Privacy Policy

Editor 5:59

Privacy Policy

Mountaingrades.com and its owner Mountain Grades LLC is dedicated to ensuring the protection and privacy of our customers and visitors to our blog, website or app. We understand and adhere to the Data Protection Act, which was set up to help and protect you – the visitor.

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

 

Access & Ordering

You may browse our website without any data being collected from you. However, in order to enjoy an easier browsing and shopping experience, we offer you the ability to register an account with us.

You do not have to have an account in order to purchase goods from MountainGrades.com. When you add items to your cart, a file is created on our server which stores details of your purchases. This file is linked uniquely to your browsing session and cannot be viewed by anyone else.

When you complete your order, we ask for personal information about you, such as your full name, address, e-mail address, phone number and debit or credit card details. This data will only be shared with our payment service provider and courier services, and only for the purposes of processing and shipping your order. All sensitive data is transmitted via an industry standard 128-bit secure socket layer connection.

We do not store your payment details.

We collect anonymous, non-personal data, such as how many times a product is purchased or viewed, in order to continually modify our website to suit the browsing trends of our users.

 

Your account

When you register for an account with MountainGrades.com, we require that you give us a valid e-mail address. This is so that our system can verify your registration and issue you with a personal password to allow you access to your personal account area. Your member account is used to store your personal data, for the purposes of viewing or changing orders with MountainGrades.com as well as to view and change or delete your personal data.

 

Your data

We do not automatically collect personal data about you. We do not share any personal data with any 3rd party organization or institutions, except for the purposes of processing your order as mentioned above, or if required to do so by law.

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

 

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping.

We may use the information to improve our website, products and services.

We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. We only send promotional emails to users who have agreed to receive our emails and confirmed by double-opt-in option.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

 

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We have a high security standard implemented to secure your data.

 

How we use cookie

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

 

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

List of partners who assist us in operating our business and processing data:

  • – Google LLC
  • – Apple Inc.
  • – Microsoft Cop
  • – Kinsta Ltd
  • – Sucuri Inc
  • – Swisscom Ltd
  • – Post CH Ltd
  • – PostFinance Ltd
  • – SIX Payment Services
  • – Twint Ltd
  • – Bexio Ltd
  • – Rocket Science Group

All our partners have best reputations. They are all committed to your data privacy and security. Please read their own privacy policies to find out more.

 

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

 

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • – Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
  • – If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us.
  • – We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the address mentioned blow or by using our contact form. We will promptly correct any information found to be incorrect.

If you no longer want your data to be used and stored on our website, please write to or email us as soon as possible, at the address mentioned blow or by using our contact form. We will promptly delete your personal data.

 

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE NAME COOKIE DESCRIPTION
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND Your sesssion ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.

 

Data protection policy

Context, overview and key details:

Policy prepared by: Marcel Isler
Approved by board / management on: 24/05/2018
Policy became operational on: 24/05/2018
Next review date: 24/05/2019

 

The need of collecting data

Mountain Grades LLC needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards and to comply with US, EU and Swiss law.

 

Why this policy exists

This data protection policy ensures Mountain Grades LLC:

  • – Complies with data protection law and follow best practice.
  • – Protects the rights of staff, customers and partners.
  • – Is open about how it stores and processes individuals’ data.
  • – Protects itself from the risks of a data breach.

 

Data protection law

The Data Protection Act 1998 describes how organisations — including Mountain Grades LLC — must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

  • – Be processed fairly and lawfully.
  • – Be obtained only for specific, lawful purposes.
  • – Be adequate, relevant and not excessive.
  • – Be accurate and kept up to date.
  • – Not be held for any longer than necessary.
  • – Processed in accordance with the rights of data subjects.
  • – Be protected in appropriate ways.
  • – Not be transferred outside the US or the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

 

People, risks and responsibilities

Policy scope. This policy applies to:

  • – The head office of Mountain Grades LLC.
  • – All branches of Mountain Grades LLC.
  • – All staff and volunteers of Mountain Grades LLC.
  • – All contractors, suppliers and other people working on behalf of Mountain Grades LLC.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • – Names of individuals
  • – Postal addresses
  • – Email addresses
  • – Telephone numbers
  • – Any other information relating to individuals

 

Data protection risks

This policy helps to protect Mountain Grades LLC from some very real data security risks, including:

  • – Breaches of confidentiality. For instance, information being given out inappropriately.
  • – Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • – Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

Responsibilities

Everyone who works for or with Mountain Grades LLC has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that Mountain Grades LLC meets its legal obligations.

The data protection officer, Marcel Isler, is responsible for:

  • – Keeping the board updated about data protection responsibilities, risks and issues.
  • – Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • – Arranging data protection training and advice for the people covered by this policy.
  • – Handling data protection questions from staff and anyone else covered by this policy.
  • – Dealing with requests from individuals to see the data Mountain Grades LLC holds about them (also called ‘subject access requests’).
  • – Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • – Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • – Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • – Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • – Approving any data protection statements attached to communications such as emails and letters.
  • – Addressing any data protection queries from journalists or media outlets like newspapers.
  • – Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

 

General staff guidelines

The only people able to access data covered by this policy should be those who need it for their work. Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers. Mountain Grades LLC will provide training to all employees to help them understand their responsibilities when handling data. Employees should keep all data secure, by taking sensible precautions and following the guidelines below. In particular, strong passwords must be used and they should never be shared.

Personal data should not be disclosed to unauthorised people, either within the company or externally. Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of. Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data protection officer. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • – When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • – Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • – Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • – Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • – If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • – Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • – Servers containing personal data should be sited in a secure location, away from general office space.
  • – Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • – Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • – All servers and computers containing data should be protected by approved security software and a firewall.

 

Data use

Personal data is of no value to Mountain Grades LLC unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • – When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • – Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • – Data must be encrypted before being transferred electronically. The data protection manager can explain how to send data to authorized external contacts.
  • – Personal data should never be transferred outside of the European Economic Area and or the USA.
  • – Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

 

Data accuracy

The law requires Mountain Grades LLC to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Mountain Grades LLC should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets. Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. Mountain Grades LLC will make it easy for data subjects to update the information Mountain Grades LLC holds about them. For instance, via the company website. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number nor email address, it should be removed from the database. It is the data protection manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

 

Subject access requests

All individuals who are the subject of personal data held by Mountain Grades LLC are entitled to:

  • – Ask what information the company holds about them and why.
  • – Ask how to gain access to it.
  • – Be informed how to keep it up to date.
  • – Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at our main email address. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged CHF 50 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

 

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Mountain Grades LLC will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing information

Mountain Grades LLC aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • – How the data is being used.
  • – How to exercise their rights.

 

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

 

We use Google AdSense Advertising on our website

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

  • – Remarketing with Google AdSense.
  • – Google Display Network Impression Reporting.
  • – Demographics and Interests Reporting.
  • – DoubleClick Platform Integration.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

 

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

 

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:
Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:
On our Privacy Policy Page.

You can change your personal information:

  • – By emailing us.
  • – By calling us.
  • – By logging in to your account.
  • – By chatting with us or by sending us a support ticket.

 

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not market to children under the age of 13 years old. By using our website or purchasing our products and services, you have to agree to be at least 18 years of age.

 

Fair Information Practices:

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email within 7 business days.

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

 

CAN SPAM Act:

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • – Send information, respond to inquiries, and/or other requests or questions.
  • – Process orders and to send information and updates pertaining to orders.
  • – Send you additional information related to your product and/or service.
  • – Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

  • – Not use false or misleading subjects or email addresses.
  • – Identify the message as an advertisement in some reasonable way.
  • – Include the physical address of our business or site headquarters.
  • – Monitor third-party email marketing services for compliance, if one is used.
  • – Honor opt-out/unsubscribe requests quickly.
  • – Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at:
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

 

EU General Data Protection Regulation (GDPR)

The new General Data Protection Regulation (GDPR) of the European Union (EU) will enter into force on 25 May 2018. From then on, the GDPR is directly applicable to all actors operating in or to the EU. The new provisions give citizens more control over their personal data; In addition, the GDPR increasingly places companies under greater responsibility while at the same time reducing their reporting obligations. It also strengthens the role of data protection authorities.

You can check, update, delete, download and or export all data that we collect from you at any time as already mentioned above. We are fully in line with GDPR and we only share data with 3rd party companies who are fully in line with GDPR as well.

 

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

Mountain Grades LLC
Beuge 7
8752 Näfels (GL)
Switzerland

By email: info@mountaingrades.com
By phone: +41 55 214 16 16

Last Edited on 2018-05-24