Our offer is subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the Basic Data Protection Regulation (DSGVO). The European Commission acknowledges that Swiss data protection law guarantees adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
Rue de Vuarpillière 29
CH-1260 NYON, SWITZERLAND.
You can contact by phone : +41 (0)22 994 21 21.
We would like to point out if in individual cases there are other persons responsible for the processing of personal data.
2. Processing of personal data
Personal data is all information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, irrespective of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The Basic DataProtection Regulation (DSGVO) describes the processing of personal data as the processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act(DSG) and the Ordinance to the Federal Data Protection Act (VDSG).
We process – if and insofar as theBasic 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 processing of personal data necessary for the performance of a contract with the person concerned and for the implementation of pre-contractual measures.
· Art. 6 para. 1 letter f DSGVO for the necessary processing of personal data in order to safeguard the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the person concerned outweigh the data subject’s own.Legitimate interests are in particular our interest in being able to provide our services permanently, user-friendly, secure and reliable and to advertise them as required, information security and protection against misuse and unauthorised use, the enforcement of our own legal claims and compliance with Swiss law.
· Art. 6 Abs. 1 lit. c DSGVO for the necessary processing of personal data in order to fulfil a legal obligation to which we are subject according to any applicable law of member states of the EuropeanEconomic Area (EEA).
· Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data to perform a task in the public interest.
· Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the person concerned.
· Art. 6 para. 1 lit. d DPA for the processing of personal data necessary to protect the vital interests of the data subject or other natural persons.
2.3 Nature, scope and purpose
We process those personal data that are necessary to provide our services in a permanent, user-friendly, secure and reliable manner. Suchpersonal data can 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, contract and payment data.
We process personal data for as long as is necessary for the respective purpose or purposes or as required by law.Personal data whose processing is no longer required will be made anonymous or deleted. Persons whose data we process have in principle the right to request a deletion.
As a matter of principle, we process personal data only with the consent of the person concerned, unless processing is permitted for other legal reasons, for example to fulfill a contract with the person concerned and for appropriate pre-contractual measures to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a person concerned voluntarily and personally submits to us when contacting us – for example by letter post, e-mail, contact form, social media or telephone – or when registering for a user account. We may store such information in an address book, in a customer relationship management system (CRM system) or with comparable tools. If you transmit personal data about third parties to us, you are obliged to guarantee data protection against such third parties and to ensure the accuracy of such personal data.
In addition, we process personal data that we receive from third parties, obtain from publicly accessible sources or collect when providing our services, if and to the extent that such processing is permitted by law.
Personal data from job applications will only be processed to the extent that it is necessary for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required to carry out an application procedure is derived from the information requested or provided, for example, in the context of a job description. Applicants have the option of voluntarily providing additional information for their respective applications.
2.4 Processing of personal data by third parties, also abroad
We may have personal data processed by commissioned third parties or process it together with third parties or with the help of third parties or transfer it to third parties. Such third parties are in particular providers whose services we use. We also guarantee appropriate data protection for such third parties.
Such third parties are generally located in Switzerland and theEuropean Economic Area (EEA). However, such third parties may also be located in other states and territories on earth and elsewhere in the universe, provided that their data protection law guarantees adequate data protection in the opinion of the Federal Data Protection and Information Commissioner (FDPIC)and – if and insofar as the Basic Data Protection Ordinance (DSGVO) is applicable – in the opinion of the European Commission, or if adequate data protection is guaranteed for other reasons, such as through a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or through corresponding certification. In the case of third parties in the United States of America (USA), certification in accordance with thePrivacy Shield could guarantee adequate data protection. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the legal data protection requirements are met, such as the express consent of the person concerned.
3. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. This includes the right to information and the right to correct, delete or block the processed personal data.
Data subjects whose personal data we process may – if and to the extent that the Basic Data Protection Ordinance(DSGVO) is applicable – obtain confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data transferability and have their personal data corrected, deleted (“right to forget”), blocked or completed.
Data subjects whose personal data we process may – if and insofar as the DS-GVO is applicable – revoke their consent at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal DataProtection and Information Commissioner (FDPIC).
4. Data security
We take appropriate and suitable technical and organizational measures to ensure data protection and in particular data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.
Access to our online offer is carried out using transport encryption (SSL / TLS, in particular with the HypertextTransfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Access to our online service is subject – as is basically the case with any use of the Internet – to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the European Union (EU), the United States ofAmerica (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.
5. Use of the website
When you visit our website, cookies can be stored temporarily in your browser as “session cookies” or fora certain period of time as so-called permanent cookies. Session cookies”are automatically deleted when you close your browser. In particular, permanent cookies make it possible to recognize your browser the next time you visit our website and thus, for example, to increase the range of our website. measure.Permanent cookies can also be used for online marketing, for example.
In the case of cookies that are used to measure success and reach or for advertising, a general opt-out is possible for many services via the Network Advertising Initiative (NAI), YourAdChoices(Digital Advertising Alliance) or Your Online Choices (European InteractiveDigital Advertising Alliance, EDAA).
5.2 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, Internet Protocol (IP)address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-pages of our website called up including the amount of data transferred, last website called up in the same browser window (referrer).
We store such information, which may also represent personal data, in server log files. This information is necessary to provide our online service 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.
5.3 Counting pixels
We may use tracking pixels on our website. Web beacons are also known as tracking pixels. Web beacons – also from third parties whose services we use – are small, usually invisible images that are automatically called up when you visit our website. The same information as in server log files can be captured using tracking pixels.
6. Notifications and communications
We send notifications and communications, such as newsletters, by e-mail and through other communication channels such as instant messaging.
6.1 Measurement of success and reach
Notifications and messages can contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We need this statistical recording of usage to measure success and reach in order to be able to offer notifications and messages effectively and user-friendly as well as permanently, securely and reliably based on the needs and reading habits of the recipients.
6.2 Consent and objection
In principle, you must expressly agree to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For a possible consent for the receipt of e-mails, we use the “double opt-in” procedure if possible, i.e. you will receive an e-mail with a web link that you must click on for confirmation, so that no abuse by unauthorized third parties can take place. We may log such consent, including Internet Protocol (IP) address, date and time, for evidence and security purposes.
You can in principle unsubscribe from notifications and communications such as newsletters at any time. We reserve the right to make notifications and communications that are absolutely necessary for our offer. By unsubscribing, you can in particular object to the statistical recording of usage for the measurement of success and range.
6.3 Service provider for notifications and messages
We send notifications and messages about services provided by third parties or with the help of service providers.Cookies may also be used in this process. We also guarantee appropriate data protection for such services.
7. Social media
We are present on social media platforms and other online platforms in order to communicate with interested people and to inform them about our offer. Personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC)and Conditions of Use as well as data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions provide information in particular about the rights of affected persons, which includes in particular the right to information.
For our social media presence onFacebook, we are, if and insofar as the DSGVO is applicable, jointly responsible with Facebook for the so-called page insights. The page insights provide information on how visitors interact with our Facebook presence.
We usePage-Insights to provide our social media presence on Facebook in an effective and user-friendly way. Facebook has published information on Page Insights data and a supplement regarding the responsibility for Page Insights.
8. Third party services
We use third party services to provide our services in a durable, user-friendly, secure and reliable manner. Such services also serve to embed content into our website. Such services – such as hosting and storage services, video services and payment services – require your Internet Protocol (IP) address, otherwise such services cannot transmit the corresponding content. Such services may be located outside Switzerland and the European Economic Area (EEA), provided that adequate data protection is guaranteed.
For their own security-related, statistical and technical purposes, third parties whose services we use may also process data in connection with our offer and from other sources -including cookies, log files and counting pixels – in aggregated, anonymised or pseudonymised form.
8.1 Contact possibilities
We use third party services to better communicate with you and others such as customers. We also guarantee appropriate data protection for such third parties.
8.2 Social media functions and social media content
We use social plugins from Facebook to embed Facebook features andFacebook content into our website. Such features include “Like” or “Share”. Cookies are also used for this purpose. You can find more information on the Facebook “Social Plug-ins” page.
The social plug-ins are an offer ofFacebook Ireland Ltd. in Ireland or the American Facebook Inc. If you are registered as a user on Facebook, Facebook can assign the use of our online offer to your profile. Further information on the type, scope and purpose of data processing can be found in the Facebook data policy.
For our website we use the possibility to embed functions and contents of Instagram.For example, we can use it to display images published by Instagram on our website. Cookies are also used for this purpose.
For our website we use the possibility to embed functions and contents of Twitter(“Twitter for websites”). We can, for example, enable you to use the”share” function of Twitter on our website or to display tweets to you within the framework of our website. Cookies are also used for this purpose.
Twitter for Websites is an offer from Twitter International Company in Ireland or the American Twitter Inc. If you are registered as a user on Twitter, Twitter can assign the use of our online offer to your profile.
8.3 Measuring success and reach
8.3.1 Google Analytics
We use Google Analytics to analyse how our website is used, whereby we can also measure the reach of our website and the success of links from third parties to our website. This is a service of the American Google LLC. The IrishGoogle Ireland Limited is responsible for users in the European Economic Area(EEA) and Switzerland.
Google also attempts to track individual visitors to our website when they use different browsers or devices (cross-device tracking). Cookies are also used for this purpose. For Google Analytics your Internet Protocol (IP)address is required, but this is not combined with other data from Google.
In any case, we will have yourInternet Protocol (IP) address anonymised by Google before the analysis. As a result, your complete IP address will in principle not be transmitted to Google in the USA.
We use Google Analytics with Google Signals. This enables us to obtain extended statistics on visitors to our website who have activated personalised advertising as registered users of Google. Despite these extended statistics, we are unable to establish a link to individual Google user accounts.
We use Hotjar to analyze how our website is used. Hotjar makes it possible to record the behaviour of visitors to our website, for example in relation to movements and clicks with a mouse or other input options. Cookies and other technologies are also used to record user behaviour and information such as screen size, anonymous Internet Protocol (IP) address and the approximate location (country). Hotjar, a service of Hotjar Ltd. in Malta, stores the collected data according to its own specifications in a pseudonymised user profile.
9. Final provisions
If you have any questions regarding our privacy policies, please don’t hesitate to reach out!
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