We are subject to Swiss data protection law as well as 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.
Responsibility for the processing of personal data:
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and Legal Basis
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, arranging, organizing, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises 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 Basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Swiss Federal Act on Data Protection(Data Protection Act, DPA) and the Ordinance on Data Protection (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:
- 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.
- 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 are, 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, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
- 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).
- 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task that is in the public interest.
- 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
- 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. Nature, Scope and Purpose
We process those personal data that are necessary to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular 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 data and contract and payment data.
We process personal data for the duration that is required for the respective purpose(s) or by law. Personal data whose processing is no longer required is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data together with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
We process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order 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 provides to us when contacting us – for example, by letter, e-mail, 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 via 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 Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular 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 ensures adequate data protection in accordance with the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do 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. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law 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 guarantees or a copy of any guarantees upon request.
5. Rights of Data Subjects
5.1 Data Protection Law Rights
We grant data subjects all rights in accordance with applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects can 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 required to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, 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 have incorrect personal data corrected and 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.
- Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements they must meet 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 exceptionally provide for costs for the exercise of rights. We will inform affected persons in advance of any costs.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
5.2 Right to Lodge a Complaint
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data 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 suitable technical and organizational measures to ensure data security appropriate to the respective risk. 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 mark transport encryption with a padlock in the address bar.
Our digital communications – like all digital communications in principle – are subject 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.
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 possible for numerous 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 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 reliably, 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.
7.3 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. With pixel counters, the same information can be collected as in server log files.
We enable you to publish comments on our website. In this context, we process in particular the information that a commenting person transmits to us, but also the Internet Protocol (IP) address used as well as the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.
We allow you to subscribe to email notifications of new comments from other people. In this context, we need your e-mail address in particular so that we can notify you or have you notified by e-mail. You may unsubscribe from such comment notifications at any time.
8. Notifications and Messages
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 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 capture 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 based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.
8.2 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, 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 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. Required notifications and communications in connection with our activities and operations remain reserved.
9. Services from Third Parties
We use services of specialized third parties to perform our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in 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-related, statistical and technical purposes, third parties whose services we use may process data in connection with 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.
9.1 Digital Infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
9.2 Digital Audio and Video Content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
We use in particular:
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Privacy and Security Center”, “My Data on YouTube”.
We use specialized service providers to process our customers’ payments securely and reliably. The legal texts of the individual service providers, such as the General Terms and Conditions (GTC) or data protection declarations, also apply to the processing of payments.
We use in particular:
10. Extensions for the Website
We use extensions for our website in order to be able to use additional functions.
We use in particular:
11. 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 activities and operations as well as the effect of third-party links to our website. However, 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 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 (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization and thus improve user data protection.
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 users. Individual services of third parties with which users are registered may be able to assign the use of our online service to the user account or user profile of the respective service.
We use in particular:
12. Final Provisions
We can adapt and supplement this data protection declaration at any time. We will inform about such adaptations and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.