Privacy & Cookie Policy

Definitions

Data Subject:
A natural person whose personal data is processed by us.

Personal Data:
Any information relating to an identified or identifiable natural person.

Sensitive Personal Data:
Data relating to trade union, political, religious or philosophical beliefs or activities; data relating to health, private or intimate life, or affiliation with an ethnicity or race; genetic data; biometric data that uniquely identifies a natural person; data relating to criminal and administrative sanctions or prosecutions; and data relating to social assistance measures.

Processing:
Any operation or set of operations performed on personal data, regardless of the means and procedures used, such as collecting, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, acquiring, deleting, revealing, organizing, structuring, saving, altering, disseminating, linking, destroying, and using personal data.

European Economic Area (EEA):
The Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

Note:
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as “processing of personal data” and to the processing of sensitive personal data as “processing of special categories of personal data” (Article 9 GDPR).

Legal Bases

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DPO/DSV).

Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of at least one of the following legal bases:

Article 6(1)(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.

Article 6(1)(f) GDPR for the processing of personal data necessary to safeguard legitimate interests, including the legitimate interests of third parties, provided that the fundamental rights and freedoms and interests of the data subject do not prevail. Such interests include, in particular, the sustainable, human-centered, secure, and reliable conduct of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.

Article 6(1)(c) GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under applicable law of Member States in the European Economic Area (EEA).

Article 6(1)(e) GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.

Article 6(1)(a) GDPR for the processing of personal data based on the consent of the data subject.

Article 6(1)(d) GDPR for the processing of personal data necessary to protect vital interests of the data subject or of another natural person.

Article 9(2) et seq. GDPR for the processing of special categories of personal data, in particular on the basis of the data subjects’ consent.

We process personal data that is necessary in order to carry out our activities and operations on a permanent, human-centered, secure, and reliable basis. The personal data processed may in particular fall into the following categories: browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact details, location data, transaction data, contract data, and payment 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, insofar as such processing is legally permissible.

We process personal data as required with the consent of the data subjects. In many cases, we may process personal data without consent, for example in order to fulfill legal obligations or to safeguard overriding interests. We may also request the consent of data subjects even where such consent is not strictly required.

We process personal data for the period necessary for the respective purpose. In particular, we anonymize or delete personal data depending on statutory retention obligations and limitation periods.

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties include, in particular, specialized service providers whose services we make use of.

For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and legal advisors, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, and insurance providers.

We process personal data in order to communicate with third parties. In this context, we process in particular the data that a data subject transmits when contacting us, for example by postal mail or email. We may store such data in an address book or by using comparable tools.

Third parties who transmit data about other persons are obliged to ensure data protection vis-à-vis those data subjects. This includes, among other things, ensuring the accuracy of the personal data transmitted.

We use selected services from suitable providers in order to communicate more effectively with third parties.

In particular, we use the following services:

LiveChat: Platform for communication with customers, in particular via chatbots; providers: LiveChat Inc. (USA) / TEXT SA (Poland); data protection information: Privacy Policy, “Legal”.

Salesforce: Customer Relationship Management (CRM); providers: Salesforce.com Inc. (USA) / Salesforce.com Germany GmbH (Germany); data protection information: “Privacy” (including the “Key Privacy Information”), Privacy Policy.

We implement appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. Through these measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and other online presence is provided via transport encryption (SSL / TLS, in particular using Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers warn users when visiting websites without transport encryption.

Our digital communication is subject—like virtually all digital communication—to indiscriminate mass surveillance without specific cause or suspicion by security authorities in Switzerland, elsewhere in Europe, in the United States of America (USA), and in other countries.

We have no direct influence over the corresponding processing of personal data by intelligence services, law enforcement agencies, and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.

We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for the purpose of processing or having such data processed there.

We may export personal data to all countries and territories worldwide, provided that the applicable law in those countries ensures an adequate level of data protection in accordance with a decision of the Swiss Federal Council and—where and insofar as the General Data Protection Regulation (GDPR) is applicable—also in accordance with a decision of the European Commission.

We may transfer personal data to countries whose laws do not provide an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will gladly provide data subjects with information about any safeguards in place or provide a copy of such safeguards.

Data Protection Claims

We grant data subjects all rights in accordance with the applicable data protection law. In particular, data subjects have the following rights:

Right of Access:
Data subjects may request information as to whether we process personal data relating to them and, if so, which personal data is concerned. Data subjects further receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data processed as such as well as, among other things, information on the purpose of processing, the duration of storage, any disclosure or transfer of data to other countries, and the origin of the personal data.

Right to Rectification and Restriction:
Data subjects may request the correction of inaccurate personal data, the completion of incomplete data, and the restriction of the processing of their data.

Right to Erasure and Objection:
Data subjects may request the deletion of personal data (“right to be forgotten”) and object to the processing of their data with effect for the future.

Right to Data Access and Data Portability:
Data subjects may request the provision of personal data or the transfer of their data to another controller.

We may postpone, restrict, or refuse the exercise of data subject rights within the limits permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their data protection rights. For example, we may refuse access in whole or in part by reference to business secrets or the protection of other persons. We may also refuse the deletion of personal data, in whole or in part, with reference to statutory retention obligations.

In exceptional cases, we may charge a fee for the exercise of rights. Data subjects will be informed in advance of any such costs.

We are obliged to identify data subjects who request information or assert other rights by appropriate means. Data subjects are required to cooperate.

Legal Remedies

Data subjects have the right to enforce their data protection claims through legal proceedings or to file a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Swiss Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some Member States of the European Economic Area (EEA), data protection supervisory authorities are structured on a federal basis, in particular in Germany.

Cookies

We may use cookies. Cookies—including our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data is not limited to traditional text-based cookies.

Cookies may be stored temporarily in the browser 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 defined storage duration. Cookies enable, in particular, the recognition of a browser upon a subsequent visit to our website and thus, for example, the measurement of the reach of our website. Permanent cookies may also be used for online marketing purposes.

Cookies can be disabled and deleted at any time, in whole or in part, via the browser settings. Without cookies, our website may no longer be fully available. We actively request explicit consent for the use of cookies, at least where and to the extent required.

For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is available 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).

Logging

For each access to our website and other online presence, we may log at least the following information, provided that such information is transmitted to our digital infrastructure during access: 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, the specific subpage of our website accessed including the amount of data transferred, and the previously accessed webpage in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. This information is necessary in order to provide our online presence on a continuous, user-friendly, and reliable basis. It is also necessary to ensure data security, including by or with the assistance of third parties.

Tracking Pixels

We may integrate tracking pixels into our online presence. Tracking pixels are also referred to as web beacons. Tracking pixels—including those of third parties whose services we use—are typically small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Through tracking pixels, at least the same information as recorded in log files may be collected.

Performance and Reach Measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and messages on a personal level. We require this statistical analysis of usage for performance and reach measurement in order to send notifications and messages effectively, user-friendly, and in a sustainable, secure, and reliable manner, based on the needs and reading habits of the recipients.

Consent and Objection

As a rule, you must consent to the use of your email address and other contact details, unless such use is permitted on other legal grounds. Where applicable, we may use a “double opt-in” procedure to obtain consent. In this case, you will receive a message with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidentiary and security purposes. You may generally object at any time to receiving notifications and messages such as newsletters. By submitting such an objection, you may simultaneously object to the statistical recording of usage for performance and reach measurement. Mandatory notifications and messages related to our activities and operations remain reserved.

Service Providers for Notifications and Messages

We send notifications and messages with the assistance of specialized service providers.

In particular, we use the following services:

ActiveCampaign:
Marketing automation platform, in particular for email marketing; provider: ActiveCampaign LLC (USA); data protection information: Privacy Policy.

Mailchimp:
Communication platform; provider: The Rocket Science Group LLC d/b/a Mailchimp (USA), a subsidiary of Intuit Inc. (USA); data protection information: Privacy Policy (Intuit), including “Country and Region-Specific Terms.”

We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The respective general terms and conditions, terms of use, privacy policies, and other provisions of the individual platform operators apply in each case. These provisions provide information in particular about the rights of data subjects vis-à-vis the respective platform, including, for example, the right of access.

With regard to our social media presence on Facebook, including so-called Page Insights, we are—where and insofar as the General Data Protection Regulation (GDPR) is applicable—jointly responsible together with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta group of companies (including entities in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights in order to provide our Facebook social media presence effectively and in a user-friendly manner.

Further information on the nature, scope, and purpose of data processing, details on the rights of data subjects, and the contact details of Facebook as well as Facebook’s Data Protection Officer can be found in Facebook’s privacy policy. We have concluded the so-called “Controller Addendum” with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. Information relating to Page Insights can be found on the “Page Insights Information” page, including the “Information on Page Insights Data.”

Third-Party Services

We use services provided by specialized third parties in order to carry out our activities and operations on a permanent, human-centered, secure, and reliable basis. By using such services, we may, among other things, embed functions and content into our website. When such content is embedded, the services used may, for technically unavoidable reasons, at least temporarily collect the IP addresses of users.

For necessary security-related, 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 includes, for example, performance or usage data required to provide the respective service.

In particular, we use the following services:

Services from Google

Providers: Google LLC (USA) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and Switzerland.
General data protection information: “Privacy & Security Principles”, “How Google uses personal data”, Privacy Policy, “Google’s compliance with applicable data protection laws”, “Privacy guide for Google products”, “How we use data from websites or apps that use our services”, “Types of cookies and similar technologies used by Google”, “Advertising you can control” (“Personalized advertising”).

Services from Microsoft

Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world.
General data protection information: “Privacy at Microsoft”, “Privacy & Data Protection”, Privacy Policy, “Data & Privacy Settings”.

Digital Infrastructure

We use services from specialized third parties to obtain the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers. In particular, we use:

Hostpoint:
Hosting; provider: Hostpoint AG (Switzerland); data protection information: Privacy Policy.

Raidboxes:
WordPress hosting; provider: Raidboxes GmbH (Germany); data protection information: Privacy Policy, sample privacy policy for Raidboxes users (“Template for your privacy policy”).

WordPress.com:
Blog hosting and website builder; providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in, among other regions, Europe; data protection information: Privacy Policy, Cookie Policy.

Automation and Integration of Apps and Services

We use specialized platforms to integrate and connect existing third-party apps and services. Using such “no-code” platforms, we can also automate processes and activities involving third-party apps and services. In particular, we use:

Zapier:
Automation and integration of apps and services; provider: Zapier Inc. (USA); data protection information: Privacy Policy, “Data Privacy at Zapier”, “Data Privacy & Security FAQ”, “Security and Compliance”.

Audio and Video Conferencing

We use specialized services for audio and video conferencing in order to communicate online. This allows us, for example, to hold virtual meetings or conduct online training sessions and webinars. Participation in audio and video conferences is additionally subject to the respective legal texts of the individual services, such as privacy policies and terms of use.

Depending on the personal situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or using a virtual background.

In particular, we use:

Google Meet:
Video conferencing; provider: Google; Google Meet-specific information: “Google Meet – Security and Privacy for Users”.

TeamViewer Meeting:
Video conferencing; provider: TeamViewer Germany GmbH (Germany); data protection information: Privacy Policy, “First-Class Data Protection”.

Twitch:
Live streaming, especially for video games; provider: Twitch Interactive Inc. (USA); data protection information: Privacy Policy, Cookie Policy.

Zoom:
Platform for collaborative work, especially video conferencing; provider: Zoom Video Communications Inc. (USA); data protection information: “Privacy at Zoom”, Privacy Policy, “Compliance”.

Online Collaboration

We use third-party services to enable online collaboration. In addition to this privacy policy, the conditions of the respective services used—such as terms of use or privacy policies—may also apply. In particular, we use:

Miro:
Whiteboard platform; provider: RealtimeBoard Inc. (USA); data protection information: Privacy Policy, “Miro Trust Center”.

Padlet:
Platform for productive collaboration; provider: Wallwisher Inc. d/b/a Padlet; data protection information: Privacy Policy.

Slack:
Platform for productive collaboration, especially chat-based; providers: Slack Technologies LLC (USA) for users in Canada and the USA / Slack Technologies Limited (Ireland) for users in the rest of the world; data protection information: Privacy Policy, “Trust Center”, “Frequently Asked Questions about Privacy”, “Data Management: Transparency and Overview”, Cookie Policy.

Microsoft Teams:
Platform for productive collaboration, particularly with audio and video conferencing; provider: Microsoft; Teams-specific information: “Privacy and Microsoft Teams”.

Maps

We use third-party services to embed maps into our website. In particular, we use:

Google Maps, including Google Maps Platform:
Mapping service; provider: Google; Google Maps-specific information: “How Google uses location information”.

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. In particular, we use:

Vimeo:
Video platform; provider: Vimeo Inc. (USA); data protection information: Privacy Policy, “Private Video Hosting”.

YouTube:
Video platform; provider: Google; YouTube-specific information: “Privacy and Safety Center”, “My Data on YouTube”.

Documents

We use third-party services to embed documents into our website. Such documents may include PDF files, presentations, spreadsheets, and text documents. This allows not only viewing but also editing or commenting on such documents. In particular, we use:

Issuu:
Digital documents and electronic publications; provider: Issuu Inc. (USA); data protection information: Privacy Policy.

Fonts

We use third-party services to embed selected fonts as well as icons, logos, and symbols into our website. In particular, we use:

Font Awesome:
Icons and logos; provider: Fonticons Inc. (USA); data protection information: Privacy Policy.

Google Fonts:
Fonts; provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts”, “Privacy and Data Collection” (Google Fonts).

Advertising

We use the opportunity to display targeted advertising for our activities and operations through third parties such as social media platforms and search engines.

In particular, we aim to reach persons who are already interested in our activities and operations or who may be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding information—including potentially personal data—to third parties that enable such advertising. We may also determine whether our advertising is successful, in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and with whom you are registered as a user may associate the use of our website with your profile on their platform. In particular, we use:

Google Ads:
Search engine advertising; provider: Google; Google Ads-specific information: advertising based on search queries, using various domain names including doubleclick.net, googleadservices.com, and googlesyndication.com; Advertising Privacy Policy; “Manage ads directly from Ads Settings”.

LinkedIn Ads:
Social media advertising; providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); data protection information: remarketing and targeting, in particular using the LinkedIn Insight Tag; “Privacy”, Privacy Policy, Cookie Policy, opt-out of personalized advertising.

Meta Ads:
Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: targeting, including retargeting, particularly using the Meta Pixel and Custom Audiences including Lookalike Audiences; Privacy Policy, “Ad Preferences” (user login required).

TikTok Ads:
Social media advertising; providers: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom, and Switzerland / TikTok Inc. (USA) for users in the USA / TikTok Pte. Ltd. (Singapore) for users in the rest of the world; data protection information: remarketing and targeting, in particular using the TikTok Pixel; Privacy Policy, “Privacy Policy for Younger Users”, Cookie Policy, “TikTok for Business – Privacy and Cookie Policy”.

We use extensions for our website in order to enable additional functionalities. We may use selected services from suitable providers or operate such extensions on our own digital infrastructure. In particular, we use the following:

Google reCAPTCHA:
Spam protection (distinguishing desired content submitted by humans from unwanted content submitted by bots and spam); provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”.

We seek to understand how our online offering is used. In this context, we may, for example, measure the success and reach of our activities and operations as well as the impact of third-party links to our website. We may also test and compare how different parts or versions of our online offering are used (A/B testing). Based on the results of performance and reach measurement, we can in particular identify and correct errors, strengthen popular content, or implement improvements to our online offering.

For performance and reach measurement, the IP addresses of individual users are in most cases stored. In such cases, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data minimization through corresponding pseudonymization.

Cookies may be used and user profiles created as part of performance and reach measurement. Any user profiles created may include, for example, individual pages visited or content viewed on our website, information about screen or browser window size, and the user’s approximate location. As a rule, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Certain third-party services with which users are registered may associate the use of our online offering with the user account or user profile of the respective service provider. In particular, we use the following services:

Google Marketing Platform:
Performance and reach measurement, in particular using Google Analytics; provider: Google; Google Marketing Platform-specific information: measurement across different browsers and devices (cross-device tracking) as well as with pseudonymized IP addresses, which are only exceptionally transferred in full to Google in the USA; Google Analytics Privacy Policy; “Browser Add-on to Disable Google Analytics”.

Google Tag Manager:
Integration and management of services from Google and third parties, in particular for performance and reach measurement; provider: Google; Google Tag Manager-specific information: Google Tag Manager Privacy Policy; further data protection information can be found in the privacy notices of the respective integrated and managed services.

We have prepared this privacy policy using the Privacy Policy Generator by Datenschutzpartner. We may amend or supplement this privacy policy at any time. We will inform you of such amendments and supplements in an appropriate manner, in particular by publishing the current version of the privacy policy on our website.