Privacy Policy

This version has been automatically translated, in the event of any discrepancy between the French version of this document and any translation into another language, the French version shall prevail. Translations are provided for informational purposes only and are not authoritative for interpreting the provisions of this document.

What is the purpose of this privacy policy?

Ensuring the confidentiality of your personal information is essential to maintaining your trust. This privacy notice explains how and why we collect, process and use your personal data.

In this privacy policy, you will learn, among other things, the following:

the personal data we collect and process

the purposes for which we use your personal data ;

who has access to your personal data

the benefits of processing your data ;

how long we process your personal data

the rights you have regarding your personal data; and how you can contact us.

This privacy notice is based on the European Union's General Data Protection Regulation (GDPR). The GDPR has established itself worldwide as a rigorous data protection standard.

Who is responsible for data processing?

Responsibility for data processing lies with the company, which determines whether such processing should take place, for what purposes and how it should be configured.

VANGUARD INTERNET SA (Av. de Lavaux 77, 1009 Pully, Switzerland) is responsible for processing your personal data on the website and mobile application (legal basis of the contract), as well as for marketing e-mails (legal basis of legitimate interest to promote services), customer account management (legal basis of consent), or payment (legal basis of the contract).

In the context of a cleaning service, personal data will be communicated to the company ONET LUXEMBOURG SÀRLL (12E rue Guillaume Kroll L-1882 Cessange), which is responsible for processing data for the management of home cleaning services (legal basis of the contract), including for responding to your comments on the Internet (legal basis of the legitimate interest in satisfying our customers).

In particular, ONET LUXEMBOURG SÀRL may process data such as identification data, financial data or business details as part of the performance of the Service contract.

To whom is this privacy notice addressed?

This Privacy Notice applies to all persons whose data we process (hereinafter "you"), regardless of the channel you use to contact us (e.g. on our website, in an app, in a physical branch, by telephone, via a social network, at an event, etc.). It applies to the processing of personal data that has already been collected and personal data that will be collected in the future.

Our data processing activities may, in particular, affect the following categories of persons if we process their personal data:

Visitors to our websites ;

Customer account holders ;

Customers of our website and our physical branches;

Other persons who use our services or come into contact with offers from us;

Users of our online offers and applications ;

Visitors to our premises ;

People who write to us or contact us in any other way;

Recipients of information and marketing communications ;

Participants in contests and prize draws ;

Participants in customer and public events;

Participants in market, opinion and customer surveys;

Contacts with our suppliers, sales outlets and other business partners, as well as with organizations and authorities.

Please also consult the contractual terms and conditions of the individual services (e.g. general terms and conditions, terms of use or terms of service). For more information on the collection and processing of personal data when using our websites, mobile applications and social media pages, in particular in relation to cookies and similar technologies, please also see our Cookie Notice.

What personal data do we process?

Personal data" is information that can be associated with a specific person. We process various categories of personal data. The main categories are presented below for information purposes.

However, we may also process other personal data in specific cases.

You will find more information on the origin of this data in section 5 and in section 6 on the purposes for which we process this data.

4.1 Basic data

Basic data includes basic information about you, such as your title, your first and last name, your contact details or your date of birth. We collect basic data in particular when you create a customer account with Batmaid. We also collect basic data when, for example, you take part in a competition or prize draw, or when you subscribe to a newsletter. We also collect basic data on contacts and representatives of contractual partners, organizations and authorities.

Batmaid collects and uses the following personal data:

Title, first name, last name, gender, date of birth ;

Address, e-mail address, telephone number and other contact details;

Customer number/identifier (e.g. for loyalty program participants) ;

Payment information (e.g. registered payment forms, bank details, billing address);

Username and profile picture ;

Information on the use of our online platforms (for example, if you are registered with Batmaid);

Details of associated websites, social media profiles, etc ;

Information about your interests and preferences, language preferences, etc;

Information about your relationship with us (customer, visitor, supplier, etc.);

Information about related third parties (for example, contacts, service recipients or representatives);

Settings for receiving advertisements, newsletters, etc;

Data relating to your status with us (inactive or blocked user account, restricted access to premises, etc.)

Information relating to participation in competitions and prize draws

Official documents in which you appear (e.g. identity documents, extracts from the commercial register, permits, etc.)

Titles and functions of contact persons and representatives of our business partners;

The date and time of registration.

Under certain circumstances, you may also register for individual online offers via the login of a third-party provider (e.g. Apple or Google). In this case, we have access to certain data stored with the provider in question, such as your user name and e-mail address, the extent of which you can normally determine. You will find information on this subject in the privacy policy of the supplier concerned.

4.2 Contractual data

Contractual data are personal data that are connected with the conclusion or performance of the contract, for example information on the conclusion of the contract, claims and acquired rights, or information on customer satisfaction. We conclude contracts mainly with customers, business partners and job applicants. If you accept our offers on the basis of a contract, for example if you purchase products or use services, we often also collect behavioral and transactional data (see also point 4.4).

Contractual data includes information:

on the initiation and conclusion of contracts, e.g. the date of conclusion of the contract, details of the application process and details of the contract in question (e.g. type and duration or, if necessary, proof of identity such as copies of official identity documents) ;

on the processing and management of contracts (e.g. contact details, delivery addresses, successful or unsuccessful deliveries, and information on payment methods), as part of our customer service and technical support ;

on our interactions with you (if applicable, a history with the corresponding entries) ;

on receivables and acquired rights and benefits (e.g. purchase vouchers) ;

on defects and complaints as well as contract amendments;

on customer satisfaction, which we can collect through surveys;

on financial matters such as establishing creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood of payment of claims), reminders, collection procedures and enforcement of claims;in connection with a job application, such as curriculum vitae, references, qualifications, certificates, meeting notes, etc ;

concerning interactions with you as a point of contact or representative of a business partner;

as part of security checks (e.g., checking for fraudulent actions on orders) and other checks concerning the establishment or continuation of a business relationship (B2B).

4.3 Communication data

If you contact us or if we contact you, for example when you contact customer service, write to us or call us, we process the content of the communication exchanged and information relating to the type, time and place of the communication.

Here are some examples of communication data:

name and contact details, such as postal address, e-mail address and telephone number;

the content of e-mails, written correspondence, chat messages, social media messages, comments on a website, telephone conversations, video conferences, etc ;

details of the type, time and, in certain circumstances, place of communication;

proof of identity, such as copies of official identity documents;

4.4 Transactional and behavioral data

When you transact with us, use our offers and infrastructure or procure our services, we frequently collect data on this usage. This happens, for example, if you make a booking with us or use our websites and apps. If you are acting on behalf of a third party, this personal data may also relate to that third party (for example, your family members if you make purchases on their behalf).

Examples of transactional and behavioral data include the following information if available as personal data:

details of your behavior on our online platform (ordered and cancelled appointments, jobs, list of preferences, search items and results, payment method, etc.)

details of your behaviour on the profile (for example, where, how often, what and which options you prefer, as well as the payment method and extras selected);

participation in our events (e.g. date, location and type of event);

details of your participation in competitions, prize draws and similar events;

information about your behaviour on our websites;

information on installing and using mobile applications;

information about your use of the e-mail messages we send you (for example, if and when you opened an e-mail or clicked on a link);

You can also use some of our offers anonymously. For example, in countries where we operate physical offices, you can visit our stores without registering to obtain more information about our services. However, on our websites and apps, transactional and behavioral data may also be attributed to your profile, even if you are not logged in at the time you visit the website or use the app.

4.5 Preference data

We want to tailor our offers and services to our customers as effectively as possible. That's why we also process data about your interests and preferences. To do this, we may combine transactional and behavioral data with other data and analyze this data on a personal and non-personal basis. This enables us to deduce likely characteristics, preferences and behaviors, such as your affinity for specific products and services.

In particular, we may create segments (permanent or case-related), i.e. groups of people with similarities in relation to specific characteristics. Preference data can be used either for personal purposes (e.g., to show you advertisements that are relevant to you) or for non-personal purposes (e.g., for market research or product development).

The processing described may also be called "profiling" in technical language. Further information on profiling can be found in section 11.

4.6 Technical data

When you use our websites, apps or other services such as our Wi-Fi network (in our physical locations), we collect certain technical data such as your IP address or device identifier. Technical data also includes the protocols by which we record the use of our systems (log files). In some cases, we may also assign a unique code number (an ID) to your end device (tablet, PC, smartphone, etc.), for example by using cookies or similar technologies, so that we can recognize it. Further information on this subject can be found in our Cookie Notice.

Technical data include:

your device's IP address and other device identifiers (e.g. MAC address);

code numbers assigned to your device by cookies and similar technologies (e.g. pixel tags);

details of your device and its configuration, such as operating system and language settings;

details of the browser used to access the offer and its configuration;

information about your movements and actions on our websites and in our apps;

information about your Internet service provider ;

your approximate location and time of use ;

system records of accesses and other events (log files).

telecommunications traffic metadata

For more information on the processing of technical data, please also see our Cookie Notice.

4.7 Image and sound recordings

We regularly produce photos, videos and sound recordings in which you may appear, for example if you attend an event, contact our customer service department or receive a call for a videoconference interview. For security and evidential purposes, we also make video recordings in our branches and other premises. In doing so, we may obtain information about your behavior in the areas concerned. The use of video surveillance systems is localized and clearly indicated.

Here are a few examples of image and sound recordings:

recordings from video surveillance systems ;

photos, videos and sound recordings of customers and public events (e.g. advertising, sponsorship, cultural and sporting events);

photos, videos and sound recordings of courses, presentations, training sessions, etc;

recordings of telephone conversations and videoconferences (e.g. for customer service or advice).

Where do personal data come from?

5.1 Data supplied

You often provide us with personal information directly, for example when you share data or interact with us. In particular, details such as master data, contract data and communication data are usually disclosed voluntarily by you. In addition, in many cases it is your responsibility to provide us with preferential data.

For example, you yourself provide us with personal data in the following cases:

create a customer account ;

enter a prize draw or competition;

contact our customer service department;

subscribe to other offers, such as our newsletter.

The provision of personal data is largely voluntary, which means that you are generally under no obligation to provide us with your personal data. However, we are obliged to collect and process personal data that is necessary for the processing of contractual relationships and the fulfilment of obligations arising therefrom or that is prescribed by law, such as mandatory basic data and contractual data, without which we would not be able to conclude or continue the contract in question.

When you provide information about other people (for example, members of your family), we assume your authorization and the accuracy of the data provided. In addition, it is essential to ensure that these persons are informed of this privacy policy.

5.2 Data collected

We may collect personal information about you, directly or automatically, for example when you carry out transactions with us, use our services or take advantage of our offers. This generally includes behavioral and transactional data, as well as technical details such as your time spent on the website.

For example, we independently collect personal data about you in the following cases:

you request a cleaning via our online platform

you visit one of our websites or use one of our apps;

you click on a link in one of our newsletters or interact with one of our electronic promotional materials in any other way.

We may also derive personal data from personal data already in our possession, for example by analyzing transactional and behavioral data.

For example, we may analyze transactional and behavioral data collected during purchases in our online stores and, on this basis, make assumptions about your interests, preferences, affinities and habits. This enables us, for example, to tailor our offers and information to your individual needs and interests. This enables us, for example, to send you a personalized selection of offers relevant to you.

Further information on transactional and behavioral data can be found in section 4.4, and on profiling in this context in section 11.

5.3 Data received

In addition, we may also receive information about you from other third parties, such as companies with which we cooperate, individuals who communicate with us, government agencies or public sources.

For example, we may receive information about you from the following third parties:

people close to you (family members, legal representatives, etc.), e.g. your cleaning address, references or powers of attorney;

credit and collection agencies such as Intrum AG.

Swiss Post and address brokers, e.g. for address updates;

banks, insurance companies and other contractual partners for purchases, payments and claims;

authorities, parties and other third parties in official and legal proceedings;

public registers such as the debt enforcement register or the commercial register, public offices such as the Swiss Federal Statistical Office, the media or the Internet.

For what purposes do we process personal data?

Personal data are mainly processed for the following purposes:

enable the performance of service contracts

provide the Service or deliver the product requested by the Customer

enable invoicing and guarantee collection of overdue payments

meet our legal obligations
develop commercial relations

deal with any claims and disputes and, in particular, establish, exercise or defend any legal rights.

We undertake to collect, by default, only the personal data that are necessary for each specific purpose of processing.

These purposes are developed in the following paragraphs.

6.1 Communication

We want to stay in touch with you and meet your specific needs. This is why we process personal data to communicate with you, respond to your requests and provide you with customer support, among other things. To this end, we specifically use communication and master data, as well as contractual data if the communication relates to a contract. In addition, we may personalize the content and timing of messages based on behavior, transactions, preferences and other data.

The aim of the communication is to:

answer inquiries ;

to contact you if you have any questions;

customer service and assistance ;

communication on cleaning changes

send other notifications (e.g. order status information);

authentication, e.g. for the use of our online offers;

quality assurance and training ;
all other processing purposes for which we communicate with you (e.g. contract processing, information and direct advertising).

6.2 Contract performance

We want to offer you the best possible service. This is why we process personal data for the purposes of establishing, administering and processing contractual relationships, for example to provide a cleaning service, deliver goods or services or organize a prize draw.

Contract processing also includes the agreed personalization of services. To this end, we use master data, contractual data, communication data, transactional and behavioral data and preference data.

The purpose of contract processing generally includes everything that is necessary or appropriate for the conclusion, performance and, where applicable, enforcement of a contract.

For example, processing to :

decide whether and how (e.g. with which payment options) we conclude a contract with you.

provide contractually agreed services, such as product delivery and cleaning services.

provide customer service and improve customer satisfaction;

implement and manage loyalty programs, e.g. to redeem claims and benefits obtained (e.g. vouchers and promotional codes) and credit them to customer accounts;

establish, notify and, if necessary, publish the names of the winners of the competitions and prize draws;

invoice our services and, in general, keep our accounts

plan and prepare the delivery of our services, e.g. scheduling our employees ;

examine the suitability of candidates for employment and, where necessary, prepare and conclude employment contracts;

examine whether we are willing and able to cooperate with a company and to monitor and evaluate its services;

prepare and conclude corporate transactions such as acquisitions, sales and mergers;

assert rights arising from contracts (collection procedures, legal proceedings, etc.);

administer and manage our IT and other resources;

retain data in accordance with document retention obligations ;

cancel and terminate contracts.

6.3 Information and marketing

Our aim is to provide you with attractive offers. To this end, we process personal data for relationship management and marketing purposes. This may involve sending you written and electronic messages, presenting you with offers and conducting marketing campaigns. This may involve our own offers, those of other Batgroup SA companies or those of advertising partners.

Messages and offers may also be personalized in order to send you, as far as possible, only information likely to be of interest to you. For this purpose, we use master data, contract data, communication data, transaction data, behavioral data and preference data, but we may also choose to access sound recordings.

These include the following messages and offers:

Newsletters, advertising e-mails, in-app messaging, sms and other electronic messages;

Advertising brochures, magazines and other printed documents;

Advertising messages and spots on screens and other advertising spaces;

Delivery of promotional coupons and promotional codes;

Invitations to events, prize draws and competitions.

You may refuse to be contacted for marketing purposes at any time (see section 15). For newsletters and other electronic messages, you can generally unsubscribe from the relevant service from your customer account or via an unsubscribe link included in the message. You can also contact us at any time in writing to unsubscribe if you cannot find the appropriate unsubscribe button.

6.4 Market research and product development

Our aim is to continually improve our offers and make them more attractive to you. To this end, we process personal data as part of market research and product development. This involves processing basic, behavioral, transactional and preference data, as well as communication data and information from customer surveys, other surveys and studies, and additional information obtained from various sources such as the media, the internet and public channels. Wherever possible, we use pseudonymized or anonymized data for these initiatives.

Market research and product development in particular include:

customer surveys, other surveys and studies;

further development of our offerings (e.g. structuring of products and services, choice of location, pricing, campaign planning, etc.)

to evaluate and improve the acceptance of our offers and our offer-related communication;

optimizing and improving the user-friendliness of websites and applications;

development and testing of new offers;

reviewing and improving our internal processes;

Statistical evaluations, for example to evaluate information about our customers' interactions with us on an anonymous basis;

market monitoring, for example to understand and respond to current trends and developments.

6.5 Safety and prevention

We want to guarantee your security and ours, and prevent misuse. For this reason, we also process personal data for security purposes, to ensure IT security, to prevent theft, fraud and abuse, and for evidential purposes. This may involve all the categories of personal data listed in section 4, in particular transactional and behavioral data and image and sound recordings. We may acquire, analyze and store such data for the purposes mentioned.

Here are a few examples of safety and prevention objectives:

the creation and evaluation of video recordings for the detection and prosecution of criminal acts;

imposing bans on access to our premises or use of our services and administering lists of persons banned from accessing our premises or using our services;

analysis of transactional and behavioral data to detect suspicious behavior and fraudulent activity;

evaluation of records of the use of our systems (log files);

prevention, mitigation and detection of cyber and malware attacks;

analyses and tests of our networks and IT infrastructures, as well as system and error checks;

controlling access to electronic systems (e.g. logging on to user accounts);

physical access controls (e.g. access to premises) ;

documentation and creation of backup copies.

6.6 Compliance with legal requirements

We want to lay the foundations for compliance with legal requirements. This is why we also process personal data to comply with legal obligations.

Examples include receiving and processing complaints and other messages, and complying with judicial and administrative orders.

This may apply to all the categories of personal data listed in section 4. Compliance with legal requirements includes, in particular:

implementation of health and safety concepts

clarifications concerning commercial customers ;

receiving and handling complaints and other messages ;

conducting internal investigations;

guaranteeing compliance and risk management ;

the disclosure of information and documents to the authorities if we have an objective reason (for example, because we ourselves are the injured party) or if we are legally obliged to do so;

assistance with external investigations, e.g. by criminal prosecution or supervisory authorities;

guarantee the level of data security required by law;

the fulfillment of disclosure obligations, information obligations or reporting obligations, for example in the context of obligations under supervisory and tax law, as well as in the case of archiving obligations and for the prevention, detection and investigation of criminal and other offenses;

the legal fight against money laundering and the financing of terrorism.

Provision of a workplace

Our agents work at the address of a designated customer. The information recorded for each "job", including the customer's name, address, e-mail address and telephone number, is recorded and kept for 10 years from the date of completion of the job, in accordance with employment law. In accordance with the law, company management reserves the right to access this information at any time.

After 10 years, reasonable efforts will be made to anonymize or delete the data.

All such cases may involve compliance with Swiss legislation or foreign regulations applicable to us, as well as adherence to self-regulatory measures, industry standards and other norms, and compliance with our own corporate governance principles or official guidelines.

6.7 Preservation of rights

We want to assert our rights and protect ourselves against the claims of others. For this reason, we also process personal data for the purpose of protecting our rights, e.g. to assert rights in judicial and extrajudicial proceedings and before authorities in Switzerland and abroad, or to defend ourselves against claims. Depending on the situation, we process different categories of personal data, such as contact data and details of events that have led or could lead to litigation.

The objective of protecting rights includes in particular:

the establishment and enforcement of our rights, which may also include the rights of our affiliates and our contractual and business partners;

defending against claims made against us, our employees, our affiliates and our contractual and business partners;

clarification of business prospects and other legal, economic and other issues;

participation in proceedings before courts and authorities in Switzerland and abroad. For example, we may obtain evidence, have business prospects investigated or submit documents to the authorities. The authorities may also ask us to disclose documents and data carriers containing personal data.

6.8 Group administration and support

We want to organize our internal processes efficiently. For this reason, we also process personal data for the internal administration of Batgroup AG. In particular, we process master data, contractual data and technical data, as well as transaction data, behavioral data and communication data.

Administration within the Group includes the following:

IT administration

accounting ;

data archiving and archive management;

training and education, for example when we analyze telephone, video or other forms of communication;

centralized storage and management of data used by several Batgroup SA companies;

reviewing or executing corporate transactions such as acquisitions, sales and mergers.

forwarding requests to the responsible offices, for example when you submit a request concerning another Batgroup company to one company;

the sale of receivables, for which we send the buyer information, for example on the reason for and amount of the receivable and, where applicable, on the borrower's creditworthiness and behaviour;

in general, the review and improvement of our internal processes.

Like any group of companies, Batgroup SA has a general interest in the success of the business activities of its group companies, and our group companies themselves have an interest in their own activities and processing objectives.

We may therefore also disclose personal data to other Batgroup SA companies in order to support their own processing purposes under the Batgroup SA Privacy Notice, in the general interest of Batgroup SA. Further information on this subject can be found in section 8.

What is the legal basis for processing personal data?

Depending on the purpose of the data processing, our processing of personal data is based on different legal grounds. In all cases, we will comply with the laws of the local jurisdiction of the Batmaid entity with which you are transacting.

For Switzerland, the laws that apply are described in the nFADP Switzerland (update: September 1, 2023). In particular, we may process personal data if:

this is necessary for the execution of an agreement with the data subject or for pre-contractual measures (for example, to carry out cleaning work and administer Batmaid SA);

processing is necessary for the exercise of legitimate interests, for example when data processing is a central part of our business activities (i.e. marketing);

processing is based on consent ;

processing is necessary to comply with Swiss and foreign legal obligations.

In particular, we have a legitimate interest in processing data for the purposes set out in section 6 above and in disclosing it in accordance with section 8 and the purposes associated therewith. In each case, legitimate interests include our own interests.

These legitimate interests include, for example, interests relating to :

good customer care, maintaining contact and other communications with customers, including outside the contractual framework ;

advertising and marketing activities ;

get to know our customers and others better;

improving existing products and services and developing new ones;

to facilitate management and communication within the group, which is necessary with a group that requires cooperation between the parties ;

support each other's activities and objectives ;

combat fraud, for example on online platforms, and prevent and investigate offences ;

protect customers and others, as well as Batgroup SA data, secrets and assets;

ensure IT security, in particular when using websites, applications and other IT infrastructures;

safeguard and organize business operations, including the operation and development of websites and other systems;

manage and develop the company;

enforcing or defending legal rights and claims;

compliance with Swiss and foreign law, as well as internal rules and regulations.

To whom do we disclose personal data?

8.1 Within Batgroup SA

We may disclose personal data we receive from you or third party sources to other Batgroup companies. Disclosure may be used to facilitate administration within the group or to support the relevant group companies and their own processing purposes (section 6), such as when we support the personalization of marketing activities, the development and improvement of products and services, the performance of credit assessments or efforts to prevent theft, fraud and misuse. Personal data received may also be reconciled and linked to existing personal data by the group companies concerned.

For example, this may include the following data disclosures:

All the categories of personal data listed in section 4 for the management and processing of contractual relations, in particular in the context of products and services involving several Group companies;

Basic data, contractual data, communication data, transactional and behavioral data and preference data, as well as the results of customer and other surveys, studies and image and sound recordings for market research and product development purposes, if the personalization of such data is necessary;

Basic data, contractual data, communication data, transaction data, behavioral data, preference data and image and sound recordings for the provision and personalization of offers, communications and marketing activities;

Basic data, contractual data, communication data, transaction data, behavioral data and preference data for fraud and abuse prevention and for assessing creditworthiness (e.g. in the context of account purchases);

Master data, transaction data, behavioral data and image and sound recordings for theft protection and evidence purposes;

Security information for security purposes and to comply with legal requirements;

Information to support the protection of rights.

If, for example, you contact us to ask a question about our service, we may pass this information on to the Batgroup company responsible for the service, for the purposes of improving service and quality.

Section 2 contains more information on Batgroup companies.

8.2 Outside Batgroup SA

In the context of a cleaning service in Luxembourg, personal data will be communicated to the company ONET LUXEMBOURG SÀRLL (12E rue Guillaume Kroll L-1882 Cessange), which is responsible for processing data for the management of home cleaning services (legal basis of the contract), including for responding to your comments on the Internet (legal basis of the legitimate interest in customer satisfaction).

In particular, ONET LUXEMBOURG SÀRL may process data such as:

Identification data (surname, first name, date of birth, address, etc.)
Contact data (e-mail address, telephone number, etc.)
Financial data (credit card number, bank details, payment history, etc.)
Connection data (IP address, connection logs, etc.)

We may also disclose your personal data to companies outside Batgroup if we use their services. These service providers generally process personal data on our behalf as "subcontractors". Our subcontractors are required to process personal data only in accordance with our instructions and to take appropriate measures to ensure data security. Some service providers are also responsible jointly with us or independently (e.g. collection agencies). Our selection of service providers and appropriate contractual agreements ensure that data protection is respected throughout the processing of your data.

These include services in the following areas:

Shipping and logistics, for example for the delivery of goods ordered on batmaid club ;

Advertising and marketing services, e.g. sending messages and information

Business management services, such as accounting or asset management

Payment services

Credit assessment, for example if you wish to make a purchase on account;

Collection services

Insurance service providers

IT services, e.g. in the fields of data storage (hosting), cloud services, e-mail newsletters and data analysis and refinement;

Consulting services, such as tax advisors, lawyers, management consultants or recruitment and staffing consultants.

It is also possible that we disclose personal data to other third parties for their purposes, for example if you have given your consent or if we are legally obliged or authorized to share this information. In this case, the recipient of the data is legally responsible as the data controller.

Here are a few examples:

Transferring receivables to other companies, such as collection agencies.

Review or execution of corporate transactions such as acquisitions, sales and mergers.

Disclosure of personal data to courts and authorities in Switzerland and abroad, such as criminal prosecution authorities in the event of suspected criminal activity.

Processing personal data in order to comply with a judicial or administrative order, or to assert or defend legal rights or claims, or if we consider that such processing is necessary for any other legal reason. We may also disclose your personal data to other parties involved in proceedings.

Please read our Cookie Notice regarding independent data collection by third-party vendors whose tools we have integrated on our websites and apps.

In the context of our contractual employment with agents only and with their explicit consent, Batgroup may receive, store and process data from healthcare professionals received by letter, telephone or e-mail.

As part of our service provision agreement with customers, you may inform us of a medical condition, disability or impairment that may affect our service provision. In this case, we will note it as a preference (comment) on your profile. In addition, you may also inform us that your insurance company or a family member is paying for your cleaning; data relating to this information will therefore also be stored.

How do we disclose personal data abroad?

We process and store personal data in Switzerland and in the European Economic Area (EEA). In some cases, however, we may also disclose personal data to service providers and other recipients (see section 8).

How do we profile?

Profiling" refers to a procedure in which personal data is processed on an automated or manual basis in order to analyze personal aspects or make predictions, for example the analysis of personal interests, preferences, affinities and habits or the prediction of likely behavior. Profiling can be used in particular to obtain data on preferences (for further information, see point 4.5).

Profiling is a common procedure, for example in automated data processing:

basic data, contractual data, transactional and behavioral data for purchases on our website ;
health-related data;

transactional and behavioral data, as well as technical data related to our websites and apps;

information relating to participation in events or competitions, prize draws and similar events;

communication data, such as your response to advertising and other messages;

other transactional and behavioral data.

Profiling helps us to :

constantly improve our offers and adapt them to individual needs;

to present you with our content and offers according to your needs;

as far as possible, only show you advertisements and offers that are likely to be relevant to you;

to help you better with our customer service;

decide, based on an assessment of your creditworthiness, which payment options are available to you.

Profiling also takes place as part of your customer account, for example when we analyze your usage and behavior on our website and apps in order to provide you with an individual user experience and send you offers tailored to your interests.

In order to improve the quality of our analyses and predictions, we may also combine personal data from different sources as a basis for our profiling, for example data that has been collected via our various departments or that we have received from other Batmaid companies. Self-learning algorithms (specific routines in computer programs) may also be used.

In some cases, you also have the right to object to profiling, as described in section 15.

Do we use automated individual decision-making or artificial intelligence?

Automated individual decision-making refers to any decision taken on a fully automated basis, i.e. without any relevant human influence.

Here are some examples of when we might use technology to make a decision:

Selecting or reassigning a cleaning agent

Cancel your cleaning when no cleaning agent is available

You'll always have the option of having the decision reviewed by a human being if you disagree.

How do we protect personal data?

We take appropriate technical and organizational security measures to safeguard your personal data, to protect you against unauthorized or unlawful processing activities, and to address the risk of loss, unintentional modification, inadvertent disclosure or unauthorized access.

Nevertheless, as with all organizations, we cannot totally eliminate the possibility of data security breaches; some residual risks are inherent. Technical security risks include data encryption and pseudonymization, archiving practices, access controls and data backup storage.

Organizational security measures include providing guidelines to our staff, conducting training initiatives and carrying out audits. In addition, we require our subcontractors to implement appropriate technical and organizational security measures.

How long do we process personal data?

The personal data collected will not be kept longer than is necessary to achieve the above-mentioned purposes, nor longer than is required or permitted by law.

We process and store your personal data:

as long as they are necessary for the purpose of the processing and for compatible purposes, up to 10 years, in the case of contracts, normally at least for the duration of the contractual relationship;

as long as we have a legitimate interest in keeping them, up to 10 years. This may be the case, in particular, if we need personal data to assert or defend rights, for archiving purposes and to ensure IT security;

as long as they are subject to a legal retention obligation, up to 10 years. Shorter retention periods apply to other data, e.g. video surveillance recordings or records of certain online processes (log data).

The storage and use of payment data will be handled by our payment service provider Datatrans. ONET LUXEMBOURG SÀRL undergoes an annual audit called PCI compliance to ensure that payment data remains private.

In some cases, we may ask for your consent if we intend to retain your personal data for an extended period (for example, for archived job applications). At the end of these periods, we will delete or anonymize your personal data. For further information, please consult our general terms of use, art. 18.

For example, we adhere to the following retention periods, although there may be exceptions in certain cases:

Customer accounts: personal data is retained for as long as the account is active. If the deletion of a customer account is ordered, the data will be deleted after examination of any outstanding claims or other relevant points that prevent immediate deletion, and after 30 days at the latest.

Contracts: We generally retain master and contractual data for ten years from the last contractual activity or the expiry of the contract. However, this period may be longer if necessary for evidential purposes, due to legal or contractual provisions, or for technical reasons. Transaction data relating to contracts is generally kept for ten years.

Technical data: Cookies are normally stored for a few days, up to a maximum of 13 months, unless they are immediately deleted at the end of the session.

Communication data: E-mails, contact form messages and written correspondence are generally kept for 3 years.

What are your rights regarding the processing of your personal data?

You have the right to object to data processing, in particular if we process your personal data on the basis of legitimate interests and other relevant requirements are met.

You may also object at any time to the processing of data relating to direct advertising (e.g. promotional e-mails). This includes opposition to profiling, insofar as it relates to direct advertising.

In accordance with the French Data Protection Act and the RGPD, you have the following rights:

Right of access (Article 15 RGPD) and rectification (Article 16 RGPD);

Right to erasure of your personal data (Article 17 RGPD);

Right to withdraw your consent at any time (Article 13-2c RGPD);

Right to limit the processing of your data (Article 18 GDPR);

Right to object to the processing of your data (Article 21 GDPR);

Right to portability of the data you have provided to us, where your data is subject to automated processing based on your consent or on a contract (Article 20 RGPD) ;

Right to lodge a complaint with the CNIL (Article 77 RGPD).

To find out more about your rights, you can also visit the website of the Commission Nationale pour la Protection des Données (French Data Protection Authority) at https://cnpd.public.lu/fr.html.

Please note that these rights may be limited or excluded in certain cases, for example in cases of doubt as to identity or to protect other persons, to safeguard interests worthy of protection or to comply with legal obligations.

You can exercise these rights, in particular the essential rights, via your customer account or our helpdesk. If you have a customer account, you can update your stored basic data (e.g. your address) at any time. From your customer account, you can also request the deactivation of your account or the complete deletion of your personal data.

In addition, you can unsubscribe from newsletters and other promotional emails by clicking on the relevant link at the end of the email. To exercise your rights or request information about the processing of your personal data, you can contact us in accordance with section 16.

In addition, you are free to lodge a complaint with a competent supervisory authority if you suspect that the processing of your personal data may violate applicable laws.

How can you contact us?

VANGUARD INTERNET SA

Avenue de Lavaux 77

CH-1009 Pully

ONET LUXEMBOURG SARL 12E, rue Guillaume J.Kroll L-1882 Cessange

If you have any queries about this policy, or if you wish to obtain information or exercise your rights regarding the processing of personal data managed by Batgroup, please contact our Data Protection Officer:

by e-mail: client@batmaid.lu or dpo@onet.lu

by post: Batmaid Luxembourg - 21, rue Glesener L-1631 Luxembourg

In the event of an unresolved dispute, you may lodge a complaint with the Commission Nationale pour la Protection des Données: 1, avenue du Rock'n'Roll L-4361 Esch-sur- Alzette.

Changes to this Privacy Policy

This privacy notice may be updated over time, particularly if changes are made to our data processing practices or if new legal requirements arise. We will actively inform individuals whose contact details appear in our records of any material changes, provided we can do so without disproportionate effort. As a general rule, the version of the privacy notice in force at the start of the data processing activity applies.

Date of last modification: 25.03.2025