Privacy Policy

1. General

Top Shop International SA, Via Ferruccio Pelli 13, 6900 Lugano, Switzerland  (the “Controller”), a company that is operating Studio Moderna website, including all its components, pages, subpages and sections which are available on *.studio-moderna.com, (the “Website”), is committed to protecting your personal data and respecting your privacy in accordance with applicable legislation of European Union and legislation of Swiss Confederation. Controller’s affiliated companies (the “Affiliated Companies”) (list of which can be found https://www.studio-moderna.com/markets) may also process submitted Personal Data, subject to terms and conditions below and all Affiliated Companies will process Personal Data in accordance with this Privacy Policy.

This Privacy Policy sets out the type of personal data Controller collects, defines the purposes, regulates the disposal of information collected by the Controller about the users visiting its Websites who submitted their Personal Data to the Controller (the “User”) and defines the rights the User has in relation to this personal data. Controller respects the privacy of all Users and will take all reasonable precautions to ensure that all the personal data that you have submitted via Website remains confidential, unless required by law or unless the User grants its explicit consent.

2. Collection and Processing of Personal Data

2.1. Is it necessary for the User to disclose Personal Data?

All Users can visit the Website and certain subsections without disclosing any personal data to Controller. However, sometimes, the failure to provide the minimum necessary personal and other data required in the relevant data entry sections and other parts of the relevant Website may result in Controller not being able to provide the User with certain services (e.g. you cannot send CV without disclosing Personal Data or submit your request to become supplier or distributor without disclosing certain Personal Data, as will be seen from the remainder of this Privacy Policy).

If the User discloses Personal Data, such User should be aware that this Personal Data may be disclosed to relevant Affiliated Companies of the Controller (e.g. if you send CV, you might be contacted from any of the Affiliated Companies).

2.2. Which Personal Data is being collected and processed?

In order to fulfill the User inquiries and for other purposes listed below in the “Purpose for Data Processing” section, Controller may collect the following personal data about the Users:

  • name,
  • surname,
  • birth date,
  • email,
  • address,
  • telephone number and
  • other specified personal data.  

By submitting Personal Data, the User warrants the Personal Data submitted is theirs, correct and up-to-date. Personal Data will be processed until the purpose defined below has been fulfilled.

3. Purpose for Data Processing

Controller processes personal data for the following purposes:

- CV submission
- Application to become Supplier of the Controller
- Application to become Distributor of the Controller

More can be found below:

3.1. Submitting your CV

Under Section “Careers” (https://www.studio-moderna.com/careers-at-studio-moderna) the Controller gives the Users a chance to apply to any position with the Controller and with Affiliated Companies of the Controller. CV is submitted to the e-mail recruitment@studio-moderna.com.

Personal Data is submitted by the User voluntarily and by submitting such Personal Data (Controller cannot predict which Personal Data will be submitted) the User agrees with processing for recruitment process with the Controller or the Affiliated Companies of the Controller.

3.2. Application to become Supplier of the Controller

The Users may submit their Personal Data for the purpose of becoming a Supplier of the Controller, by submitting the form (http://smsupplierportal.questionpro.com/). By submitting their Personal Data, the Controller may process their Personal Data for the purpose of inquiries and potential conclusion of supplier’s agreement and cooperation with the User. Personal Data which may be collected includes:

  • Contact Person;
  • Phone;
  • E-mail address.

Inquiries about potential Suppliers can also be sent to newproducts@studio-moderna.com.

Personal Data and all other related information may be disclosed to relevant employees of the Controller and in other Affiliated Companies of the Controller.

3.2. Application to become Distributor of the Controller

By sending inquiry about becoming a Distributor of the Controller, the potential Distributor sends an e-mail to maja.umek@studio-moderna.com and may disclose certain Personal Data. The Controller and Affiliated Companies of the Controller may process this Personal Data only for the purpose of inquiries about potential relationship with the potential Distributor and negotiation of the Distribution Agreement.

4. Use and Disclosure of Personal Data to Third Parties

The Controller will not disclose or transmit your Personal Data to any third party, unless such third party is an Affiliated Company and is required in order to achieve the purpose for which the User has submitted his/her Personal Data or to the processors of Personal Data, with which the Controller (or Affiliated Companies) have concluded data processing agreement in order to process Personal Data on behalf of the Controller (or Affiliated Companies).

To any other third party Personal Data will be disclosed only if legally required, or in order to enforce or defend legal rights of the Controller or Affiliated Companies, in order to prevent fraud or any other criminal activity or to comply with mandatory obligations or in connection with the corporate activities (e.g. merger, acquisition, sale or purchase of business assets).

5. Disclosure of Personal Data to Processors

You agree that personal data may be disclosed to other persons and entities (parties) to enable the performance of the purpose in accordance with “Purpose of Processing Data” as defined above. Provider uses services of other parties to perform functions on its behalf, such as providing marketing assistance, providing fraud checking services and providing other services. Such persons will have access to personal data needed to perform these functions, but may not use personal data for any other purpose or for their own business purposes. Provider requires these third parties to comply strictly with its instructions and to process the data in accordance with applicable legislation.

6. Rights of the User

User may at any time:

  • request information and access to his/her Personal Data;
  • request modification of Personal Data;
  • request erasure of Personal Data;
  • request restriction or objection of Processing of Personal Data;
  • request transfer of his/her Personal Data to third party;

by sending e-mail to info.si@studio-moderna.com.

The Controller or the Affiliated Companies do not perform any processing activities involving automated decision making and profiling.

The Controller will reply to your request as soon as possible, but within 30 (thirty) days.

7. Minors

By submitting Personal Data the User warrants being over age of 18 and Controller strongly advises all parents and guardians to teach their children safe and responsible handling of personal data on the Internet. Controller will never intentionally collect any Personal Data from anyone under 18 years or use it in any way or disclose it to third parties without permission. Controller assumes that the users of its websites are 18 years old or older.

8. Cookies

Cookies are small files that are temporarily stored on User’s hard disk, enabling the website to recognize the User’s computer on the following visits. Controller uses cookies exclusively to gather information concerning the use of the Website. The data provided by cookies are anonymous and are not related to and do not constitute Personal Data. Web beacons, also known as single pixel or clear gif technology, or action tags, may be used on Controller’s Websites. Web beacon technology allows Controller to know which Users clicked on key elements (such as links or graphics) on a Controller’s Website or a Controller’s email. The data provided by web beacons are anonymous, are not related to personal data and do not constitute personal data. The User may opt to turn off cookies/web beacons using browser settings to disable cookies and web beacons any time. When you access the website of Controller (as an unregistered regular User), some non-personal information (type of internet browser used, number of visits, average time spent on website, websites viewed) is recorded automatically. This information is used as a feedback to improve the Controller’s Website appeal, content and functionality. For more information about cookies please read Cookie Statement.

9. Security

Controller intends to protect and administer the personal data of all Users of its Website in line with the applicable legislation. Controller has taken all appropriate technical, organizational and personal measures in order to keep the maintained personal data of its Users secure and protected from accidental or unlawful destruction and accidental loss, unlawful handling, unauthorized disclosure or access, and against all other unlawful forms of processing.

Controller will supervise the security in place and update or revise the security measures in accordance with the findings and legal requirements.

10. Links to Other Web Sites

This Privacy Policy applies to the Website as defined above and with  General Terms and Conditions. Some sections of this Website may contain links to websites of other Controllers/other entities within or outside of Controller. When the Users leave these websites, they are advised to follow carefully and read the principles for the personal data protection for each individual website that collects personal data. Controller does not control any information contained within these links and the principles of the personal data protection applicable to the other sites and is not responsible for any content, goods or services they offer. The use of these linked websites is subject to conditions and agreements applicable to such linked websites. Controller does not accept any responsibility or liability for the privacy practices of such third party websites and the use of such websites is at the user’s own risk.

11. Exclusion of Liability

The Controller reasonably assumes personal data has been disclosed by the User to whom the personal data apply or other authorized person. If the User suspects that the personal data is being used by a third unauthorized party or that the personal data has been disclosed without authorization, he/she must immediately inform the Controller thereof. The Controller shall in no event be held liable for damage that may arise due to unauthorized disclosure of personal data to Controller.

12. More information, complaints

In the event of any questions or requests related to your Personal Data, you can at any time send e-mail to info.si@studio-moderna.com. In the event of any complaints, you can at any time turn to Federal Data Protection and Information Commissioner (FDPIC) in Switzerland.

Changes of this Privacy Policy

This Privacy Policy may be updated, revised or supplemented at any time, without prior warning or notice to the User. By virtue of using the Website, following the changes of the Privacy Policy, the User agrees in full extent with the changes. This Privacy Policy enters into force on 11.9.2018.