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Privacy Policy

Last updated: May 13, 2021

I. Introduction

The American Swiss Foundation (“ASF”), 271 Madison Avenue, Suite 1403, New York, NY 10016, United States of America, is a nonprofit organization, and provides this website (americanswiss.org) and any other sub-domains or affiliated websites of americanswiss.org (collectively, the “ASF website”) in support of its charitable and educational mission to connect and engage Swiss and American leaders. ASF is responsible for processing your personal information.

The protection of your personal information is of utmost important to us, which is why we only process your personal information in accordance with applicable data protection law. This privacy policy (as may be amended from time to time, this “Privacy Policy”) explains the types of personal information that we collect when you visit the ASF website or otherwise interact with us online, and how we collect and use that personal information. 

More information concerning our collection or processing of personal information can be requested from ASF at any time by emailing us at [[email protected]]. You can also call ASF directly at (212) 754-0130 for matters relating to the purchase or renewal of a membership or to make a donation offline, as well as to exercise your data protection rights set out in Chapter VI of this Privacy Policy.

II. The personal information that we collect, and how we use it 

Depending on your use of the ASF website, ASF or third parties providing services to or on behalf of ASF, which include [Google (for analyzing use of our website)] , Classy, Inc. (our payment processing and event registration vendor), Americaneagle.com (our website provider), and Constant Contact (our marketing vendor), may collect certain personal information from you, through publicly available information or third-party vendors. Such information may include one or more of the following:

  • First name, last name, telephone number, company name, billing address, mailing address, country, state, email address, city, ZIP/Postal code, date of birth, payment information and other personal information;
  • Browser type, language, plug-ins, Internet domain and operating system;
  • Internet Protocol address;
  • The website(s) visited before visiting the Site and the website(s) visited after visiting the ASF website;
  • Unique identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
  • Data collected through cookies and other tracking technologies, provided that any use of cookies or of other tracking tools by the ASF website or by the providers of third-party services used by the ASF website serves the purpose of providing the services made available through the ASF website; and
  • Data relating to your interactions with content on the ASF website, such as the type of content viewed on the ASF website.

At the time of collection of your personal information, we will indicate whether the information is required or optional. Please note that we may not be able to serve you as effectively or process your donation or membership application if you choose not to share certain required information with us. Any information you provide to us that is not marked as required is voluntary and will not affect our offers or your donation or membership.

Such information might be freely provided by you, or, in the case of usage data, collected automatically when you use and interact with the ASF website or our vendors. Below are examples of ways that your personal information might be collected by us or our vendors.

A. Online memberships and donations

When you purchase, renew or gift an ASF membership or make a donation to ASF online, we will ask you to provide us with the information we need to process your membership or to acknowledge your contribution, including your payment information and contact information. These transactions are facilitated by a third-party vendor, Classy.org. We encourage you to review our vendors’ privacy policies. If you prefer to purchase or renew a membership or make a donation offline, you may do so by calling ASF directly at (212) 754-0130.
The processing of your data by us, is based on our contractual duties towards our members according to art. 6(1)(b) of the EU General Data Protection Regulation ("GDPR") and in certain cases, our legitimate interest to answer any questions members may have or to process donations based on art. 6(1)(f) GDPR. In cases, where we process your personal data based on our legitimate interest, you can object to such processing at any time if you have a specific interest in doing so via the following e-mail: [email protected].
B. Online purchases of event tickets
ASF uses a third-party vendor to administer and process your online purchase of event tickets. The information that you provide, including your payment information and contact information, may be collected by our vendors when you make such purchases.
The processing of your data by us, is based on our contractual duties towards our members according to art. 6(1)(b) GDPR.
C. ASF Newsletter
ASF offers visitors to the ASF website and other supporters the opportunity to subscribe to our online newsletter, a service hosted by a third-party vendor. You may unsubscribe at any time following the instructions included in each email.
The processing of your data by us, is based on your consent that you provide to us by signing up to the ASF newsletter according to art. 6(1)(a) GDPR. You can withdraw consent at any time via the following e-mail: [email protected].
D. Emailing ASF
If you send an email to ASF, your message and email address may be saved, and we may send you emails in order to respond to your message. Any material, business information, ideas, concepts, or other information sent to ASF by email will be treated as non-confidential and non-proprietary.
The processing of your data by us, is based on our legitimate interest to answer and process emails you send to us based on art. 6(1)(f) GDPR. You can object to such processing at any time if you have a specific interest in doing so via the following e-mail: [email protected].
E. Website usage information
ASF automatically collects, including through third-party vendors, certain information to help us operate and provide the ASF website to you. As is the case with many websites, our servers automatically collect your IP address when you visit the ASF website, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your website usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the website, the pages or content you see or click on during your visit and when and for how long you do so, items you download, transactions you complete, and any search terms you have entered on the ASF website or a referral site.
Among other things, this information enables us to generate analytics reports on the usage of our website. We use Google Analytics to do this. To opt out of your ASF website usage being included in our Google Analytics reports, you may follow the instructions at https://tools.google.com/dlpage/gaoptout.
The processing of your data by us, is based on our legitimate interest to provide our website to you based on art. 6(1)(f) GDPR. You can object to such processing at any time if you have a specific interest in doing so via the following e-mail: [email protected].
F. Other communications
We may use the contact information that you provide to contact you to provide information about other ASF activities, programs, membership and fundraising opportunities, and special events that may interest you. If you send us an inquiry or request, we may also use your information to respond to your inquiry or request, or to resolve any issues related to your event attendance. You may opt-out of having your information used by ASF for these purposes, or you may update your contact information anytime, by contacting us via the following e-mail: [email protected].
The processing of your data by us, is based on our legitimate interest to send you information on ASF activities based on art. 6(1)(f) GDPR or, if required by law, your consent according to art. 6(1)(a) GDPR. You can withdraw consent at any time or object to such processing at any time if you have a specific interest in doing so via the following e-mail: [email protected].
G. Cookies
The ASF website uses cookies to distinguish you from other users, provide a better experience when you browse our website, and improve our site’s performance and usefulness. You may elect to allow this use of cookies, or decline.
A cookie is a small data file that websites can place on your hard drive when you visit. A cookie file can contain information such as a user ID that tracks the pages you’ve visited within that site. The cookies on ASF’s website are primarily used to recognize that a user has visited the website previously and to track user traffic patterns.

Name: _fbp
Use: Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers
The main purpose of this cookie is: Targeting/Advertising

Name: __utmt
Use: This cookie is set by Google Analytics. According to their documentation it is used to throttle the request rate for the service - limiting the collection of data on high traffic sites. It expires after 10 minutes
The main purpose of this cookie is: Performance

Name: ASPXAdmin
Use: Keeps track of logged in admin.

Name: ASP.NET_SessionId
Use: General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Usually used to maintain an anonymised user session by the server.
The main purpose of this cookie is: Strictly Necessary

Name: _gcl_au
Use: Used by Google AdSense for experimenting with advertisement efficiency across websites using their services
The main purpose of this cookie is: Targeting/Advertising

Name:  __utmz
Use: This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour measure of site performance. This cookie identifies the source of traffic to the site - so Google Analytics can tell site owners where visitors came from when arriving on the site. The cookie has a life span of 6 months and is updated every time data is sent to Google Analytics.
The main purpose of this cookie is: Performance

Name: __utmc
Use: This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. It is not used in most sites but is set to enable interoperability with the older version of Google Analytics code known as Urchin. In this older versions this was used in combination with the __utmb cookie to identify new sessions/visits for returning visitors. When used by Google Analytics this is always a Session cookie which is destroyed when the user closes their browser. Where it is seen as a Persistent cookie it is therefore likely to be a different technology setting the cookie.
The main purpose of this cookie is: Performance

Name: _hjid
Use: Hotjar cookie. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
The main purpose of this cookie is: Performance

Name: __utmb
Use: This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. This cookie determines new sessions and visits and expires after 30 minutes. The cookie is updated every time data is sent to Google Analytics. Any activity by a user within the 30 minute life span will count as a single visit, even if the user leaves and then returns to the site. A return after 30 minutes will count as a new visit, but a returning visitor.
The main purpose of this cookie is: Performance

Name: __utma
Use: This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. This cookie lasts for 2 years by default and distinguishes between users and sessions. It it used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics. The lifespan of the cookie can be customised by website owners.

The main purpose of this cookie is: Performance

Name: _ga
Use: This search has identified a match with a recognised pattern type cookie: _ga. The results below are based on data aggregated from all known incidences of this pattern.
The main purpose of this cookie is: Performance

Name: __gads
Use: This cookie is associated with the DoubleClick for Publishers service from Google. Its purpose is to do with the showing of adverts on the site, for which the owner may earn some revenue.
The main purpose of this cookie is: Targeting/Advertising

Name: 1P_JAR
Use: This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.
The main purpose of this cookie is: Targeting/Advertising

Name: ANID
Use: Unknown

Name: NID
Use: This domain is owned by Google Inc. Although Google is primarily known as a search engine, the company provides a diverse range of products and services. Its main source of revenue however is advertising. Google tracks users extensively both through its own products and sites, and the numerous technologies embedded into many millions of websites around the world. It uses the data gathered from most of these services to profile the interests of web users and sell advertising space to organisations based on such interest profiles as well as aligning adverts to the content on the pages where its customer's adverts appear.
The main purpose of this cookie is: Targeting/Advertising

Name: _uetvid
Use: This is a cookie utilised by Microsoft Bing Ads and is a tracking cookie. It allows us to engage with a user that has previously visited our website.
The main purpose of this cookie is: Performance

Name: fpestid
Use: Unknown

Name: RES_TRACKINGID
Use: Unknown

Name: Encrypted Cookie MemberId
Use: Used to store current logged in MemberID

Name: DisplayBugNotes
Use: Keeps track of if DisplayBugNotes is enabled (sysParam)

Name: smartbug-1 ( Encrypted )
Use: Used by our admin smartbug tool
If you prefer not to receive cookies through the site, you can decline their use when prompted by the pop-up.
The processing of your data by us, is based on our legitimate interest to analyze the usage, functionality and reach of our website based on art. 6(1)(f) GDPR or, if required by law, your consent according to art. 6(1)(a) GDPR. You can withdraw consent at any time or object to such processing at any time if you have a specific interest in doing so via the following e-mail: [email protected].
 

H. Legal or regulatory obligations
We may use your personal information described above if it is necessary for compliance with a legal or regulatory obligation according to art. 6(1)(c) GDPR.

III. With Whom Personal Information is Shared

ASF does not sell or share your personal information with other organizations. However, ASF engages third-party vendors such as IT and software providers, payment processors, advertising companies or CRM-tool providers for the purposes described above in order to help manage the website, process online and offline transactions, better respond to the needs of members, and enhance marketing efforts, which may require the sharing of some of your personal information. We and our third-party vendors or partners use analytics data for a variety of purposes such as to improve the design and content of our website, to help us learn things like what pages are most attractive to all of our visitors and what promotions visitors like to see, and to gauge the success of our advertising campaigns.

ASF may also use or disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with legal process served on ASF; (b) protect and defend ASF’s rights or property, the website, or ASF’s users; and (c) act under emergency circumstances to protect the personal safety of ASF affiliates, agents, or the users of the website or the public.

IV. Where we store and process personal information

ASF is based in the United States of America ("US") which is why your personal information is, generally, processed and stored there too. Some of our third-party vendors may also be based in the US or other countries outside of the country you live in. Please note that the US and other countries may not provide the same level of data protection as the country you live in.
If you live in the European Union ("EU"), United Kingdom ("UK") or Switzerland, ASF only discloses your personal information to third parties outside the EU, UK or Switzerland if the receiving country provides an adequate level of data protection according to a decision by the competent supervisory authority in the EU, UK or Switzerland or if the third party receiving your personal information agrees to so-called standard contractual clauses approved by the competent supervisory authority in the EU, UK or Switzerland.

V. Your data protection rights

Depending on the data protection laws applicable to you and your personal information, you may exercise certain rights regarding personal information collected and processed by ASF, including:

  • The right to access – You may have the right to learn about the personal information being processed by ASF, obtain disclosure regarding certain aspects of the personal information, and obtain a copy of the personal information that we have collected about you.
  • The right to rectification – You may have the right to request that ASF correct any information about you that you believe is inaccurate. You may also have the right to request ASF complete information about you that you believe is incomplete.
  • The right to erasure – You may have the right to request that ASF erase your personal information, under certain conditions.
  • The right to restrict processing – You may have the right to request that ASF restrict the processing of your personal information, under certain conditions.
  • The right to object to processing – You may have the right to object to ASF’s processing of your personal information, under certain conditions.
  • The right to data portability – You may have the right to request that ASF transfer the information that we have collected to another organization, or directly to you, under certain conditions.

The availability of these rights is subject to the applicability of data protection laws to you and your information, and, in any case, may not be absolute. For example, if you withdraw consent to ASF’s processing of personal information, ASF may be permitted to continue to process your personal information to the extent required or otherwise permitted by law, including in connection with exercising and defending its legal rights or meeting its legal and regulatory obligations.

If you would like to exercise any of these rights, please contact us at our email: [email protected], or call us at (212) 754-0130.

Furthermore, if you feel we have not handled your query or concern to your satisfaction or if you are of the opinion that we are not processing your personal information in accordance with applicable data protection law, you may have the right to contact the competent data protection authority and file a complaint.

VI. How long we store your personal information

We retain your personal information for as long as is necessary for the purpose for which it was collected, for example, as long as:

  • you are a member of ASF;
  • you have not unsubscribed from the ASF newsletter;
  • you are in direct contact with us regarding a specific query you sent via email; or
  • you have not withdrawn your consent to specific processing activities.

We will further retain your personal information to comply with legal and regulatory obligations, for as long as claims could be brought against us and for as long as legitimate interests, including data security, require.

VII. Security

We have put in place appropriate security measures to hold your personal information securely in electronic and physical form to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Our premises are access controlled and surveyed by video recording where required and our electronic databases require logins and password authentication. Our partners, staff and third-party vendors who have access to confidential information (including personal information) are subject to confidentiality obligations.

Although ASF makes efforts to create a secure and reliable website, no security system is perfect, and ASF cannot guarantee the security of the ASF website or the information we collect, including the confidentiality of any communication or materials transmitted to/from this website over the Internet. ACCORDINGLY, TO THE GREATEST EXTENT PERMITTED UNDER APPLICABLE LAW, WE EXPRESSLY DISCLAIM ANY LIABILITY FOR UNAUTHORIZED ACCESS, USE, DISCLOSURE, ALTERATION OR DESTRUCTION OF INFORMATION COLLECTED THROUGH THE ASF WEBSITE.

You assume the sole and complete risk for using the ASF website, and must make your own determination as to these matters. It is important for you to protect yourself against unauthorized access to your password and to your computer. Be sure to use a known and trusted secure connection and to log off when finished using a shared computer.

VIII. Revisions to our privacy policy

Please note that ASF may revise this Privacy Policy at any time and such changes will be effective immediately upon posting on the ASF website. Such revisions may arise in response to changes in the law, policy, or other factors. We encourage you to periodically visit this page to review our most current Privacy Policy. In some cases (for example, if we significantly expand our use or sharing of your personal information) we may also tell you about those changes by additional means, such as by sending an email to the email address we have on file for you. In some cases, we may request your consent to those changes.