ASMALLWORLD Hospitality AG of Seidengasse 20, 8001, Zürich, Switzerland is the data controller (“ASMALLWORLD” or “ASW” or “we”) and we take your privacy seriously.

If you have any questions about this policy, we can be reached by email at privacy@asw.com.

Alternatively, you can contact us at:

This privacy policy sets out the basis on which any personal data that we have collected about you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We review this privacy policy regularly. Occasionally we may need to make changes or additions to this privacy policy that may affect how we handle your data. We will post new versions of this privacy policy on our website at www.asmallworldhospitality.com/ (the “Site”).

We may also notify you of changes to this privacy policy by email.

This privacy policy was last reviewed and updated on 30 August 2023.

When you use our media contact form or sign up for our investor newsletter, we will collect personal information from you, such as your name & email address.

We may also collect data about your navigation of the Site on an aggregate basis, such as your Internet Protocol Address (“IP Address”), which is identified and logged automatically in our server log files whenever you navigate the Site, your Internet Service Provider (“ISP”), your login frequency, the pages you visited within the Site, and the Internet browser or device you are using while browsing the Site.

You may also voluntarily provide personal information when you send us an enquiry or raise a support request via email. When you contact us, we keep a record of your communication and may use third-party service providers (e-mail marketing providers such as Emarsys, or CRM systems such as Salesforce), to help solve any issues you might be facing in the future.

The website www.asmallworldhospitality.com/ does not use cookies.

We may disclose your personal information to any company within the ASMALLWORLD group, which means our subsidiaries, our ultimate holding company and its subsidiaries for outsourcing purposes (i.e. where such a member of our group provides services for and on our behalf).

When you submit information to ASMALLWORLD Hospitality AG, it is collected, processed and maintained solely by us or by our third-party contractors, those third party contractors being bound by our privacy policy or by restrictions at least as restrictive as those set forth in this policy.

Partners may sponsor special offers, promotions, privileges or contests that require you to disclose personal information to benefit from them. We will never disclose private data, including email addresses, to partners without your prior express consent.

Certain partners may require you to opt-in or agree to terms on the partners' landing pages authorising us to provide your information to the partner in question. We advise you always to check our partners' privacy policies before submitting information about yourself.

• in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
• if we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be some of the transferred assets; and
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements or to protect our rights, property, or safety of our customers, or others.

By using the Site you are consenting to the terms of this privacy policy and you agree that ASMALLWORLD Hospitality AG and its partners (if you have provided the respective partner with your email address or have consented to us giving your email address to the respective partner) may send you communications regarding goods, services, events and other information that may be of interest to you.

You may opt-out of receiving communications from us and/or our partners, and from participating in member surveys at any time by either following the simple unsubscribe process set out in each email, or by sending us an email at privacy@asw.com.

Please be aware that on certain, rare occasions, we will send emails to communicate important corporate or member messages, like changes in our privacy policy or a receipt of your membership payment. These emails will not have an unsubscribe feature, as they are one-time only communications.

To ensure removal from any lists, please provide us with your exact name and email address you provided in your original communication with us.

Our main servers for registered users and members are based in Switzerland. However, the data that we collect from you may be transferred to, and stored at, a destination outside Switzerland and the European Economic Area ("EEA") by us. It may also be processed on our behalf by staff operating outside Switzerland and the EEA who work for us or our suppliers, including but not limited to countries such as the United Kingdom and the United States of America.

By consenting to the collection and processing of your personal data, you agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy.

The transfer, storage or processing of personal information outside Switzerland and the EEA does not diminish your rights and we will take all reasonable steps necessary to ensure that any information that is transferred, stored or processed outside Switzerland and the EEA will be treated securely, in accordance with this privacy policy and with the same level of protection required by the Swiss Federal Act on Data Protection (“Swiss-Act”).

If you unsubscribe from ASMALLWORLD Hospitality AG services, we may retain information submitted by you or collected from you, for such time as is reasonably necessary for backup, archival and/or auditing purposes, to prevent fraud or other criminal activity, and for such time as may be required by applicable laws.

We will remove personal information by deleting it from our database if required to do so by law. We will also delete personal information upon your request in line with the right to erasure (‘right to be forgotten’) according to Art. 17 GDPR and similar local and national regulations elsewhere.

According to Art. 16 GDPR (and similar local and national regulations elsewhere), following the right to rectification, we will also rectify inaccurate personal data concerning you id you so choose (For both, please submit your request via e-mail to privacy@asw.com).

We regularly review the way we collect, store and process information, including physical security measures, in order to protect our systems from any unauthorised access.

All of our services are fully encrypted using SSL, and access to any personal information is limited to ASMALLWORLD Hospitality AG employees, contractors and agents, to the extent relevant to their job duties (such as processing certain information). Anyone with access to private data is bound by strict confidentiality obligations.

The Swiss-Act, GDPR and other local and national regulations give you the right to access personal data held about you. Your right of access can be exercised in accordance with these Acts, subject to any fees that ASMALLWORLD Hospitality AG may be permitted to charge you under such Acts (send e-mail request to privacy@asw.com).

On occasion, we may use personal information for new, unanticipated uses not previously disclosed in this privacy and cookie policy. In such cases, we will notify you of the content and purposes of the change by email.

If you do not oppose such change in writing (by email to privacy@asw.com) within ten (10) days of the date of the email, the changes will be deemed accepted by you. Any data collection changes will be effective from then on. We will not retroactively collect data for new collection procedures.