Privacy Policy and Cookie Policy
1. Introduction
We recognize the importance of your privacy and of transparency in our processing of your personal data.
At GOWAGO AG (we, our or GOWAGO), we recognize the importance of your privacy and of transparency in our processing of your personal data. This privacy notice (Privacy Notice) informs you on the personal data we collect and process in connection with the provision of our GOWAGO platform accessible without limitation at https://gowago.ch (the Platform) and/or the services provided through the Platform (together with the Platform, our Services).
By accessing and using our Services, you expressly acknowledge and agree that we may collect and process your personal data in accordance with this Privacy Notice.
This Privacy Notice is incorporated into and forms an integral part of our terms of use for the Platform (Terms of Use). All capitalized terms not defined in this document have the meaning given to them in the ToU.
2. Who is responsible for the processing of your personal data
GOWAGO AG, Josefstrasse 216, 8005, Zürich, Switzerland, is responsible for the processing, as controller, of your personal data. You will find our contact details below in Section 12.
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, such as Facebook, Google, PandaDoc, Intrum, credit scoring companies, car service companies, tire companies, warranty companies or car insurance companies, we are not responsible for their policies in relation to personal data. In such circumstances, the collection and use of your personal data are governed by the privacy policy of those third party websites or services, which you should carefully review to learn more about their personal data processing practices.
3. How we collect your personal data
We collect the personal data that you provide to us.
We collect the personal data that you provide to us when using our Services, for example when you willingly and voluntarily submit personal data through web forms, communicate with us, create and/or manage your account, subscribe to our newsletter or alert services, or when you request a test drive.
We also collect personal data which we receive from partners.
If you start an application with us, in particular to request a lease or a credit, we collaborate with partners to be able to verify your eligibility and provide you with the requested Services (our Partners), in which case our Partners may provide information about you. This includes:
Ø Migros Bank AG, which is our leasing and credit partner;
Ø Credit information service providers (such as ZEK, IKO or CRIF AG);
Ø Insurance providers or other service providers (for instance our partners in charge of the maintenance of the vehicles).
Ø Car dealership, if you apply for a lease directly through one of our dealership partners.
Certain personal data are also collected in an automated manner.
We also automatically collect personal data, including by means of tools, web forms, cookies and other active elements, as further described in this Privacy Notice.
You may define certain authorizations relating to the automatic collection of your personal data when you configure your device or your internet browser according to available functionalities. For more detailed information, please see the cookie section below (section 10).
4. How we process your personal data
We process your personal data by automated means for the purposes indicated in this Privacy Notice and in accordance with applicable law.
We process your personal data in compliance with the Swiss Federal Act on Data Protection, using computers or computer tools, in line with the purposes set out in this Privacy Notice.
The information we collect when you fill in a lease application may be considered as a personality profile under the Swiss Federal Act on Data Protection, which we will process in accordance with this Privacy Notice and only share it with third parties when necessary for our activities in accordance with section 6.
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 internal benchmarking or analytics purposes, or to develop and market new services).
We take the technical and organizational appropriate security measures to prevent unauthorized access, disclosure, modification, alteration or destruction of your personal data, as specified in Section 9 below.
5. Purposes for which we process your personal data?
We process your personal data for legitimate and clearly identified purposes:
Your personal data is collected and processed for the purpose of operating the Services and for the other legitimate purposes explicitly specified below, only to the extent relevant to achieve these purposes, and is not further processed in a manner that is incompatible with them.
To operate the Platform and provide the related Services.
We mainly process your personal data to provide the Platform and the Services, based on our Contractual Necessity to do so, such as enabling you to apply for a leasing online or for our other Services, including the GOWAGO AG All-in-one services, and to providing you with the requested information and other Services, as well as for customer and user management purposes.
In addition to the personal data which you provide when interacting with the Platform (e.g. when you fill in forms), we automatically collect technical information about your interactions with the Platform, such as such as your IP address, the content that was accessed (list of car lease offers viewed), date and time of access, information about your web browser, your preferences, or other information related to your interaction with the Platform, including your navigation details on the Platform. We process this data to establish a connection with your device over the internet, to identify you when you use the Platform, control the use of the Platform and manage its stability and security.
For contract management purposes, including managing your lease and payments.
If you start a lease application with us, request other services, or sign contracts using the Platform, we will process the information that is required for this purpose, including for contacting you in this respect. This includes all information which you voluntarily provide (e.g. when you fill in forms or upload documents), as well as information we must gather from third parties to process your request and manage the contracts (as detailed in section 3 above).
To contact you and respond to your queries.
You have the option of contacting us via the Platform, by email, telephone or chat. In this context, we process the data which you provide to us (including your contact information and the subject-matter of the request).
To send you our newsletter, search alert report, and other advertising information.
If you subscribe to our newsletter, or search alert functionality (frequent summary of the deals meeting your criteria), we will process the information you provide in this context (e.g. name and email address, as well as criteria for the search alert) to provide you with the requested Services. You may unsubscribe from such service at any time, in which case your contact details will be deleted. We also analyze your use of such services, e.g. whether you have opened our email or clicked on certain links, and process this data to optimize and improve our newsletter, based on our Legitimate Interest.
Independently from your subscription to our newsletter or search alert functionality, we may also 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 12). The legal basis for the corresponding processing of your data is our Legitimate Interest to advertise certain sales offers and activities relating to our previous interactions with you.
For our legitimate business interests, including to improve our Services, as well as for monitoring or statistical purposes.
Furthermore, we may also process your personal data e.g. the content you accessed, date and time of access and your preferences 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, as well as support services); (ii) improving and developing the Services (including monitoring the use of the our Services, and for statistical purposes); (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) achieving our corporate goals; (iv) comply with our legal obligations (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); and (v) providing Users with targeted marketing and advertising tailored to their preferences.
We use cookies and similar technologies in connection with these purposes. You will find information in Section 10 in relation to the use of cookies.
By accessing the Platform and using the Services, you agree to such activities. You may however object at any time to such processing activities (see section 11 for your right), in which case we will cease processing your information for these purpose unless we have a valid ground for doing so in accordance with Swiss data protection laws.
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.
6. The circumstances in which we disclose your personal data to third parties
We may disclose your personal data to 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.
We may in some limited instances disclose your personal data (on a strict need-to-know basis) to third parties in connection with the operation of the Services and to subcontractors such as IT service providers, cloud service providers, database providers, contract signing process, automated marketing solutions providers and consultants. This includes Amazon Web Services (cloud/storage provider).
In addition, we may disclose your personal data to car dealerships when necessary to provide any requested services, including, but not limited to, test drives or vehicle handovers.
If you start an application with us, in particular to request a lease or a credit, we may share your information with the Partners listed in Section 3 to verify your eligibility, process your request, sign the contract and provide you with the requested Services.
We use the services of CRIF AG to conduct credit checks. You acknowledge that your personal data will be transferred to CRIF AG for their legitimate use as a business information agency to check payment histories (particularly those that concern uncontested demands that remain unpaid after the due date) and any potential debt enforcement information and address details. CRIF AG will use the information to check your identity and credit standing, and will disclose it to authorized third parties. The payment histories may be analyzed by CRIF AG on the basis of mathematical/statistical calculation methods to facilitate automated decision-making processes, and particularly to evaluate a person’s credit standing. CRIF AG’s privacy policy is applicable in this context https://www.crif.ch/en/privacy-policy/
In addition, we partnered with Migros Bank AG which is your contractual partner for all lease contracts made on the Platform. Accordingly, your personal information will be shared with Migros Bank AG and processed by it to verify your eligibility and manage the leasing contract. You will find its privacy policy, which is applicable in this context, here https://www.migrosbank.ch/grundlagen. As further detailed in section 6.5 of our Terms of Use , Migros Bank AG may conduct additional credit checks with the Central Office for Credit Information (ZEK), the Consumer Credit Information Center (IKO) and other third parties (e.g. credit information service providers such as CRIF AG).
We may also disclose your personal data to third parties where we have a legal obligation to do so or a legitimate interest in doing so.
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.
7. International Transfers
Your personal data may be disclosed outside of Switzerland, including to countries that do not guarantee the same level of data protection and privacy as Switzerland.
The personal data that we collect from you may be stored and processed in Switzerland, or transferred to, stored at or otherwise processed outside of Switzerland, including in the E.U (Germany, France, Netherlands, Belgium), the UK and in the U.S., or any other country which may not necessarily offer an adequate level of data protection as recognized by Switzerland. 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.
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 12 below.
8. How long we store your personal data?
Your personal data will not be stored longer than necessary.
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 5 of this Privacy Notice. This period varies, depending on the type of data concerned and the applicable legal requirements.
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.
9. Security
We maintain physical, technical and procedural safeguards to keep secure your personal data.
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 use two-factor authentication whenever possible. We restrict access to your personal data to those persons who need to know it for the purpose described in this Privacy Notice. In addition, we use standard security protocols and mechanisms to exchange the transmission of sensitive data. When you enter sensitive information on our Platform, we encrypt it using Transport Layer Security (TLS) technology.
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.
10. How we use cookies or other analytical tools
We use Cookies, other analytical tools and similar technologies in connection with the Platform.
We use various types of cookies, other analytical tools or similar technologies (collectively, Cookies) in connection with our Platform, some of which are capable of automatically processing data on your electronic device and/or of transferring personal data about you to us or third parties.
These technologies are generally used to monitor and analyze your interactions with the Platform and/or to enable us to improve the Platform and its functionalities, including customizing the Platform and related services, depending on your interactions. We may also use Cookies to measure and monitor the traffic and use of the Platform and its performance.
Cookies are generally divided in four categories:
A. Essential Cookies. Some cookies are placed on your electronic devices to make the Platform capable of being used, by providing basic features such as page browsing and accessing secure areas. The Platform cannot function properly without this type of Cookies.
B. Functionality Cookies. Some Cookies enable the Platform to remember choices persons make, for example, user name, and language or text size. These cookies are known as “functionality cookies” and help to improve a person's experience of the Platform by providing a more personalized service.
C. Advertising Cookies. These cookies are used to better understand user interests and to display more relevant advertisements.
D. Analytics/productivity Cookies. Analytics/productivity Cookies, such as those linked to Google Analytics, help understand how users interact with the Platform by anonymously collecting and reporting information.
Our use of cookies may vary depending on the section or functionalities of the Platform you access.
You can manage Cookies through the settings of your web browser and/or electronic device.
If you do not want Cookies to be stored on your electronic device, you can configure your internet browser or electronic device to refuse and/or restrict them. However, some Cookies are essential to the functioning of the Platform, and it may operate differently if you refuse or completely restrict Cookies.
If you do not refuse or restrict Cookies, you consent to their use and to the processing of your personal data collected in this manner.
You may opt-out to the use of Google Analytics (which collects information and reports website usage statistics without personally identifying individual visitors to Google), with no impact on their experience of the Platform, by following the procedure described on https://tools.google.com/dlpage/gaoptout.
For more information, please visit the website http://www.allaboutcookies.org. You can also see the help section of your internet browser or electronic device for more specific instructions on how to manage Cookies.
The following Cookies are used:
Cookie GOWAGO
Cookie name locale
Expires after in 13 months
Locale selected by user
Cookie GOWAGO
Cookie name language
Expires after in 13 months
Language selected by the user.
Cookie GOWAGO
Cookie name userDeviceId
Expires after 13 months
Store the userDeviceId to track usage of an app on same device.
Cookie GOWAGO
Cookie name userDeviceSessionId
Expires after 13 months
Store the userDeviceSessionId to track usage of an app on same device in unique session.
Cookie Facebook
Cookie name _fbp
Expires after in 3 months
Used to distinguish users.
Cookie Google Analytics
Cookie name _ga
Expires after in 12 months
Used to distinguish users.
Cookie Google Analytics
Cookie name ga*
Expires after in 12 months
To store and count pageviews.
Cookie Google Analytics
Cookie name _gid
Expires after in 24 hours.
Used to distinguish users.
Cookie Google Analytics
Cookie name _gat
Expires after in 1 minute
Used to throttle request rate.
Cookie Google Analytics
Cookie name gac
Expires after in 90 days
Contains campaign related information for the user.
Cookie Google Ads
Cookie name gclau
Expires after in 90 days
To store and track conversions.
Cookie Hotjar
Cookie name _hj*
Expires after max 1 day
Several Hotjar cookies to track user interactions on the platform as well as to show polls and surveys.
Cookie Heap Analytics
Cookie name hp2ses_props.*
Expires after in 30 minutes (Session)
To store performed actions on the website.
Cookie Heap Analytics
Cookie name hp2id.*
Expires after in 13 months
To store and track interaction.
11. Your rights with regard to the processing of your personal data
You have the right to access your personal data we process and may request without limitation that they be removed, updated, or rectified.
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.
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 informed consent. You may revoke at any time such consent (without such withdrawal affecting the lawfulness of processing made prior to).
If you want to exercise any of your rights, or want additional information about them, please contact us using the contact detailed listed below (see section 12).
12. 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 info@gowago.ch.
13. Translations and Updates to this Privacy Notice
The original language of this Privacy Notice is English. Any translation made available is for convenience only. In case of conflicts between the original English version and any translation, the English version shall prevail.
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 Platform, 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.
__14. Recording of Telephone Conversations
Purpose and Legal Basis for Recording
At GOWAGO AG, we strive to continuously improve our customer service quality and ensure the effectiveness of our services. As part of these efforts, we engage in recording telephone conversations between our customers and our customer service team through a trusted third-party provider. The purposes of these recordings include:
Enhancing the quality of our services;
Training our employees;
Efficient handling of customer complaints and requests;
Providing evidence in legal proceedings, when necessary.
The legal basis for these activities is our legitimate interest in achieving the highest possible service quality, fulfilling our contractual obligations, and protecting our legal interests.
Consent for Recording
We obtain your consent for recording these conversations tacitly. At the beginning of each call, you will be informed that the conversation is being recorded. By continuing the call after this notification, you are consenting to the recording. If you prefer not to be recorded, we offer alternative communication methods, such as email or chat.
Use of Third-Party Provider
To facilitate the recording of telephone conversations, we utilize the services of a third-party provider, selected for their reliability and compliance with our data protection standards. This provider is contractually bound to manage and protect your data with the utmost care and in accordance with our privacy policies and legal obligations.
Storage, Access, and Retention
Recorded conversations are stored securely on the third-party provider’s platform, with access strictly limited to authorized GOWAGO AG personnel. These recordings are retained for no longer than necessary for the purposes for which they were collected and processed, typically up to 10 years, unless specified otherwise by legal requirements.
Your Rights
You retain the right to request access to, correction or deletion of your personal data contained in these recordings. You may also object to the processing of your data under certain conditions. For detailed information on exercising these rights, please see Section 11 of this Privacy Notice.
Updates to Recording Practices
We may revise this section to reflect changes in our practices or legal requirements related to the recording of telephone conversations. We encourage you to review this Privacy Notice periodically for the latest information on our privacy practices.
