RealTyme| GENERAL PRIVACY Notice

Short Version

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The following is a summary of (butnot a replacement for) this Privacy Notice. We recommend you to read the noticefully.  

• Our role. We, RealTyme, are responsible for the processing, as controller, of your personal data (but only for our own activities and not those of third party providers) (s
• Data we collect. We collect the personal data which is provided to us by you, our customers, the persons with whom we interact, or which we otherwise lawfully obtain in the course of our activities(see section Error!Reference source not found.);
• How we use it. We process such personal data in compliance with Swiss and other data protection laws applicable to us, mainly for the purpose of providing our professional services to our customers, to manage our business, and to comply with our legal obligations (see section Error!Reference source not found.);
• Control and Access. Your personal data is stored in Switzerland and/or the European Union. We do not share it with third parties or transfer it abroad unless this is both necessary for our professional activities and permitted by applicable laws. This may for instance be the case when we use service providers or must interact with third parties to conduct our professional activities (see sections Error!Reference source not found. and Error!Reference source not found.);
• Retention and Security. We do not store your personal data for longer than necessary for us to fulfil the purposes set out in this Privacy Notice. We apply security measures and strive to protect your personal data (see sections Error!Reference source not found. and Error!Reference source not found.);
• Your rights. You may contact us (dataprotection@realtyme.com)to exercise your rights pertaining to your personal data (see section Error!Reference source not found.).  

1.  Introduction

At RealTyme SA (we, our or RealTyme), werecognize the importance of your privacy and of transparency.

This general privacy notice (Privacy Notice)applies to all our activities, including our websites, digital platforms and solutions (the Solutions), and the services we provide in this context (together with the provision of the Solutions, our Services). It describes how we collect and process personal data about:

• the representatives of our customers, prospects, and suppliers or any person involved with them;
• users of our solutions and visitors of our websites;
• individuals who apply for a position with us; and

We may have additional privacy notices (the Additional Privacy Notices) which apply in addition or instead of this General Privacy Notice in specific situations or for specific Services, in which case the terms of such Additional Privacy Notices will prevail over those of this General Privacy Notice. This includes for instance:

1. RealTyme Pro app Privacy Policy
2. RealTyme app Privacy Policy

We encourage you to refer to those specific notices where applicable.

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2. Who is responsible for the processing of your personal data?

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RealTyme, with registeredaddress at Clos Belmont 12, 1208 Geneva, is responsible for the processing ofyour personal data. You will find our contact details below in section Error! Reference source not found..

However, some of the processing activities set out in this Privacy Noticeare undertaken by our group entities, which will then act as data controller.The exact split differs between group entities and over time. We can confirmwhich processing activities are undertaken by which entity, on request.

This Privacy Notice onlyapplies to processing undertaken by or on behalf of us. Whilst we may providelinks to third party websites or services, we do not accept any responsibilityor liability for their policies in relation to any personal data or theircollecting processing of any personal data.    

3. How we collect your personal data

3.1 The information we collect

We collect the information that you provide to us directly. By doing so, you acknowledge the processing set out in this Privacy Notice.

We might also obtain your personal data from other persons or entities we enter in contact with in the conduct of our work, such as our business partners, third parties involved with them or the legal entity for whom you work. The information about you that we may collect from others will depend on the context, but can include identity details, contact information and account information.  

Insofar as it is permitted to us, we may also obtain the categories of personal data listed above from publicly available or private sources, such as public or commercial registries(e.g. debt registers, land registries, commercial registers), the press,websites, or social media platforms.

Also, if you visit our website or digital platforms, we may collect personal data in an automated way,including through cookies and other active elements, as further described in this Privacy Notice.

3.2 Some information is mandatory and some is optional

Whenever personal data is collected (e.g. in application forms), we will indicate whether the provision of such data is mandatory (e.g. with an asterisk) and the consequences of refusal to provide the requested data. In general, if mandatory data fields are not completed, we will not be able to provide our services. You are not required to complete the optional data fields in order to access our Services.  

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4. How we use your data

We process your personal data in accordance with applicable laws and only if we have a valid legal ground to do so.

We process your personal detain compliance with applicable law, in particular Swiss data protection laws and, to the extent they apply to us, other data protection legislations, such as the EU General Data Protection Regulation (GDPR).

This means that we will only process your information for certain reasons (see section Error! Referencesource not found.) where we have a legal basis to do so.

Additional Information on the "legal basis"

• Here is what each of these legal bases are:
  1. Contractual Necessity: the processing is necessary to fulfil our contractual obligations to you or to take pre-contractual steps at your request. This is particularly the case in particular when processing your personal data is strictly required to provide you with the Services. When the GDPR applies, Contractual Necessity is based on Article 6(1)(b) GDPR.
  2. Legitimate Interest: the processing is necessary for the fulfilment of our legitimate interests, and only to the extent that your interests or fundamental rights and freedoms do not require us to refrain from processing. When the GDPR applies, Legitimate Interest is based on Article 6(1)(f) GDPR.
  3. Consent: we have obtained your prior consent in a clear and unambiguous manner. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.  When the GDPR applies, Consent is based on Article 6(1)(a) GDPR.
  4. Legal Obligation: the processing is necessary to comply with our legal or regulatory obligations. When the GDPR applies, Legal Obligation is based on Article 6(1)(c) GDPR.
• Additional Information on profiling and automated decisions

We do not process your personal data to create a profile about you (profiling).

We also do not make decisions exclusively on the basis of an automated processing which have legal effects on the data subjects or affect them significantly (automated individual decision).

5. Why use your data

We process your personal data for the reasons indicated in this Section or in any Additional Privacy Notice:

To provide our Services, operate the Solutions and for customer management purposes.

We mainly process your personal data to provide the Solutions and the Services, including for creating and maintaining your user account, interacting with you, and other users (including for allowing other users to interact with you), and for related customer management purposes (such as invoicing).

Legal basis: Contractual Necessity, Legitimate Interests

Additional Information

1. Managing your account. You will be required to provide certain information, like a name or username, an email address and/or a phone number to create your account.
2. Contacting you and responding to your queries. You have the option of contacting us via the Solutions. In this context, we process the data which you provide to us (including your contact information and the subject-matter of the request).This data is used for the purpose of providing you with the requested information and services.
3. Providing maintenance and support. We use data to maintain our Services, troubleshoot and diagnose problems, and to provide customer support services.
4. Managing our customers and suppliers. If we are in a business relationship with your employer or you directly, we process the personal data that is necessary for our customer or supplier management,as well as for the following other related purposed, including (i) to carry out the transactions in which we are engaged, and to procure products and services from our suppliers and subcontractors; (ii) process your orders and payment(iii) to interact with you, for instance to reply to your inquiries; (iv) to track our activities (measuring sales, our work time, etc.) and those of our suppliers; (v) to manage our archiving and records; and (vi) for invoicing purposes. If you are our direct customer, our basis for processing the data is our contractual necessity. In other cases (e.g. if you are a representative of one of our customers), it is our legitimate interests in delivering our Services to our customers and ensuring we are paid for our services.

For our legitimate businessi nterests related to the provision of the Services, including to ensure the security of the Services, improve our Services, as well as for monitoring ors tatistical purposes.

We may also process your personal data for our legitimate business operations related to providing our Services, which include (i) ensuring that our Services are provided in an efficient and secure way (e.g. through internal analysis of the Services’stability and security, updates and troubleshooting); (ii) protecting the security of our IT systems, architecture and networks; (iii) benefiting from cost-effective services (e.g. we may opt to use certain services offered by suppliers rather than undertaking the activity ourselves); (iv) improving and developing the Services (including monitoring the use of our Services, and for statistical purposes); and (v) achieving our corporate goals).

Legal basis: Legitimate Interests, Consent

Additional Information

Additional information on the processing of your personal data for our legitimate business operations:

1. ‍Ensuring that our Solutions are provided in an efficient, secure and lawful way. In addition to the personal data which you provide when logging-in to your account or interacting with the Solutions,we automatically collect technical information about your interactions with the Solutions, such as [IP address, the actions that was carried out, etc.].
2. Improving our Services. We may process your personal data, in particular data relating to your use of our Services,for internal analysis and statistical purposes, in order to better understand the needs of our users, to optimize their experience by personalizing our Services, and in general to improve the ergonomics and functionality of our Services. You may object to such processing activities at any time (see section Error! Reference source not found. Below for additional information on your rights). We do not link this information to you or your account.
3. Data anonymization. We may combine your personal data with other information(aggregate) or erase any information that allows us to identify you(anonymize), so that it is no longer considered personal data under applicable data protection law, in which case this General Privacy Notice will no longer apply and we may use such data for purposes not contemplated by this General Privacy Notice (e.g. for benchmarking or analytics purposes, or to develop and market new services). You may object to the anonymization or aggregation of your personal data for this purpose at any time(see section Error! Reference source not found. Below for additional information on your rights).

To send you our newsletter and other advertising information.

If you subscribe to our newsletter, we will collect your contact details (name and email address) and use it to provide you with our newsletter. You may unsubscribe from the newsletter service at any time, in which case your contact details will be deleted.

Legal basis: Consent

We also process the time of registration and your opt-in confirmation to demonstrate compliance. We also analyze your use of our newsletter, e.g.whether you have opened it or clicked on certain links, and process this data to optimize and improve our newsletter.

Legal basis: Legal Obligation;Legitimate Interests

Independently from your subscription to our newsletter, we may contact you by email to inform you about our activities if you have previously purchased a similar product or service from us, if you have not objected to the corresponding use of your email address. You can object to the use of your email address for this purpose at any time by contacting us (see contact detail in section Error! Reference source not found.).

Legal basis:

To provide you with job opportunities within RealTyme.

We may process your personal data to allow you to consult and apply for job opportunities within RealTyme. We will process the personal data you provide. In addition, if you provide us with links to your profile on social media platforms (such as LinkedIn) or with contact information for references, we will assume that we may gather information fromthese sources.

Any information you submit must be true, complete and not misleading. Should the information provided be inaccurate, incomplete, or misleading, subject to applicable law, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been employed.

We will process your personal data exclusively for assessing your application. Your personal data is retained no longer than the duration of the recruitment process unless otherwise permitted by applicable laws and regulations.

Legal basis: Contractual Necessity (to take pre-contractual steps at your request)

To comply with our other legal obligations or for other legitimate interests.

We may further process your personal data if we have a legal obligation to do so or for other legitimate interests. This will for instance be the case if we need to disclose certain information to public authorities or retain such information for tax or accounting purposes, or for the establishment, exercise or defense of legal claims.

The personal data that we process for this purpose are those that we collected for one of the purposes indicated elsewhere in this section Error! Reference source not found. We retain the personal data for the duration of the legal obligation imposed on us.

Legal basis: Legal Obligations, Legitimate Interests

If we have obtained your consent

In addition to the above, we may process your personal data if we have obtained your prior unambiguous consent for specific purposes. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal

Legal basis: Consent

6. The circumstances in which we share your personal data with third parties

We will only share your personal data with third parties if this is necessary for the operation of our Services, if there is a legal obligation or permission to do so, or if there is another valid reason to do so.

Additional Information

1. Our service providers. We may share your personal data with third parties in connection with the operation of the Services or our business operations and with subcontractors such as IT service providers, cloud service providers, database providers, automated marketing solutions providers and consultants.  
2. Public information. Your personal data may also be made available to other users of the Services or to third parties to the extent necessary for the proper operation and provision of the Services,for example for the purpose of enabling users to interact.
3. Legal Obligation. We may also disclose your personal data where we have a legitimate interest in doing so, for example(i) to respond to a request from a judicial authority or in accordance with a legal obligation; (ii) to bring or defend against a claim or lawsuit; or (iii)in the context of restructuring, in particular if we transfer our assets to another company.

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7. Who has access to personal data and with whom are they shared?

7.1 In General

8. International Transfers

We store your personal data on servers located in Switzerland and/or the European Union.

In principle, we do not transfer your personal data to other countries or make it available there. However, incertain limited circumstances related to our marketing activities, some personal data may be made available to third-party service providers located outside Switzerland and the European Union. For instance, we use HubSpot for our marketing activities, which is headquartered in the United States. When you visit our main website, we may also use US based analytic tools such as Google Analytics.We stress that it does not concern the content your stores on our apps. We will ensure that suitable safeguards are in place, in accordance with applicable data protection laws, for instance by relying on standard contractual clauses adopted by the European Commission or by relying on statutory exception such as consent, performance of contracts, the establishment, exercise or enforcement of legal claims, overriding public interests or published personal data.

If you transmit information and data to us, you are expressly deemed to consent to such data transfers. You may request additional information in this regard and obtain a copy of the relevant safeguards upon request by sending a request to the contact address indicated in section Error! Reference source not found. below.

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9. How long do we store your data?

We will erase or anonymize personal data as soon as it is no longer necessary for us to fulfil the purposes set out in Section Error!Reference source not found.. This period varies, depending on the type of data concerned and the applicable legal requirements. More information on each type of processing can be found in Section Error!Reference source not found..

In view of the legal obligations incumbent upon us, certain information relating in particular to the contractual relationship must be retained for at least 10 years.

Where it is not possible to specify a fixed retention period, we apply clear criteria to determine the appropriate duration. These criteria include the nature of the data, the purpose of the processing, statutory retention obligations, and the existence of any actual or potential disputes or investigations that would justify extended retention.

10. Security

We are committed to the security of your personal data, and have in place physical, administrative and technical measures designed to keep secure your personal data and to prevent unauthorized access to it. We restrict access to your personal data to those persons who need to know it for the purpose described in this Privacy Notice.

Although we take appropriate steps to protect your personal data, no IT infrastructure is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.

If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication (including by posting a notice on our website)

11. Your rights with regard to the processing of your personal data

Unless otherwise provided by law, you have the right to know whether we are processing your personal data. You may contact us to know the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be supplemented, updated, rectified or erased. You also have the right to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law, and you have the right to object to any processing of personal data for legitimate reasons.

By accessing your user account (if you have one), you can review, update, corrector delete the personal data available within your user account.

If you request us to delete your personal data from our systems, we will do so unless we need to retain your data for legal or other legitimate reasons. Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request.

Where we rely on your consent to process your personal data, we will seek your freely given and specific consent by providing you within formed and unambiguous indications relating to your personal data. You may revoke at any time such consent (without such withdrawal affecting the lawfulness of processing made prior to).

The above does not restrict any other rights you might have pursuant to applicable data protection legislation under certain circumstances

Additional Information

In particular, if the GDPR applies to the processing of your personal data, you have the following rights under the GDPR if the respective requirements are met:

1. Right of access (Art. 15 GDPR) - you have the right to access and ask us for copies of your personal data.
2. Right to rectification (Art. 16 GDPR) - you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
3. Right to erasure (Art. 17 GDPR) - you have the right to ask us to erase your personal data in certain circumstances.
4. Right to restriction of processing (Art. 18 GDPR) - you have the right to ask us to restrict the processing of your personal data in certain circumstances.
5. Right to data portability (Art. 20 GDPR) - you have the right to ask that we transfer in a structured, commonly used and machine-readable format the personal data you gave us to another organization,or to you, in certain circumstances.
6. Right to object to processing (Art. 21 GDPR) - you have the right to object to the processing of your personal data which is based on our legitimate interests, in certain circumstances. In such case, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.
7. As a rule, you are not required to pay any charge for exercising your rights and we will respond to your request within one month.

You will find further details of your rights in sections  Error! Reference source not found. and Error! Reference source not found. of this Privacy Notice in connection with each processing activity we perform. If you want to exercise any of your rights, or want additional information about them, please contact us using the contact details  listed below (see section Error! Reference source not found.).

You have the right to lodge a complaint with the competent authority.

If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in addition to the rights described above.

Although this is not required, we recommend that you contact us first, as we might be able to respond to your request directly.

12. Contact us

If you believe your personal data has been used in a way that is not consistent with this General Privacy Notice, or if you have any questions or queries regarding the collection or processing of your personal data, please contact us at

RealTyme SA , Clos Belmont 12, 1208,Geneva or by e-mail: dataprotection@realtyme.com

If you are a EU resident, you may also contact our EU Representative:

Rickert Rechtsanwaltsgesellschaft mbH , - REALTYME SA - Colmantstraße 15, 53115 Bonn, Germany or by e-mail: art-27-rep-REALTYMESA@rickert.law

Further, If you are a UK resident, you may also contact our UK Representative:

RickertServices Ltd UK, -RealTyme SA -, POBox 1487, Peterborough PE19XX, United Kingdom or by e-mail: art-27-rep-RealTyme SA@rickert-services.uk

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12. Updates of this policy

This Privacy Notice may be subject to amendments. Any changes or additions to the processing of personal data as described in this privacy notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you (including by email and/or via the Solutions, e.g. banners, pop-ups, or other notification mechanisms). If you do not agree to the changes made, you must stop accessing and/or using the impacted Services.

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Last updated: 12.05.2025