Privacy Policy

Our Privacy Policy is constituted with your privacy by default.

We aim to be compliant with the Swiss Law on data protection and privacy of individuals.

1. What Is This Privacy Notice about?

Ensuring the confidentiality of your personal information is essential for maintaining your trust. This Privacy Notice outlines how and why we gather, handle, and utilize your personal data.

In this Privacy Notice, you will learn, among other things:

• what personal data we collect and process;

• the purposes for which we use your personal data;

• who has access to your personal data;

• what benefits our data processing has for you;

• for how long we process your personal data;

• what rights you have with respect to your personal data; and

• how you can contact us.

We have based this Privacy Notice on both the Swiss Data Protection Act and the European Union’s General Data Protection Regulation (GDPR). The GDPR has established itself globally as a standard for rigorous data protection.

2. Who Is Responsible for Data Processing?

According to data protection law, responsibility for data processing lies with the company that determines whether such processing is to take place, for what purposes it is to take place, and how it is to be configured.

In Switzerland, where this policy applies, the following entity can be contacted:

Batmaid SA

℅ Data Protection & Processing

Avenue de Lavaux 77

CH-1009 Pully

3. Who Is This Privacy Notice Intended For?

This Privacy Notice applies to all persons whose data we process (hereinafter referred to as “you”), regardless of which channel you use to contact us (e.g. on our website, in an app, in a physical branch, by telephone, via a social network, at an event, etc.). It applies to the processing of personal data that has already been collected and personal data that will be collected in the future.

Our data processing activities may, in particular, affect the following categories of persons if we process their personal data:

• Visitors to our websites;

• Holders of a customer account;

• Customers on our website and physical branches;

• Other people who use our services or come into contact with offers from us;

• Users of our online offers and apps;

• Visitors to our premises;

• Individuals who write to us or contact us in any other way;

• Recipients of information and marketing communications;

• Participants in competitions and prize draws;

• Participants in customer and public events;

• Participants in market research and opinion and customer surveys;

• Contacts at our suppliers, outlets, and other business partners, as well as at organizations and authorities; and

Please also consult the contractual conditions for individual services (e.g. general terms and conditions, terms of use or terms of service). For information about the collection and processing of personal data when using our websites, mobile apps, and social media pages, particularly in connection with cookies and similar technologies, please also see our Cookie Notice.

4. Which Personal Data Do We Process?

“Personal data” constitutes information that can be associated with a specific person. We process various categories of such personal data. The key categories are set out below for your orientation.

However, we may also process other personal data in individual cases.

You can find out more about the origin of this data in Section 5 and Section 6 about the purposes for which we process this data.

4.1 Master data

Master data comprises the fundamental data about you, such as your salutation, name, contact details, or date of birth. We collect master data in particular when you create a customer account with Batmaid. We also collect master data if, for example, you take part in a competition or prize draw, or register for a newsletter. We additionally collect master data about contacts and representatives of contractual partners, organizations, and authorities.

Examples of master data include:

• title, first name, last name, gender, date of birth;

• address, e-mail address, telephone number, and other contact details;

• customer numbers/ ID (e.g. for participants in a loyalty program);

• payment information (e.g. stored payment forms, bank details, invoice address);

• username and profile picture;

• information on the use of our online platforms (e.g. whether you are registered with Batmaid);

• details of associated websites, social media profiles, etc.;

• details of interests and preferences, language preferences, etc.;

• details about your relationship with us (customer, visitor, supplier, etc.);

• details about related third parties (e.g. contacts, recipients of services, or representatives);

• settings concerning the receipt of advertising subscribed newsletters, etc.;

• details concerning your status with us (inactive or blocked user account, bans from entering premises, etc.);

• details about participation in competitions and prize draws;

• official documents in which you appear (e.g. ID documents, commercial register extracts, permits, etc.);

• details of titles and corporate functions for contacts and representatives of our business partners;

• date and time of registrations.

Under certain circumstances, you can also register for individual online offers via the login of a third-party provider (e.g. Apple or Google). In this case, we receive access to certain data saved with the provider in question, for example your username and e-mail address, the scope of which you can normally determine. Information in this regard can be found in the Privacy Notice of the provider concerned.

4.2 Contract data

Contract data is personal data that arises in connection with the conclusion or execution of the contract, e.g. information on the conclusion of the contract, claims and receivables acquired, or information on customer satisfaction. We conclude contracts primarily with customers, business partners, and job applicants. If you accept offers from us based on a contract, e.g. if you purchase products or make use of services, we will often also gather behavioral and transactional data (see also Section 4.4).

Contract data includes details:

• about the initiation and conclusion of contracts, e.g. date of contract conclusion, details from the application process, and details of the contract in question (e.g. type and duration or, if necessary, proof of identity such as copies of official IDs);

• about the processing and administration of contracts (e.g. contact details, delivery addresses, successful or unsuccessful deliveries, and information about payment methods);

• in connection with our customer service and support with technical issues;

• about our interactions with you (where applicable, a history with corresponding entries);

• on receivables and acquired rights and benefits (e.g. vouchers);

• about defects and complaints as well as contract amendments;

• about customer satisfaction that we may collect via surveys;

• about financial matters such as establishing creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood that receivables will be settled), reminders, collection proceedings, and about the enforcement of claims;

• in connection with a job application, such as curriculum vitae, references, qualifications, certificates, meeting notes, etc. (that may also contain personal data of third parties);

• about interactions with you as the point of contact or representative of a business partner;

• in connection with security checks (e.g. checking for fraudulent actions on orders) and other checks concerning the establishment or continuation of a business relationship (B2B).

4.3 Communication data

If you contact us or we contact you, for example when you contact customer service, or when you write to us, or call us, we process the exchanged communication contents and information about the type, time, and place of communication. In certain situations, we may also ask you to provide proof of identity.

Examples of communication data are:

• name and contact details such as postal address, e-mail address, and telephone number;

• content of e-mails, written correspondence, chat messages, social media posts, comments on a website, telephone conversations, video conferences, etc.;

• details of the type, time, and in certain circumstances place of communication;

• proof of identity such as copies of official IDs;

Telephone conversations and video calls with us may be recorded. If you do not want us to record such conversations, you may terminate the conversation at any time and contact us in another manner (e.g. by e-mail).

4.4 Transactional and Behavioral Data

When you transact with us, make use of our offers and infrastructure, or procure our services, we frequently collect data about this usage. This occurs, for example, if you make a booking with us or if you use our websites and apps. If you are acting on behalf of a third party, this personal data may also pertain to that third party (e.g., your family members if you make purchases on their behalf).

Examples of transactional and behavioral data include the following information if available to us as personal data:

• details about your behavior in our online platform (ordered and canceled appointments “jobs”, preference-list “checklist”, search items and results, payment method, etc.);

• details about your profile behavior (e.g. where, how often, what, and at what options you prefer, as well as the method of payment and extras selected);

• attendance of our events (e.g. date, place and type of event);

• details about participation in competitions, prize draws, and similar events;

• details about your behavior on our websites;

• details about the installation and use of mobile apps;

• details about your use of electronic messages from us (e.g. whether and when you opened an e-mail or clicked on a link);

You can also use some of our offers anonymously. For example, in countries where we operate physical offices, you can visit our stores without registering for more information on our services. However, on our websites and apps, transactional and behavioral data may also be assigned to your profile even if you are not logged in at the time you visit the website or make use of the app.

4.5 Preference Data

We wish to tailor our offers and services to our customers as effectively as possible. We therefore also process data about your interests and preferences. To do so, we may combine transactional and behavioral data with other data and analyze such data on a personal and non-personal basis. This enables us to conclude characteristics, preferences, and likely behavior, such as your affinity for specific products and services.

In particular, we may create segments (permanently or case-related), that is, groups of persons displaying similarities about specific characteristics. Preference data may be used either personally (e.g. to show you advertising that is relevant to you) or on a non-personal basis (e.g. for market research or product development purposes).

The processing described can also be called "profiling" in technical language. You can find further information about profiling in Section 11.

4.6 Technical Data

When you make use of our websites, apps or other services such as our Wi-Fi network (in our physical locations), we collect certain technical data such as your IP address or device ID. Technical data also include the protocols in which we record the use of our systems (log files). In some cases, we may also assign a unique code number (an ID) to your end device (tablet, PC, smartphone, etc.), for example by using cookies or similar technologies, to be able to recognize it. Further details concerning this can be found in our Cookie Notice.

Technical data includes:

• the IP address of your device and further device IDs (e.g. MAC address);

• code numbers assigned to your device by cookies and similar technologies (e.g. pixel tags);

• details of your device and its configuration, such as operating system and language settings;

• details about the browser with which you access the offer, and its configuration;

• information about your movements and actions on our websites and in our apps;

• details about your Internet provider;

• your approximate location and the time of use;

• system recordings of accesses and other events (log files).

• metadata from telecommunications traffic

For more information on the processing of technical data, please also see our Cookie Notice.

4.7 Image and Sound Recordings

We regularly produce photos, videos, and sound recordings in which you might be featured, for example if you attend an event, contact our customer service, or receive an interview call by video conference. For security and evidentiary purposes, we also make video recordings in our branches and other premises. In doing so, we may obtain information on your behavior in the relevant areas. The use of video surveillance systems is localized and clearly indicated.

Examples of image and sound recordings include:

• Recordings from video surveillance systems;

• photos, videos, and sound recordings of customer and public events (e.g. advertising, sponsorship, cultural events, and sports events);

• photos, videos, and sound recordings of courses, presentations, training courses, etc.;

• recordings of telephone conversations and video conferences (e.g. in customer service or advice to customers).

5. Where Does the Personal Data Come From?

5.1 Data Provided

You frequently provide us with personal information directly, such as when you share data or interact with us. Specifically, details like master, contract, and communication data are typically voluntarily disclosed by you. Additionally, in many instances, you are responsible for providing preference data to us.

For example, you provide us with personal data yourself in the following cases:

• You create a customer account;

• You take part in a prize draw or competition;

• You contact our customer service;

• You register for other offers, such as our newsletter.

The provision of personal data is largely voluntary, which means that you are not generally obliged to disclose your personal data to us. However, we do have to collect and process the personal data that are required for processing contractual relationships and fulfilling associated obligations or that are prescribed by law, such as mandatory master and contract data, as we would otherwise be unable to conclude or continue the contract in question.

When submitting information regarding other individuals (e.g., family members), we presume your authorization to do so and the accuracy of the provided data. Additionally, it's essential to ensure that these individuals are informed about this Privacy Policy.

5.2 Data Gathered

We may gather personal information about you either directly or automatically, for instance, when engaging in transactions with us, utilizing our services, or benefiting from our offers. This typically includes behavioral and transactional data, along with technical details such as your website visit times.

For example, we independently collect personal data about you in the following cases:

• You request a cleaning via our online platform

• You visit one of our websites or use one of our apps;

• You click on a link in one of our newsletters or interact with one of our electronic promotional materials in another way.

We may also derive personal data from personal data already available to us, for example by analyzing transactional and behavioral data.

For example, we can analyze the transaction and behavior data collected during purchases in our online shops and, on this basis, make assumptions about your interests, preferences, affinities, and habits. This enables us, for instance, to tailor our offers and information to your individual needs and interests. For example, this enables us to send you an personalised selection of offers relevant for you.

You can find further information about transactional and behavioral data in Section 4.4, and about profiling in this context in Section 11.

5.3 Data Received

Moreover, we may also receive information about you from other third parties, such as from companies with which we cooperate, persons who communicate with us, government bodies or public sources.

For example, we may receive information about you from the following third parties:

• persons close to you (family members, legal representatives, etc.), e.g. your address for cleanings, references, or powers of attorney;

• Credit & recovery agencies such as Intrum AG.

• Swiss Post and address brokers, e.g. for address updates;

• banks, insurance companies and other contractual partners for purchases, payments and claims;

• Authorities, parties, and other third parties in connection with official and judicial proceedings;

• Public registers such as the debt collection or commercial register, from public offices such as the Swiss Federal Statistical Office, from the media, or from the Internet.

6.For What Purposes Do We Process Personal Data?

6.1 Communication

We aim to stay connected with you and cater to your specific needs. Hence, we handle personal data to communicate with you, respond to inquiries, and provide customer support, among other purposes. Specifically, we utilize communication and master data for this purpose, along with contract data if the communication pertains to a contract. Additionally, we may personalize message content and timing based on behavior, transactions, preferences, and other data.

The purpose of communication particularly comprises:

• responding to inquiries;

• contacting you in the event of questions;

• customer service and customer care;

• communication in connection with cleaning changes

• the delivery of other notifications (e.g. order status information);

• authentication, for example for the use of our online offers;

• quality assurance and training;

• all other processing purposes for which we communicate with you (e.g. contract processing, information, and direct advertising).

6.2 Contract Execution

We wish to offer you the best possible service. We therefore process personal data in connection with the initiation, administration, and processing of contractual relationships, for instance, to provide a cleaning service, deliver goods or services, or run a prize draw.

Contract processing also includes any agreed personalization of services. For this purpose, we make use of master data, contract data, communication data, transactional and behavioral data, and preference data in particular.

The purpose of contract processing generally comprises everything that is necessary or appropriate for concluding, executing, and, where applicable, enforcing a contract.

For example, this includes processing to:

• decide whether and how (e.g. with which payment options) we enter into a contract with you.

• provide contractually agreed services, such as deliver products and provide cleaning services.

• provide customer service and enhance customer satisfaction;

• to run and manage loyalty programs, e.g., to redeem claims and benefits earned (e.g. promotional vouchers and codes) and to credit them to customer accounts;

• establish, notify, and, if applicable, publish winners of competitions and prize draws;

• invoice our services and generally for accounting;

• plan and prepare the provision of our services, for example scheduling of our employees;

• review the suitability of job applicants and, if applicable, prepare and conclude employment contracts;

• review whether we are willing and able to cooperate with a company and to monitor and assess its services;

• prepare and conclude corporate transactions such as corporate acquisitions, sales, and mergers;

• assert legal claims from contracts (collection proceedings, legal proceedings, etc.);

• administer and manage our IT and other resources;

• store data in compliance with obligations to preserve records;

• terminate and end contracts.

6.3 Information and Marketing

Our goal is to provide you with appealing offers. To achieve this, we handle personal data for relationship management and marketing objectives. This may involve sending you written and electronic messages, presenting offers, and conducting marketing campaigns. These may comprise our own offers, those of other companies of Batgroup SA, or those of advertising partners.

Messages and offers may also be personalized to – as far as possible – only send you information that is likely to be of interest to you. For this purpose, we in particular make use of master data, contract data, communication data, transaction data, behavior data, and preference data, but may choose to access sound recordings.

Examples include the following messages and offers:

• Newsletters, advertising e-mails, in-app messaging, sms other electronic messages;

• Advertising brochures, magazines, and other printed materials;

• Advertising messages and spots on screens and other advertising spaces;

• Delivery of promotional coupons and promotional codes;

• Invitations to events, prize draws, and competitions.

You can refuse contacts for marketing purposes at any time (see Section 15). For newsletters and other electronic messages, you can generally opt out of the corresponding service from your customer account or via an unsubscribe link included in the message. You can also contact us at anytime by writing to unsubscribe if you do not locate the appropriate unsubscribe button.

6.4 Market Research and Product Development

Our objective is to enhance our offerings continually and render them more enticing for you. To achieve this, we engage in processing personal data for market research and product development endeavors. This involves handling master, behavioral, transactional, and preference data, along with communication data and insights from customer surveys, as well as other surveys and studies, and additional information obtained from various sources such as media, the internet, and public channels. Whenever feasible, we utilize pseudonymized or anonymized data for these initiatives.

Market research and product development in particular include:

• the conducting of customer surveys, other surveys, and studies;

• the further development of our offers (e.g. structuring of products and services, location selection, pricing, and campaign planning, etc.);

• the assessment and improvement of the acceptance of our offers and our communication in connection with offers;

• the optimization and improvement of user-friendliness of websites and apps;

• the development and testing of new offers;

• the review and improvement of our internal processes;

• statistical evaluations, for example, to evaluate information about our customers’ interactions with us on an anonymous basis;

• market monitoring, for example, to understand current developments and trends and respond to them.

6.5 Security and Prevention

We wish to guarantee your and our security and prevent misuse. We therefore also process personal data for security purposes, to guarantee IT security, to prevent theft, fraud, and misuse, and for evidentiary purposes. This can concern all the personal data categories listed in Section 4, in particular transactional and behavioral data and image and sound recordings. We can acquire, analyze, and store this data for the purposes mentioned.

Examples of the purpose of security and prevention include:

• the creation and evaluation of video recordings for the detection and prosecution of criminal acts;

• the imposition of bans from entering our premises or using our service and the administration of lists of persons banned from entering our premises or using our services;

• the analysis of transactional and behavioral data to detect suspicious behavior patterns and fraudulent activities;

• the evaluation of system recordings of the use of our systems (log files);

• the prevention, mitigation, and detection of cyber and malware attacks;

• analyses and tests of our networks and IT infrastructures, and system and error checks;

• control of access to electronic systems (e.g. logins for user accounts);

• physical access controls (e.g. access to office premises);

• documentation purposes and creation of backups.

6.6 Compliance With Statutory Requirements

We wish to lay the foundations for compliance with statutory requirements. We therefore also process personal data to comply with legal obligations.

Examples of this include receiving and processing complaints and other messages, and complying with court and administrative orders.

This can apply to all the personal data categories listed in Section 4.

Compliance with statutory requirements particularly includes:

• implementation of health and safety concepts;

• clarifications concerning business customers;

• the receipt and processing of complaints and other messages;

• the conducting of internal investigations;

• ensuring compliance and risk management;

• the disclosure of information and documents to authorities if we have an objective reason (e.g. because we ourselves are the injured party) or are legally obliged to do so;

• assistance with external investigations, for instance by criminal prosecution or supervisory authorities;

• guaranteeing the legally required standard of data security;

• fulfillment of duties of disclosure, duties to provide information, or reporting obligations, for instance in connection with obligations under supervisory and tax law, such as in the case of archiving obligations and for the prevention, detection, and investigation of criminal and other offenses;

• the statutory combating of money laundering and of the financing of terrorism.

Place of work provision

Our agents work at a designated client’s address. The information recorded of each “job” including client name, address, email and phone number is recorded and stored for 10 years from the date of the end of the job in accordance with employment law and the accounting laws of Switzerland. (CO. Art. 590). In accordance with the law, company officers reserve the right to access this information at any time.

Following the 10 years reasonable efforts will be made to anonymize and or delete the data .

All such instances may involve compliance with Swiss legislation or foreign regulations applicable to us, along with adherence to self-regulatory measures, industry standards, and other norms, as well as compliance with our own corporate governance principles or official directives.

6.7 Preservation of Rights

We aim to assert our rights and protect ourselves against the claims of others. Therefore, we also handle personal data for rights protection purposes, such as enforcing claims in legal proceedings, both in and out of court, and before authorities in Switzerland and abroad, or defending ourselves against claims. Depending on the situation, we process different categories of personal data, such as contact data and details of events that have led to or could lead to a dispute.

The purpose of the protection of rights in particular includes:

• establishment and enforcement of our claims, which may also include claims of companies affiliated with us and of our contractual and business partners;

• defense against claims made against us, our employees, affiliated companies, and our contractual and business partners;

• clarification of case prospects and other issues of a legal, economic, or other nature;

• participation in proceedings before courts and authorities in Switzerland and abroad. For example, we may secure evidence, have case prospects investigated, or submit documents to authorities. Authorities may also request us to disclose documents and data carriers containing personal data.

6.8 Administration and Support Within the Group

We wish to shape our internal processes efficiently. We therefore also process personal data for the internal administration of the Batgroup SA. We particularly process master data, contract data, and technical data, as well as transaction data, behavior data, and communication data.

Administration within the Group includes the following in particular:

• administration of IT

• accounting;

• archiving of data and management of our archives;

• training and education, for instance when we analyze recordings of telephone, video, or other forms of communication;

• central storage and management of data used by multiple companies of the Batgroup SA;

• the review or execution of corporate transactions such as corporate acquisitions, sales, and mergers.

• forwarding of inquiries to the offices responsible, for instance when you submit an inquiry to a Batgroup company that concerns another company;

• the sale of receivables for which we send the purchaser information, for instance about the reason for and amount of the receivable and, if applicable, the creditworthiness and behavior of the borrower;

• generally the review and improvement of our internal processes.

Like every group of companies, the Batgroup SA has an overall interest in the successful business activities of its Group companies, and our Group companies themselves have an interest in their own activities and processing purposes.

We may therefore also disclose personal data to other companies of the Batgroup SA in order to support their own processing purposes under the Batgroup SA Privacy Notice in the overall interests of the Batgroup SA. Further information about this can be found in Section 8.

7.What Is the Legal Basis for Processing Personal Data?

Depending on the purpose of the data processing, our processing of personal data is based on different legal grounds. In all cases we will comply with the laws of the local jurisdiction of the Batmaid entity you are transacting with.

For Switzerland the laws that govern are outlined in the nFADP Switzerland (updated: 1 September, 2023).

In particular, we may process personal data if:

• doing so is necessary to fulfill an agreement with the person concerned or for pre-contractual measures (e.g. to perform a cleaning job and administer Batmaid SA);

• it is necessary for the exercise of legitimate interests, for example when data processing is a central component of our business activities (i.e. Marketing);

• doing so is based on consent;

• doing so is required for compliance with Swiss and foreign legal obligations.

In particular, we have a legitimate interest in processing for the purposes set out in Section 6 above and the disclosure of data in accordance with Section 8 and the associated objectives. The legitimate interests in each case include our own interests.

Examples of these legitimate interests include interests in connection with:

• good customer support, maintaining contact and other communications with customers, including outside the framework of a contract;

• advertising and marketing activities;

• getting to know our customers and other individuals better;

• improving existing products and services and developing new ones;

• facilitating management and communication within the Group, which is necessary with a group that requires cooperation between parties;

• mutually supporting the Group companies in their activities and objectives;

• combating fraud, for example in online platforms, and preventing and investigating offenses;

• protecting customers and other individuals, as well as data, secrets, and assets of Batgroup SA;

• ensuring IT security, especially in connection with the use of websites, apps, and other IT infrastructure;

• safeguarding and organizing business operations, including the running and further development of websites and other systems;

• ensuring corporate management and development;

• the enforcement or defense of legal rights and claims;

• complying with Swiss and foreign law, as well as internal rules and regulations.

8. To Whom Do We Disclose Personal Data?

8.1 Within Batgroup SA

We may disclose personal data that we receive from you or third-party sources to other Batgroup companies. Disclosure may serve to facilitate intra-group administration or support of the group companies concerned and their own processing purposes (Section 6), such as when we support the personalization of marketing activities, the development and improvement of products and services, the conducting of credit assessments, or endeavors to prevent theft, fraud, and misuse. The personal data received may also be matched and linked to existing personal data by the relevant group companies.

For example, this may include the following disclosures of data:

• All personal data categories listed in Section 4 for the administration and processing of contractual relationships, especially in connection with products and services involving multiple Group companies;

• Master data, contract data, communication data, transactional and behavioral data, and preference data, as well as findings from customer and other surveys, studies, and image and sound recordings for market research and product development purposes, if the personalization of that data is necessary;

• Master data, contract data, communication data, transaction data, behavior data, preference data, and image and sound recordings for the delivery and personalization of offers, communication, and marketing activities;

• Master data, contract data, communication data, transaction data, behavior data, and preference data for the prevention of fraud and misuse and for credit assessments (e.g. in connection with a purchase on account);

• Master data, transaction data, behavior data, and image and sound recordings for purposes relating to theft protection and the provision of evidence;

• Security-relevant information for security purposes and compliance with statutory requirements;

• Information to support the safeguarding of rights.

If, for example, you contact us with an inquiry about our service, we may forward this information to the individual Batgroup company responsible for the service, for service & quality improvement purposes.

Section 2 contains more information on the companies belonging to the Batgroup.

8.2 Outside Batgroup SA

We may disclose your personal data to companies outside Batgroup if we make use of their services. These service providers generally process personal data on our behalf as so-called “contract processors”. Our contract processors are obliged to only process personal data under our instructions and to take suitable measures to ensure data security. Certain service providers are also responsible jointly with us or independently (e.g. collection agencies). We ensure through the selection of service providers and suitable contractual agreements that data protection is upheld during the entire processing of your data

Examples include services in the following areas:

• Shipping and logistics, for example for the delivery of ordered goods on batmaid club;

• Advertising and marketing services, for example for the delivery of messages and information

• Corporate management services, for example accounting or asset management

• Payment services

• Credit assessments, for example if you want to make a purchase on account;

• Collection services

• Insurance service providers

• IT services, for example in the areas of data storage (hosting), cloud services, the delivery of e-mail newsletters, and data analysis and refinement;

• Advisory services, for example, the services of tax advisers, lawyers, management consultants, or advisers in the field of personnel recruitment and placement.

It is also possible that we may disclose personal data to other third parties for their purposes, for example, if you have granted your consent or we are legally obliged or authorized to share such information. In such cases, the data recipient is legally responsible as the controller of the data.

Examples of such cases include the following:

• The transfer of claims to other companies, such as collection agencies.

• the review or execution of corporate transactions such as corporate acquisitions, sales, and mergers.

• The disclosure of personal data to courts and authorities within Switzerland and abroad, such as criminal prosecution authorities in case of suspected criminal activities.

• The processing of personal data in order to comply with a court or administrative order, or to enforce or defend legal rights or claims, or if we consider such processing to be necessary on any other legal grounds. We may also disclose your personal data to other parties involved in any proceedings.

Please take note of our Cookie Notice concerning independent data collection by third-party providers whose tools we have integrated into our websites and apps.

Medical Data

In the context of our contractual employment with agents only and with their explicit consent, Batgroup may receive, store, and process data originating from medical professionals received by letter, phone or email.

In the context of our agreement with clients to provide services, you may inform us of a medical condition, disability, or impairment that may affect our provision to provide services. In which case we will note this as a preference (comment) on your profile. In addition, you may also inform us that it is your insurance company or family member who is paying for your cleaning therefore data around this information will also be stored.

9. How Do We Disclose Personal Data Abroad?

We process and store personal data in Switzerland and the European Economic Area (EEA). In certain cases, however, we may also disclose personal data to service providers and other recipients (see Section 8).

10. How Do We Process Sensitive Personal Data?

Certain types of personal data are considered under data protection law to be sensitive, such as details about health. Depending on the circumstances, the categories of personal data listed in Section 4 may also comprise such sensitive personal data. However, we generally only process sensitive personal data if this is necessary for the provision of a service, if you have voluntarily disclosed this data to us, or have consented to such processing. We may also process sensitive personal data if this is necessary for the protection of rights or compliance with Swiss or foreign legal provisions, if the data concerned have clearly been publicly disclosed by the person in question, or if the applicable law otherwise permits its processing.

For example, we may process sensitive personal data in the following cases:

• You apply for a vacancy and provide details about your state of health, about a union affiliation, or about criminal records and criminal law measures.

11. How Do We Conduct Profiling?

“Profiling” refers to a procedure during which personal data is processed on an automated or manual basis in order to analyze personal aspects or make predictions, e.g. the analysis of personal interests, preferences, affinities, and habits or the prediction of likely behavior. Profiling can be used in particular to derive preference data (further details about this can be found in Section 4.5).

Profiling is a common procedure, e.g. it occurs in the context of the automated processing

• of master, contract, transactional and behavioral data for purchases on our website

• of transactional and behavioral data, as well as technical data, in connection with our websites and apps;

• of information in connection with the attendance of events or the participation in competitions, prize draws, and similar events;

• of communication data, such as your response to advertising and other messages;

• of other transactional and behavioral data.

Profiling helps us to:

• improve our offers on a continuous basis and tailor them to individual needs;

• present our contents and offers to you in accordance with your needs;

• to the extent possible only show you advertisements and offers that are likely to be relevant for you;

• support you better with our customer service;

• decide on the basis of a credit assessment which payment options are available.

Profiling also takes place in connection with your customer account, for instance when we analyze your usage and behviour on our website and apps in order to offer you an individual user experience and send you offers tailored to your interests.

In order to improve the quality of our analyses and predictions, we may also combine personal data that originates from different sources as the basis of our profiling, for example data that has been collected via our various departments or that we have received from other Batmaid companies. Self-learning algorithms (specific routines in computer programs) can also be used.

In certain cases, you also have the right to object to profiling, as described in Section 15.

12.Do We Use Automated Individual Decision-Making or Artificial Intelligence?

Automated individual decision-making refers to any decision that is made on a fully automated basis, meaning with no relevant human influences.

Examples of when we might use technology to take a decision:

• Select or reallocate a cleaning agent

• Cancel your cleaning when no cleaning agent is available

You will always have the option of having the decision reviewed by a human being if you do not agree with it.

13. How Do We Protect Personal Data?

We take appropriate technical and organizational security measures in order to safeguard your personal data, protect you against unauthorized or unlawful processing activities, and to address the risk of loss, unintentional changes, inadvertent disclosure, or unauthorized access.

Nonetheless, similar to all organizations, we cannot entirely eliminate the possibility of data security breaches; some residual risks are inherent. Technical security risks encompass data encryption and pseudonymization, record-keeping practices, access controls, and data backup storage.

Organizational security measures include providing guidelines to our staff, conducting training initiatives, and performing audits. Additionally, we mandate our contract processors to implement suitable technical and organizational security measures.

14.For How Long Do We Process Personal Data?

We process and store your personal data:

• for as long as it is required for the purpose of processing and compatible purposes, in the case of contracts normally for at least the duration of the contractual relationship;

• for as long as we have a legitimate interest in storing it. This may be the case, in particular, if we need personal data to enforce or defend claims, for archiving purposes, and to ensure IT security;

• for as long as it is subject to a statutory retention requirement. For example, a ten-year retention period applies to certain data. Shorter retention periods apply for other data, for example for recordings from video surveillance or for recordings of certain online processes (log data).

In specific instances, we may seek your consent if we intend to retain your personal data for extended durations (e.g., for archived job applications). Upon the expiration of the designated timeframes, we will either delete or anonymize your personal data.

For instance, we comply with the following retention periods, though there might be exceptions in certain cases:

• Customer accounts: personal data is stored for the duration that the account is active. If a customer account is ordered to be deleted, the data will be deleted after any open claims or other relevant points that prevent an immediate deletion have been examined, and after 30 days at the latest.

• Contracts: We generally retain master and contract data for ten years as of the last contractual activity or contract expiry. However, this period may be longer if this is necessary for the provision of evidence, due to statutory or contractual provisions, or for technical reasons. Transaction data in connection with contracts are generally retained for ten years.

• Technical data: The storage period of cookies is normally between a few days and two years unless they are immediately deleted at the end of the session.

• Communication data: E-mails, messages via the contact form and written correspondence are generally retained for ten years.

• Image and sound recordings: The retention period varies depending on the purpose. It can range from a few days in the case of video surveillance recordings to several years in the case of reports about events with pictures.

• Job applications: We generally delete application data within five years after the conclusion of the application process. We may keep your application on file with your consent with a view to potential recruitment at a later stage.

15. What Rights Do You Have in Connection With the Processing of Your Personal Data?

You have the right to object to data processing, especially if we process your personal data based on legitimate interests and other relevant requirements are met.

You can also object to data processing related to direct advertising (e.g., promotional emails) at any time. This includes objecting to profiling, to the extent that it pertains to direct advertising.

Subject to applicable conditions and statutory exceptions, you also have the following rights:

• The right to request information about your stored personal data.

• The right to have incorrect or incomplete personal data corrected.

• The right to request deletion or anonymization of your personal data.

• The right to request the restriction of processing your personal data.

• The right to receive certain personal data in a structured, commonly used, and machine-readable format.

• The right to withdraw consent for future processing, where processing is based on consent.

Please note that these rights may be restricted or excluded in individual cases, such as doubts about identity or to protect other individuals, safeguarding interests worthy of protection, or complying with legal obligations.

You can exercise these rights, particularly the essential ones, via your customer account or our Help Center. If you have a customer account, you can update your stored master data (e.g., address) at any time. From your customer account, you can also request account deactivation or complete deletion of your personal data.

Additionally, you can unsubscribe from newsletters and other promotional emails by clicking the corresponding link at the email's end. For exercising rights or inquiries about personal data processing, you may contact us under Section 16.

Furthermore, you have the freedom to file a complaint with a competent supervisory authority if you suspect that the processing of your personal data might violate applicable laws.

The competent supervisory authorities are as follows:

Switzerland: Federal Data Protection and Information Commissioner (FDPIC).

16. How Can You Contact Us?

Batmaid SA

℅ Data Protection & Processing

Avenue de Lavaux 77

CH-1009 Pully

17. Changes to This Privacy Policy

This Privacy Notice might undergo updates over time, particularly if there are alterations to our data processing practices or new legal requirements emerge. We will actively notify individuals whose contact information is on file with us of any significant changes, provided that we can do so without disproportionate effort. Typically, the version of the Privacy Notice in force at the start of the relevant data processing activity applies.

Last Modification Date: 14.03.2024