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 recognizes that Swiss data protection law ensures adequate data protection.
1. Contact Addresses
Responsibility for the processing of personal data:
We indicate if there are other responsible parties for the processing of personal data in individual cases.
Data Protection Officers or Data Protection Advisors
We have the following data protection officer or data protection advisor as a contact point for affected persons and authorities for inquiries related to data protection:
2. Terms and Legal Bases
Personal Data are all information relating to a specific or identifiable natural person. A data subject is a person whose personal data we process.
Processing includes every handling of personal data, irrespective of the means and procedures used, such as querying, matching, adapting, archiving, storing, retrieving, disclosing, obtaining, recording, collecting, deleting, revealing, ordering, organizing, storing, altering, distributing, 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 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 – insofar as the General Data Protection Regulation (GDPR) is applicable – personal data according to at least one of the following legal bases:
- Art. 6 Para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for carrying out pre-contractual measures.
- Art. 6 Para. 1 lit. f GDPR for the necessary processing of personal data to protect the legitimate interests of us or third parties, provided that the fundamental freedoms and fundamental rights as well as interests of the data subject do not prevail. Legitimate interests are particularly our interest in being able to exercise our activities and operations sustainably, user-friendly, securely, and reliably, as well as being able to communicate about it, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.
- Art. 6 Para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject according to possibly 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 to perform a task 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 to protect the vital interests of the data subject or another natural person.
3. Type, Scope and Purpose
We process those personal data that are necessary for us to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. Such personal data may fall into categories such as 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 necessary for the respective purpose or purposes, or as required by law. Personal data that is no longer necessary for processing is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data together with third parties or transmit it to third parties. Such third parties are particularly specialized providers whose services we use. We also ensure data protection with such third parties.
We generally process personal data only with the consent of the affected individuals. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process data without consent in order to fulfill a contract, comply with legal obligations, or protect overriding interests.
In this context, we particularly process information that a data subject voluntarily transmits to us when making contact – for example, by mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We can store such information in an address book or with similar tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection towards 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 carrying out our activities and operations, if and to the extent that such processing is legally permissible.
4. Data Security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the processed personal data.
Access to our online presence, especially our website, is made using transport encryption (SSL/TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.
Our digital communication is subject – as is generally the case with digital communication – to mass surveillance without cause and suspicion, as well as other surveillance 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 intelligence services, police authorities, and other security agencies.
5. Personal Data Abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly for processing or to have it processed there.
We can export personal data to all countries and territories on Earth, and elsewhere in the universe, provided the local law ensures adequate data protection according to the decision of the Swiss Federal Council, and – to the extent that the General Data Protection Regulation (GDPR) is applicable – according to the decision of the European Commission.
We may transmit personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular based on standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the special data protection legal requirements are met, such as the explicit consent of the data subjects or a direct connection with the conclusion or execution of a contract. We gladly provide information to data subjects upon request about any guarantees or deliver a copy of any guarantees.
6. Rights of Data Subjects
6.1 Data Protection Claims
We grant data subjects all claims according to applicable data protection law. Data subjects have, in particular, the following rights:
- Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data. Data subjects also receive further information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also information about 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 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 Release and Data Transfer: Data subjects can request the release of personal data or the transfer of their data to another controller.
We may postpone, limit, or refuse the exercise of rights of data subjects within the legally permissible framework. We can point out to data subjects any conditions that must be fulfilled to exercise their data protection claims. For example, we may refuse to provide information referring to trade secrets or the protection of other persons entirely or partially. We may also refuse the deletion of personal data referring to statutory retention obligations entirely or partially.
We may exceptionally provide for costs for the exercise of rights. We inform data subjects in advance about any possible costs.
We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are required to cooperate.
6.2 Legal Protection
Data subjects have the right to enforce their data protection claims through legal proceedings or to file a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for complaints from data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Possible data protection supervisory authorities for complaints from data subjects – to the extent that the General Data Protection Regulation (GDPR) is applicable – are organized 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.
7. Use of the Website
Cookies can be stored in the browser temporarily as “Session Cookies” or for a specific period as so-called permanent cookies. “Session Cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies, in particular, enable a browser to be recognized on the next visit to our website and thereby measure, for example, the reach of our website. Permanent cookies can also be used for online marketing.
For cookies used for success and reach measurement or for advertising, a general objection («Opt-out») is possible for many 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 can record the following data for each access to our website, if these are 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 the amount of data transferred, the last website called up in the same browser window (referer or referrer).
We store such data, which can also be personal data, in server log files. The data is necessary to provide our website in a sustainable, 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 visiting our website. Tracking pixels can capture the same information as recorded in 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 message has been opened and which web links have been clicked. Such web links and tracking pixels may also capture the use of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement, to be able to send notifications and communications effectively and user-friendly based on the needs and reading habits of the recipients and to ensure they are sustainable, secure, and reliable.
8.2 Consent and Objection
You must generally explicitly consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. For possible consent, we use the “Double Opt-in” procedure whenever possible, meaning you will receive an email with a web link that you must click to confirm, to prevent misuse by unauthorized third parties. We may log such consents, including the IP address, date, and time, for proof and security reasons.
You can generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously oppose the statistical recording of usage for success and reach measurement. Reserved are necessary notifications and communications related to our activities and operations.
8.3 Service Providers for Notifications and Communications
We send notifications and communications with the help of specialized service providers.
We particularly use:
9. Social Media
We are present on social media platforms and other online platforms to communicate with interested parties and to inform 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 – 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 effectively and user-friendly.
10. Third-Party Services
We use services of specialized third parties to be able to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. With such services, we can embed functions and content into our website. In such embedding, the used services technically necessarily capture at least temporarily the IP addresses of users.
For necessary security, statistical, and technical purposes, third parties, whose services we use, may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. These are, for example, performance or usage data to provide the respective service.
We particularly use:
10.1 Digital Infrastructure
We use services from specialized third parties to access the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We particularly use:
10.2 Social Media Functions and Social Media Content
We use services and plugins from third parties to embed functions and content from social media platforms and to enable sharing of content on social media platforms and other means.
We particularly use:
We use services from third parties to embed selected fonts, as well as icons, logos, and symbols into our website.
We particularly use:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts”, “Privacy and Data Collection”.
We operate e-commerce and use third-party services to successfully offer services, content, or goods.
We use the opportunity to specifically display advertising for our activities and operations on third-party platforms such as social media platforms and search engines.
With such advertising, we particularly aim to reach people who are already interested in our activities and operations or could be interested (Remarketing and Targeting). For this purpose, we may transmit corresponding – possibly also personal – data to third parties that enable such advertising. We can also determine whether our advertising is successful, meaning particularly whether it leads to visits to our website (Conversion Tracking).
Third parties, where we advertise and where you as a user are registered, may possibly associate the use of our website with your profile there.
We particularly use:
- Google Ads: Search engine advertising; Provider: Google; Specific information about Google Ads: Advertising based on search queries, using various domain names – particularly doubleclick.net, googleadservices.com, and googlesyndication.com – for Google Ads, “Advertising” (Google), “Why am I seeing a specific ad?”.
11. Success and Reach Measurement
We attempt to determine how our online offer is used. In this context, we can measure, for example, the success and reach of our activities and operations, as well as the impact of third-party links on our website. We can also test and compare how different parts or versions of our online offer are used (using the “A/B testing” method). Based on the results of success and reach measurement, we can, in particular, fix errors, strengthen popular content, or make improvements to our online offer.
For success and reach measurement, the IP addresses of individual users are most often stored. In this case, IP addresses are generally shortened (“IP masking”) to follow the principle of data economy through the corresponding pseudonymization.
In success and reach measurement, cookies can be used, and user profiles created. Any created user profiles may include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the – at least approximate – location. Generally, any user profiles are created exclusively in a pseudonymized manner and are not used for identifying individual users. Individual third-party services where users are registered can possibly assign the use of our online offer to the user account or profile at the respective service.
We particularly use:
- Google Analytics: Success and reach measurement; Provider: Google; Specific information about Google Analytics: Measurement across different browsers and devices (Cross-Device Tracking) and with pseudonymized IP addresses, which are only exceptionally transmitted in full to Google in the USA, “Privacy”, “Google Analytics Opt-out Browser Add-on”.
- Google Tag Manager: Integration and management of other services for success and reach measurement and further services from Google as well as third parties; Provider: Google; Specific information about Google Tag Manager: “Data Collected by Google Tag Manager”; further privacy information is available for each integrated and managed service.
12. Final Provisions