Our offer is subject to Swiss data protection law and any applicable, foreign data protection law, particularly that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission acknowledges that Swiss data protection law guarantees adequate data protection.
1. Contact Addresses
Responsibility for the processing of personal data:
Other persons responsible for the processing of personal data will be pointed out in their respective cases.
2. Processing of personal data
2.1 Terms and definitions
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, particularly 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 General Data Protection Regulation (GDPR) describes the processing of personal data as any operation or set of operations which are performed on personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection.
We process – if and insofar as 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 GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the processing of personal data necessary to safeguard the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject outweigh these. 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 para. 1 lit. c GDPR for the necessary processing of personal data in order to fulfil a legal obligation to which we are subject in accordance with any applicable law of member states of the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out 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 letter d GDPR for the processing of personal data necessary to protect vital interests of the data subject or another natural person.
2.3 Nature, scope and purpose
We process personal data that is necessary to provide our services in a permanent, user-friendly, secure and reliable manner. 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 a duration as long as is necessary for the respective purpose or purposes or as required by law. Personal data for which processing is no longer required will be made anonymous or deleted. Persons whose data we process have a fundamental 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 fulfil a contract with the data subject and for appropriate pre-contractual measures to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context particularly, we process information that a data subject 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 or with comparable tools. If you transmit personal data about third parties to us, you are obliged to guarantee data protection for such third parties and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect when making our offer available, 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 providers whose services we use. We also guarantee appropriate data protection against such third parties.
Such third parties are generally located in Switzerland and the European 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 General Data Protection Regulation (GDPR) is applicable – in the opinion of the European Commission, or if adequate data protection is guaranteed for other reasons, such as by a corresponding contractual agreement, particularly on the basis of standard contractual clauses, or by appropriate certification. In the case of third parties in the United States of America (USA), certification in accordance with the Privacy Shield can 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 data subject.
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 General Data Protection Regulation (GDPR) is applicable – obtain free confirmation 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 to the extent that the GDPR is applicable – revoke any consent 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 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, particularly with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Access to our online offer is subject – as is basically the case with all Internet use – to mass surveillance without cause or suspicion and other monitoring 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 forces and other security authorities.
5. Use of the websites
When you visit our websites, cookies can be temporarily stored in your browser as „session cookies“ or for a certain period of time as so-called permanent cookies. „Session cookies“ are automatically deleted when you close your browser. Permanent cookies make it possible to recognise your browser the next time you visit our websites and thus to measure the reach of our websites, for example. Permanent cookies can also be used for online marketing, for example.
You can completely or partially deactivate or delete cookies in your browser settings at any time. Without cookies, our websites may no longer be fully available.
In the case of cookies used for measuring 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 Interactive Digital Advertising Alliance, EDAA).
5.2 Server log files
We may collect the following information for each access to our websites, 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 websites called up including transferred data volume, last website called up in the same browser window (referer).
We store such information, which may also represent personal data, in server log files. This information is required to provide our online services in a permanent, user-friendly and reliable manner and to ensure data security and thus the protection of personal data – also by third parties or with the help of third parties.
5.3 Tracking pixels
We may use tracking pixels on our websites. Tracking pixels are also known as web beacons. Web beacons are small, usually invisible images that are automatically retrieved when you visit our websites, including those of third parties whose services we use. Tracking pixels can be used to record the same information as in server log files.
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 Measuring success and reach
Notifications and messages can contain weblinks or tracking pixels that record whether an individual message was opened and which weblinks were clicked. Such weblinks 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 provide 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 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 to receive e-mails, we use the „double opt-in“ procedure whenever possible, i.e. you will receive an e-mail with a web link that you must click on to confirm your consent so that no misuse by unauthorized third parties can occur. We may log such consents including Internet Protocol (IP) address and date and time for evidence and security purposes.
You can 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 services. By unsubscribing, you object to the statistical recording of usage for the measurement of success and reach.
6.3 Service providers 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 privacy policies and other provisions of the individual operators of such online platforms, also apply in each case. These provisions provide information about the rights of data subjects, which includes the right to information.
For our social media presence on Facebook, we are, if and insofar as the GDPR 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 use Page-Insights to provide our social media presence on Facebook in an effective and user-friendly manner. Facebook has published information about Page Insights data and an addendum regarding the responsibility for Page Insights.
8. Services of third parties
We use third-party services to provide our services in a permanent, user-friendly, secure and reliable manner. Such services also serve to embed content into our websites. Such services – for example, hosting and storage services, video services and payment services – require your Internet Protocol (IP) address, otherwise such services will not be able to transmit the relevant 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 tracking pixels – in aggregated, anonymised or pseudonymised form.
8.1 Social Media Features and Social Media Content
We use social plugins from Facebook to embed Facebook features and Facebook content into our websites. 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 of Facebook Ireland Ltd. in Ireland or the American company 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 websites, we use the possibility of embedding functions and content from Twitter („Twitter for websites“ or „Twitter for websites“). For example, we may enable you to use the „share“ feature of Twitter on our websites or display tweets to you on our websites. Cookies are also used for this purpose.
8.3 Measuring success and reach
We use Google Analytics to analyze how our websites are used, and we may also measure the reach of our websites and the success of third-party links on our websites. This is a service of the American Google LLC. The Irish Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland.
Google also attempts to track individual visitors to our websites when they use different browsers or devices (cross-device tracking). Cookies are also used for this purpose. Google Analytics requires your Internet Protocol (IP) address, but this is not combined with other data from Google.
We use Facebook Ads in order to be able to advertise our offer on Facebook. Facebook Ads is an offer from Facebook Ireland Ltd. in Ireland or the American Facebook Inc. Cookies are also used in Facebook Ads.
With such advertising, we would particularly like to reach people who are interested in our online offer or who are already using our online offer. For this purpose, we transmit corresponding – possibly also personal – information to Facebook (custom audiences including lookalike audiences), in particular with the so-called Facebook pixel. We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).
Further information on the type, scope and purpose of data processing can be found in Facebook's data protection declaration (“data policy”). In addition, Facebook users can use their advertising preferences to influence which advertisements they see on Facebook and which advertisements will be displayed to them on Facebook in the future.
9. Final provisions