this link, Facebook is informed that your browser has visited the corresponding page of our website, even if you do not have a Facebook profile or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a Facebook server located in the United States and stored there. If you have a Facebook account, it can directly associate the visit to our site with your Facebook profile. If you interact with the plugins, e.g. by pressing the “Like” button or leaving a comment, this information is also transmitted directly to a Facebook server where it is saved.
Additionally, this information is published on your Facebook profile and your Facebook friends can see it. You will find the purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as your related rights and setting options to protect your privacy in the information Facebook provides regarding data protection.
If you do not want Facebook to associate the data collected via our website directly with your Facebook profile, you should log out of Facebook before visiting our website.
You can also block the download of Facebook plugins by using add-ons in your browser.
- 3.2 LinkedIn plugin
Our website uses functions from the LinkedIn network. The service provider is LinkedIn Ireland Unlimited, Company Wilton Plaza, Wilton Place, Dublin 2 Ireland. Each time a page of our site containing LinkedIn functions is viewed, a connection to the LinkedIn servers is established. LinkedIn is informed that you have visited one of our pages via your IP address.
If you click on the “Recommend button” and are logged into your LinkedIn account, LinkedIn can then link your visit to our website to you and your user account. Further information can be found in the LinkedIn privacy policy.
- Data sharing and transfer
We may share personal data with third parties if you have given your consent, if this is necessary to provide the service in question, fulfil the purpose of the contract or preserve our legitimate interest, or if we are required to do so by law.
The following categories of recipients may receive personal data from us:
- Service providers (e.g. IT service companies, hosting providers, suppliers, advisors, lawyers, insurance companies).
- Third parties within the framework of our legal or contractual obligations, authorities (in particular audit oversight authorities or tax authorities), government institutions, courts.
The third parties we commission are contractually committed to respecting data protection and to only processing the data for the purpose we have indicated to them.
Our service providers are mostly located in Switzerland. If a transfer of data to a country without an adequate level of data protection proves necessary, it will be carried out on the basis of standard contractual clauses (e.g. in the case of Google) or other appropriate guarantees. The information you have shared with us may also be anonymised and transmitted to third parties for statistical analysis purposes.
- Your rights
Any person may request information about the data processed concerning them, as well as the origin, recipient and purpose of the collection and processing of the data. Furthermore, you have the right to request the amendment, blocking, deletion or transfer of your data. Data retained under legal provisions or necessary for business management cannot be deleted/erased. If the data is not affected by a legal archiving obligation or by our overriding interest in retention, we will delete your data at your request. If the archiving obligation applies, we can block your data.
You can also assert your rights in court or file a complaint with the relevant data protection authority.
- Final provisions
- 1 Responsible entity and contact
We are responsible for data processing in accordance with this data protection declaration, unless otherwise stated.
The contact responsible for data protection is the Human Resources department.
General inquiries regarding data protection can be sent to us by post or e-mail:
Les Bains de Lavey SA
Service des Ressources Humaines
Route des Bains 46
1892 Lavey-Les-Bains
lpd@bains-lavey.ch
For questions regarding a specific person, requests for amendment or a request for deletion, a copy of the identity card or passport allowing identification of the user must also be attached.
- 2 Amendments to the data protection declaration
We may adapt our data protection declaration at any time by publishing it on the website. This data protection declaration was last updated on 31 August 2023.
