Welcome to www.iwishu.com, the platform of access to the world of IWISHU (hereinafteralso the “Website” or “Data Owner”). IWISHU is a content-sharing service thatallows video massages to be associated with cards, presents or postcards to addvalue to your thoughts, gestures and actions. Postcards and videos to sharewith those you love most, which may accompany products purchased online or in brick-and-mortar stores subscribing to the service.

The protection of privacy and of personal data is of fundamental importance for the Website. This document (hereinafter “Privacy Policy” or simply the “Policy”) describes the rules of conduct observed by the Website with regard to the handling of its users’ personal data, whether they are registered users or simple visitors.

The capacity to provide certain services requested by users (for example: the processing, sharing and receiving of contents, the reception of newsletters andother informative communications, setting up discussion forums etc.), thenature of the Internet itself as an ‘open’ network, as well as the technicalproperties of the network (client-server infrastructure), necessarily requirethe collection and processing of information by the Website, including personal information, relating to its users. Examples of such information are the IP address assigned to the device used to navigate the Internet, unique identifiers of mobile devices and SIM cards etc.

By using the Website, you show your full and unconditional acceptance of the termsof this Policy, with particular reference to the processing by the Website ofthe personal data described or assumed by the Policy. If you do not intend to comply with the Policy, you are requested to discontinue your use of the Website immediately.

The Website reserves the right to modify the Policy at any time and at its own discretion. Specifically, the Policy is continuously updated as either the Swiss Federal Act on Data Protection (hereinafter “FADP”) or European laws (hereinafter “GDPR”) develops. It is your responsibility to check, whenever you access the Website, what thestatus of the Policy is. Any changes to the Policy, as well as the date onw hich they come into force, shall be communicated on the Website, underobservance of a notification period of at least 7 days prior to the anticipated date of their coming into force. Once in force, the new Policy is automatically binding on all users. Use of the Website following the coming into force of the new Policy entails acceptance of the intervening changes.
Below we describe our policy approach to the protection of our users’ personalinformation. We wish you profitable navigation on www.iwishu.com.


A. Personal Details

The Data Owner may process personal information only under strict observance of this Policy and/or of applicable laws (primarily FADP and GDPR). By persona linformation is meant all information concerning you that is not in the public domain, in so far as you are identified or are made identifiable by it (hereinafter “personal information”). Unprotected information in the public domain specifically comprises data communicated to or made accessible to everybody by you, insofar as you have not expressly opposed this data being processed.

B. Gathering and processing of personal information

The Website processes the following information/data that is supplied by you during registration or afterwards:

  • mandatory user data: forename and surname / company, date of birth, sex (M or F), full address, telephone number, email address;
  • other data: information provided spontaneously by you or requested from you, personal interests and preferences, videos uploaded by you, fax number, credit card data, Paypal coordinates, delivery address, information contained in your‘contacts’ form, forename, surname and email address of the addressee of videos uploaded by you, your geolocation data (sent during the video uploading phase) and that of the addressee of the video (during viewing);
  • data listed at point a) above are mandatory. In their absence the Website could not provide site registration and any kind of service. Data listed at point b) above are optional. User can decide to either not provide any data at all or to withdraw consent to treat those data at a later stage: in this case, some Services offered by the Website could become unavailable to the User.

The Website does not request from you, nor does it advise you to provide personal data worthy of particular protection pursuant to Article 3, c of the FADP, such as your racial origin, ethnic origin, religious beliefs or state of health.
The Website neither gathers nor processes personal information about its users unless this is necessary to allow access to or use of or improvement of the Website (and of related resources, including software for mobile devices), without prejudice to these provisions.

Without prejudice to the provisions below, the Website neither processes nor transmits advertisements conceived on the basis of its users’ online behaviour; it neither tracks its users’ online activities beyond the website itself nor doesit use instruments designed to monitor the use of web resources or of email.
Where they are not obvious from the circumstances, the Website will indicate the purposes for which personal information is gathered and processed. It will do so no later than at the time when the information is gathered. These purposes may not be communicated via the web browser, by individual or general communication, nor can they rely on this Policy.

Personal information may be processed solely for the purpose indicated or for purposes surmisable from the circumstances at the time data is collected. For example,if you send an email with a query or a comment, the Website may use your email address in order to reply. The Website may save and permanently archive the email and the email address and a copy of the reply.

The Website collects and processes personal data without User formal consent (Chapter.6Articles b), e) GDPR) for some or all of the following reasons:
-To provide services to Users under a contract
-To comply with any legal, contractual, fiscal obligation related to a contractwith the User
-To allow users to sign up to the newsletter service or to any other serviceprovided by the Website
-To comply with laws and or regulations
-To prevent or discover frauds
-To exercise Website rights such as the right to legal defense

Aspart of its activities, the Website makes use of external suppliers of goodsand of services (cloud computing, IT services, hosting and housing services,legal services, etc.) The website provides these suppliers with access topersonal information insofar as this is useful or necessary for the proper andefficient performance of their tasks. The transmission of or access to personalinformation is subject to the condition that the said third parties, as well asthe data, are active and/or located in Switzerland or in the European Union andthat they have signed an undertaking to keep the said information confidentialand not to use it for reasons other than for the performance of their tasks.The Website accepts no responsibility for the actions of third parties insofaras no seriously negligent conduct is detectable in the Website’s selection, instruction and control of these third parties.

The Website is authorised to
- send you via e-mail, mail and/or text,marketing communication or materials related to products or services providedby the Website;
- send you electronic questionnaires tounderstand the level of satisfaction on services offered;
-send you via e-mail, mail and/or text, marketing communication or materialsrelated to products or services provided by third parties (ie: businesspartners, insurances).
-transmit personal information to third parties for marketing purposes only byobtaining express and informed prior consent from the user concerned (that is,if you ‘opt in’ – Chapter 7 GDPR)). These third parties may include affiliates,sponsors, marketing partners or advertisers. Information is transmitted inorder to enable the user to receive promotional offers, notification of eventsand personalised advertising.
Youhave the power to request, at any time, that such personalised transmissions beterminated (that is, you can ‘opt out’). In this case, only non-personalisedadvertising banners will remain active, along with messages from the Websiteregarding its own activities. The methods for communicating such a request areindicated in Section I below.

Other personal information, such as, for example, information regarding your use ofthe Website, (IP address, duration of visits to the website, services used,links and messages activated, etc.) is analysed in a completely automated wayin order to assess the introduction of new functions, to improve the quality ofservices offered and to optimise the usability of the Website.

The Website does not install, or encourage the installation of, third-party cookies(with the exception of Google Analytics, as described below) nor (as a rule) ofenduring cookies (evercookies) on your computer. However, the Website’s owncookies are admitted. A cookie is a file installed onto a computer’s hard diskthat can be used to recognise the user’s terminal on the web. Cookies can beused automatically to call up personal information previously entered on theWebsite (such as username, password, interests, settings or preferences) sothat it does not need to be re-entered on subsequent visits.
The use of cookies is also permitted in order to personalise the Website’sconfiguration automatically for the purpose of system administration. Withregard to the management of cookies, you may set up your own browser so that itinforms you of when it has received a cookie, or so that it blocks cookies as arule. If you block cookies, you may, however, suffer a slight reduction in theWebsite’s functionality.
The Website uses Google Analytics. Thanks to its own cookie, Google Analyticsanonymously detects information and navigation trends among users of theWebsite, storing and processing information such as IP address, time of visit,pages viewed, duration of navigation per page, links activated, whether thiswas a user’s first visit, etc. as well as information about the origin oftraffic towards the Website. The information generated by these cookies istransmitted to a server belonging to Google in the USA and is archived there.Google may then transfer this information to third parties if this is requiredby law or where third parties process this data on behalf of Google. Google undertakes to abide by the provisions regarding data protection in compliance with the US - Swiss Safe Harbor agreement. If you wish to deactivate GoogleAnalytics, a suitable browser add-on can be downloaded via this link . Forfurther information about advertising and the protection of data in Google: link .

Unless otherwise provided for by this Policy or by the law, the Website undertakes notto sell, hire, lend, trade or transfer personal information (including emailaddresses) to third parties, and, in addition, to treat all personalinformation as confidential.

It is underlined that the Website does not retain information concerning anyinstruments for electronic payment such as the purchaser’s credit card detailsor Paypal account: when acquired, such data are sent on to the respective payment gateways and are not stored on the iwishu.com platform. Responsibility for safeguarding such data therefore falls exclusively on the provider of the payment services chosen by the user when making the purchase, pursuant to the legislation applicable to the policy of the said provider.

C. Transmission and storage of personal information

The Website transmits personal information about its users to third parties if itis authorised to do so by law, by the Policy or through prior consent of theperson concerned and on condition that the addressee has their registered offices/domicile in Switzerland or in the European Union. Exception to the foregoing are cases where transmission is requested or authorised by the law or is ordered/authorised by a judicial or administrative authority of Switzerland or of the state where the data are located.
The Webiste processes personal through the operations listed by Chapter 4 art. 2GDPR: collection, recording, organisation, structuring, storage, adaptation oralteration, retrieval, consultation, use, disclosure by transmission,dissemination or otherwise making available, alignment or combination,restriction, erasure or destruction. Processing can happen either by automatedmeans or not (paper, manual processes).

The Website stores the personal information relating to its users for as long as thisserves the purpose for which it was gathered, or for as long as a legalobligation to retain it applies. To the extent permitted by the law, if aregistered user cancels their account, all personal information containedtherein or information referring to the account is automatically deleted, withthe exception of any correspondence that has taken place between the parties inwritten or electronic formats. An uploaded video will be deleted on writtenrequest by the video’s sender or by the addressee (the email address for thisis info@iwishu.com).

Currently, all data (including data of apersonal nature) flow into and are stored at the Data Center of Dedagroup Spain Trento (Italy) and the entire information platform of the Website and of its related resources is managed by Dedagroup Swiss SAGL, Lugano (Switzerland), a subsidiary of Dedagroup Wiz srl, Castenaso (Italy),which holds ISO 9001 Certification regarding data security and privacyprotection. If needed the Website will have the right to move some of all data even outside the EEC. In this case the website will of course continue to comply with Swiss and EEC data protection principles, laws and regulations

D. Consent for the collection and processing of personal information

By providing personal information, or by using the website, you accept that your information will be subjected to gathering and processing in compliance with the law and/or with this Policy.
Depending on the circumstances - that is, on the sensitivity of the data supplied or processed- you may be requested expressly to declare your consent to the gathering and processing of your personal information. This consent may be revoked at anytime, following the methods for communicating such a request, indicated in Section I below.

Where permitted or required by the law, or in the presence of an order originating from a judicial or administrative authority from Switzerland or from the state where the data are located, the Website is authorised to gather, use andtransmit personal information about its users without obtaining their prior consent and without informing them it has done so (Chapter 6 Articles b) and c) GDPR).

E. Security

Only authorised persons have access to personal information about the users and only insofar as such access is strictly necessary for the performance of their tasks. The Website implements all security measures reasonably demanded by and proportional to circumstances against non-authorised access, use, transmission, loss or destruction of its users’ personal information. These measures include technical, physical and organisational provisions. However, in view of the nature of the Internet as an open network, the Website cannot guarantee, nor does it guarantee, an absolute level of protection.
In this regard, it therefore accepts no liability unless the damaging event is the direct consequence of intentionally illegitimate or seriously negligent conduct ascribable to the Website. Similarly, the Website is not able to guarantee the confidentiality of the data provided by or transmitted through the website orby email. The Website therefore accepts no responsibility regarding the security of data in transit via the Internet from/towards the website in theabove terms.

F. Users’ have, under Chapter 15 GDPR the following rights:

i. to obtain confirmation of the existence or not of personal data concerning himself/herself, even if not yetrecorded, and their communication in intelligible form.
ii. to obtain information: a. of the originof personal data; b. the purposes and methods of processing; c. of the logicused should the processing be carried out with the help of electronicinstruments; d. of the identity of the data owner, data supervisors and therepresentative designated pursuant to Article 5, paragraph 2; e. of the names of subjects or categories of subjects to whom the personal data may be communicated or who can acquire it, for example, the data processing managers.
iii. to obtain: a. the updating, correction or integration of their personal data; b. erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention isunnecessary for the purposes for which they have been collected or subsequently processed; c. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entitiesto whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
iv. to object, wholly or in part: a. on legitimate grounds, to the processing of personal data concerning you, even though they are relevant to the purpose ofthe collection; b) to the processing of personal data concerning them, where itis carried out for the purpose of sending advertising materials or direct selling or else for the performance of market research or commercial communication surveys. obtain from the website confirmation as to whether or notpersonal data concerning him or her are being processed even if not stored yet, and, where that is the case, access to the personal data;
Where applicable, users also have the rights under Chapters 16-21 GDPR (right torectification, right to erasure, right to restriction of processing, right todata portability, right to object), as welll ad the right to lodge a complaint with a supervisory authority.
The Website will positively evaluate any suggestion or complaint stemming from users regarding its policies concerning the safeguarding of privacy and personal data.

G. Links to third-party websites and resources

The Website may contain links to websites and other Internet resources attributable to third parties. The Website is not responsible in any way for the contents, security or usability of these websites and resources; specifically, the Website does not check their policies or issue guarantees concerning the protection of privacy and of personal data by these third parties.

H. Proprietorship of the Website and person responsible for data protection

The proprietor of the Website is IWISHU SA, Contrada Cozóra 30, 6984 Pura, Switzerland. The internal head of data protection may be contacted via the email address given in Section I below.

I. How to contact us – how to exercise users’ rights

If you have any comments or queries relating to our Policy, to our processing of your personal information, or you want to exercise any of your rights kindly send an email to info@iwishu.com.


This Privacy Policy is upheld by Swiss Substantive Law, without prejudice to rules of international private law or to any foreign laws whose application is a cknowledged to be imperative.

The parties choose the Court of Lugano (Canton of Ticino) as the exclusively competent court for any disputes arising from or simply connected with use ofthe Website, without prejudice to any foreign norms concerning the choice of judicial forum, whose application is acknowledged to be imperative. The Website’s proprietor may furthermore summon you before a court close to your domicile or registered offices.

2014 IWISHU - All rights reserved
Contrada Cozóra 30, 6984 Pura - Canton of Ticino - Switzerland