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 recognises that Swiss data protection law ensures adequate data protection.
1 Contact addresses
Responsibility for the processing of personal data:
Data protection representation in the European Economic Area (EEA)
We have the following data protection representative in accordance with Art. 27 DSGVO:
The Data Protection Representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries related to the GDPR.
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 retrieving, matching, adapting, archiving, storing, reading, disclosing, procuring, 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.
3 Nature, scope and purpose
We process those personal data that are necessary to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular 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 period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit 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.
As a matter of principle, we only process personal data with the consent of the persons concerned. If and insofar as the processing is permitted for other legal reasons, we may waive the requirement to obtain 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.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example, by letter, 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 or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection with regard to these persons and to ensure the accuracy of this personal data.
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.
4 Personal data abroad
We process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order 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 local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – adequate data protection in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does not ensure 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 appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements 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 a copy of any guarantees on request.
5 Rights of data subjects
5.1 Data protection rights
We grant data subjects all rights under 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 rights under data protection law and to ensure transparency. This includes the personal data processed 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 can have incorrect personal data corrected, incomplete data completed and 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 release and data transfer: Data subjects may 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 the rights of data subjects to the extent permitted by law. We can draw the attention of data subjects to 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 exceptionally provide for costs for the exercise of rights. We inform data subjects in advance of any costs.
We are obliged to take appropriate 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 rights 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 suitable technical and organisational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject – as is basically all 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 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. Cookies make it possible in particular 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.
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 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).
7.2 Server log files
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, 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 in a permanent, user-friendly and reliable manner and 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 known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Pixel counters can be used to collect the same information as server log files.
8 Notifications and Messages
We send notifications and messages via email and other communication channels such as instant messaging or SMS.
8.1 Performance and reach measurement
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 may also record the use of notifications and messages 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
In principle, you must 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 where possible, i.e. you receive an e-mail with a web link which you must click to confirm so that no misuse by unauthorised third parties can take place. We may log such consents including IP address, date and time for evidence and security reasons.
In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is without prejudice 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 specialist service providers.
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 Switzerland and the European Economic Area (EEA).
10 Third party services
We use services from specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. In the case of such embedding, the services used record the 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, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
10.1 Digital infrastructure
We use services from specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
10.2 Audio- und Video-Konferenzen
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background superimposed.
In particular, we use:
10.4 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.
In particular, we use:
We use third party services to enable us to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents. We can thus enable not only viewing, but also editing or commenting on such documents.
In particular, we use:
We use the possibility of displaying targeted advertising 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 who might 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 can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our website to your profile there.
In particular, we use:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific claims: Advertising based, inter alia, on search queries, using various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, «Advertising» (Google), «Why do I see a certain advertisement?».
11. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use:
- Google reCAPTCHA: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); Provider: Google; Google reCAPTCHA-specific information: «What is reCAPTCHA?».
12. Success and reach measurement
We try to determine how our online offer is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect 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 offer 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 offer.
In most cases, the IP addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are always shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymisation.
Cookies may be used for performance and reach measurement and user profiles may be created. 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 in pseudonymised form and are not used to identify individual users. Individual services of third parties with which users are registered may be able to assign the use of our online services to the user account or user profile of the respective service.
In particular, we use:
- Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: «With Google Tag Manager collected data»; Further information on data protection can be found in the individual integrated and managed services.
13. Final provisions
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.