Privacy Policy

 

Effective Date: January 4th, 2026

 

1. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) sets out how 360LUXAGENCY processes your personal data in connection with our business, including the provision of our website at https://www.360luxagency.com/ (“Site”) and the services we offer (“Services”).

In particular, this Cookie Policy explains our approach to any personal data that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data).

This Cookie Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Cookie Policy. It is intended to be read in conjunction with our Terms of Use and Cookie Policy.

Finally, this Cookie Policy is intended to meet the requirements of the legal requirements on the protection of natural persons with regard to the processing of personal data.

 

2. SCOPE OF THIS Cookie Policy

This Cookie Policy only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).

Further, this Cookie Policy is not intended to cover the processing of workplace personal data. Accordingly, if you are engaged as a worker for us, please see our Workplace Cookie Policy which sets out further information about how we may process your personal data in connection with your employment and/or engagement.

 

3. CHANGES TO THIS POLICY

We will update this Cookie Policy from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Cookie Policy, but we encourage you to review this Cookie Policy periodically to keep up to date on how we use your personal data. If we update this Cookie Policy, we will update the effective date at the top of the page.

 

4. ABOUT US

The Site and Services are made available by various companies in the 360LuxAgency group of companies (each a “Group Company”).

Where this Cookie Policy refers to “360LuxAgency”, “we”, “us”, “our”, this means one or more of the particular Group Companies that provide the particular Site or Services.

Except as stated otherwise, each Group Company is an independent controller of your personal data. The Group Companies are companies incorporated under the laws of Switzerland.

For the purpose of this Cookie Policy, unless we state otherwise we shall be considered a data controller of your personal data in connection with use cases identified in this Cookie Policy. Please note that in many cases where we process data in relation to Services that we provide, we may carry out the activities referred to in this Cookie Policy in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Cookie Policy.

 

5. HOW TO CONTACT US

If you have any questions about this Cookie Policy or want to exercise your rights as a data subject set out in this Cookie Policy, you can contact us using the following methods:
Email: Send us an email at:office@360luxagency.com
Post: Write to us at: Avenue de l’Amandolier, 20-1208 Geneva
Telephone: Call us on: +41 78 260 59 85

 

6. TYPE OF PERSONAL DATA WE COLLECT/PROCESS

When we talk about personal data, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:

For more information about the personal data, we collect please refer to section “HOW WE USE PERSONAL DATA” below.

 

7. HOW WE COLLECT PERSONAL DATA

We may collect and receive your personal data using different methods:

 

8. WHO WE COLLECT PERSONAL DATA ABOUT

We collect and process personal data from the following people:

 

9. HOW WE USE PERSONAL DATA

A. OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING

B. BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL

 

10. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

 

11. SHARING YOUR PERSONAL DATA

We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

We are part of the Omnicom Group of marketing and PR firms and (subject to the above) may share data within Omnicom Group companies, Omnicom Networks, or with our partner agencies or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data; (c) provision of IT and other support or internal administrative business services; or (d) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group

Further (again subject to the above) we may share your personal data with third parties, as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

 

12. DATA TRANSFERS OUTSIDE SWITZERLAND

We may transmit personal data outside Switzerland to certain categories of third parties (as listed above in SHARING YOUR PERSONAL DATA and more specifically to Omnicom Group entities, networks or partners agencies in other locations globally.

We transfer personal data abroad in accordance with Switzerland law.

 

13. OBTAINING YOUR CONSENT

Where our use of your personal data requires your consent, you can provide such consent:

at the time that we collect your personal data following the instructions provided; or
by informing us by e-mail, post or phone using the contact details set out in this Cookie Policy.
Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

 

14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.

 

15. YOUR DATA PROTECTION RIGHTS

You have the following rights in relation to the personal data we hold about you under certain circumstances:

Data deletion does not apply where we can demonstrate that we are required to retain personal data under applicable law or other regulations.

If we have shared your personal data with others, we will let them know about the deletion where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Data subjects may exercise these rights verbally or in writing using our contact information provided in the section below entitled “How to contact us” above. We will endeavour to promptly respond to your requests. If your request is denied, we will inform you about the reasons for denial.

Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

 

16. OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled “how to contact us” above.

 

17. THIRD PARTY LINKS AND SERVICES

This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Cookie Policy no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.

You’re browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

 

18. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain personal data only for as long as is necessary for the purposes described in this Cookie Policy, and for as long as we are required to keep it by law, after which it is deleted from our systems.

The length of time for which we keep different types of personal data can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.

 

19. PERSONAL DATA OF MINORS

Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

 

20. UNINTENDED CONSEQUENCES AND DAMAGES

During the data processing, we always strive to comply with legal regulations, ensure information security, and implement system security measures to protect your personal data. However, due to technical factors or other reasons beyond our control, data loss or information leakage may occur, resulting in unintended consequences or damages for you and/or us. In such cases, we will make every effort to rectify and enhance security measures to minimize losses for you.