Last update: [21 July 2023]

Anna Bey Privacy Notice (Privacy Notice) explains how we use personal data collected by us. Personal data is information that relates to you and may identify you as an individual. This Privacy Notice applies to Bey International SA (“Anna Bey”, “we”, “us”, or “our”), where we are acting as a data controller (in other words, where we determine the purposes and means of the personal data processing) and with respect to our websites and services referencing this Privacy Notice. We value your right to privacy and strive to protect your data by applicable data protection legislation in each relevant country, including the Swiss Federal Data Protection Act (known as revFADP), effective as of 1 September 2023.

We do not have to receive your acceptance of this Privacy Notice, but if we need to receive your consent before using your personal data, we will explain the purpose of such use and invite you to agree to or refuse it. You can withdraw your consent at any time by contacting us (see section 1 below).

Our website may contain links to websites or services not controlled by us (third-party services). Such third-party services are provided by other persons (third parties), and their personal data processing practices may differ from ours; we encourage you to read the privacy notices of such third parties to be aware of how they use personal information.

If you have any questions or concerns about our use of your personal data, feel free to contact us.

1. Who we are and how you can contact us or relevant authorities 

   Who we are:

   We are registered in Switzerland under company registration number CHE-477.501.782 and have our principal place of business at Boulevard Georges-Favon 43, 1204 Geneva, Switzerland.

   How to contact us:

   You can contact us by email at team@annabey.com or by mail to Boulevard Georges-Favon 43, 1204 Geneva, Switzerland.

   If we do not satisfactorily answer your questions or concerns, you can contact relevant data protection authorities: the Federal Data Protection and Information Commissioner (FDPIC) or your national data protection authority.

   For the FDPIC, please refer to https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.

2. Information we may collect about you

   • We may collect personal information directly from you

     When you make inquiries about or purchase our products or services, contact our team, register an account on our website, register to attend our events, subscribe to our newsletters, or otherwise liaise with us, we may collect from you such information as name, surname, phone number, e-mail address, address, billing and shipping address, payment method.

   • We may collect certain information automatically

     When you use our website or other services, or contact us through electronic means, we may collect such information as:

     • Technical and user experience information: This information includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, approximate location, browser plug-in types and versions, operating system, and platform, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

       We do not normally use this information to identify you as an individual, but you can sometimes be recognized from such information, either alone or when combined or linked with other information. In these situations, this information can also be considered personal data under applicable laws, and we will treat such data as personal data.

     • Cookies: A cookie is a small piece of data (text file) that a website when visited by a user asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We may also use third party cookies which are cookies from a domain different than the domain of the website you are visiting. For example, we may use Google Analytics, Facebook Pixel, and TikTok Pixel, among others. You can find information on how we use cookies and how to manage your cookie preferences here: http://millionaireplaces.com/cookie-policy/.
   • Information we receive from other sources

     We may receive information about you from various third parties, including our service providers, business partners, or social media platforms. We may also collect information about you from publicly available sources. We will notify you about such information we have received, as appropriate.

     Note that to use some of our services you may be required to pass through the ID verification process or to make a payment. We engage service providers for the purposes of payment processing and your ID verification. When you interact with those service providers you may be required to provide additional information (such as your bank card details, your government documents and identifiers, or biometric data). We do not receive this information from our service providers, and their use of such information about you is subject to their own terms of personal data processing.

   • Sensitive information

     Such personal information as ethnicity, religious and political opinions, information relating to your health or sexual life has a higher degree of legal protection. Such information is broadly known as sensitive information or special categories of personal information. We do not collect special categories of personal information.

   • Children

     None of our services are intentionally directed to and intended for use by children whose age makes it illegal to process their personal data or requires parental consent to process their personal data. We do not knowingly collect personal information from any person under 16 years of age.

     If you’re a parent of a child under the age limit and become aware that your child has provided personal data to us, please, contact us at team@annabey.com.

   • Information you voluntarily submit

     You may not provide us with your personal information if you do not want to do so. Please, note that if you choose not to provide us with certain information about you, you may not be able to use all or a part of our services.

     When interacting with our services (and other users of our services), for example, when you attend our events, join, and participate in our social club, you may choose to share other information by your own choice. Please, be aware that the information you provide in this manner can be read, collected, or used by other users of these services. We are not responsible for the information you choose to submit in this way.

3. Purposes and legal bases of personal information processing 

   We process your personal information for specific reasons (purposes). Also, we may need to have specific grounds (also known as legal bases) to process your personal information. Below, you can see these reasons and legal bases (as applicable to you):

   • Running our business and services:Registration and authentication on our websites or services, organizing our events, recordkeeping, security maintenance and fraud prevention, managing risks and/or obtaining professional advice, and where necessary for the establishment, exercise, or defense of legal claims.

     Legal basis: legitimate interest; legal requirements.

   • Performing our agreements:Processing and fulfillment of your orders, supplying our goods or services, generating invoices or other payment documents, payment processing, accounting, shipping, and delivery.

     Legal basis: contract.

   • Support:Replying to your inquiries, notifying you of any changes/updates to our service (service-related communications), solving issues via live chats, phone, or email.

     Legal basis: legitimate interest; contract.

   • Improving our services:Testing features, interacting with feedback platforms and questionnaires, managing landing pages, heat mapping our site, traffic optimization and data analysis and research, including profiling and other techniques over your data and in some cases using third parties to do this.

     Legal basis: contract; legitimate interest.

   • Marketing and newsletters:Sending you emails and messages about events and new features, products and services, and content (marketing communications), conduct marketing activities, including profiling (creation of profiles by analyzing information regarding your interests and preferences concerning our products and services and your consumption choices, for example by identifying the type and frequency of purchases made by you). We do not perform high-risk profiling.

     Legal basis: legitimate interest; consent.

   • Other reasons:We may seek your consent for specific purposes. When we do so, we will explain the particular purpose in the relevant consent request.

     We may be required to take some actions by law or public authorities. If we are really obliged to do so, we may use your personal information to comply with such requirements.

     Legal basis: consent; legal requirements.

   More details on legal bases:

   • Contract: we generally process your personal information when we need to do so to fulfil a contractual obligation or where we take steps as requested by you;
   • Legitimate interest: we may process your information for legitimate purposes relating to our business – for example, for security maintenance or fraud prevention.
   • Legal requirements: we may use your personal information when we are obliged to meet our legal obligations – for example, we have to keep records to comply with our tax obligations.
   • Consent: we may also use your personal information where you have provided your consent. At any time, you have a right to withdraw your consent – the easiest way to do so is to email us by team@annabey.com.

4. Providing your personal information to third parties

   We use third parties to provide you with our services and products, and to maintain and improve our business. When we do this, sometimes it is necessary for us to share your personal information with them in order to get these services to work well. We work with the following third parties:

   • payment processing providers;
   • shipping companies;
   • hosting and IT services providers;
   • event management service providers;
   • ID verification services providers;
   • customer communication and relationship management services providers;
   • mail handling service providers;
   • analytics service providers.

   If certain cookies are enabled on your device, then we may also share cookie-related information with related service providers, such as analytics, as described above in this Privacy Notice.

   We may also share your personal information:

   • within the family of companies controlled by us for internal reasons, primarily for business and operational purposes;
   • if we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred; and/or
   • when legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings).

5. Where, when, and how we store your personal information

   1. Place. We store your personal information on servers that may be located in Europe or in the U.S. Personal information we collect may be transferred outside the country or territory where it was collected for further processing to any country where we have facilities or in which we engage service providers for the purposes as described in this Privacy Notice. Some countries are recognised by the UK, Switzerland and the European Commission as providing an adequate level of data protection. For transfers from the EEA, the UK, or Switzerland to countries not considered adequate by respective authorities, we have put in place adequate measures, such as ensuring that the recipient is bound by Standard Contractual Clauses, to protect your personal information. For transfers from Switzerland, we may transfer your personal information to the European Economic Area and the U.S.
   2. Duration. We retain your personal information only as long as reasonably necessary for the purposes set out in this Privacy Notice and as required by applicable laws and regulations. If you opt for the deletion of your personal information, we may still keep minimal necessary information about you for the period necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
   3. Security. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to us, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to help prevent unauthorized access such as access controls, confidentiality obligations, and technical measure to secure your information.

6. Your data protection choices and rights

   Under data protection laws, you may have specific rights in relation to our processing of your information, such as the right to access, rectify, object to, or complain about the processing and request your data erasure or blockage. Data subject rights may be subject to exemptions under applicable data protection laws. If you make a request, generally, we have one month to respond to you. Please, contact us (see section 1 above) if you wish to make a request in relation to:

   1. Your right of access – you have the right to ask us for copies of your personal information;
   2. Your right to rectification – you have the right to ask us to correct personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
   3. Your right to erasure – you have the right to ask us to delete your personal information;
   4. Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal information;
   5. Your right to object to processing – you have the right to object to the processing of your personal information;
   6. Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organization, or to you;
   7. Withdrawal of your consent and opt-outs – if you want to withdraw your consent previously given to us or opt out from direct marketing, you can do so at any time – the easiest way is to email us at team@annabey.com.

   Also, you have the right to lodge a complaint regarding our use of your personal information. Please tell us first, and we will address your concerns. If it does not work, you can contact relevant data protection authorities – check contact information in the section 1 above.

7. Changes to our Privacy Notice

   We may change our Privacy Notice from time to time. Any changes we make to our Privacy Notice in the future will be posted on this page and where appropriate, may be notified to you by e-mail. Please check back regularly to see any updates or changes to our Privacy Notice.