We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.
1. contact addresses
Responsibility for the processing of personal data:
In individual cases, there may be other controllers for the processing of personal data or joint controllership with at least one other controller
2. terms and legal basis
Personal data means 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 retrieving, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organising, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises 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 the processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and 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 GDPR for the necessary processing of personal data to fulfil 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 GDPR 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 GDPR for the processing of personal data with the consent of the data subject
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or of another natural person
3. nature, scope and purpose
We process the personal data that is necessary to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymised 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, specialised providers whose services we use. We also guarantee data protection for such third parties.
We only process personal data in principle with the consent of the data subjects. If and to the extent that 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 fulfil a contract, to comply with legal obligations or to protect overriding interests.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
We process personal data in order to be able to communicate with third parties. In this context, we process in particular data that a data subject transmits when contacting us, for example by post or email. We may store such data in an address book or using comparable tools.
Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. To this end, the accuracy of the personal data transmitted must be ensured, among other things.
5. data security
We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the personal data processed, without being able to guarantee absolute data security.
Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.
Our digital communication - like in principle all digital communication - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot exert any direct influence on the corresponding processing of personal data by secret services, police forces and other security authorities. We also cannot rule out the possibility that individual data subjects may be subject to targeted surveillance.
6. Personal data abroad
We process personal data in principle 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 as well as elsewhere in the universe, provided that the law there is in accordance with decision of the Swiss Federal Council provides adequate data protection and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - in accordance with decision of the European Commission ensures adequate data protection.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment 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.
7. Rights of data subjects
7.1 Data protection rights
We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:
- 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 required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also 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, among other things.
- Correction and restriction:
- Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Erasure and objection: Data subjects can have their personal data erased ("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 controller.
We may defer, restrict or refuse the exercise of data subjects' rights to the extent permitted by law. We may 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. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.
We may exceptionally provide for costs for the exercise of rights. We will inform data subjects of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
7.2 Legal protection
Data subjects have the right to enforce their data protection claims through legal action or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for complaints by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities for complaints from data subjects - if and insofar as the General Data Protection Regulation (GDPR) is applicable - are organised as members of the European Data Protection Board (EDPB). In some Member States in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, especially in Germany.
8. 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 make it possible to recognise 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.
We may log at least the following information for each access to our website and our other online presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, 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, last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The information is required to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.
8.3 Tracking pixels
9. Notifications and messages
We send notifications and messages by email and via other communication channels such as instant messaging or SMS.
9.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
9.2 Consent and objection
You must generally consent to the use of your email address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log consents obtained, including IP address and timestamp for evidence and security reasons.
You can in principle object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
10. third party services
We use the services of specialised third parties to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. We can use such services to embed functions and content in our website, among other things. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
10.1 Digital infrastructure
We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
10.2 Audio and video conferences
We recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences, depending on the life situation.
We use in particular:
10.3 Online collaboration
We use in particular:
- Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; Provider: Microsoft; Teams-specific information: "Privacy and Microsoft Teams".
11. final provisions