Privacy Policy under the New Federal Law Pursuant to Art. 6 and Art. 19 DPA

CLUB MOVE SA (P.VAT CHE - 50130177209), in the person of its legal representative pro tempore, with registered office at Via Trevano 85 - 6900 Lugano (Ticino), in its capacity as Data Controller, informs you that, in compliance with the new Federal Data Protection Act (DPA), which governs and regulates the protection of personal data and their free movement, your personal data will be processed in accordance with the aforementioned Federal Law, guided by the principles of fairness, lawfulness, proportionality of interests and transparency as well as the protection of your privacy and your rights, for the purposes, in the manner and for the terms set out in more detail below.

-1- Purposes, methods and legal bases of data processing

This privacy policy applies only to the online activities of this site and applies to visitors/users of the site. It does not apply to information collected through channels other than this websiteclubmove The purpose of the privacy policy is to provide maximum transparency regarding the information the site collects and how it uses it.
Your personal data will be processed exclusively for purposes strictly related, instrumental and necessary for the fulfillment of the obligations inherent in the relationship with our Company; in particular:
The processing of personal data is carried out by means of the operations of collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction.
The processing of personal data will be carried out by means of computer media by the owner, the person(s) in charge and authorized persons (appointees) with the observance of all precautionary measures, which guarantee their security and confidentiality. The data will not be subject to profiling.
The data will be stored at the data controller and at the data processors designated by the data controller. In any case, your personal data will be stored and processed within the borders of the Helvetica confederation and will only be transferred outside this border with your explicit consent.
In the event that you provide comments and/or personal data for the purpose of requesting information and/or specific services requested by you (including but not limited to requesting commercial information, subscribing to our portal, subscribing to our newsletter), such data shall be deemed to have been voluntarily provided by you at the time of the request for the provision of the service. By entering a comment or other information, the user expressly accepts this privacy policy.
The data received will be used solely for the purpose of providing the requested service and only for the time necessary for the provision of the service.
The information that users of the site will deem to be made public through the services and tools made available to them, is provided by the user knowingly and voluntarily, exempting this site from any liability for any violation of laws. It is up to the user to verify that he or she has permissions to enter personal data of third parties or content protected by national and international regulations.
The data collected by the site during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the specified activities. In any case, the data collected by the site will never be provided to third parties, for any reason, unless it is a legitimate request by the judicial authority and only in the cases provided for by law.

-2- Nature of data collection and consequences of failure to provide data

Like all Web sites, this site also makes use of log files in which information collected in an automated manner is stored
automated during users' visits.The information collected may be as follows:
- internet protocol (IP) address;
- browser type and parameters of the device used to connect to the site;
- name of the internet service provider (ISP);
- date and time of visit;
- web page of the visitor's origin (referral) and exit;
- possibly the number of clicks.
- Your e-mail address in case you decide to subscribe to our newsletter, for which your explicit
consent

The aforementioned information is processed in an automated form and collected in an aggregate form only in order to verify the proper functioning of the site, for security reasons and for the legitimate interests of the owner provided for by current legislation.For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the Ip address, which could be used, in accordance with the relevant laws, in order to block attempts to damage the site itself or to harm other users, or otherwise harmful activities or constituting a crime. Such data is never used for user identification or profiling, but only for the purpose of protecting the site and its users and the legitimate interests of the Owner in the
data processing.By using or consulting this site, visitors and users explicitly approve this privacy policy and consent to the processing of their personal data in the manner and for the purposes described below, including the possible disclosure to third parties if necessary for the provision of a service. Providing data and therefore consenting to the collection and processing of data is optional, however, denying consent may result in the inability to provide certain services and the site browsing experience may be compromised.

The consent to the use of your data for marketing and/or advertising purposes (sending e.mail and/or communications with advertising offers
newsletters), is optional and requires on your part, in addition to the provision of your personal data also explicit request through the function of
opt-in on this website

-3- Timelines and deadlines

The Data Controller, data processors and authorized persons (processors) will process personal data for the time necessary to
fulfill the above purposes and, in any case, for no longer than 10 years from the termination of the relationship where provided for or made necessary by the
regulations in force.Regarding the provision of data by you for the receipt of commercial information, newsletters and informative
periodicals, the data will be processed until your request to unsubscribe.

-4- Communication and dissemination of data

Your personal data, for the purpose of the execution of the contract or from the services requested by you and for the purposes stated above, may
be communicated to:

to all natural and legal persons (including but not limited to legal, administrative, tax consulting firms,
auditing companies, couriers and forwarding agents, data processing center, computer consultants, suppliers etc.) in cases where the
communication is necessary for the purposes outlined above;
To banking institutions for the management of collections and payments;
To factoring or debt collection companies;
To our specially assigned contractors and employees and within the scope of their duties.
To SMTP providers for sending Newsletters.

-5- Rights of the data subject

By calling +41 91 924 01 07 or writing toclubmove at any time you may exercise your rights vis-à-vis the data controller ( Data Controller ) under the Federal Data Protection Act DPA which we reproduce for your convenience.
You have the right to obtain confirmation of the existence and/or whether or not personal data is being processed that
concern, even if not yet registered, as well as their communication in intelligible form. The interested party has the right to obtain
the indication:

of the origin of the personal data (with special regard to the case where the data are not collected from the data subject and, for the case of data transfer to a third country, the existence of adequate safeguards, the purposes and methods of processing;
Of the logic applied in the case of processing carried out with the aid of electronic instruments;
of the identification details of the Owner, responsible persons and designated representative;
Of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or authorized parties;
Of the categories of personal data being processed;
Of the data retention period or the criteria used to determine this period;
of the existence of automated decision-making processes, especially with regard to profiling, and the logic applied by them;
Of the right to obtain copies of the personal data being processed;

The person concerned has, in addition, the right to obtain:

updating, rectification or, when interested, integration of data;
the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the protected right;
data portability to other entities for which an explicit request must be made to the following contact details +41 91 924 01 07,clubmove
deletion of the data in our files (so-called right to be forgotten), by communication to +41 91 924 01 07,clubmove
To restrict data processing under the Federal Data Protection Act (DPA).

The data subject has the right to object, in whole or in part, to the processing of data:

for legitimate reasons related to your particular situation, even if the processing is relevant to the purpose of collection;
to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
to the processing of data including profiling on the basis of these provisions.

Where data processing is based on the consent of the data subject, the data subject has the right to revoke this consent at any time by making an explicit request to the following contact details +41 91 924 01 07,clubmove
The data subject also has the right to lodge a complaint with the Supervisory Authority.
'exercise of the aforementioned rights may be exercised with a request addressed to the Data Controller or the Manager transmitted by telephone, by e-mail to the addresses indicated above or also by registered letter A/R.

Consent of the person concerned

In requesting your express manifestation of your consent to the processing (which we will, however, consider to have been given orally in the event that you fail to return this undersigned letter), we will consider you, as of now, informed about the processing we carry out, in accordance with and for the purposes of the Federal Data Protection Act DPA.