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What is it?

When you use our website my.lugano.ch, the MyLugano App, the MyLugano Card or the MyLugano Pass, the Municipality of Lugano collects and processes information concerning you (so-called "personal data"). The purpose of this page is to inform you about the personal data collected, the processing carried out, the purposes pursued, the recipients of the data and their possible transfer abroad. Since you have a wide choice of services at your disposal, you will find below a general section with information that applies to all services and several special sections with information specific to individual services. Please take the time to read through everything and if you have any questions, write to us (my@lugano.ch) or call us (+41 58 866 48 00). To help you, we have provided icons to represent the various types (you can see the legend here). We wish you a beneficial and informed use of the services offered by the City of Lugano!

Who are we and how can you contact us?

It is the City of Lugano (CH) that determines the purpose and means of the processing of your personal data. To communicate with the Municipality, please use the following contacts: (i) postal address: Municipio di Lugano, Cancelleria Comunale, piazza della Riforma 1, 6900 Lugano; (ii) Tel. +41 58 866 48 00; (iii) e-mail: my@lugano.ch.

Our Philosophy on the Use of Personal Data

The City of Lugano only collects and uses the personal data necessary to operate the platform in a smooth and secure manner. We do not profile you, we do not monitor your behaviour, we do not give your personal data to third parties and we do not allow third parties to offer you personalised advertising. To expand and improve our services, we only analyse the use of our services in an aggregated manner, i.e., we guarantee the anonymity of the users concerned. In addition, we carry out the processing that is required by law.
We give preference, where necessary, to expressly given consent as the legal basis for processing and try to carry out all processing "in-house". Only in exceptional cases, i.e., where the municipality does not have the necessary technology or expertise, will processing be delegated to carefully selected external providers who have undertaken strict data protection obligations. Finally, personal data is processed in Switzerland. Only in exceptional cases will processing take place abroad. This can only take place in countries that have legislation that protects personal data in an appropriate manner in accordance with the instructions of the Federal Data Protection and Information Commissioner (FDPIC).

Are you an individual residing in the European Union? Read more here

You came to visit us from abroad, thank you very much!
As you are probably aware, Switzerland is not a member state of the European Union (EU), so European law is not directly applicable. Nevertheless, Article 3(2) of the General Data Protection Regulation (EU) 679/2016 ("GDPR”) specifies that the GDPR applies to entities established outside the EU in the case of data processing that is dependent on: (i) offering goods or services to individuals in the EU or (ii) monitoring the behaviour of individuals in the EU.
The Municipality of Lugano does not direct its activities to the EU, nor does it monitor the behaviour of those in the EU, so the GDPR is inapplicable. Don't despair: Swiss law offers adequate protection for your personal data, as determined by the European Commission on July 26, 2000 (read the adequacy decision here ).
In case of subjection to the GDPR, this document is valid as information pursuant to and for the purposes of Art. 13 and 14. In addition to benefiting from all the protections provided by the GDPR, you can assert your rights as expressed in Articles 15, 16, 17, 18, 19, 20, 21, 22 GDPR, by contacting the Municipality of Lugano. You have the right, at any time, within the limits and under the conditions established by the GDPR, to ask the Municipality of Lugano for access to your personal data, to rectify or erase it, to limit the processing concerning you or to object to its processing, as well as to exercise the right to the portability of such data. If the processing is based on Article 6(1)(a) or Article 9(2)(a) GDPR, you have the right to withdraw your consent at any time. You have the right to lodge a complaint with the competent supervisory authority. In the case of a request for data portability, the Municipality of Lugano shall provide you with the personal data concerning you in a structured format that is commonly used and machine-readable, subject to paragraphs 3 and 4 of Article 20 GDPR.
Without prejudice to any other administrative and judicial remedy, if you believe that the processing of data about you is in breach of the GDPR, you have the right to lodge a complaint with the competent Data Protection Supervisory Authority (Switzerland: IFPD │ UE: list of national authorities).
In no event shall references to the GDPR be construed as voluntarily subjecting you to such legislation, respectively to the supervision and/or decision-making power of any foreign Authority (with respect to Switzerland).

Are you under 18? Read more here

Treatment based on your consent is only lawful if you are at least 16 years old. If you are under 16 years of age, consent must be given or ratified by your parents (or guardian). This is the case, in particular, if you use the MyLugano Card, which can be issued from the age of 14, to obtain discounts on admission to establishments and city events for young people.
While we make reasonable efforts, considering available technology, to verify that parental consent, where required, is present and effective, you have an obligation to state your correct age and to refrain from giving consent without parental involvement.

General information (applies to all services)

Applicable law. In the context of service provision, the municipality carries out an activity of an economic nature that does not derive from a sovereign power. The processing of personal data is therefore governed by the Federal Act on Data Protection (FADP, CC 235.1).
Obligation to consult.The information is variable over time because data processing evolves according to the services offered. As changes are only published online, it is your duty to visit this page each time you use the services so that you are always up to date.
What other rules apply to the services?This is the information on the processing of personal data. The contractual clauses, prices and other conditions applicable to the provision of services can be viewed by clicking here.
What is "personal data"?It is any information concerning an identified or identifiable individual, such as first name, last name, e-mail, telephone number, IP address, personal interests, purchases made, sites visited, location and movement data, etc.
What is "data worthy of special protection"? This refers to particularly sensitive personal data: (i) data concerning religious, philosophical, political or trade union opinions or activities, health, intimate sphere or membership of a race or ethnic group, (ii) genetic data, (iii) biometric data that uniquely identify a natural person, (iv) data concerning administrative and criminal prosecutions and sanctions, (vi) data concerning social welfare measures.
Help us protect you - it's your duty. There are risks associated with using the Internet and email. Protect your devices and manage your passwords properly. Follow security recommendations from experts. Email only information that you would be willing to make public. Remember that you alone are responsible for what you do with your devices, accounts, apps and cards. Given the nature of the Internet as an "open network," we cannot guarantee that your information will not be intercepted or acquired by unauthorized third parties.
Authorization to use e-mail. By providing us with your e-mail address, unless we instruct you otherwise, you authorize us to transmit to you, at your own risk, any documents and information requested, including any personal or confidential information, by non-certified, unencrypted e-mail.
Length of time your personal data is stored. When the purposes for which the data was collected are achieved, we destroy or anonymise your data. Any statutory retention obligations are reserved. You can request detailed information on the personal data retention policy for a specific processing operation from the IT Division of the Municipality of Lugano or by writing to
.
Legal grounds for processing personal data. The processing of personal data is lawful if it is based on the consent of the data subject, on an overriding public or private interest or the law. An overriding private interest exists, in particular, if the processing is necessary for the provision of goods and/or services requested by the user. If required by law, e.g., in the case of analysis, marketing or advertising activities involving user profiling or automated decision-making or the processing of particularly sensitive data, the municipality will submit a request for consent together with the information via electronic channels (online or by e-mail) or analogue channels (regular mail or signed authorisation forms on site).
External service providers handling personal data. It is sometimes necessary to engage external service providers to provide you with the services you require in the best possible way. External service providers only have access to data to the extent that is strictly necessary for the performance of their tasks, subject to strict confidentiality and non-use obligations in relation to personal data. We only use service providers established in Switzerland or in countries that provide adequate protection for personal data. Your personal data is stored in Switzerland.
Without prejudice to the transmissions of data provided for by law, the data may be communicated to recipients belonging to the following categories: (a) subjects that provide services for the management of information and telecommunication systems functional to the provision of the platform (in particular, these are currently the following services: booking platform, e-commerce platform (payment system integration), evaluation and optimization of the user experience, hosting and cloud computing, payment services, e-mail and Newsletter management service); (b) subjects that provide services in the legal, accounting, administrative, tax and audit fields.
The complete and updated list of external suppliers is available for viewing at the Municipal Registry of the Municipality of Lugano. For security reasons, some information may be anonymized or partially masked.

If you use our site, read more here

Showcase on events, exhibitions and promotions. When you visit our site in search of information on events, exhibitions and promotions, the processing of personal data can be summarized as follows:
• Data collected: Data collected: IP address; technical and analytical-statistical cookies (see dedicated section); browser characteristics (name, language, plug-ins installed); pages visited, length of stay, page of origin (e.g. google search, previous site); approximate location based on IP address (generally corresponding to the headquarters of your Internet access provider); unique identifier of the mobile device used.
• Purposes pursued: (i) to allow navigation on the site; (ii) to perform analysis and statistics on the use of the site for the purposes of optimizing the security, usability and quality of services and content, as well as the introduction of new services and content.
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none. Booking and purchase of tickets and services. When you book or purchase tickets or services on the site, you must fill in the online form and make the required payment. The processing of personal data can be summarized as follows:
• Data collected: the data you enter in the online form and during the payment process (currently: first name, last name, billing address, email, phone number and payment method data).
• Purposes pursued: (i) booking, purchasing and paying for tickets or purchases; (ii) calculating the cost of the ticket according to age group; (iii) sending e-mail confirmation of the purchase; (iv) administration, accounting and internal organization.
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none.
• Attention: online payments are managed independently by an external payment service provider; when you access this platform, please read the relevant information on the processing of personal data.
Newsletter subscription. See section dedicated .
Marketing and advertising. See the section dedicated .
Social media plug-in. See the section dedicated .
Pandemic and contact tracing. See the section dedicated .

If you subscribe to our newsletter, read more here

The newsletter is a free and optional service made available to all interested parties. To receive it you must subscribe by providing your e-mail address and specifying the areas of interest. Unsubscribing from such is possible at any time and with immediate effect by activating the dedicated link at the bottom of each e-mail.
The Newsletter does not track or profile you on the basis of the content or links you activate. On the other hand, we carry out statistical analysis in an analytical manner (guaranteeing your anonymity) to assess general interest in the content and events offered.
Your e-mail address will not be passed on to third parties. For technical reasons, we may delegate the management of the Newsletter to an external provider, who must be established in Switzerland or in a country that adequately protects personal data in accordance with the instructions of the Federal Data Protection and Information Commissioner.

If you use our Mobile App, read more here

Introduction. You can use the MyLugano Mobile App free of charge to find out about current events, exhibitions and promotions, to book and/or purchase tickets, goods and services, to digitally manage your MyLugano Card and MyLugano Pass and to accumulate and spend "LVGA points". The App does not geolocate you, does not track your movements, does not monitor you and does not profile you. The App implements cookies (see dedicated section).
Showcase on events, manifestations, shops and promotions. When you use the App in search of information on events, shows and promotions, the processing of personal data can be summarized as follows
• Collected data: IP and MAC address of the mobile device; technical and analytical-statistical cookies (see dedicated section); unique identifier of the mobile device, those you enter in the App form and during the payment process (currently: first name, last name, billing address, email, phone number and payment method data).
• Purposes pursued: (i) to enable the use of the App; (ii) to perform statistical analysis on the use of the site for the purposes of optimizing the security, usability and quality of services and content, as well as the introduction of new services and content
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none.
Booking and purchasing tickets and services. When you book or purchase tickets or services through the App, you have to fill in the online form (which will be pre-filled on the occasion of the following accesses) and make the required payment. The processing of personal data can be summarized as follows:
• Data collected: the data you enter in the App form and during the payment process (currently: first name, last name, billing address, email, phone number and payment method data).
• Purposes pursued: (i) booking, purchasing and paying for tickets or services; (ii) calculating the cost of the ticket according to age group; (iii) sending e-mail confirmation of the purchase; (iv) administration, accounting and internal organization.
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none.
• Please note: online payments are managed independently by an external payment service provider; when you access the payment platform, please read the provider's privacy policy
Wallet for virtualized MyLugano Card or MyLugano Pass. When you virtualize your MyLugano Card or MyLugano Pass through the App, the processing of personal data can be summarized as follows:
• Collected data: those you enter in the virtualization form (currently: card number, expiration date, first name, last name, address, email, phone number).
• Purposes pursued: (i) to virtualize (by PIN sent by regular mail to your address) the MyLugano Card or MyLugano Pass by means of a digital certificate; (ii) to enable you to legitimize yourself with business partners; (iii) to perform the annual renewal of the certificate (by PIN sent by e-mail); (iv) to send the transaction confirmation e-mail; (v) invoicing; (vi) administration, accounting and internal organization.
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none.
LVGA Points. When you accumulate or spend "LVGA Points" via the App, the processing of personal data can be summarized as follows:
• Collected data: Data relating to the crediting and debiting of "LVGA Points"
• Purposes pursued: (i) accounting for available balance "LVGA Points"; (ii) making payments in "LVGA Points".
• Addressees: Municipality of Lugano and its service providers.
• Transfers abroad: none.
Marketing and advertising. See the dedicated section .
Pandemic and contact tracing. See the dedicated section .

If you use MyLugano Card or MyLugano Pass, read more here

MyLugano Card and MyLugano Pass in digital version. The digital management of loyalty cards is done through the App, so proceed to the dedicated section for the relevant information.
MyLugano Card and MyLugano Pass in analogue version (physical card) . If you use the analogue versions of MyLugano Card and MyLugano Pass (cards with "QR Code"), the processing of personal data can be summarized as follows:
• Collected data: the data you enter in the loyalty program registration form (currently: first name, last name, date of birth, address, e-mail); number and expiry date of MyLugano Card or MyLugano Pass; number of accumulated "LVGA Points" (available balance); debits and credits of "LVGA Points".
• Purposes pursued: (i) to virtualize (by PIN sent by regular mail to your address) the MyLugano Card or MyLugano Pass by means of a digital certificate (ii) to enable you to legitimize yourself with business partners and (iii) to perform the annual renewal of the certificate (by PIN sent by e-mail); (iv) to send e-mail confirmation of the transaction; (v) invoicing; (vi) administration, accounting and internal organization.
• Addressees: Municipality of Lugano.
• Transfers abroad: none.
LVGApoints. When you accumulate or spend "LVGA Points" via the App, the processing of personal data can be summarized as follows:
• Data collected: Data relating to the crediting and debiting of "LVGA Points".
• Purposes pursued: (i) accounting available balance "LVGA Points" (ii) execution of payments in "LVGA Points".
• Addressees: Municipality of Lugano.
• Transfers abroad: none.
Marketing and advertising. See the dedicated section
Pandemic and contact tracing. See the dedicated section

We use your personal data for direct marketing purposes: read more here

Yes, but only after obtaining your express consent, unless you have already used our services and there are new similar services or promotions for similar services. In any case, we do not pass on your data to third parties, we do not analyse your online behaviour and we do not cross-reference your data with information from external sources in order to provide you with personalised offers. The processing of personal data can be summarized as follows:
• Data collected: name / surname; telephone number; home address; e-mail; information on products and/or services purchased; sectors of preference indicated when subscribing to the newsletter; cookies.
• Purposes pursued: manual and automated direct marketing by (i) sending information and advertising material, surveys, events and initiatives concerning products and/or services previously purchased or according to the interests communicated by the user; (ii) carrying out analyses and statistics in order to optimize the usability and quality of services and contents, as well as to introduce new services and contents (in particular through the newsletter and cookies; see dedicated sections).
• Methods of communication:SMS, telephone calls with operator, paper mail and e-mail.
• Recipients: Municipality of Lugano; Google as Provider of analytical - statistical cookies limited to the use of the website and the App (see sezione dedicated to cookies); Newsletter Manager, limited to the relative data (see sezione dedicated to the Newsletter).
• Transfers abroad: none; for cookies, see dedicated section

We use "cookies" to provide you with the best possible user experience: read more here

What are cookies? Cookies are text files placed on your system by websites or servers when you browse the web or use Apps. Thanks to cookies, these sites or servers are able to recognise your browser while you are browsing or later when you return. Cookies help to improve your online experience, for example by keeping track of your preferences over time or by preventing you from logging in every time you change pages. Cookies may also be used to monitor and track your online behaviour in order to provide you with tailored advertising.
Types of cookies. There are several types of cookies. When the party that deposits the cookie on your system is the same as the site you visit, the cookie is called a "first party" cookie. Otherwise, it's called a "third-party" cookie. "Session" cookies are automatically deleted when you close your browser, while "persistent" cookies are stored until their expiration date. "Technical" cookies make it possible to browse the web and provide the services requested by the user. "Analytical-statistical" cookies are assimilated to technical cookies when they are used directly by the site to collect information, in aggregate form, on the number of users and how they interact with the site or the App. "Profiling" cookies are third party cookies used to profile you based on your online behaviour in order to provide you with personalised advertisements.
Which cookies does the platform implement? Firstly, the platform implements first-party technical cookies in order to customize the configuration of the platform, keep navigation active, manage electronic transactions, ensure security, and for system administration purposes. Secondly, it implements a third-party analytical-statistical cookie (Google Analytics) in order to analyse the use of the platform by users and the flow of traffic, both to optimise the offer of products and services and to improve the usability of the site and the App. Google's analytical - statistical cookie is managed in "masked" mode, meaning that the last octet of your IP address (v4), respectively the last 80 bits of your IP address (v6), is set to "zero". The masking of your IP address occurs as soon as the data is received by the Analytics collection network, before any storage or processing takes place.
List of active cookies, purpose and duration.. The platform implements the following cookies.
a) First-party cookies:
• Name: prenota_lugano_session
Typology: Technical
Purpose: Creation of the user session
Duration: 120 minutes
Necessity for the purpose of using the Site: YES, generation of the CSRF-TOKEN
• Name: XSRF-TOKEN
Typology: Technical
Purpose: Cross-site request forgery
Duration: 120 minutes
Necessary for the use of the Site: YES, for security reasons (protection from one-click attacks)
• Name: prenota_lugano_cookielaw
Typology: Technical
Purpose: Memorize previous acceptance of cookies, facilitate site usability
Duration: 1 year
Necessity for use of the Site: NO
• Name: prenota_lugano_anagrafica
Typology: Technical
Purposes: Memorisation of personal data, auto-completion of the booking request form, facilitating use of the site
Duration: 1 year
Necessity for use of the Site: NO
• Name: localeInfo
Typology: Technical
Purposes: Cookie for managing country, language, currency
Duration: 1 day
Necessity for use of the Site: YES
• Name: .AspNet.ApplicationCookie
Typology: Technical
Purposes: Cookie technical della piattaforma ASP.Net
Duration: 14 days
Necessity for use of the Site: YES
• Name: .AspNet.TwoFactorRememberBrowser
Typology: Technical
Purposes: ASP.Net platform technical cookie
Duration: 14 days
Necessity for use of the Site: YES
• Name: CookieAlarm
Typology: Technical
Purposes: Technical cookie for the management of the pop-up cookie warning
Duration: 1 day
Necessity for use of the Site: YES
• Name: PopulateCheckoutModelAddresses
Typology: Technical
Purposes: Technical cookie to display the user's address in the shopping cart screen
Duration: 1 day
Necessity for use of the Site: YES
• Name: SL_GWPT_Show_Hide_tmp
Typology: Technical
Purposes: ASP.Net platform technical cookie
Duration: session
Necessity for use of the Site: YES
• Name: SL_wptGlobTipTmp
Typology: Technical
Purposes: ASP.Net platform technical cookie
Duration: session
Necessity for use of the Site: YES
• Name: _RequestVerificationToken
Typology: Technical
Purposes: Cookie to associate the user to the cart
Duration: session
Necessity for use of the Site: YES
• Name: ai
Typology: Technical
Purposes: Cookie to identify the user hooked on the cart
Duration: 3 days
Necessity for use of the Site: YES
• Name: userSessionId
Typology: Technical
Purposes: Cookie to identify the user hooked on the cart
Duration: 1 day
Necessity for use of the Site: YES
b) Third Party:
• Name: Google Analytics (GA)
Typology: analytical - statistical
Purposes: identification of the user on more than one session for analytical - statistical purposes; to trace and analyse the use of the site; to compile reports and share them (in a "masked" form; see above) with other services developed by Google
Duration: 1 anno
Necessity for use of the Site: NO
Please refer to Google's Privacy Policy: link
Possibility of deactivation or cancellation, technical consequences.The platform offers you the possibility, via the cookie management plug-in on the home page of the Site, to freely choose which cookies to authorise and which to refuse. You also have the possibility to refuse consent to unnecessary cookies (in particular, the Google analytical-statistical cookie), while keeping the technical cookies active.
You can also set your browser to inform you of the receipt of cookies or to block cookies (in general or by type of cookie or by site of origin). The general blocking of cookies, since it also applies to technical cookies, can lead to serious limitations in the use of the platform (in particular the site). You have the option of manually deleting cookies from your browser's memory, as well as setting your browser to automatically delete cookies when you close the program (recommended).
By default, browsers generally accept cookies. Instructions for disabling or deleting cookies can be found on the website of your browser's developer:Microsoft Internet Explorer and Edge;Google Chrome; Apple Safari; Mozilla Firefox and Opera.
There are other ways to reduce the risk of online tracking (to be used cumulatively):
• enable the DoNotTrack option in your browser (if available);
• use the "private" or "anonymous" browsing feature of your browser (if available), which prevents cookies from being stored after browsing;
• install privacy plug-ins on your browser, such as uBlock Origin, Privacy Badger or Ghostery;
• Exercise your right to be excluded from specific behavioural advertising schemes (e.g. : DAA Consumer Opt-Out Page; NAI Consumer Opt-Out Page).
Regarding the App, you may exercise your right to refuse one or more cookies through the privacy settings of the App itself. By default, technical cookies and Google's statistical-analytical cookies are activated, as the relevant processing is based on the overriding private interest of the Municipality of Lugano.

Let's integrate some possibilities offered by "social media": read more here

What are social media "plug-ins" and "widgets"? Social plug-ins are small, optional pieces of software that link sites to social media to allow you to easily interact with content you find online (for example, "Like" or "Share" in Facebook). Social plug-ins include so-called "widgets," which are graphical control elements that are placed in corresponding sections of the site to give you access to the social plug-in's functionality. With a simple click on the widget, you are able, for example, to disseminate content within your favourite social media outlet. If you activate the social plug-in, your browser makes a direct connection to the servers of the provider of the social plug-in (e.g., Facebook). For this reason, certain personal information, such as your IP address and the pages you have visited, is transmitted to the provider of the social plug-in. This is the case even if you are not a registered user of social media. If you are a registered user, social media can associate the content you visit with your personal profile. The information published on social media is shown to your contacts or made public (in the case of a public profile).
What precautions have we taken to protect your privacy? Social plug-ins, where exceptionally present, are set in the "two click" procedure. The first click activates the plug-in and creates a link to the relevant social media. With the second click, the actual functionality of the widget is activated (generally, the publication of the content on your social profile).
List of active social media plug-ins, provider, privacy policy. Google Maps Widget (Google Inc.)
The platform implements the following social media plug-ins.
Google Maps is a map display service operated by Google Inc. that allows the site to integrate such content into its pages.
Personal data processed: Cookies and Usage Data.
Please refer to Google's Privacy Policy: link.
How to manage social media plug-ins. If you want to prevent social media from acquiring information about you when you use our platform, you should not click on widgets. In addition, we recommend that you "log out" of social media and delete all browsing data from your browser before visiting the site. Finally, you can prevent the launch of plug-ins with small pieces of software that you install on your browser (recommended solution), such as, for example, NoScript or Ghostery.

We use your personal data as part of our plans to protect against the Covid-19 pandemic: read more here

The rules for combating the pandemic are constantly changing: for an up-to-date view, we refer you to the relevant page of the Canton of Ticino (link) and that of the Federal Office of Public Health (link).
Of course, the processing of data for the purpose of "contact tracing" is limited to cases in which you have participated in public events or had access to facilities of the Municipality of Lugano by reserving a seat or buying a ticket through the site or the App in application of the respective protection plans required by law.
The processing of personal data can be summarized as follows:
• Data collected: first name; last name; e-mail; telephone number; information on services purchased; date of access to the establishment or event.
• Purposes pursued: (i) contact tracing; (ii) notification of infection risk.
• Communication methods: SMS, telephone calls with operator, e-mail.
• Addressees: Municipality of Lugano; Cantonal Medical Office (in case of ascertained risk of contagion).
• Transfers abroad: none.
• Shelf life: 14 days from the date of the event unless a longer period is required by law.

If you leave our digital platform, what happens? read more here

We have no control over the processing of personal data carried out independently by third parties (with respect to the Municipality of Lugano), so we do not carry out any checks, nor do we accept any responsibility in this respect. It is your duty to inform yourself about the processing carried out by these third parties before purchasing goods or services, visiting sites, using applications or devices.
As an example, leave the City's digital platform whenever:
a) you write us an e-mail or you connect to the internet;
b) you visit web pages outside the domain "my.lugano.ch";
c) purchase goods and services from merchants affiliated with the MyLugano Card and MyLugano Pass loyalty program;
d) effect online payments by credit cards and the like;
e) use applications other than the MyLugano App.

What are your rights under data protection law?

Rights Under the conditions established by law, we grant you in particular the following rights (this is not an exhaustive list: inform your local Data Protection Officer):
• obtain the rectification of inaccurate or outdated personal data:
• be informed in writing and free of charge if personal data concerning you are processed;
• revoke the consent to the processing of data that you have previously given;
• prevent the disclosure to third parties of personal data worthy of particular protection;
• express your opinion on an automated individual decision or request that it be reviewed by a natural person;
• The right to obtain the delivery of your personal data or to demand its transmission to third parties;
• request that the processing of the data be blocked, that its communication to third parties be prevented or that the personal data be corrected or destroyed;
• he right to request that a certain processing of personal data be prohibited, that a certain disclosure of personal data to third parties be prohibited, or that personal data be deleted or destroyed;
• if neither the accuracy nor the inaccuracy of the personal data can be demonstrated, request that a remark be added to the data to emphasise its disputed nature;
• request that the rectification, destruction, blocking, in particular the communication to third parties, as well as the mention of the disputed character or the judgment be communicated to third parties or published;
• to establish the illegality of the processing of personal data.
Legitimation and exercise. If you wish to exercise your rights, you must do so in writing by means of a reasoned request to be sent by ordinary mail or electronically, attaching the necessary supporting documents, as well as proof of your identity. It is indeed our duty to rigorously verify that requests for access to data come from the entitled parties and not from unauthorized third parties.
Timing of execution. We will process your request without delay but, in any case, except in exceptional circumstances, within 30 days of receiving it complete with all the information necessary for the judgement.

Are you still in doubt? Write to the municipal data protection officer!

In order to promote transparency and trust with users, we have appointed a Municipal Data Protection Officer, whose role is to advise the Municipality on the applicable data regime, conduct regular audits, respond to requests for information and follow up on the exercise of users' rights.
You can contact the Municipal Data Protection Commissioner by regular mail at the following address: Municipal Data Protection Officer of the City of Lugano, c/o Divisione Affari Giuridici, via della Posta 8, 6900 Lugano. Alternatively, you can send a message by email to the following address: privacy@lugano.ch.
Don't hesitate: we are at your disposal!

Legend

RULES FOR SAFE ACCESS TO PUBLIC SPACES AND EVENTS IN THE CITY OF LUGANO

INTRODUCTION

The present document describes the use of the platform "My Lugano" (hereinafter the "Platform"), consisting of the Web App available at the address my.lugano.ch (hereinafter the "Site") and of the resources linked to it. It also establishes the requirements and rules for safe access to public spaces and events of the City of Lugano, especially during the COVID-19 health crisis.

Paragraphs A and B specify the ownership of the Platform, the coordinates for communications and describe the mechanism of acceptance and review of this document. The conditions for accessing and using the Platform and its functionalities are described in paragraph C. Finally, paragraph D governs the substantive law applicable to the legal relationship between the parties and establishes the competent court in the event of a dispute related to this relationship.

The general conditions of purchase, the requirements for accessing and remaining in public facilities, as well as the updated and complete health protection plans, are published on my.lugano.ch/en/information. These contents are considered to be fully reproduced and integrated here. .

The policy on the processing of personal data and cookies relating to the Platform, with the consequent information to the user, is described in a separate document, accessible at my.lugano.ch/en/information. This document is understood to be reproduced and integrated here in its entirety.

If a contract is concluded with third-party suppliers of goods and/or services as a result of using the Platform, the general and special contractual conditions relating to this legal relationship will apply.

"User" refers to any natural or legal person who uses the Platform. "Supplier" refers to any individual or legal entity that offers products and/or services through or from the Platform.

A. PLATFORM HOLDER AND COMMUNICATIONS

The Platform is owned by the Municipality of Lugano (CH) (hereinafter the "Owner"). All communications must be in writing and will be considered validly and effectively executed upon receipt of the same, if made by ordinary mail, respectively at the time of sending confirmation of reading, if made by e-mail.

All communications must be in writing and will be considered validly and effectively executed upon receipt of the same, if made by ordinary mail, respectively at the time of sending confirmation of reading, if made by e-mail.

Contacts:

• Lugano Town Hall, Municipal Chancellery, Piazza della Riforma 1, 6900 Lugano
• Tel. +41 58 866 68 91 (daily from 08.00 to 19.30)
• e-mail: prenota@lugano.ch

B. ACCEPTANCE AND MODIFICATION OF TERMS AND CONDITIONS

By using the Platform, the User accepts the terms and conditions in force at the time of access. The current version can be viewed by clicking on the appropriate link at the bottom of the Website. It is the responsibility of the User to carefully check the status of the terms and conditions before accessing the Platform, the right being reserved for the Owner to update this document at any time and at their own discretion, particularly in accordance with the evolution of applicable law, functionalities and the services and products made available to the User.

C. CONDITIONS OF USE OF THE PLATFORM

a) Subject matter

The Platform is intended for the booking and purchase of tickets for safe access to public spaces and events of the Municipality of Lugano. The Platform has been conceived to offer the municipal administration a tool to manage, in an efficient and non-discriminatory way, in particular during the health crisis dictated by COVID-19, the safe access to public spaces and events, in order to guarantee, in compliance with the health protection plans, the maximum availability in the interest of the population.

b) Exclusion of liability for third-party suppliers

It should be noted that the City of Lugano only offers the possibility to book and/or purchase online entrance tickets to public spaces and events, therefore any service of a different nature (for example: restaurant services, catering, entertainment, etc.) is understood to be provided by a third-party supplier under a separate contract between the user and said supplier. As these are goods and services provided by third parties under separate agreements, even if they are based on choices made by the user through the Platform, the City of Lugano is not liable for the quality, completeness and timeliness of the contractual service provided to the user by the third-party supplier.

c) Hyperlink policy

The Owner authorises, reserving the right to revoke at any time, hypertext links to the home page of the Website or to social profiles, provided that these links are in no way detrimental to the image of the Platform, the Owner and its bodies, directors and officers.

Hypertext links to the internal pages of the Website, downloading and incorporating, in part or in full, the contents of the Platform into other websites or online and/or offline resources are prohibited and will be prosecuted civilly and criminally, unless a written license is issued by the Owner.

d) Tools and contents of the Platform

Portal for booking and purchasing entrance tickets

The booking and purchase of tickets, as well as the access and stay in public spaces and events, are subject to special conditions and limitations due to the particular period of health crisis. Without claiming to be exhaustive, we draw your attention to the following points:

• the maximum capacity of the facilities, for health reasons, is limited;
• the user must strictly comply with the health protection plan and the rules for accessing and participating in the event, under penalty of immediate exclusion from the event;
• for the binding conditions of access and participation, complete and up to date, as well as specific to each event, please refer to the my.lugano.ch page, which the user acknowledges knowing and accepting by using the Platform.

Intellectual Property on the Platform

The Owner holds full and exclusive intellectual property rights over the individual components of the Platform, its graphics, its databases and its content, as well as over legally protected signs and designations, as well as registered (where indicated) and unregistered trademarks. Any use by third parties that is not supported by a legal or contractual licence for use, in the latter case in writing, is unlawful and liable to prosecution under civil and criminal law.

e) Obligations of the Holder and limitations of liability

Platform Availability

The Owner makes the Platform and related resources available to Users on a purely voluntary basis. The availability of the Platform does not therefore confer any right to the provision of goods or services, nor to the maintenance of the Platform.

The Owner reserves the right to suspend, modify or discontinue, at any time, without prior notice and at its own discretion, the availability of the Platform and its content.

Limitation of liability

Any liability of the Owner is excluded in the event of malfunction or unavailability of the Platform and its connected resources due to external events (for example: internet interruptions, malfunction of the user's devices, cyber-attacks, blackouts, etc.) or as part of ordinary or extraordinary maintenance work. In case of urgency during periods of temporary unavailability of the Platform, the user may contact the Owner by telephone or email.

f) Links to sites, resources and online services external to the Platform

The Platform integrates links to sites, resources and online services external to its own domain, for example to acquire real-time data and display information (e.g., images, news and videos). The Owner has no control over these sites and resources, in particular with regard to security, quality of the information received and data protection, and therefore declines any responsibility for any malfunctioning, unavailability, damage or loss resulting from the use of or reliance on any content, goods and/or services from third party sources or available on sites and resources outside the my.lugano.ch domain.

g) General rules of conduct on the Platform

Users agree to use the Platform (and related resources) in a lawful manner, respecting the rights of the Owner and third parties, as well as in accordance with this document.

In particular, they undertake to:

• communicate complete, up-to-date and truthful data and information, in particular in the online event and congress quotation form;
• not to use the Platform (and related resources) and the information contained therein to carry out unlawful, fraudulent or harmful acts to the rights of third parties;
• not to post or share, directly or indirectly via links, any content that is deceptive, unlawful, harassing, offensive, discriminatory, threatening, harmful, vulgar or otherwise inappropriate;
• not to insert or share, directly or indirectly through links, data, images, videos, or photographs relating to third parties without having obtained their express consent;
• not to include or share, directly or indirectly via links, any content that infringes industrial and intellectual property rights or the rules in force on the protection of personal data;
• refrain from disseminating and distributing Platform content to third parties without the prior written permission of the Owner;
• not interfere or attempt to interfere with the operation of the Platform or hinder the usability of the services by other users;
• to ensure that their computer devices are protected (e.g., by antivirus and firewalls) and free of malicious elements (such as malware, viruses, Trojan horses, etc.);
• communicate personal data through the computer platform only with the prior and express consent of the persons concerned, after having fully informed them about the related personal data processing.

Each User agrees to indemnify and hold harmless the City of Lugano and/or its governing bodies, directors and employees from any damage and/or prejudice and/or loss of earnings, whether economic or moral, resulting from the illicit and/or non-compliant use of the Platform and its related resources.

h) Exclusion of users and/or content from the Platform

The Owner reserves the right, at its sole discretion, to restrict, partially or completely, access and/or use of the Platform and the information and resources linked to it, as well as to delete content without prior notice, particularly when there are indications of potential activities or behaviour that do not comply with this document.

D. APPLICABLE LAW AND JURISDICTION

The legal relationship between the User and the Municipality of Lugano with reference to the access and use of the Platform (and related resources) is governed by Swiss substantive law, subject to cantonal law where applicable, excluding the rules of private international law.

The parties choose the competent Court for the District of Lugano as the exclusive court of jurisdiction in the event of a dispute arising from or simply related to the use of the Platform (and related resources), subject to any mandatory law provisions imposing a different forum. The City of Lugano reserves the right to refer the matter to the competent Court at the registered office, branch or domicile of the User.

Effective date: 17 December 2020

General Terms and Conditions

The present General Terms and Conditions (hereinafter, the "GTC") apply to all products and/or services offered through the platform "My Lugano" managed by the Municipality of Lugano (hereinafter, the "Platform"). By booking and/or purchasing a product or service, in particular admission tickets to facilities and events (hereinafter referred to as "Events"), the User fully accepts the present General Terms and Conditions.

The term digital "cash-back" literally means "cash return" and is used to identify the crediting of a certain amount against a purchase made or a subscription to a paid service. It is a popular way to build customer loyalty globally.

1. By reserving or purchasing one or more tickets for an Event (and any related products and/or services) via the Platform, a contract is concluded, in accordance with these GTCs, between the provider of the Event, respectively the related product and/or service, and the User.

2. Special contractual terms and conditions applicable to individual Events are reserved. These are indicated in the corresponding description sheets and are binding for the user. These terms and conditions are hereby incorporated in their entirety.

3. The identity of the supplier of the product and/or service purchased by the user, as the user's contractual partner in relation to the purchased service, is indicated in the event sheet.

4. Unless otherwise indicated, the City of Lugano only operates the Platform and therefore assumes no responsibility for the proper fulfilment of the contract between the user and the provider of the Event, respectively the related product and/or service.

5. The contract is concluded when the corresponding online transaction is completed. The transaction (including free bookings) is confirmed immediately by email based on the data provided by the user. If you do not receive an order confirmation, please contact customer service on +41 58 866 68 91 (daily from 8 a.m. to 7:30 p.m.).

6. The printed order confirmation or the order confirmation available on the user's electronic device is the only proof of entitlement to the services acquired by the user. The user is solely responsible for keeping the order confirmation. The replacement of lost order confirmations is excluded.

7. The order confirmation contains the main data relating to the transaction. Only the person(s) (in the case of a multiple transaction) whose name appears on the order confirmation shall have access to the Event. The right of access is not transferable. For each order, the user receives only one access right (even if it relates to several people), so all persons concerned must have access at the same time.

8. If the user conducts a transaction for several persons, the user shall notify these persons without delay of the terms and conditions for participating in the event. The user assumes full responsibility under Article 111 of the Swiss Code of Obligations (hereinafter, "CO") for the contractual and applicable lawful conduct of these persons.

9. The user agrees to communicate complete, updated and correct data during the online reservation process, under penalty of invalidation of the transaction and exclusion, at any time, from the event. Refunds and any form of compensation are excluded.

10. Reproduction, disclosure and/or transfer of the order confirmations (or rights related to them) is excluded. The Event Manager may deny access to the facilities if he discovers the presence of prints, reproductions, copies or imitations of order confirmations. However, the operator is not obligated to verify that the person who comes to the facilities with the order confirmation is the actual owner, respectively to check the authenticity of the document shown.

11. In the event of non-access to the facilities of the Municipality of Lugano, for any cause or reason whatsoever, including non-access within the established timeframe, entitlement to benefits will automatically lapse. The right to any substitute service and/or reimbursement is excluded.

12. Prices are indicated in CHF on the online purchase and payment portal. The prices are inclusive of VAT and net of commissions applied for the use of credit cards for payment, which are charged to the Municipality of Lugano.

13. Tickets are strictly personal and are not transferable, refundable, exchangeable or substitutable. In case of postponement of the event, the user will be entitled only to a replacement ticket for the new date. In case of permanent cancellation, only the refund of the cost of the ticket.

14. By completing the transaction via the Platform you acknowledge that you are aware of and accept the provisions related to the Events with respect to security, COVID-19 protection plan, access and any other provisions in force, and you acknowledge that in the event of a breach of these provisions you forfeit any right to stay and/or access the Event without any right to be refunded or compensated.

15. In the case of a multiple order receipt, i.e., involving several persons, the holder of the order receipt must be able to trace and contact all persons involved in the collective transaction in a timely manner (by telephone or e-mail).

16. Each participant must be able to identify himself/herself by means of a valid identification document at any time, under penalty of exclusion from the event.

17. The Municipality of Lugano and/or the supplier of the products and/or services purchased by the user through the Platform are not liable for any interruption, suspension, cancellation, modification, delay (and similar) which may be attributed to events and behaviour outside of their sphere of control or influence or attributable to auxiliaries. Liability shall in any case be limited, within the limits permitted by mandatory law, to direct damage and to intent or gross negligence. Liability for slight negligence and for indirect or consequential damage is expressly excluded. Consequential damages include loss of earnings, damage to reputation and loss of data caused by a temporary limitation or interruption of the availability of services, as well as those caused by interruptions in distribution channels, transmission errors, unsuccessful delivery of reservations or purchases, errors in the indication of prices or services offered and errors in booking confirmations.

18. The risks arising from the unauthorised use and/or loss of the order confirmation relating to Events purchased or reserved via the Platform are the sole responsibility of the holder of the confirmation.

19. The Municipality of Lugano declines all responsibility in case of loss, anomalies or technical failures which make it impossible to use the services offered through the Platform, without any right to compensation or reimbursement on the part of the user.

20. In any case, within the limits allowed by mandatory law, the responsibility for any title or circumstance of the City of Lugano and/or the supplier of the products and services purchased or reserved by the User through the Platform will be forfeited with the reimbursement or replacement of the service purchased.

21. The Municipality of Lugano reserves the right to modify the present GTC at any time. The modifications will be made accessible directly on the platform and will come into force at the moment of their online publication.

22. The legal relationship between the user and the Municipality of Lugano with reference to the access and use of the Platform (and of the related resources), as well as the legal relationship with the supplier of the products and services (if it is a third party compared to the Municipality of Lugano) provided to the user, is regulated by the Swiss substantive law, subject to the cantonal law where applicable, excluding the rules of private international law.

23. The parties choose the competent court for the District of Lugano as the exclusive court of jurisdiction in the event of a dispute arising from or simply related to the use of the Platform (and related resources), respectively the use of the Events, subject to any mandatory rules of law imposing a different jurisdiction. The right to take legal action before the competent court at the registered office, branch or domicile of the User is reserved.

General Terms and Conditions and Data Protection Policy and Cookies
Introduction

The present document sets out the contractual conditions for joining the loyalty circuit called "MyLugano", consisting of the MyLugano App and the homonymous physical cards (hereinafter, the "Circuit"), provided by the Municipality of Lugano (hereinafter, the "Municipality"). Through the Circuit, users can benefit from privileges and advantages depending on current promotions (in particular in the form of digital "cash back") when purchasing goods and services at a local level (see section "GENERAL CONTRACTUAL CONDITIONS").

The term digital "cash-back" literally means "cash return" and is used to identify the crediting of a certain amount against a purchase made or a subscription to a paid service. It is a popular way to build customer loyalty globally.

The Circuit is part of the plan for the progressive digitalization of user services and relations with citizens, the promotion of digital literacy, and the containment of the risk of Covid-19 infection through the elimination, where possible and in compliance with the principle of non-discrimination of users without access to technology, of physically obsolete instruments.

The conditions for joining the Circuit for commercial users, i.e., suppliers of local goods and services, are specified in a separate contract. To obtain information on this, please write to the following e-mail address my@lugano.ch or call the following number +41 (0)58 866 48 00.

Finally, this document includes the policy regarding the protection of personal data and the management of cookies within the Circuit (see section "PROTECTION OF PERSONAL DATA AND COOKIES").

GENERAL TERMS AND CONDITIONS
Acceptance and modification of these general conditions

By joining the MyLugano Loyalty Scheme, the user agrees to be bound by the terms and conditions set out in this document in the version in force at the time of each use. It is the user's responsibility to carefully check the status of the applicable terms and conditions before using the platform, being reserved the right of the Municipality to modify such terms and conditions at any time and with immediate effect by publishing the updated documentation online.

Loyalty Circuit Manager; Contacts

The Loyalty Circuit is managed by the City of Lugano (CH).
All communications must be in writing and will be considered validly and effectively executed upon receipt of the same, if made by ordinary mail, respectively at the time of sending confirmation of reading, if made by e-mail.

Contacts:

• Lugano City Hall, Events Division, Sportello Foce, via Foce 1, 6900 Lugano
• T. +41 (0)58 866 48 00
• e-mail: my@lugano.ch

Circuit components, costs and membership conditions

The MyLugano fidelity circuit is structured in two types of programs depending on the users concerned: MyLugano Card and MyLuganoPass. Both programs can be used either in a completely digital (App) or analogue form (physical card).

I. The MyLugano Card program

MyLugano Card is addressed to citizens living in the Municipality of Lugano from 14 years of age. To join, it is necessary to be regularly registered with the Municipal Population Control and to have deposited in the database of the Population Control a copy of an identity document (passport or identity card).

The program is also aimed at employees of the City of Lugano. Upon specific request and if decided by the Municipality, the program may be extended to the employees of bodies and companies linked to the City itself, as well as to entities outside the City, for example in the field of education, and to private businesses in the Lugano area. In this case, a specific agreement between the City of Lugano and the body or company regulates the collection and access to the data necessary for the identification of users (address and a copy of a legitimacy document - passport, identity card or driving licence for Swiss citizens or a legitimacy document with a photograph valid for foreign travel for foreign citizens) by the City and the Self-Regulation Organism to which the City is affiliated.

The MyLugano Card allows holders to obtain a discount in the form of "cashback" for each purchase made within the Circuit. Unless otherwise specified within a specific promotion, the amount of the digital "cashback" corresponds to 10% (ten percent) of the value of the transaction made. It is recognized in the form of loyalty points ("LVGA points") which can be spent within the entire Network. The digital cash back is converted into LVGA points at a fixed ratio of 1 LVGA point = CHF 0.01.

If the goods are returned, the user must return the digital "cashback" without delay to the merchant who issued it according to the instructions given by the same.

LVGA points can be purchased by users through the MyLugano App in packages of 2000, 5000 and 10'000 points. The Municipality of Lugano may (without being obliged) grant discounts or free points.

Conditions and costs for the digital MyLugano Card:
• 1 year - CHF 4.- but with the allocation of the same amount as initial assets in the form of "LVGA points" (400 points)
• - 5 years - CHF 10, but with the allocation of the same amount as initial assets in the form of "LVGA points" (1000 points)
Conditions and costs for the analogue MyLugano Card:
• 1 year - CHF 5.
• 5 years - CHF 11.

II. The MyLuganoPass programme

MyLuganoPass is open to all citizens from 14 years of age who are not domiciled in the Municipality of Lugano, including tourists, students and people passing through.

The possession of the MyLuganoPass allows holders to access discounts and benefits defined by the individual commercial activities. Within the framework of the MyLuganoPass, "cash-back" and "LVGA points" are not granted.

Conditions and costs MyLuganoPass Digital:
• 1 year - CHF 6.-
• 5 years - CHF 12.-
Conditions and costs analogue MyLuganoPass:
• 1 year - CHF 7.-
• 5 years - CHF 13.-

III. Vouchers

The Municipality of Lugano can issue (without being obliged to do so - except for recognizing a "cash-back" to MyLugano Card analogue users) nominative vouchers in the name of the user containing predetermined packages of points that the user can load on the MyLugano App at Studio Foce or info point (Puntocittà - Centro, Pambio-Noranco and Pregassona) or that can be spent directly within the MyLugano Circuit.
Replacement and reimbursement of the nominative vouchers is excluded, particularly in the event of loss, theft, damage, tampering and/or incorrect use of the nominative vouchers. The vouchers must be stored carefully and protected from outside influences that could damage them.
For the use of the same at a partner of the circuit, the user must provide legitimacy (through an identity document) to prove the legitimacy of use (proof of being the holder and the direct beneficiary).

IV. Common limitations and restrictions inherent in LVGA points

The accumulation of LVGA points is subject to an annual (calendar year) cap of 100,000 points. The Circuit also has a monthly cap on incoming and outgoing movements (cumulatively) of 500,000 points. Once one of these thresholds is reached, the user is excluded from the digital cashback program and does not receive any new points for further purchases.

For underage users, the consent of the legal representative to the activation of the service is reserved. This consent is considered implicit, it is therefore the responsibility of the minor to have obtained it.

LVGA points cannot be transferred between private users and are linked to the individual account of the MyLugano Card and MyLugano Pass holder.

LVGA points can be used as a means of payment for 2 years from the date of issue. If they are not used within the prescribed period, the points are automatically forfeited and deleted from the App.

Please note: LVGA points received or purchased do not give any right to conversion and/or redemption in Swiss legal tender or any other currency by the issuer or third parties. LVGA points do not confer any right, except to be used as a means of payment towards suppliers of goods and/or services that decide to join the MyLugano Circuit in relation to goods and/or services determined by the individual supplier and limited to the period of membership of the supplier. If the MyLugano network is closed, LVGA points will automatically expire without the right to conversion and/or refund.

General rules of conduct and responsibility
Responsibility and safety

The User undertakes to diligently protect and keep confidential all security elements relating to their programs (App, wallet and similar) and mobile devices used to operate within the framework of the Loyalty Circuit (in particular, username, password and temporary codes, correspondence with the Municipality).

Passwords must meet the following security requirements: minimum 8 characters, maximum 32 characters, at least one capital letter. It is the user's responsibility, for security purposes, to change the access passwords himself on a regular basis (recommended frequency: every three months). The application also provides the possibility of activating biometric recognition (face or fingerprint identification - depending on the device used - combined with a 4-digit pin code). By activating this option, the user is aware of the risks involved in using this simplified method.

The user acknowledges and accepts that, towards the Municipality and any third party, any activity carried out using his credentials will be attributable to the user himself. The user fully assumes all contractual obligations, as well as expenses or damages that may arise from the misuse of such data (including the theft of "LVGA points" by unauthorized users), holding harmless the City from any liability and / or prejudice.

The municipality is expressly released from any liability and/or general obligation to monitor the activities of users. For the sake of clarity, this exemption does not mean that the obligations to monitor transactions for the purposes of the Money Laundering Act (MLA) have been waived.

The Municipality takes all reasonable and appropriate measures according to the circumstances and technological evolution to guarantee the integrity, availability and confidentiality of the information accessed or received by the users. On the other hand, communication between the user and the Municipality via the Internet (as an open public network) is under the sole responsibility of the user, who declares himself to be fully aware of the risks involved in such transmission. The Municipality does not assume any responsibility for any violation, direct or indirect, inherent to the confidentiality and/or integrity of the information that takes place outside of its computer network.

The user also acknowledges that the Municipality does not guarantee the continuous and uninterrupted availability of the Circuit, nor the presence of a minimum number of suppliers of goods and/or services. Access may be suspended at any time and without prior notice, in particular but not exclusively due to technical failures, maintenance operations (ordinary and/or extraordinary) or in cases of force majeure (e.g., blackouts, strikes, natural disasters, etc.). In this regard, the user renounces in advance and unconditionally any and all claims based on the lack or deficiency of availability of the loyalty circuit, in particular for compensation.

Exemption from liability for goods and/or services provided by suppliers of goods and services participating in the Affiliate Circuit

It should be noted that the City of Lugano merely offers the user the opportunity to accumulate loyalty points that can be spent within a network of independent merchants. As these are goods and services provided by third parties according to separate agreements, the City of Lugano is not liable for the quality, completeness and promptness of the contractual service provided to the user by the third-party supplier.

General waiver of liability in favour of the Municipality of Lugano

Neither the City of Lugano nor any other member of the Circuit shall be liable for any injury, loss of income, direct or indirect, consequential, punitive or incidental damages, including loss and/or theft of tokens/LVGA points, loss of data, damage to reputation, person or property related to or arising from the digital services connected to the LVGA Circuit.

The City of Lugano provides the digital services linked to the LVGA Circuit as is and without warranty. The City does not warrant or represent that the services (including the App and the digital wallet contained therein) are accurate, reliable, uninterrupted or error-free, that defects will be corrected or that the digital services are free of viruses or other harmful components. You assume full responsibility for your use of the services.

The City and all other members of the Circuit assume no liability for any loss or damage (including loss and/or theft of tokens/LVGA points) arising from or related to the Third-Party Services.

Events beyond the sphere of control. The Municipality of Lugano and the other members of the Circuit accept no responsibility for any event beyond the reasonable control of the Municipality of Lugano.

General rules of conduct

The user undertakes to use the Loyalty Merchant Network (and its associated resources: email, telephone, web pages, social profiles, etc.) correctly and with respect for the rights of third parties.

In particular, the user undertakes to:

• hold and use LVGA points in their own name and on their own account;
• not transmit content that is unlawful, harassing, offensive, discriminatory, threatening, harmful, vulgar or otherwise inappropriate;
• not use the Loyalty Circuit (and related resources) and the information contained therein to engage in any unlawful, fraudulent or infringing acts, including copyright and personality rights;
• communicate personal data only with the prior and informed consent of the persons concerned;
• communicate updated and truthful data and information;
• ensure that the computer devices used are protected (e.g., by antivirus software and firewalls) and free of malicious elements (such as malware, viruses, Trojan horses, etc.);
• not interfere or attempt to interfere with the activity of the Loyalty Circuit or hinder the usability of the services by users.

Payment methods and security through the App

Online payments in connection with the provision of services (in particular the purchase of LVGA points by holders of the digital wallet) are made via third-party e-payment platforms. Payment can be made using PostFinance, TWINT and credit cards (MasterCard and Visa), but the payment methods can be changed at any time. The Municipality assumes no liability in this regard, as this is a separate platform operated by a third party. The conditions of use and data protection policy can be viewed on the website of the service provider.

Creating, modifying or deleting a service

The Municipality of Lugano reserves the right to activate, modify, suspend or cancel services and functions of the Loyalty Circuit at any time and without prior notice.

Account deletion by the user

You may cancel your account at any time. This will result in the immediate blocking of access to the Loyalty Circuit and the permanent loss of all accumulated LVGA points. The cancellation does not prevent the user from registering again.

Suspension or deactivation of the account by the Municipality

The City shall provide for the suspension or deactivation of an account, specifically, in the following instances:
a) Breach of rules of conduct and safety;
b) Breach of these general conditions;
c) Violation of applicable Swiss or foreign regulations;
d) At the written request of the authorities.
The City reserves the right to suspend the account for purely precautionary purposes in the presence of simple reports and / or indications of violations throughout the verification process of the same.
In cases where the suspension or lockout relates to schedulable time events, the City shall provide advance notice to the user specifying the cause and date of account suspension or revocation.
In case of suspension or deactivation of the account, the Municipality does not assume any responsibility, with consequent waiver by the user of any claim for any reason or circumstance.

DATA PROTECTION AND COOKIES
Reference regulatory framework

In the context of the management of the Loyalty Circuit, the Municipality of Lugano, as a public body under Swiss law, carries out an activity of an economic nature that does not derive from a sovereign power. In view of this, the processing of users' personal data is in principle governed by the Federal Data Protection Act (DPA, RS 235.1).

General reference to the Municipality's policies in relation to the MyLugano platform

As regards the processing of personal data (including cookies) carried out by the Municipality of Lugano within the web platform, consisting of the Web APP available at the address my.lugano.ch (hereinafter referred to as the "Website") and the Mobile APP "MyLugano" (hereinafter referred to as the "App"), which is available free of charge and without registration at online stores, please refer to the general document entitled "Privacy Policy and Cookie Policy - Information on the processing of personal data" published at the bottom of each page of the Website (my.lugano.ch). With specific regard to the "MyLugano" App, before installation, the user will be presented for approval with a special information notice on the processing of personal data, the text of which is accessible at the link my.lugano.ch, which is understood to be reproduced and integrated herein in its entirety.

With specific regard to the "MyLugano" App, before installation, the user will be presented for approval with a special information notice on the processing of personal data, the text of which is accessible at the link my.lugano.ch, which is understood to be reproduced and integrated herein in its entirety.

Additional information in the context of the MyLugano analogue loyalty circuit

Given that the processing of personal data within the framework of the digital MyLugano Card and the digital MyLuganoPass is carried out through the "MyLugano" App, for which in this context we have referred to the information concerning the App (see previous paragraph), the processing of personal data carried out within the framework of the analogue versions of the MyLugano Card and the MyLuganoPass requires additional information, it being understood that for the rest we refer to the general policy concerning the "MyLugano" website.

Common provisions within the framework of the analogue MyLugano loyalty circuit
Owner of the treatment and communications

Municipality of Lugano (CH), Events Division, Sportello Foce, via Foce 1, 6900 Lugano; Tel +41 (0)58 866 48 00 (Mon - Fri: 08:00 - 12:00 / 13:00 - 17:00); email: my@lugano.ch

Status of information on the processing of personal data

The user must carefully check the status of the legal notices (including this document with references) before availing himself of the prerogatives offered by the analogue loyalty scheme, as they may be subject to change at any time and the user may renounce the use of the scheme if he does not subscribe.

Municipal Data Protection Officer

Any communication relating to the protection of personal data may be sent to the Municipal Data Protection Commissioner at the following address: Data Protection Officer of the City of Lugano c/o Divisione Affari Giuridici, via della Posta 8, 6900 Lugano. Any communication relating to the protection of personal data may also be sent to the following e-mail address: privacy@lugano.ch.

Main purposes of personal data processing

The data is processed to the extent strictly necessary to ensure the management and operation of the analogue loyalty scheme, to activate your account, to identify you (for the purposes of combating money laundering where required by applicable law), to provide the services you have requested (in particular, to account for and accumulate LVGA points), and to communicate with you in order to support you in the proper use of the benefits offered by the loyalty scheme.

Aggregated or anonymized forms of user data processing are reserved for statistical purposes, for the evaluation of the quality of services and for the optimization of technical functionalities and the usability of systems, based on the preponderant private interest of the Municipality of Lugano.

Treatment based on law, in particular in the administrative, fiscal and accounting fields, is also reserved.

At the user's request (and until consent is revoked, exercisable through the link at the bottom of each communication), the same can subscribe to the MyLugano newsletter with the promotions offered to users and/or to the general newsletter on events organized by the Events and Congresses Division of the Municipality of Lugano. The Newsletter does not pursue the purpose of tracking or analysis of user behavior. It does not detect the opening or not of the e-mail and/or the activation of the links contained within it.

User Consent

By adhering to the MyLugano loyalty scheme, the user authorises (where necessary) the processing of personal data by the Municipality of Lugano in accordance with applicable law and according to the purposes and methods indicated or presupposed by the present document (including references). Where required by law, the Municipality will request express consent from the user via electronic channels (online or by e-mail).

Conservation policy

The Municipality of Lugano will keep personal data for as long as it is necessary to keep them in consideration of the purpose for which the data were collected, or insofar as there is a legal obligation to keep them or another justifying reason recognised by law. Once the retention period has expired, the Municipality will proceed with the definitive and secure deletion of the data or, alternatively, with their anonymisation.

Detailed information on the personal data retention policy within a specific processing operation can be requested from the Information Technology Division by means of a written request sent to privacy@lugano.ch.

Own processing activities; location of data

The Municipality of Lugano is responsible for the provision and management of the MyLugano loyalty circuit in the context of the analogue versions of the MyLugano Card and MyLuganoPass, as well as the issuing of nominative vouchers.

All personal data is physically located in Switzerland and is not transferred abroad.

Monitoring and user profiling activities

The Municipality of Lugano does not carry out any activity to monitor user behaviour or user profiling, nor does it carry out any personal data processing activities that go beyond what is strictly required by the provision of the User Loyalty Circuit and by the anti-money laundering regulations in force.

Disclosure of data to third parties; automated decisions

Under no circumstances will personal data be disclosed to third parties, subject to legal obligations. The disclosure of data based on the Anti-Money Laundering Act (AMLA) and/or on the application rules of the relevant self-regulatory body is excluded.

The Circuit does not incorporate automated decision-making systems that could materially affect the factual or legal position of the user.

Exemption from liability for data processing carried out by third parties (including suppliers of goods and services)

The Municipality of Lugano has no control over, and assumes no responsibility for, any processing of personal data carried out by suppliers of goods and/or services who participate as merchants in the Loyalty Circuit in relation to individual transactions concluded by the user.

It is recommended that the user ask the supplier for a copy of the information on the processing of personal data before purchasing goods and/or services.

Specific provisions within the individual programmes of the MyLugano analogue loyalty circuit

MyLugano Card analogue programme (card)

Personal data collected: name, surname, date of birth, address, e-mail address
Retention period: until membership ends or expires without renewal of the card (whichever comes first), subject to statutory retention obligations (in principle: 10 years)

MyLuganoPass analogue programme (card)

Personal data collected: name, surname, date of birth, address (abroad), e-mail
Retention period: until membership ends or the pass expires (whichever is sooner), subject to statutory retention obligations (in principle: 10 years)

Applicable law - User rights

In the context of economic activities that do not derive from a sovereign power, for example in the case of the provision of goods and/or services in competition with the private sector, the processing of personal data is governed by the Federal Data Protection Act (FADP). The user's rights are specified in Articles 5, 8, 12, 15, 34 and 35 of the FADP which reference should be made.

The user has the right to be informed of all circumstances relating to the processing of his or her data, to revoke consent given, and to have inaccurate or outdated data corrected.

The user who intends to exercise his/her rights must do so in writing by means of a motivated request by ordinary mail or e-mail, attaching the necessary supporting documents, as well as proof of his/her identity. The Municipality will follow up on the request without delay but, in any case, except in exceptional circumstances, within 30 days of receiving it complete with all the necessary elements for judgement.