We are subject to Swiss data protection law and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, disclosing, organizing, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) includes the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (Data Protection Act, DPA) and the Data Protection Ordinance (Data Protection Ordinance, DPA).
We process – if and insofar as the General Data Protection Regulation (DSGVO) is applicable – personal data in accordance with at least one of the following legal bases:.
- Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner, as well as to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
- Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA)
- Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 para 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 para 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3. Type, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. In particular, such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or edge data and usage data, location data, sales data, and contract and payment data.
We process personal data for the period that is required for the relevant purpose(s) or by law. Personal data whose processing is no longer necessary will be anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are in particular specialized providers whose services we use. We also ensure data protection with such third parties.
We process personal data basically only with the consent of the persons concerned. If and to the extent that the processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject provides to us voluntarily when contacting us – for example, by mail, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obligated to ensure data protection with respect to these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
4. Personal data abroad
We process personal data basically in Switzerland and the European Economic Area (EEA). However, we may also export or transfer Personal Data to other countries, in particular to process it or have it processed there.
We may export Personal Data to all states and territories on Earth and elsewhere in the universe, provided that the law there is in compliance with decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to decision of the European Commission.
We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.
5. Rights of data subjects
5.1 Data protection rights
We grant data subjects all claims in accordance with applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we process personal data about them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects may correct inaccurate personal data, complete incomplete data and have the processing of their data restricted.
- Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data surrender and data transfer: Data subjects can request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.
We may provide for costs for the exercise of rights exceptionally. We inform data subjects in advance of any costs.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
5.2 Right to complain
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have the right – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European data protection supervisory authority.
6. Data Security
We take appropriate technical and organizational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Access to our website is made by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communication is subject – as basically any digital communication – to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.
7. Use of the Website
Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies enable us to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
In the case of cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA) possible.
7.2 Server logfiles
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliable, as well as to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those provided by third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.
8. Notifications and communications
We send notifications and communications via email and other communication channels, such as instant messaging or SMS.
8.1 Success and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which web links were clicked on in the process. Such web links and tracking pixels may also capture usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
8.2 Consent and objection
You must basically expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure whenever possible, which means that you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
You can basically object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for performance and reach measurement. This is subject to necessary notifications and communications in connection with our activities and operations.
8.3 Service providers for notifications and communications
We send notifications and communications using specialized service providers.
In particular, we use:
9. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
For our Social Media presence on Facebook including the so-called Page Insights, we are – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.
Further information about the nature, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook’s data protection officer can be found in the Data protection statement of Facebook. We have concluded the so-called “Addendum for Responsible Parties” with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the “Page Insights Information” page, including “Page Insights Data Information”.
10. Third Party Services
We use services of specialized third parties to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed features and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
In particular, we use:
10.1 Digital Infrastructure
We use services from specialized third parties to access needed digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
10.2 Contact options
We use services from selected providers to better communicate with third parties such as potential as well as existing customers.
10.3 Social media features and social media content
We use third-party services and plugins to embed features and content from social media platforms as well as to enable the sharing of content on social media platforms and other ways.
In particular, we use:
We use third-party services to embed maps on our website.
In particular, we use:
- Google Maps including Google Maps Platform: mapping service; provider: Google; Google Maps-specific disclosures: “How Google Uses Location Information”.
10.5 Digital audio and video content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
In particular, we use:
- YouTube: video platform; provider: Google; YouTube-specific details: “Privacy and Security Center”, “My Data on YouTube”.
We engage in e-commerce and use third party services to successfully provide services, content or goods.
We use specialized service providers to process payments from our customers securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, apply additionally to the processing of payments.
We use the option to display targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular people who are already interested in our activities and operations or could be interested in them (Remarketing and Targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We may also determine whether our advertising is successful, that is, in particular, whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are logged in as a user may, if necessary, assign the use of our website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific details: Advertising based on search queries, among other things, using various domain names – specifically doubleclick.net, googleadservices.com, and googlesyndication.com – for Google Ads, “Advertising” (Google), “Why am I seeing a particular ad?”.
11. Extensions for the website
We use extensions for our website in order to take advantage of additional features.
In particular, we use:
We try to determine how our online offer is used. As part of this, we may, for example, measure the success and reach of our activities and operations, as well as the impact of third-party links to our website. But we can also, for example, try out and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for success and reach measurement. In this case, IP addresses are basically shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.
Cookies may be used and user profiles may be created when measuring success and reach. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively pseudonymously and are not used to identify individual users. Individual services of third parties to which users are logged in can, if necessary, assign the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, “Privacy”, “Browser Add-on to disable Google Analytics”.
- Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google as well as from third parties; provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager”; further information on data protection can be found with the individual integrated and managed services.
13 Cookie Banner
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/.
Legal bases for the processing of personal data in this context are Art. 6 para. 1 lit. c DS-GVO and Art. 6 para. 1 lit. f DS-GVO. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of the personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
14. Final provisions