General_2.2.1-0

Privacy Notice

With the following Privacy Notice, Sunrise LLC (hereinafter "Sunrise" "us" or "we") informs you about which personal data (hereinafter "Data") is collected and processed when using our website, obtaining services as a customer (concluded service contract) or receiving promotions (e.g. newsletter, giveaways). This Privacy Notice also applies to the services offered under the brand names yallo, Lebara, MySports, swype and UPC.

Please note that this Privacy Notice may be updated from time to time. We therefore recommend that you check our website regularly for any updates.

1. Processing Purposes

The available Data will primarily be used by us to fulfill our contractual obligations, to acquire new customers, to ensure the smoothest possible operation of our services, to contribute to the improvement of our services, to enable marketing and analyses, and to comply with our legal and regulatory obligations, this includes in particular:

 

1.1 Conclusion and performance of the contract

  • Verification of the conditions for concluding a contract;

  • Performance of contractual obligations;

  • Processing and responding to inquiries or complaints;

  • Ensuring customer and user administration;

  • Invoicing and, if necessary, the consultation of a debt collection agency.

1.2 Data processing in our legitimate interest

  • Evaluation of your usage, ordering or inquiry behavior;

  • Updating and validating your Data;

  • Information about our services, products and promotions;

  • Prevention of unlawful use of services (in particular, to prevent fraud at the conclusion of the contract and during the term of the contract);

  • Maintenance, development and preservation of customer relations;

  • Individualizing services and providing personalized content, e.g. research demographics, usage behavior and user interests;

  • Direct marketing and analysis purposes.

1.3 Legal reasons

  • Publication of directories;

  • Credit checks;

  • Compliance with legal or regulatory obligations;

  • Detection and prevention of misuse of services, equipment or infrastructure;

  • Establishment of a connection and transmission of information;

  • Collection of location data from telecommunications traffic.

     

2. Types of data

The data we process are the following:

 

2.1 Personal Data

Personal Data, includes any information that relates to an identified or identifiable natural person. Examples of personal data include identifying information such as your first and last name, address, gender, date of birth, telephone number or email address, copy of your ID or passport.

We use this data for the purposes set out in Section 1.

 

2.2 Location Data

Location data is personal data transmitted by Wi-Fi or GPS signals, bluetooth, IP addresses or mobile network and contains information about where you or the device you are using are located. In particular, location data is created when your cell phone or other device connects to a network, or your router connects to the internet. The location of a hotspot can also be identified via an IP address.

We use this data to fulfill legal or regulatory obligations.

 

2.3 Usage Data (telephone, internet or TV).

Usage data is data about services and products that you use, such as numbers dialed when making phone calls, TV programs, data volumes, IP addresses, subscriptions and devices (e.g., cell phone, smart devices, internet/TV box, etc.) as well as information about the frequency, time and duration of the use.

We use this data for the purposes stated under Section 1.

 

3. Specific Use Cases

3.1 Visit of our website

When visiting our website, technical data is automatically collected to ensure the functionality as well as the security of the website.

For this purpose, cookies and other tracking technologies such as web beacons are used. Cookies are small information files that a web server generates and sends to a web browser. The latter stores the received cookies for a certain time or for the duration of the session on our website. The information that your browser automatically sends to our servers includes your IP address, language settings, session duration, referral URL, web browser and operating system details, and the date and time of the visit.

This Data is processed for the purpose of providing and optimizing the website and for system security reasons.

Sunrise uses cookies from third-party providers and transmits Data to the servers of the third-party providers, which may be located abroad.

The processing of this information is based on legitimate interests of Sunrise, so that the functionality of the website can be ensured.

In addition to the so-called necessary cookies, Sunrise may use additional or optional cookies when you visit our website. Performance and functional cookies are used for this purpose. These cookies help Sunrise to improve your experience on our website and to customize it according to your needs as well as to conduct market research. At the same time, this simplifies the usage as you don’t need to enter certain information repeatedly (e.g. when logging in).

You are free to deactivate the use of optional cookies at any time. However, this may limit the experience or functionality of our website. In addition, you should also delete the cookies accordingly on your browser.
 

3.2 Use of our Services

When you obtain our services as a customer, we process your personal data to fulfill our contractual obligations, to provide you our products, for invoicing and to make bug fixes or improvements, as well as for marketing purposes.

In this case, the data processing is carried out in connection with the fulfillment of pre-contractual or contractual obligations as well as in our legitimate interest.

Please also note that when you use our services, in addition to this declaration, the data protection provisions in accordance with the current General Terms and Conditions and other applicable contractual provisions apply.

We process the required data provided by you when concluding a contract, using our services or entering them on a registration page.

If you choose an online payment option, such as credit card, to purchase a product or obtain a service, the payment will be made via the online payment system of the respective provider. Please note that when using online payment systems, the data protection provisions of the respective provider also apply.
 

3.3 Apps

We use your data to ensure that our apps work properly. This concerns login data as well as information about functions you use within the app. To fix bugs and malfunctions, we sometimes need to use Data, to e.g., evaluate why an app is not working properly. During the system check, we keep our analyses as simple and short as possible and delete the data once it is no longer needed for bug fixing or improvement.

This concerns for example the following data:

  • Your first and last name;

  • Your home address and billing address;

  • Your e-mail address;

  • Your date of birth;

  • Your MySunrise/MyYallo/MyLebara/My UPC/swype;

  • Your preferred correspondence language.

In your personalized and protected area in MySunrise/MyYallo/MyLebara/My UPC/swype, you have the possibility to manage your Data as well as the data regarding services you have obtained.
 
3.4 Marketing and Newsletters

In connection with the provision of our services, we use your Data for marketing purposes and for newsletters.

This data processing is done in our legitimate interest to optimize our services.

Users of our website have the option to subscribe to newsletters on specific topics. By registering for the newsletter, you consent to us processing your e-mail address for electronic advertising and marketing measures, for invitations to events or the like.

In connection with the technical processing of the newsletter, we involve third parties with whom we share your email address for this purpose. You can revoke your consent regarding this processing at any time by unsubscribing via the unsubscribe link at the end of the respective newsletter.

 

3.5 Raffles and contests

Data is processed in accordance with the applicable legal provisions. The data collected for the implementation of the raffles or contests will be used exclusively for the purpose of implementing the raffle or contest and to determine the winners as well as to award the prizes unless you provide your consent for a more extended Data usage.

Applicable terms of participation remain reserved.

 
3.6 Credit Checks

If you wish to conclude a contract with us, we are entitled to carry out a credit check before we conclude the contract. For this purpose, we may consult debt collection agencies (in particular Intrum AG, based in Schwerzenbach). In addition, we use our own information about your previous payment history. This information flows into the credit rating. The credit check is a partially automated process that helps us to decide whether or to what extent and under what conditions we can conclude the contract you have requested. In addition, we transmit to the aforementioned third parties’ data about non-contractual or fraudulent behavior. This processing is carried out in connection with the conclusion of the contract.

3.7 Contact Requests

You can send support or other service-related requests at any time via helpdesk, chat or via Sunrise Community.

The mandatory fields specified in the contact form or Sunrise Community include your user login data (e-mail address, telephone number or customer number) as well as support topic and the transmitted message (including any uploaded files).

This information is required for the purpose of processing your request and to provide feedback. In addition, we may analytically evaluate the content of your chats (chat history) as well as all uploaded files in order to improve our service quality and/or to better understand requests.

The communication channel used for this purpose is provided by our partner Qualtrics and the data is processed and stored in Belgium. For more information, please see the privacy policy of Qualtrics .

 

3.8 Social Media

Sunrise uses plug-ins to social media. By clicking on the respective logo, you are automatically linked to the Sunrise account of the corresponding platform.

The data protection provisions of the respective platform provider apply, whereby some content may only be accessible if you have a corresponding user account on the platform.

By clicking on the logo, the platform provider receives the information that you have visited the Sunrise website with your IP address and your user account may be mapped to Sunrise. To prevent this from happening, you must log out of the corresponding platform before clicking the icons of the platform providers.

 

4. Protection of your personal data

Sunrise has implemented numerous technical and organizational measures to protect your data from unauthorized or unlawful processing and to protect it from loss, alteration, misuse, destruction, or unauthorized access.

 

5. Duration of data storage

We store the data for as long as is necessary to achieve the purpose. After that, they are deleted or, anonymized.

Location data is stored for legally required activities in accordance with legal obligations for a period of six months and then deleted.

Usage data is only stored for as long as it is required for the fulfillment of the contract or our legitimate interests and then deleted.

Legal retention periods as well as the use of the data in connection with the enforcement of legal claims remain reserved.

 

6. Data transfer to third parties

In order to be able to offer you our website and services, we involve third parties. These are primarily service providers, such as our cloud providers. Due to legal and/or regulatory requirements, we may also be obliged to disclose data to competent courts, authorities, or other government bodies. In addition, we pass on your location data to the responsible emergency call center if you make an emergency call from your smartphone.

We work particularly closely with some partners, for example in customer service (call center) or with IT service providers. Before these partners are allowed to process your personal data on our behalf, we contractually ensure that they comply with the applicable data protection laws and implement the necessary technical and organizational measures to protect your data.

We may share your personal data with our parent company (Liberty Global Group), subsidiaries and other entities that are jointly managed (collectively, "Subsidiaries"). In that case, we require our affiliates to comply with this Privacy Notice.

 

7. Data transfers abroad

While providing its services, Sunrise also relies on products and services from producers and suppliers abroad who process Data or telecommunications data on behalf of Sunrise in the course of fulfilling their obligations, for example when providing maintenance or service support (including call centers).

Your data will always be treated with the necessary care and processed in compliance with the applicable data protection regulations. Your data will be processed within the European Union, the European Economic Area (EEA), Moldova, the United States, the United Kingdom and Switzerland.

Should the processing of personal data take place in countries that do not ensure adequate data protection, the conclusion of standard contractual clauses will ensure that appropriate technical and organizational measures are implemented to provide adequate protection of your data.

 

8. Your rights regarding your personal data

You have the right to request information about your data being processed by Sunrise. To do so, send us a written request for information, enclosing a copy of your identity card or passport, to the following address.
 

Sunrise GmbH
Data Protection Office
Thurgauerstrasse 101 B
P.O. Box
8152 Glattpark (Opfikon)

 

Or by using the button ‘Data Access Request’ at the top of this page.

As a rule, this information is provided free of charge. However, Sunrise expressly reserves the right to charge fees in accordance with the applicable data protection regulations if the provision of information involves a disproportionately large amount of work or is carried out for obviously frivolous reasons or several times a year.

Furthermore, you have the right to request the correction of your personal data. Subject to legal restrictions as well as relevant archiving requirements.

You also have the right to request deletion of your personal data, subject to legal and/or regulatory retention requirements. The deletion includes the data on the productive system. Due to legitimate interests, to comply with legal requirements, as well as technical necessity, data deletion does not include backup copies.

Finally, you have the right to revoke your consent to the processing of personal data or to object to the processing. You can do this in particular via your MySunrise/MyYallo/MyLebara/My UPC/swype account, by unsubscribing to newsletters or deactivating cookies.

In addition, you are entitled to have Sunrise make the data available to you in a machine-readable format or to have it delivered to an authorized third party designated by you.

 

Last update: January 2024