- Roy Franke
- Mühlezelgstrasse 20
- 8047 Zürich Schweiz email@example.com
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Processing of personal data
Personal data is any 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, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.The European Economic Area (EEA) includes 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 basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (DPA) and the Ordinance to the Federal Data Protection Act (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:
- 6 Abs. 1 lit. b DSGVO for the necessary processing of personal data for the fulfillment of a contract with the data subject as well as for the implementation of pre-contractual measures.
- 6 Abs. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject override. Legitimate interests are, in particular, our interest in being able to provide our offer permanently, in a user-friendly, secure and reliable manner and to be able to advertise for it as required, information security as well as protection against misuse and unauthorized use, the enforcement of our own legal claims and compliance with Swiss law.
- 6 Abs. 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).
- 6 Abs. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task that is in the public interest.
- 6 Abs. 1 lit. d DSGVO für die erforderliche Bearbeitung von Personendaten, um lebenswichtige Interessen der betroffenen Person oder einer anderen natürlichen Person zu schützen.
We process those personal data that are necessary to provide our offer permanently, user-friendly, secure and reliable. Such personal 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 the period of time required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required will be anonymized or deleted. Persons whose data we process generally have a right to deletion.
As a matter of principle, we process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, to fulfill a contract with the data subject and for corresponding 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 data subject voluntarily and self-submits to us when contacting us - for example, by letter, e-mail, contact form, social media or telephone - or when registering for a user account.We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If you transmit data about other persons to us, you are obligated to ensure data protection with respect to such persons as well as to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.
Personal data from applications are only processed insofar as they are required for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required for the implementation of an application procedure is derived from the information requested or provided, for example, in the context of a job advertisement. Applicants have the option of voluntarily providing further information for their respective applications.
2.4 Processing of personal data by third parties, including abroad
We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties. Such third parties are generally located in Switzerland and in the European Economic Area (EEA). Such third parties may also be located in other states and territories on earth as well as elsewhere in the universe, provided that their data protection laws guarantee adequate data protection according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - according to the assessment of the European Commission, or if adequate data protection is guaranteed for other reasons, such as by a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or by a corresponding certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the data protection requirements for this, such as the express consent of the data subject, are met.
3. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law.
Data subjects whose personal data we process may - if and insofar as the General Data Protection Regulation (GDPR) is applicable - request 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 portability and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed. Data subjects whose personal data we process may - if and insofar as the GDPR is applicable - revoke consent they have given 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 Data Protection 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 takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Access to our online offering is subject - like all Internet use - to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the European Union (EU), 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.
5. Use of the website
Cookies can be stored temporarily in your browser as "session cookies" when you visit our website or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they allow us to recognize your browser the next time you visit 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 possible for many services via AdChoices (Digital Advertising Alliance Of Canada), NetworkAdvertisingInitiative (NAI), YourAdChoices (Digital Advertising Alliance) or YourOnlineChoices (European Interactive Digital Advertising Alliance, EDAA).
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 data volume 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 online offer permanently, user-friendly and reliably 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 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also known 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.
6. Notifications and messages
We send notifications and communications such as newsletters via email and other communication channels such as instant messaging.
6.1 Success and reach measurement
Notifications and messages may 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 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 offer notifications and communications effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
6.2 Consent and objection
As a matter of principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure where possible, i.e. 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 evidence and security reasons.
In principle, you can unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. Notifications and communications that are absolutely necessary for our offer remain reserved.
6.3 Service provider for notifications and messages
We send notifications and messages via third-party services or with the help of service providers. Cookies may also be used in the process.
We use in particular:
- SendGrid: Platform for transactional e-mail ("e-mailing made easy"); Provider: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); data protection information: privacy statement ("Twilio Privacy Statement").
7. Social Media
For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland), if and to the extent that the GDPR is applicable. 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 in an effective and user-friendly manner.
8. Third party services
We use third-party services in order to be able to provide our offer permanently, user-friendly, secure and reliable. Such services may also be used to embed content on our website. Such services - for example, hosting and storage services, video services, and payment services - require your Internet Protocol (IP) address, as such services cannot otherwise transmit the corresponding content.
For their own security-related, statistical, and technical purposes, third parties whose services we use may also process data related to our offer as well as from other sources - including with cookies, log files, and counting pixels - in an aggregated, anonymized, or pseudonymized manner.
We use in particular:
8.1 Digital Infrastructure
We use third-party services in order to be able to make use of the digital infrastructure required for our offering. These include, for example, hosting and storage services from specialized providers.
We use in particular:
- Google Cloud including Google Cloud Platform (GCP): storage space and other infrastructure; Google Cloud-specific providers: Google LLC (USA) for users in the USA and elsewhere / Google Ireland Limited or Google Commerce Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland and elsewhere (see "Google Contracting Entity" for providers in other countries); Google Cloud-specific privacy disclosures: "Privacy Resource Center", "Data Protection", "Compliance Resource Center", "Trust and Security".
- The platform itself is run through the service of Bubble Group, Inc. (Bubble Group Inc., 900 Broadway, Suite 504, New York, NY 10003). All data is encrypted according to the latest technology. We also have access to communications marked as private. For more information, see DPA and Privacy at Bubble.
We use third-party services to better communicate with you and others, such as customers.
We use in particular:
8.3 Social media functions and social media content
We use third-party services and plugins to embed features and content from social media platforms and to enable the sharing of content on social media platforms and other ways.
We use in particular:
8.4 Map material
We use third party services to embed maps on our website.
We use in particular
- Google Maps including Google Maps Platform: mapping service; Google Maps-specific privacy disclosures: "How Google uses location information".8.5 Audiovisual Media
8.5 Audiovisual media
We use third-party services to enable the direct playback of audiovisual media such as music or videos on our website.
We use in particular
- We use third-party services to enable the direct playback of audiovisual media such as music or videos on our website.
- YouTube: Videos; Provider: Google (among others in the USA); YouTube-specific information on data protection: "Privacy and Security Center", "My data on YouTube".
We use the option of embedding third-party advertising in our website in return for performance-based compensation. Third parties whose advertising is embedded in our website and where you are logged in as a user may be able to assign the use of our offer to your profile there.
We use in particular:
- Google AdSense: Personalized website advertising; Google AdSense-specific privacy disclosures: "Advertising" (Google), "Why am I seeing a particular ad?".
9. Success and reach measurement
We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our online offering and the effect of third-party links to our website. We can also, for example, test and compare how different versions of our online offering or parts of our online offering are used ("A/B test" method). Based on the results of the performance and reach measurement, we can, in particular, correct errors, strengthen particularly popular content or make improvements to our online offering.
When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened in order to comply with the principle of data economy through the corresponding pseudonymization and to improve the data protection of visitors to our website ("IP masking").
When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. As a matter of principle, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual visitors to our website. Individual services to which you are logged in as a user can, if necessary, assign the use of our online offering to your profile at the respective service, whereby you usually had to give your consent to this assignment in advance.
We use in particular:
- Google Analytics: Success and reach measurement; Google Analytics-specific data protection information: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, "Data protection", "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: integration and management of services for success and range measurement as well as other services from Google and third parties; Further information on data protection can be found in the individual integrated and managed services.
10. Final Terms
We have created this data protection declaration with the data protection generator from data protection partner.
We can adapt and supplement this data protection declaration at any time. We will inform you about such adjustments and additions in a suitable form, in particular by publishing the current data protection declaration on our website.