Privacy Policy

EMR Suisse AG operates the Emaar mobile app (“App”) and is responsible for collecting, processing and using your personal data in compliance with the applicable data protection law.

As part of the App, we enable you to use and display, in particular, the use of the Emaar Loyal-ty Program. When you use our App we may process personal data about you. Personal data in this sense refers to all information relating to an identified or identifiable person. Because your trust is important to us, we would like to inform you about what and how we may use personal data.

We take the protection of data seriously and ensure appropriate security. We observe the statutory provisions of the Federal Act on Data Protection (FADP), the Ordinance to the Federal Act on Data Protection (OFADP), the Telecommunications Act (TCA) and other applicable data protection provisions of Swiss and international law, in particular where applicable EU law.

You can at any time check our privacy policy on our App when accessing the Terms and Use page via the account section of the Mobile App. Access to it would be available from the registration screen. If you have any questions regarding data protection, you can get in touch with us by sending us a message to support@emrtoken.com.

Data processing in connection with our App

1. What data do we collect when you download and access our App?

When you download our App the following technical data is collected without your intervention and stored by us until automated deletion, as in principle with every download and access of an app:

– the IP address of the requesting device,
– the location (country) of your device,
– the operating system version of your device,
– the configuration of the App when using our services,
– the date and time of your use of our services,
– the status code (e.g. error message, debug information), and
– potentially additional statistical information.

The collection and processing of these data are carried out for the purpose of enabling the use of our App (establishing a connection), ensuring system security and stability over the long term and optimizing our services as well as for internal statistical purposes. It is within our legitimate interest to process such data for the above-named purposes.

The data collected may also be used in the event of attacks on the network infrastructure respectively other unauthorized or abusive use of the App to identify offenders in connection with civil or criminal proceedings. The processing of this information is in our legitimate interest to secure and improve our App accordingly.

2. Is personal data automatically collected?

When using our App, we automatically collect certain data required to ensure the usability of the App. In particular:

– the internal ID of your device,
– the version of your operating system, and
– the time of access.

The collection and processing of this data are carried out for the purpose of enabling the use of our App (establishing a connection), ensuring system security and stability over the long term and ensuring a customer-friendly use of our App as well as internal statistical purposes. The processing of this personal data is within our legitimate interest.

The internal ID of your device may also be evaluated together with other data in the event of attacks on the network infrastructure or other unauthorised or abusive use of our website for the purpose of clarification and defence and, if necessary, used within the framework of criminal proceedings for identification and for civil and criminal action against the users concerned. The processing of this information is in our legitimate interest.

3. What data do we collect when you create an account with us?

You can create a user account on our App, through which you can easily access information about the Emaar Loyalty Program. To do so we require you to provide us with the following information:

– first name,
– last name,
– user name,
– telephone number phone,
– email address, and
– date of birth.

In addition you can enter other voluntary information. If a user wishes to become a connector on our App then the following additional information is required:
– country of residence, and
– a copy of an identification document including a selfie.

If you do not enter all the information mentioned above, you will not be able to create a user account. In addition, you can provide other voluntary information.

We use the mandatory information to authenticate you when you log in and to follow up re-quests to reset your password. The processing of this data is, therefore, necessary for us to fulfill our pre-contractual and contractual obligations and is also in our legitimate interest.

We use voluntary information in order to display it in the App according to the settings you have made. The processing of this personal data is, therefore, necessary for us to fulfill our pre-contractual and contractual obligations and is also in our legitimate interest to offer our services.

4. What personal data is collected when you are using the App?

When using the App, you can enter, manage and edit various information, tasks and activities. In particular, this information includes personal data that we receive directly from you (such as name, date of birth, selfie) as well as location data or other data that we receive via interfaces.

The App also requires the following permissions:

– Internet access: This is required in order to save your entries on our server.
– Camera access: This is required to take photos of your documents and store them in the app and on our servers.
– Biometric access: This is required in order to securely access the App using FaceId/TouchId/Fingerprint access.

The processing of this data is necessary for the fulfillment of pre-contractual and contractual obligations as well as for the use of the App.

5. What personal data do we collect when you allow us to send you push notifications or SMS?

You have the possibility to allow push notifications or SMS messages by us to be informed about news and current offers. For this we need the following information:

– first name, last name,
– telephone number.

We use this information to deliver our communications only if you have consented to receive them. You can unsubscribe from our news services at any time.

6. What personal data do we collect from third parties?

We may collect information, including personal information, that existing users provide about you to refer you to us. We do not control, supervise or respond for how the existing users providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such existing users. If you are invited to join the Emaar Loyalty Program or respond to one of our offers, the person who invited you may submit personal information about you such as your email address or other contact information.

We process this information to facilitate the referral invitation which is in our legitimate interest.

7. What are cookies? Do we need cookies?

Cookies help in many ways to make the use of our App easier, more enjoyable and more meaningful. Cookies are information files that your web browser automatically saves on your device’s hard drive when you visit our App. In particular, we use the following cookies:

– technically necessary cookies,
– performance cookies, and
– functional cookies.

We use these cookies, for example, to temporarily store your entries when filling out a form on the App, so that you do not have to repeat the entry when calling up another subpage. Cookies may also be used to identify you as an authorized and registered user after you register on the App, without you having to log in again when you visit another page.

Usually, cookies are automatically accepted. You can disable the function, however, so that no cookies are stored on your device or a message always appears when you receive a new cook-ie.

Disabling cookies may prevent you from using all features of our App. This information is required for the adequate performance of the contract between you and us and is in our legitimate interest in being able to provide and improve the functionalities of the App.

8. Do we track your activity on the App?

We use tracking tools such as Google Analytics for Firebase for the purpose of designing and continuously optimizing our App to meet your needs. In this context, pseudonymized user profiles are created and small text files stored on your device (cookies) are used. The information generated by the cookies about your use of our App is transferred to the servers of the provider of these services, stored there and processed for us. In addition to the data listed in section 1, we may receive the following information:

– navigation path of a user,
– time spent on the App,
– the country, region or city from which access is made,
– the device (type, version, color depth, resolution, width, and height of the browser window), and
– if you are a recurring or new user.

The information is used to evaluate the use of the App, to compile reports on App activity and to provide other services related to the use of the App and the internet for purposes of market research and needs-based design of this App. In addition, this information may be transferred to third parties if this is required by law or if third parties process this data on our behalf. Such processing is required by us for the performance of the contract between you and us and is in our legitimate interest in being able to provide and improve the functionalities of the App.
Storage and exchange of data with third parties

9. Is this data stored or linked?

We store the data collected with our server host. The processing of this data is based on our legitimate interest in customer-friendly and efficient customer data management.

10. How long will my data be kept?

We only store personal data for as long as it is necessary to use the above tracking services and further processing in the context of our legitimate interest. Contract data is stored by us for a longer period of time, as this is prescribed by statutory obligations. Obligations to store data arise out of accounting law, civil law and tax law. According to these laws, business communication, concluded contracts and accounting vouchers must be stored for up to 10 years. If we no longer need this data to carry out the services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.

11. Will my data be disclosed to other third parties?

We only disclose your personal data to other third parties if you have expressly consented, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular, to enforce claims arising from the contractual relationship. In addition, we may disclose your data to third parties such as our affiliates, collaborators or partners such as IT partners and our App developer insofar as this is necessary for the development or the use of the App.

12. Do we transfer personal data abroad?

We are entitled to transfer your personal data to third parties (contracted service providers) abroad for the purpose of the data processing described in this privacy policy. These are bound to protect data to the same extent as we are. If the level of data protection in a country does not correspond to that in Switzerland or Europe, we will contractually ensure that the protection of your personal data corresponds to that in Switzerland or Europe at all times.

Anything else you need to know?

13. You have a right of access, rectification, deletion and limitation of the processing as well as of data transferability

You have a right to request information regarding the personal data that we store about you. In addition, you have a right to correct incorrect data and a right to request the deletion of your personal data, insofar as there is no legal obligation to retain such data and no legal basis for further processing the existing data.

You can contact us for the aforementioned purposes via the email address support@emrtoken.com. In order to process your requests, we may request proof of your identity.

In many countries, you also have the right to file a complaint with the relevant data protection authority if you have concerns about how we process your data.

These rights depend on the applicable data protection legislation and may be either more limited or more comprehensive.

14. Is your data safe with us?

We use suitable technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

You must always treat your access data confidentially, especially if you share your device, tab-let or smartphone with others. If you do not do so, we may have claims against you for damages caused by a breach of your confidentiality obligations to us.

We also care about data protection internally. Our employees and service providers are contractually obliged to ensure the confidentiality of personal data and compliance with applicable data protection laws.

15. Is the same protection provided when data is transferred abroad and in particular to the USA?

For the sake of completeness, for users residing or domiciled in Switzerland, the EU or the EEA, we would like to point out that in the USA there are surveillance measures by US authorities which generally allow them to get access to all personal data that has been transferred from Switzerland to the USA. This is done without differentiation, limitation or exception based on the objective pursued and without an objective criterion that would allow limiting the access to the data and subsequent use thereof by US authorities to very specific, strictly limited purposes that could justify the interference associated both with access to and use of such data. In addition, we would like to point out that in the USA there are no legal remedies available for the persons concerned from Switzerland that would allow them to gain access to the data concerning them and to obtain its correction or deletion, or that there is no effective legal protection against general access rights of US authorities. We explicitly draw your attention to this legal and factual situation in order to enable an informed decision to consent to the use of your data.

We would like to point out to users residing in Switzerland or an EU or EEA member state that the USA does not have an adequate level of data protection, partly due to the issues mentioned in this section.

Insofar as we have explained in this privacy statement that recipients of data (such as Google) are based in the USA or in another country that does not have an adequate level of data protection, we will ensure that your data is protected at an appropriate level by our service providers, either through contractual arrangements with these companies or by ensuring that these companies are certified under the EU or Swiss-US Privacy Shield.

16. Which law do we apply? And where does the law apply?

This privacy policy and the contracts concluded on the basis of or in connection with this policy are subject to Swiss law, unless the law of another country is mandatory. The place of jurisdiction shall be the registered office of EMR Suisse AG, unless another place of jurisdiction is mandatory.

17. Can this policy be amended?

Should individual parts of this privacy policy be invalid, this shall not affect the validity of the rest of the privacy policy. The invalid part of this privacy policy shall be replaced in such a way that it comes as close as possible to the economically intended purpose of the invalid part.

Due to the further development of our App and offers or changes to the statutory requirements, it may become necessary to amend this privacy policy. The most current privacy policy is published on our App.

18. Questions about data protection? Please, contact us!

This page was last modified on February 04, 2020. If you have any questions or comments about our legal notices or data protection, please contact us at support@emrtoken.com.