Privacy Policy

When we speak about ELITO in the following, it refers to the companies mentioned in the imprint (compare legal information in the imprint). We, i.e. ELITO, are responsible under the data protection law pursuant to art. 4 no. 7 GDPR for the collection, processing and use of your personal data and lawful data processing. We are committed to handling your personal data responsibly. Consequently, we consider it as a matter of course to meet the statutory requirements of the Swiss Federal Data Protection Act (FDPA), the Ordinance to the Federal Data Protection Act (OFDPA), the Telecommunications Act (FMG) as well as the provisions of the EU General Data Protection Regulation (EU-GDPR) and other regulations of the Swiss and European data protection law. 

In the following, we would like to inform you about how we handle your personal data.

1. Central storage

We save the data specified in the afore-mentioned provisions in a central electronic data processing system. Your data is thereby systematically recorded, linked and evaluated in order to process your enquiries and to process our services.

This processing is based on our legitimate interest within the meaning of art. 6 para. 1 lit. f EU-GDPR in customer-friendly and efficient customer data management. This data processing is also based on the contract fulfilment within the meaning of art. 6 para. 1 lit. b EU-GDPR.

You can object to such data processing at any time if reasons exist in your particular situation, which speak against the data processing (for this, refer to section 14 Contact).

2. Forwarding of the data to third parties

We forward your data only if you have explicitly consented to the same, we are obligated to do so by law, if this is necessary for the assertion of our rights or we need to do this to run our business. In addition, we shall transmit your data to our affiliated companies (compare Imprint). Moreover, we forward personal data of users to third parties if this is necessary within the scope of the use of the website as well as the answering of questions, processing of enquiries or for any provision of services requested by the user. The use of such forwarded data by the third parties is strictly limited to the specified purposes.

An overview of service providers within the meaning of the preceding paragraph is available here. Other third-party service providers are explicitly mentioned in this Privacy Policy (e.g. in section 4 Use for marketing purposes, section 7 tacking tools).

3. Use for marketing purposes

Newsletters and other marketing campaigns

 With your subscription to the newsletter, if you have expressly agreed that we can, we will use your address and personal data for marketing campaigns such as the delivery of the ELITO newsletter and/or the dispatch of catalogues. You can unsubscribe from all marketing campaigns at any time. You can find the contact information below in section 14 Contact.

For sending our newsletter, we use e-mail marketing services of Schober

Our newsletter can contain a so-called web beacon (tracking pixel) or similar technical means. A web beacon is a 1×1 pixel, invisible graphic that is associated with the user ID of the respective newsletter subscriber.

For each newsletter sent, there is information about the address file used, the subject and the number of newsletters sent. In addition, you can see as to which addresses have not yet received the newsletter, to which address the newsletter was sent and in case of which addresses the dispatch has failed. The opening rate including the information as to which addresses have opened the newsletter and which addresses have unsubscribed from the newsletter mailing list can also be explained. We use this data for statistical purposes and to optimise the newsletter in terms of content and structure. This enables us to better tailor the information and offers in our newsletter to the individual interests of the recipients. The tracking pixel is deleted if you delete the newsletter. 

To prevent the use of the web beacon in our newsletter, please set your mail program such that no HTML is displayed in messages, if this is already not the case by default. On the following pages, you shall find explanations as to how you can make this setting for the most common e-mail programmes.

Microsoft Outlook

Mail for Mac ("Load removed contents in messages") This data processing is based on art. 6 para. 1 lit. f EU-GDPR. This general permission allows the processing of personal data within the scope of our legitimate interest. The legitimate interest lies in sending marketing to promote our business, ensuring our direct marketing messages are received, and the analysis of the use of the newsletters. You can object to such data processing at any time (refer to section 14 Contact).

DoubleClick by Google / DoubleClick Floodlight

DoubleClick by Google, a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") is used on this website. For this purpose, Google uses the so-called DoubleClick cookie, which makes it possible to recognise the browser used by the user when visiting other websites. The information generated by the cookie about the visit to these websites (including the IP address) shall be transmitted to and stored on a Google server in the USA (refer to section 9 Information on data transfers to the USA). 

Google uses this information to evaluate the use of the website concerning the advertisements to be shown in order to compile reports for the websiteoperator regarding the website activities and advertisements, and to provide further services related to the use of the website and Internet usage. Google may also transfer this information to third parties insofar as this is prescribed by law or if third parties process this data on Google’s behalf. Google shall however, under no circumstances, associate the IP address of a user with any other data held by Google.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data that is collected by Google through the use of this tool and we would therefore like to inform you according to our state of knowledge: by integrating DoubleClick, Google receives the information that you have called up the corresponding part of our website or have clicked on an advertisement placed by us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is the possibility that the provider finds out and stores your IP address.

In addition, the DoubleClick Floodlight cookies used allow us to understand as to whether you are undertaking certain actions on our website after you call up one of our display/video advertisements on Google or another platform via DoubleClick or have clicked on these (conversion tracking). DoubleClick uses this cookie to understand the content you have interacted with on our websites, in order to later send you targeted advertising.

For more information on DoubleClick by Google, please visit https://www.google.de/doubleclick, as well as for data protection at Google in general: https://www.google.de/intl/de/policies/privacy. The creation of pseudonymised user profiles for advertising and analysis purposes is based on a legitimate interest within the meaning of art. 6 para. 1 lit. f EU-GDPR. This applies to all data processing operations listed. The legitimate interest lies in the direct marketing and the analysis of the use of our website.

You can object to the previously listed data processing in different ways:

through an appropriate setting of your browser software, in particular, the suppression of third-party cookies that causes you not to receive third-party advertisements (refer to section 6 below);
by disabling the cookies for conversion tracking by setting your browser such that cookies are blocked by the domain, https://www.google.de/settings/ads, where this setting is deleted when you delete your cookies;
by disabling the interest-related advertisements of the providers, who are part of the self-regulatory campaign "About Ads", via the link http://www.aboutads.info/choices, where this setting is deleted when you delete your cookies;
through permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin.

Facebook Pixel / Facebook Custom Audience

On our website, we use "Facebook Pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are a resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Facebook can designate visitors to our website as a target group for displaying advertisements (so-called "Facebook Ads") using Facebook-Pixel. Accordingly, we use Facebook-Pixel to display Facebook ads that are placed by us only to such Facebook users, who have also shown interest in our website or have shown specific characteristics (e.g. interests in specific topics or products that are determined based on the websites visited), which we transmit to Facebook (so-called "Custom Audiences").

With the help of Facebook-Pixel, we would also like to ensure that our Facebook ads correspond to the potential interest of the users and are not harassing. Using Facebook-Pixel, we can also understand the effectiveness of Facebook Ads for statistical and market research purposes, in which we see as to whether users were forwarded to our website after clicking on a Facebook ad (so-called "Conversion").

Facebook-Pixel is directly integrated by Facebook when accessing our website and can save a so-called cookie on your device. If you subsequently log in to Facebook or visit Facebook while being logged in, the visit to our website shall be noted in your profile. The data collected about you is anonymous for us, so it does not provide us with any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible. The data can therefore be used by Facebook for its own market research and advertising purposes.

Furthermore, when using Facebook-Pixel, we use the additional function "expanded comparison", in which data on the creation of target groups ("Custom Audiences" or "Look Alike Audiences") is transmitted to Facebook in an encrypted form.

The processing of data by Facebook takes place within the framework of Facebook‘s Privacy Policy. You can obtain special information and details on Facebook-Pixel and its functionality in the Help Area of Facebook.

You can object to the collection by Facebook-Pixel and use of your data to display Facebook Ads. In order to set which types of advertisements are displayed to you within Facebook, you can view them by visiting Facebook’s set-up page and follow the information on the settings for use-based advertising.

You can also object to the use of cookies that serve for reach measurement and advertising purposes using the Deactivation page of the Network Advertising Initiative. You can find additional opt-out options here:

The legal basis for the aforementioned data processing lies in our legitimate interest in the analysis, optimisation and economic operation of our online offer (art. 6 para. 1 lit. f GDPR).

Sizmek Retargeting 

We use the technology of the provider Sizmek Inc., 401 Park Avenue S, 10016 New York City, USA, which allows us to present you with relevant and targeted advertising material as well as advertising displays on our website even about offers of third parties based on your interests and user behaviour. We also use Sizmek to measure and statistically analyse the success of our advertising displays (e.g. interaction with or click on an advertisement).

For this purpose, cookies are used to analyse and evaluate your usage behaviour (e.g. clicks) and the interaction with advertisements. The data collected includes usage-related data (e.g. clicks on advertisements, websites, time and length of stay) and browser data (e.g. language setting, screen resolution), which does not permit us to draw any conclusion about your identity. For more detailed information on privacy and your setting options, visit https://www.sizmek.com/privacy-policy-de. You can object to the use of Sizmek via the opt-out tool under https://www.sizmek.com/privacy-policy-de at any time. The legal basis for the aforementioned data processing lies in our interest to promote our business using personalised and interest-based advertisement(art. 6 para. 1 lit. f GDPR).

4. Transmission of personal data abroad

ELITO transfers your data to third-party companies abroad to the extent this is required in connection with the processing of your requests, the provision of services and marketing campaigns. These third-party companies are obligated to respect the privacy of users to the same extent as the provider itself. If the level of data protection in a country is considered unsuitable by Swiss standards or within the meaning of the EU General Data Protection Regulation, we shall ensure, by means of a contract, that your personal data is protected according to Swiss regulations or the EU General Data Protection Regulation at all times. Most service providers are located either in Switzerland, Germany or the EU. The website is hosted on a dedicated server of the company aspectra AG, Weberstrasse 4, 8004 Zurich, Switzerland. However, some of the third-party service providers mentioned in this Privacy Statement are based in the USA (refer to section 7 Tracking Tools and section 8 Social Media Functionalities). Further information on data transfers to the USA can be found in section 9.

5. Cookies

In many respects, cookies help to make visiting our website easier, more pleasant and more useful. Cookies are information files stored automatically by your web browser on the hard disk of your computer when you visit our website.

For example, we use cookies in order to temporarily save your entries when completing a form on the website, so that you do not have to repeat the entries when you call up a different sub-page. Most Internet browsers accept cookies automatically. However, you can configure your browser such that no cookies are stored on your computer or a notice always appears when you receive a new cookie. An objection to the setting of cookies and the collection of personal data can also be implemented in this way. The following pages explain how to configure the processing of cookies for the most common browsers: 

Microsoft Windows Internet Explorer
Microsoft Windows Internet Explorer Mobile
Mozilla Firefox
Google Chrome for Desktop
Google Chrome for Mobile
Apple Safari for Desktop
Apple Safari for Mobile

Deactivating cookies may however result in you not being able to use all functions of our website.

6. Tracking tools

Google Analytics

The website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Google Analytics uses methods that allow an analysis of the use of the website, such as "Cookies" (refer above to section 6 Cookies). The following information generated by the cookie about your use of this website  navigation path that a visitor takes on the site, length of stay on the website or sub-page, the sub-page, on which the website is left, the country, region or city, from where access takes place, end device (type, version, colour depth, resolution, width and height of the browser window), recurring or new visitor, browser type/version, operating system used, referrer URL (the previously visited page), host name of the accessing computer (IP address) and time of the server query is transmitted to and stored on Google servers, a company of the holding company Alphabet Inc., in the USA. The IP address is shortened by the activation of IP anonymisation ("anonymizeIP") on this website, before transmission within the Member States of the European Union or other states that are party to the Agreement on the European Economic Area, as well as in Switzerland. Google does not merge the anonymised IP address transmitted by your browser within the scope of Google Analytics with other data. Only in exceptional cases, the full IP address is transferred to a Google server in the USA and shortened there. In these cases, we ensure through contractual guarantees that Google complies with a sufficient level of data protection. 

The information is used in order to evaluate the use of the website, to compile reports on the activities on the website and to provide other services related to the use of the website and the Internet for the purposes of market research and tailor- made website design. Google may also transfer this information to third parties insofar as this is prescribed by law or if third parties process this data on order. According to Google, no connection is ever made between the IP address and other data relating to the user.

Users can prevent the collection of the data (including the IP address) generated by the cookie and related to the website use by the respective user by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de  As an alternative to the browser plug-in, users can click on this link to prevent the collection by Google Analytics on this website in the future. An opt-out cookie is stored on the user’s end device. If the user deletes cookies (refer to section 6 Cookies), the link must be clicked again. 

Google Tag Manager

The website uses the Google Tag Manager from Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Google Tag Manager is a solution, using which the marketer can manage website tags via an interface. The Tag Manager tool is a domain without cookies that does not record personal data. The tool ensures the triggering of other tags, which may, under certain circumstances, collect personal data on their part. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it remains for all tracking tags that are implemented with Google Tag Manager. You can prevent the placement of tags at any time (refer to section 6 Cookies).

Facebook Connect

On our website, you can log in to create a customer account or to register by means of the social plug-in "Facebook Connect" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"), within the scope of the so-called Single Sign-On technique, if you have a Facebook profile. You can recognise the social plug-ins of "Facebook Connect" on our website by the button with the Facebook logo and the "Connect with Facebook" or "Log in with Facebook" or "Sign in with Facebook" label.

When you call up our website that contains such a plug-in, your browser connects directly to the Facebook servers. The content of the plug-in is transmitted directly by Facebook to your browser and integrated into the page. By integrating the plug-in, Facebook receives information that your browser has accessed the relevant page of our website, even if you do not have a Facebook profile or are currently not logged into Facebook. This information (including your IP address) is transmitted by your browser directly to a Facebook server in the USA and stored there (refer to section 9 Information on data transfers to the USA).

By using this "Facebook Connect" button on our website, you also have the option to log in or register on our website with your Facebook user data. Only if you, before the registration process, give your express consent to the exchange of data with Facebook on the basis of a corresponding notification pursuant to art. 6 para. 1 lit. a EU-GDPR, we shall receive the general and publicly accessible information stored in your profile for use of the "Facebook Connect" button from Facebook, depending on your personal data protection settings on Facebook. This information includes the user ID, name, profile image, age, and gender.

We would like to point out that in accordance with changes to the data protection conditions and terms of use of Facebook when giving the consent, there can also be a transfer of your profile images, the user IDs of your friends and the friends list if these were marked in your private sphere settings on Facebook as "public". The data transmitted by Facebook is stored and processed by us to create a user account with the necessary data, if they have been released by you on Facebook (title, first name, last name, address data, country, e-mail address, date of birth). On the other hand, based on your consent, data (e.g. information about your surfing or purchasing behaviour) can be transferred from us to your Facebook profile.

The consent granted can be revoked at any time with effect for the future (refer to no. 14 Contact).

To find out about the purpose and extent of data collection and further processing and use of the data by Facebook and your rights in this regard and the setting options for protecting your privacy, please refer to Facebook’s privacy notices: http://www.facebook.com/policy.php

If you do not want Facebook to directly assign the data collected via our web presence directly to your Facebook profile, you must log out of Facebook before visiting our website.

7. Social media functionalities

These are not plug-ins from the provider, which already transmit data to the provider when loading the page without any action on the user’s part. The interfaces to the social media networks only contain a link to the social network including transfer of the website to be shared. No user data is transmitted from the website to the social network.

When you click on the relevant social network icons, you will be linked with the relevant social network to perform the chosen functionality, e.g. to share content on Facebook or to tweet on Twitter. To do this, however, you must log into your corresponding user account or be already logged in.

If you select one of the functionalities provided and click on the icon of the relevant social network, a direct connection is established between your browser and the server of the relevant social network. This gives the network the information that you have visited our website with your IP address and accessed the link. If you access a link to a network while being logged in to your account on the relevant network, the contents of our page may be linked with your profile in the network, which means that the network can link your visit to our website directly to your user account. If you want to prevent this, you should log out before clicking on the relevant links. An assignment takes place in any case, if you log into the relevant network after clicking on the link.

Links to our own social media presences

If you click on the relevant social network icons, you will be automatically redirected to our profile on the relevant network. In order to use the functions of the relevant network there, you must partially log in to your user account with the relevant network.

When you open a link to one of our social media profiles, a direct connection between your browser and the server of the relevant social network is established. This gives the network the information that you have visited our website with your IP address and accessed the link. If you access a link to a network while being logged in to your account on the relevant network, the contents of our page may be linked with your profile in the network, which means that the network can link your visit to our website directly to your user account. If you want to prevent this, you should log out before clicking on the relevant links. An assignment takes place in any case, if you log into the relevant network after clicking on the link.

8. Information on data transfers to the USA

For the sake of completeness, please note that under US law, the US authorities may carry out surveillance measures that allow the general storage of all data transferred from the European Union or Switzerland to the USA. This is done without distinction, restriction or exemption on the basis of the objective pursued and without objective criteria that would make it possible to restrict the US authorities’ access to personal data and its subsequent use for specific, strictly limited purposes that would justify access to that data. 

We point out to users with domicile in a Member State of the EU that the USA does not have a sufficient level of data protection from the perspective of the European Union – among other things, due to the topics mentioned in this section. To the extent we have explained in this Privacy Policy that recipients of data (such as Google) have their registered office in the USA, we ensure either by contractual regulations with these companies or by ensuring the certification of these companies under the EU-US Privacy Shield, that your data is protected by our partners at an appropriate level.

Right to information, correction, deletion and restriction of the processing; right to data transferability, right of appeal

You can any time object to data processing, particularly to data processing in connection with direct advertisement (e.g. against advertising e-mails). You have the following rights:

Right to information: You have the right to demand an insight into your personal data saved with us any time and free of charge if we are processing this data. You can check as to which of your personal data is being processed by us, and that we are using it according to the applicable data protection regulations.
Right to correction: You have the right to have incorrect or incomplete personal data corrected and to be informed about the correction. In this case, we shall inform the recipients of the data concerned about the corrections made unless this is impossible or associated with disproportionate effort.
Right to deletion: You have the right to have your personal data deleted under certain circumstances. In the individual case, the right to deletion may be excluded.
Right to restriction of the processing: Under certain conditions, you have the  right to demand restriction of the processing of your personal data.
Right to data transfer: Under certain circumstances, you have the right to get the personal data that was provided to us by you free of charge in a readable format.
Right of appeal: You have the right to appeal to a competent supervisory authority against the method of the processing of your personal data.
Right of revocation: You basically have the right to revoke an issued consent at any time. Processing activities in the past based on your consent shall however not become illegal through your revocation.

10. Advice for children and parents

The Zoë Luxury website is aimed at an adult audience. It is forbidden for minors and especially children under 13 years of age, to transmit personal data about  themselves to us or to register to receive a service. If we detect that such data has been transmitted to us, it will be deleted from our database. The parents (or legal guardians) of the child may contact us and request deletion of the data or de-registration. For this purpose, we require a copy of an official document confirming you as a parent or guardian.

11. Data security

We use suitable technical and organisational security measures that seem appropriate to us to protect your data stored by us from manipulation, partial or total loss and unauthorised access by third parties. Our security measures are continuously updated according to technological developments.

We also take the protection of our own internal company data very seriously. Our staff and the service providers engaged by us are obligated to maintain confidentiality and to comply with the data protection regulations. Moreover, these are granted access to personal data only as far as is necessary.

12. Storage of data

We only store personal data as long as necessary, in order to use the listed tracking services within the framework of our legitimate interest; in order to perform the above cited scope of services that you have requested or to which you have given your consent.

We retain contract data for longer as this is prescribed by statutory retention requirements. Retention requirements that obligate us to retain data derive from provisions of accounting and tax regulations. According to these provisions, business communication, concluded contracts and booking documents must be stored for up to 10 years. If we no longer need this data to perform the services for you, the data shall be blocked. This means that the data may then only be used for fulfilling our retention requirements. 

14. Contact and contact details of the data protection officer

If you have any questions on data protection on our website, would like more information or would like to arrange for your data to be deleted, please get in touch with us by filling in the relevant online contact form or sending an e-mail to info@elito.shop

By post, please send your requests to the address below: 

ELITO
Data Privacy 
Rue du Rhône 14 
1204 Genève Switzerland 

The Data Protection Officer of the party responsible is available via mail at  info@elito.shop

15. Right of appeal to a supervisory authority

Irrespective of another judicial remedy or remedy under the administrative law, you have the right of appeal to a supervisory authority, in particular in the Member State of your place of residence, place of work or the place of the suspected infringement if you believe that the processing of your personal data infringes the EU-GDPR. The supervisory authority, to which the appeal was made, shall inform the appellant about the status and the results of the appeal including the possibility of a judicial remedy pursuant to art. 78 EU-GDPR. 

16. Automated decisions in individual cases including profiling

You have the right to not be subjected to a decision based exclusively on automated processing – including profiling – which has a legal effect against you or significantly affects you in a similar manner. This shall not be applicable  if the decision;

is necessary for the conclusion or fulfilment of a contract between you and the party responsible,
is admissible based on legal provisions of the Union or of the Member States, which the party responsible is subject to, and these legal provisions contain appropriate measures to safeguard your rights, freedoms and legitimate interests, or
takes place with your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to art. 9 para. 1 EU-GDPR, unless art. 9 para. 2 lit. a or g EU- GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests. With regard to the cases stated in (1) and (3), the party responsible takes appropriate measures to protect the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person from the party responsible, to state your own point of view and to challenge the decision. 

Last updated: April 2021