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:
Old country road 415
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and Legal Bases
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 out, 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 the 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 to the extent that 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 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, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance 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 boundary 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 process personal data for the period of time required by law.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 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 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 or with comparable tools. If we receive data transmitted to us 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 in principle 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 law there is in compliance with decision of the Swiss Federal Council an adequate level of data protection as well as – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to Decision of the European Commission ensures adequate data protection.
We may transfer personal data to countries whose law does 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. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection 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 safeguards or provide a copy of any safeguards upon request.
5. Rights of data subjects
5.1 Data protection rights
We grant data subjects all claims 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 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 may request the surrender of personal data or the transfer of their data to another 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 to 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 about any costs.
We are obliged to exceptional costs.We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obligated 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 controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – the right 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 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 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.
For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is required for many 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.
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – also from 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 by email and through other communication channels, such as instant messaging or SMS.
8.1 Performance 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. Such web links and tracking pixels may also track 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 evidentiary and security purposes.
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 Notifications and communications service providers
We send notifications and communications using specialized service providers.
We use in particular:
9. Social Media
We are present on social media platforms and other online platforms in order to be able to communicate with interested persons as well as to inform them 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 – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – are 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 help us 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, statistical and technical purposes, third parties whose services we use may process data related to 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.
We use in particular:
- Services provided by Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom, and Switzerland; General privacy information: “Privacy at Microsoft”, “Data Protection and Privacy (Trust Center)”, privacy statement, privacy dashboard (data and privacy settings).
10.1 Digital Infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
We use third party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific disclosures: “How Google uses location information”.
10.3 Digital audio and video content
We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.
We specifically use:
- YouTube: video platform; provider: Google; YouTube-specific details: “Privacy and Security Center”, “My Data on YouTube”.
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We specifically use:
- Google Fonts: fonts; provider: Google; Google Fonts-specific details: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”.
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 in particular:
- zahls.ch: Digital receipt of payments; Provider: siebenberge gmbh (Switzerland); Data protection information: Data protection statement.
We use the possibility 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 who might be interested in them (Remarketing and Targeting). For this purpose, we may transmit relevant – if necessary 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 associate the use of our website with 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 – in particular 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 to take advantage of additional features.
We use in particular:
- Google reCAPTCHA: spam protection (distinguishing between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA-specific details: “What is reCAPTCHA?” (“What is reCAPTCHA?”).
We try to determine how our online offer is used. In this context, we may, 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 offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular fix errors, strengthen popular content or make improvements to our online offering.
For performance and reach measurement, in most cases the Internet Protocol (IP) addresses of individual users are stored. In this case, IP addresses are basically shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.
In the case of success and reach measurement, the Internet Protocol (IP) addresses of individual users are stored in most cases.In measuring success and reach, cookies may be used 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 pseudonymously and are not used to identify individual users. Individual services of third parties, with which users are registered, can assign the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Google Analytics: Success 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”.
13. Final provisions