プライバシーに関する一般的な通知

• Our role. We, All Here, are responsible for the processing, as controller, of your personal data (but only for our own activities and not those of third party providers) (see section 2);
• 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 3);
• 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 4);
• 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 5 and 6);
• Retention and Security. We do not store your personal data for longer than necessary for us to fulfill the purposes set out in this Privacy Notice. We apply security measures and strive to protect your personal data (see sections 7 and 8);
• Your rights. You may contact us welcome@allhere.org to exercise your rights pertaining to your personal data (see section10).

1. はじめに

At All Here SA (we, our or All Here), we recognize the importance of your privacy and of transparency. This general privacy notice (Privacy Notice) describes how we collect and process personal data about:

• the representatives of our customers, prospects, and suppliers or any person involved with them;
• participants to our events and meditation research
• individuals who apply for a position with us;
• visitors of our websites; and

We may also have additional privacy notices that apply in specific circumstances, such as the processing of neurological and health related personal data in the context of meditation research and EEG recordings.

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

All Here SA, Clos-Belmont 12, 1208 Genève, is responsible for the processing, as controller, of your personal data. You will find our contact details below in section 10.

This Privacy Notice only applies to processing undertaken by or on behalf of us. Whilst we may provide links to third party websites or services, we do not accept any responsibility or liability for their policies in relation to any personal data or their collecting processing of any personal data.

3. How we collect your personal data

a. 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 (e.g. if you are the contact person designated by your employer to manage the relationship with us). The information about you that we may collect from others will depend on the context, but can include the following categories:

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.

b. Some information is mandatory and some is optional 

Whenever personal data is collected (e.g. when you subscribe to our newsletter or register to participate to one of our events), we will indicate whether the provision of such data is mandatory (e.g. with an asterisk) and the consequences of a refusal to provide the requested data. In general, if mandatory data fields are not completed, we will not be able to provide our services.

c. The personal data we process may contain sensitive data

To the extent authorised by law, we may collect sensitive data about you, such as data related to your health connected through the services we provide or the research activities we carry out. We will process such sensitive data in accordance with applicable data protection laws, as specified in this Privacy Notice or in separate notices describing our activities. In addition to the usual appropriate technical and organizational measures we implement to ensure the security and integrity of the personal data processed by us, we may implement additional measures in relation to sensitive data, as appropriate.

4. How we Process your personal data

a. In General

We process your personal data in compliance with 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) – for the purposes specified in this section 4

We will only process your personal data if we have valid legal ground for doing so. Depending on the processing activity carried out, we will therefore only process your personal data based on

In addition, we will only process sensitive data if we have obtained your explicit consent for one or more specified purposes, or if we can rely on another lawful justification in accordance with applicable data protection laws.

We generally do not process your personal data to create a profile about you (profiling) and 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). If we do, you will receive specific information about it in advance.

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 Privacy Notice will no longer apply and we may use such data for purposes not contemplated by this Privacy Notice (e.g. for research activities, 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 9 below for additional information on your rights).

b. Processing Purposes

We process your personal data for the following purposes:

1. To provide our professional services to our customers

We process the personal data we need to carry out our professional services, including meditation research, EEG recordings, and development of meditation-related products and methodologies. We collect the contact details of the individuals with whom we interact and the personal data that they provide us with. Further, we collect the personal data that is necessary for the provision of our professional services.

Processing your personal data as just described above is necessary for us in order to provide our professional services. If you personally hired us, our basis for processing the data is our contractual necessity. In other cases, it is our legitimate interests in delivering our services to our customers.

The personal data which we must retain for record-keeping, tax or another legal obligation will, as a rule, be kept for the duration of the contractual relationship and thereafter for a period of 10 years (or such other retention period as applicable). Shorter retention periods apply for personal data which must not be retained for the above reasons.

2. For event organization and management purposes

We process personal data when you register for or participate in our events, demonstrations, and showcases. This includes collecting registration information such as your name, email address, phone number, and selected event dates. We may also collect information about your meditation practice and experience level when relevant to the event.

We process this data based on our contractual necessity (to provide the event services you registered for) or our legitimate interests (to organize and manage our events effectively).

We may also take photographs or videos during our events for promotional and documentation purposes. Where required by law, we will obtain your consent before capturing or using your image.

Personal data collected for event purposes is retained for the duration necessary to fulfill the event-related services and for a reasonable period thereafter for follow-up communications and future event planning, unless you object to such processing.

3. For general customer or supplier management purposes

If we are in a business relationship with you, your employer, or are in discussions to enter into one, we process the personal data that is necessary for our customer or supplier management, as well as for the following other related purposed:

• to carry out the transactions in which we are engaged, and to procure products and services from our suppliers and subcontractors;
• to interact with you, for instance to reply to your inquiries;
• to track our activities (measuring sales, our work time, ) and those of our suppliers;
• to manage our archiving and records; and
• for invoicing

The personal data that we process in this context includes:

• personal data about individuals with whom we interact, such as the name, title, position, company name, email and/or postal address and the professional fixed and/or mobile phone number;
• personal data relating to our interactions and the services provided;
• any other information provided to us by you or third

We do so based on our contractual necessity (if we are in relation with you directly) or our legitimate interests (if you are representative of a legal person).

4. To send you our newsletters and other advertising

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, based on your consent. You may unsubscribe from the newsletter service at any time, in which case your contact details will be deleted.

We also process the time of registration and your opt-in confirmation, based on our legal obligation to demonstrate compliance, and 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, based on our legitimate interests.

Independently from your subscription to our newsletter, we may also contact you by email to inform you about our activities if you have previously subscribed for the use of our Services, 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 10). The legal basis for the corresponding processing of your data is our legitimate interests to advertise certain sales offers and activities relating to our previous interactions with you.

5. For internal analysis and statistical purposes in order to improve our technologies, research methodologies, and meditation-related products.

Unless you object to such processing, we may process your personal data that we access in connection with our services and products, for internal analysis and statistical purposes, in order to better understand the needs of our customers, to optimize their experience, and in general to improve the ergonomics and functionality of the our services and products. You may object to such processing activities at any time (see section 10 below for additional information on your rights).

6. If you apply for a position with us

If you apply for a position, we will process your personal data exclusively for assessing your application in view of the possible establishment of an employment relationship, including to assess your capabilities and qualifications, and conduct reference checks, if and as authorized by Swiss law. Our legal basis for processing your personal is contractual necessity (to take pre -contractual steps at your request).

We will process the personal data you provide (e.g. your contact information, CV, résumé, cover letter, information relating to previous work experiences). 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 from these 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.

Personal data of applicants who have not been hired is deleted at the end of the recruitment process. If an employment relationship is established following your application, your personal data will be entered into your HR file and further processed in accordance with our HR data processing policies.

7. If you visit our website

In addition to the personal data which you provide, we automatically collect certain technical information about your interactions with our websites (such as your IP address, the content that was accessed, date and time of access, information about your web browser, your preferences, or other information related to your interaction with the websites, including your navigation details on the websites).

We process this data to provide you with the requested functionalities, based on our contractual necessity, and to establish a connection with your device over the internet, to identify you when you use the websites, manage their stability and security, and for analytics and statistical purposes, based on our legitimate interests in doing so.

We use cookies on the websites. To find out more about how we use cookies, please see our Cookies Policy at https://allhere.org/cookie-policy/.

8. To comply with our other legal obligations

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 the purposes indicated elsewhere in this section 4. We retain the personal data for the duration of the legal obligation imposed on us.

9. 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.

We may for instance process your personal data, including neurological data from EEG recordings, for meditation research purposes if we have obtained your prior explicit consent. is includes processing data to develop and improve our meditation methodologies, create performance benchmarks, and advance scientific understanding of meditation practices.

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

We only share your personal data if you expressly consent, if there is a legal obligation or permission to do so, if disclosure is necessary to assert, exercise or defend legal claims, or if the disclosure of data is directly connected with the conclusion or the performance of a contract with you or in your interest. We mainly share personal data:

6. 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, in certain circumstances, in particular in connection with the operations of our subcontractors, your personal data may be made available to recipients located abroad. In particular, we use service providers headquartered [in the EU, in the U.S., in India or in Japan], from which location some data may be available.

In such cases, 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 a 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 10 below.

7. 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 fulfill the purposes set out in Section 4. 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 4.

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.

8. 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.

The internet is a global environment. As a result, by sending information to us electronically, such data may be transferred internationally over the internet depending upon your location. Internet is not a secure environment and this Privacy Notice applies to our use of your personal data once it is under our control only. Given the inherent nature of the internet, all internet transmissions are done at your own risk.

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).

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

Within the limits and under the conditions set forth in applicable data protection laws, you have the following rights:

• to access your personal data as processed by us and obtain a copy thereof (Right of Access and 15 GDPR);
• to request any correction or update thereof (Right to Rectification under 16 GDPR);
• to request the erasure of your personal data (Right to Erasure under 17 GDPR)
• to ask us to cease any specific processing of personal data that may have been obtained or processed in breach of applicable law (Right to Restriction of Processing under 18 GDPR),
• to object to any processing of personal data which is based on our legitimate interests, in certain circumstances (Right to Object to Processing under 21 GDPR). 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 defense of legal claims;
• 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 (Right to Data Portability under 20 GDPR); and
• to withdraw your consent where we base our processing of your personal data on your consent (without such withdrawal affecting the lawfulness of processing made prior to);

You will find further details of your rights in section 4 of this Privacy Notice in connection with each processing activity we perform. If you want to exercise any of your rights, please contact us using the contact detailed listed below (see section 10).

In addition to your rights outlined above, you may also have the right to lodge a complaint with a competent data protection supervisory authority (in particular in the Member State of your habitual residence, place of work or place of the alleged infringement) if you are not satisfied with how we process your personal data. Although this is not required, we recommend that you contact us first (see section 10) as we might be able to respond to your request directly.

10. Contact us

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

11. 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.