Last updated: March 22, 2022
At Urbio SA (we, our or Urbio), we recognize the importance of your privacy and of transparency.
This privacy notice (Privacy Notice) describes how we process your personal data when you interact with us, our website available at www.urb.io (the Website), as well as the digital applications and solutions (together with the Website, the Solutions), and the services we provide through the Solutions (together with the provision of the Solutions, our Services).
By using our Services, or otherwise providing us your information, you expressly acknowledge that we may process your personal data in accordance with this Privacy Notice.
2. Short Version
The following is a summary of (but not a replacement for) this Privacy Notice:
Our role. We, Urbio SA, are responsible for the processing, as controller, of your personal data (but only for our own activities and not those of third party providers) (see section 3);
Data we collect. We collect the information which is provided to us by you, your Organization, or third parties. We also collect some information automatically when you interact with the Services (see section 4);
How we use it. We process your personal data in compliance with Swiss laws and other data protection laws applicable to us. This means that we will only process your information where we have a legal basis to do so (see sections 5), and only for certain reasons (mainly for providing our Services, operating our our Solutions, and for the other legitimate purposes indicated in this Privacy Notice) (see section 6);
Control and Access. Your personal data is stored in Switzerland and/or the European Union. We do not share it with third parties or transfer it abroad unless this is both necessary for the operation of our Services and permitted by applicable laws. This may for instance be the case when we use service providers or must interact with third parties to conduct our professional activities (see sections 7 and 9);
Retention. We do not store your personal data for longer than necessary for us to fulfill the purposes set out in this Privacy Notice (see section 10);
Security. We apply security measures and strive to protect your personal data. However, no IT infrastructure is completely secure and we cannot guarantee that ours is (see section 11);
Your rights. You may contact us (email@example.com) to exercise your rights pertaining to your personal data (see sections 13 and 14).
3. Who is responsible for the processing of your personal data
Urbio SA, Rue de l'Industrie 17, 1950 Sion, Switzerland, is responsible for the processing, as controller, of your personal data. You will find our contact details below in section 12.
As further detailed in this Privacy Notice, we may process your personal data in connection with the Services we provide to your employer, respectively the organization to which you are affiliated in any other way (each an Organization), or to other users. This Privacy Notice does not govern how Organizations and other users process your personal data through the Services. You must refer to their policies. Please see section 7 below for additional information in this respect.
4. How we collect your personal data
We collect the personal data you provide to us, or which your Organization provides us with.
We collect the personal data that you provide to us when interacting with us and/or using our Services, for example when you create and/or manage your account, use our Solutions, through web forms you fill, and when you subscribe to our newsletter, apply for a job, or communicate with us.
You are only authorized to provide us with personal data relating to you directly, unless you obtain the prior consent of the individuals you want to share information about.
It is only mandatory that you complete the data fields identified as such. If one or more mandatory data fields are not completed, we will not be able to provide access to our Services. You are not required to complete the optional data fields in order to access our Services.
Some information about you may also be provided to us directly by our users
Even if you are not a user of our Services, we may collect certain information about you if this is provided to us by one of our users.
Such information may comprise anything that is included in the datasets that are uploaded by our users in connection with their use of our Services (for instance personal data regarding building and parcel owners, such as name or contact information; or commercial history of our users' own customers, such as time of last contact or energy demand.
If we are processing your personal data because it has been provided to us by one of our users, please see section 7 below for additional information.
We may also collect personal data from third parties.
We collaborate with third parties (our Partners) which provide us with datasets that we use in our Solutions. This may include information about buildings and their owners that are available on public registers.
If we are processing your personal data because it has been provided to us by one of our Partners, please read the following: this Privacy Notice does not address how our Partners collect and use your personal data. If you would like to make any requests or queries regarding your personal data, please contact such Partner(s) directly.
You may contact us to request that we no longer process your information collected in this manner (see our contact details in section 14).
Certain personal data are also collected in an automated manner.
We also automatically collect personal data, including by means of cookies and other active elements, as further described in this Privacy Notice.
You may define certain authorizations relating to the automatic collection of your personal data when you configure your device or your internet browser according to available functionalities. You may also define certain settings for the automated collection of your personal data through the cookies setting plugin available on the Solutions. For more detailed information, please see the cookie section below (section 12).
5. How we use your data
We process your personal data in accordance with applicable laws and only if we have a valid legal ground to do so.
We process your personal data in compliance with applicable law, in particular Swiss data protection laws and, to the extent they apply to us, other data protection legislations, such as the EU General Data Protection Regulation (GDPR), manually or automatically using computer tools.
This means that we will only process your information for certain reasons (see Section 7) where we have a legal basis to do so.
Additional Information on the "legal basis"
Here is what each of these legal bases is:
Contractual Necessity: the processing is necessary to fulfill our contractual obligations to you or to take pre-contractual steps at your request. This is particularly the case in particular when processing your personal data is strictly required to provide you with the Services. When the GDPR applies, Contractual Necessity is based on Article 6(1)(b) GDPR.
Legitimate Interest: the processing is necessary for the fulfillment of our legitimate interests, and only to the extent that your interests or fundamental rights and freedoms do not require us to refrain from processing. When the GDPR applies, Legitimate Interest is based on Article 6(1)(f) GDPR.
Consent: we have obtained your prior consent in a clear and unambiguous manner. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal. When the GDPR applies, Consent is based on Article 6(1)(a) GDPR.
Legal Obligation: the processing is necessary to comply with our legal or regulatory obligations. When the GDPR applies, Legal Obligation is based on Article 6(1)(c) GDPR.
What about the "processor position"?
When we act as processor for an Organization you are affiliated to, our processing of your personal data is governed by the agreement between us and your Organization (see section 7).
If we access your personal data because it was transmitted to us by one of our Partners (see Section 4 above), it is our Partner which is responsible for ensuring that your personal data is collected and transferred to us in accordance with all privacy and data protection laws of all relevant jurisdictions, based on an appropriate legal ground. Please refer to our Partner’s privacy notice for information about their processing activities.
Additional Information on profiling and automated decisions
We may process your personal data to create a profile about you and provide you with more relevant information and services (profiling), for instance to show you more relevant information based on prior interactions with our Services. However, we do not make decisions exclusively on the basis of automated processing which have legal effects on the data subjects or affect them significantly (automated individual decision).
6. Why we use your data
We process your personal data for the following reasons:
To provide our Services, operate the Solutions and for client management purposes.
We mainly process your personal data to provide the Solutions and the Services, based on our Contractual Necessity to do so, including for creating and maintaining a user account, interacting with you, and other users (including for allowing other users within your Organization to view your public content), providing you with the requested information and Services, and for related client management purposes (such as invoicing).
Contacting you and responding to your queries. You have the option of contacting us via the Solutions, through our chat or by email. In this context, we process the data which you provide to us (including your contact information and the subject-matter of the request). This data is used for the purpose of providing you with the requested information and services, based on our Contractual Necessity. The retention period depends on the reason for your request and its context.
Providing maintenance and support. We use data to maintain our Services, troubleshoot and diagnose problems, and to provide client support services.
Managing our clients and suppliers. If we are in a business relationship with your Organization or you directly, we process the personal data that is necessary for our client or supplier management, as well as for the following other related purposed, including (i) to carry out the transactions in which we are engaged, and to procure products and services from our suppliers and subcontractors; (ii) process your orders and payment (iii) to interact with you, for instance to reply to your inquiries; (iv) to track our activities (measuring sales, our work time, etc.) and those of our suppliers; (v) to manage our archiving and records; and (vi) for invoicing purposes.
The personal data that we process in this context includes (i) personal data about individuals with whom we interact, such as the name, title, position, company name, email and/or postal address and the professional fixed and/or mobile phone number; (ii) personal data relating to our interactions and the services provided; (iii) any other information provided to us by you, your Organization, or third parties.
Our basis for processing the data is our Legitimate Interests in delivering our Services to our clients.
The personal data which we must retain for record-keeping, tax or other legal obligations will, as a rule, be kept for the duration of the contractual relationship and thereafter for a period of 10 years (or such other retention period as applicable). Shorter retention periods may apply for personal data which must not be retained for the above reasons.
What if you are not a user or client of our Services?
If you are not a user, we will process your personal data if it is provided to us by one of our users, for instance due to your position in an organization to which a user is affiliated (Organization). Please see section 7 below for additional information in this respect.
We may also use datasets provided by third parties, as detailed in section 4 above.
For our legitimate business interests related to the provision of the Services, including to ensure the security of the Services, improve our Services, as well as for monitoring or statistical purposes.
We may also process your personal data for our legitimate business operations related to providing our Services, which include (i) ensuring that our Services are provided in an efficient and secure way (e.g. through internal analysis of the Services’ stability and security, updates and troubleshooting); (ii) protecting the security of our IT systems, architecture and networks; (iii) benefiting from cost-effective services (e.g. we may opt to use certain services offered by suppliers rather than undertaking the activity ourselves); (iv) improving and developing the Services (including monitoring the use of our Services, and for statistical purposes); and (v) achieving our corporate goals).
When doing so, we generally rely on our Legitimate Interests. We may also process your data if we have obtained your prior unambiguous Consent. You may withdraw your consent, respectively, object to such processing activities, at any time.
Additional information on the processing of your personal data for our legitimate business operations:
Ensuring that our Solutions are provided in an efficient and secure way. In addition to the personal data which you or your Organization provide when logging-in to your account or interacting with the Solutions (e.g. when you fill in forms or upload content to the Solutions), we automatically collect technical information about your interactions with the Solutions, such as IP address, the content that was accessed, date and time of access, information about your web browser, your preferences, or other information related to your interaction with the Solutions, including your navigation details on the Solutions.
We process this data to establish a connection with your device over the internet, to identify you when you use the Solutions, control the use of the Solutions and for security purposes.
Protecting the security of our IT systems, architecture and networks. We use data to protect the security of our IT systems, architecture and networks, for instance to detect and disrupt the operation of malicious software by systematically scanning contents in an automated manner.
Internal analysis and statistical purposes to improve our Services. We may process your personal data, in particular data relating to your use of our Services and your habits and preferences (e.g. the content you accessed, date and time of access and your preferences), for internal analysis and statistical purposes, in order to better understand the needs of our users, to optimize their experience, and in general to improve the ergonomics and functionality of our Services. You may object to such processing activities at any time (see section 13 below for additional information on your rights).
Data anonymization. We may combine your personal data with other information (aggregate) or erase any information that allows us to identify you (anonymize), so that it is no longer considered personal data under applicable data protection law, in which case this Privacy Notice will no longer apply and we may use such data for purposes not contemplated by this Privacy Notice (e.g. for benchmarking or analytics purposes, or to develop and market new services). You may object to the anonymization or aggregation of your personal data for this purpose at any time (see section 13 below for additional information on your rights).
To send you our newsletter and other advertising information.
If you subscribe to our newsletter, we will collect your contact details (name and email address) and use it to provide you with our newsletter, based on your Consent. You may unsubscribe from the newsletter service at any time, in which case your contact details will be deleted.
We also process the time of registration and your opt-in confirmation based on our Legal Obligation to demonstrate compliance. We also analyze your use of our newsletter, e.g. whether you have opened it or clicked on certain links, and process this data to optimize and improve our newsletter, based on our Legitimate Interest.
Independently from your subscription to our newsletter, we may contact you by email to inform you about our activities if you have previously subscribed for the use of our Services, if you have not objected to the corresponding use of your email address. You can object to the use of your email address for this purpose at any time by contacting us (see contact detail in section 14). The legal basis for the corresponding processing of your data is our Legitimate Interest to advertise certain activities relating to our previous interactions with you.
To provide you with job opportunities within Urbio.
We may process your personal data to allow you to consult and apply for job opportunities within Urbio. We will process the personal data you provide. In addition, if you provide us with links to your profile on social media platforms (such as LinkedIn) or with contact information for references, we will assume that we may gather information from these sources.
Any information you submit must be true, complete and not misleading. Should the information provided be inaccurate, incomplete, or misleading, subject to applicable law, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been employed.
We will process your personal data exclusively for assessing your application, based on our Contractual Necessity (to take pre-contractual steps at your request). Your personal data is retained no longer than the duration of the recruitment process unless required otherwise by applicable laws and regulations or our Legitimate Interests.
To comply with our other legal obligations or for other legitimate interests.
We may further process your personal data if we have a Legal Obligation to do so or for other Legitimate Interests. This will for instance be the case if we need to disclose certain information to public authorities or retain such information for tax or accounting purposes, or for the establishment, exercise or defense of legal claims.
The personal data that we process for this purpose are those that we collected for one of the purposes indicated elsewhere in this section 6. We retain the personal data for the duration of the legal obligation imposed on us.
7. Our Operations with Your Organization or Other Users
If you are an end user of a Service we provide to your Organization, or if you are not an end user, but we process your personal data on behalf of your Organization or another user (for instance, if your information is contained in a dataset provided to us by a user), please read the following:
In the situations described above, our processing of your personal data is governed by a contract between us and the relevant Organization which is our client. We will process your personal data as data processor for the providing of our Services to such Organization and/or user, or in some cases, as a controller for our legitimate business operations related to providing those Services, as detailed in this Privacy Notice.
Some information about you may be provided to us directly by your Organization or other Users. If this is the case, they are responsible for ensuring that your personal data is collected and transferred to us in accordance with all privacy and data protection laws of all relevant jurisdictions, based on an appropriate legal ground.
If you would like to make any requests or queries regarding our processing of your personal data on behalf of your Organization or other users, please contact the relevant Organization directly. For example, if you wish to request access, correct, amend, or delete inaccurate personal data that was originally transmitted by your Organization or other users, please direct your query to them. If we are requested by your Organization or another person/organization to remove your personal data, we will respond to such request in a timely manner upon verification and in accordance with applicable law (for example, 30 days under Swiss law or the GDPR).
If you have questions about our legitimate business operations in connection with providing Services to Organizations and users, please contact us as described in section 14.
8. The circumstances in which we share your personal data with third parties
We may share your personal data with third parties if this is necessary for the operation of our Services, if there is a legal obligation or permission to do so, or if there is another valid reason to do so.
Our service providers. We may share your personal data with third parties in connection with the operation of the Services or our business operations and with subcontractors such as IT service providers, cloud service providers, database providers, automated marketing solutions providers and consultants, including Amazon Web Services (cloud/storage provider), Wix.com Ltd (software development services provider), Google Analytics and Hotjar (data analytics tools), Clickup (project management), Intercom (messaging platform), Mailchimp (email marketing). Detailed information on these providers can be found in section 6.
Your Organization. If you use a Service provided by an Organization you are affiliated with, we share certain data, such as interaction data and diagnostic data to enable your Organization to manage the Services. In addition, other users within your Organization may have access to certain information.
Legal Obligation. We may also disclose your personal data where we have a legitimate interest in doing so, for example (i) to respond to a request from a judicial authority or in accordance with a legal obligation; (ii) to bring or defend against a claim or lawsuit; or (iii) in the context of restructuring, in particular if we transfer our assets to another company.
9. International Transfers
We store your personal data on servers located in Switzerland and/or the European Union. In principle, we do not transfer your personal data to other countries or make it available there. However, in certain circumstances, in particular in connection with the operations of our subcontractors, your personal data may be made available to recipients located abroad (e.g. Amazon Web Services, Google and ClickUp are headquartered in the U.S, and Wix.com Ltd is headquartered in Israel, and Hotjar Ltd in Malta, from which locations some data may be available). In such cases, we will ensure that suitable safeguards are in place, in accordance with applicable data protection laws, for instance by relying on standard contractual clauses adopted by the European Commission.
If you transmit information and data to us, you are expressly deemed to consent to such data transfers. You may request additional information in this regard and obtain a copy of the relevant safeguards upon request by sending a request to the contact address indicated in section 14 below.
10. How long we store your personal data
Your personal data will not be stored longer than necessary. We will erase or anonymize personal data as soon as it is no longer necessary for us to fulfill the purposes set out in section 6 of this Privacy Notice. This period varies, depending on the type of data concerned and the applicable legal requirements. More information on each type of processing can be found in section 6 above.
Your account information is retained for as long as your account is active. Upon suppression of your user account, we will within reasonable time following a written request from you, permanently delete or anonymize your account information still under our control, unless data must be retained for a valid reason (such as evidentiary or tax purposes). In any case, we will be allowed to permanently delete or anonymize your account information 60 days after suppression.
In view of the legal obligations incumbent upon us, certain information relating in particular to the contractual relationship must be retained for at least 10 years.
We are committed to the security of your personal data, and have in place physical, administrative and technical measures designed to keep secure your personal data and to prevent unauthorized access to it. We restrict access to your personal data to those persons who need to know it for the purpose described in this Privacy Notice.
Although we take appropriate steps to protect your personal data, no IT infrastructure is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.
The internet is a global environment. As a result, by sending information to us electronically, such data may be transferred internationally over the internet depending upon your location. The internet is not a secure environment and this Privacy Notice applies to our use of your personal data once it is under our control only. Given the inherent nature of the internet, all internet transmissions are done at your own risk.
If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication (including by posting a notice on the Solutions).
13. Your rights with regard to the processing of your personal data
You have the right to access your personal data we process and may request that they be removed, updated, or rectified.
If you are using a Service provided by your Organization, you should direct your privacy inquiries relating to our use of your personal data on behalf of your Organization, including any requests to exercise your data protection rights, directly to your Organization’s contact person.
In other cases, you may contact us directly to exercise your rights. Unless otherwise provided by law, you have the right to know whether we are processing your personal data, to know the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be supplemented, updated, rectified or erased. You also have the right to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law, and you have the right to object to any processing of personal data for legitimate reasons.
By accessing your user account (if you have one), you can review, update, correct or delete the personal data available within your user account.
If you request us to delete your personal data from our systems, we will do so unless we need to retain your data for legal or other legitimate reasons. Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request.
Where we rely on your consent to process your personal data, we will seek your freely given and specific consent by providing you with informed and unambiguous indications relating to your personal data. You may revoke at any time such consent (without such withdrawal affecting the lawfulness of processing made prior to).
The above does not restrict any other rights you might have pursuant to applicable data protection legislation under certain circumstances.
In particular, if the GDPR applies to the processing of your personal data you have the following rights under the GDPR if the respective requirements are met:
Right of access (Art. 15 GDPR) - you have the right to access and ask us for copies of your personal data.
Right to rectification (Art. 16 GDPR) - you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure (Art. 17 GDPR) - you have the right to ask us to erase your personal data in certain circumstances.
Right to restriction of processing (Art. 18 GDPR) - you have the right to ask us to restrict the processing of your personal data in certain circumstances.
Right to data portability (Art. 20 GDPR) - you have the right to ask that we transfer in a structured, commonly used and machine-readable format the personal data you gave us to another organization, or to you, in certain circumstances.
Right to object to processing (Art. 21 GDPR) - you have the right to object to the processing of your personal data which is based on our Legitimate Interests, in certain circumstances. In such a case, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defense of legal claims.
As a rule, you are not required to pay any charge for exercising your rights and we will respond to your request within one month.
You will find further details of your rights in sections 5 and 6 and of this Privacy Notice in connection with each processing activity we perform. If you want to exercise any of your rights, or want additional information about them, please contact us using the contact details listed below (see section 14).
You have the right to lodge a complaint with the competent authority.
If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in addition to the rights described above.
Although this is not required, we recommend that you contact us first, as we might be able to respond to your request directly.
14. Contact Us
If you believe your personal data has been used in a way that is not consistent with this Privacy Notice, or if you have any questions or queries regarding the collection or processing of your personal data, please contact us at (firstname.lastname@example.org).
15. Updates to this Privacy Notice
This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you (including by email and/or via the Solutions, e.g. banners, pop-ups or other notification mechanisms). If you do not agree to the changes made, you must stop accessing and/or using the impacted Services.