Data protection declaration
With this data protection declaration we inform which personal data we process in connection with our activities and operations including our
Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation.
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.
1. Contact address
Responsibility for the processing of personal data:
Reto Seiler
Stationstrasse 17a
8952 Schlieren
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
2.1 Terms
Personal data is any information that relates 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) plus 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:
- Art. 6 par. 1 lit. b GDPR 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.
- Art. 6 par. 1 lit. f GDPR 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 override. 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 and 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 par. 1 lit. c GDPR 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 par. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 par. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 par. 1 lit. d GDPR 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, safe and reliable manner. Such personal data may 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, in particular.
We process personal data for the period of time that is necessary for the respective purpose(s) or required by law. Personal data whose processing is no longer necessary is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer 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 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 safeguard 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 mail, 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 about other persons, the transmitting persons are obliged to ensure data protection towards 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 basically 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 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. 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 information about any guarantees to data subjects upon request or provide a copy of any guarantees.
5. Rights of data subjects
5.1 Claims under data protection law
We grant data subjects all claims in accordance with applicable data protection law. Data subjects have the following rights in particular:
- 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 are also provided with the information necessary to assert their claims under data protection law 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 can have incorrect personal data corrected, incomplete data completed 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 with effect for the future.
- 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, limit or deny the exercise of data subjects’ rights to the extent permitted by law. We can point out to data subjects any requirements they may have to meet in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part on the grounds of trade secrets or the protection of others. For example, we may also 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 the rights. We inform affected persons in advance about any costs.
We are required to take reasonable steps to identify data subjects who request information or assert other rights. Affected persons are obliged to cooperate.
5.2 Right to complain
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 that is appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website takes place using 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.
7. Website use
7.1 Cookies
We may use cookies. Cookies — our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) — are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
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 make it possible 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.
Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request — at least if and to the extent necessary — the express consent to the use of cookies.
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. Counting 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 capture the same information as server log files.
8. Third party services
We use services of specialized third parties in order to carry out our activities and operations in a durable, user-friendly, safe and reliable manner. Among other things, such services allow us to embed functions 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.
- Microsoft services: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Data protection at Microsoft”, “Data protection and privacy (Trust Center)”, data protection declaration, data protection dashboard (data and privacy settings).
8.1 Digital infrastructure
We use services from specialized third parties to access 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:
- Hostpoint: Hosting; Provider: Hostpoint AG (Switzerland); Data protection information: Privacy policy.
- StackPath CDN: Content Delivery Network (CDN); Anbieterinnen: StackPath LLC (USA) / Highwinds Network Group Inc. (USA); Data protection information: Privacy policy.
8.2 Audio and video conferencing
We use specialized audio and video conferencing services to communicate online. For example, we can use it to hold virtual meetings or conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services such as data protection declarations and terms of use apply in addition.
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or fading in a virtual background.
We use in particular:
- Microsoft Teams: platform for audio and video conferencing, among other things; provider: Microsoft; Teams-specific information: “Privacy and Microsoft Teams”.
9. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
We use in particular:
- jQuery (OpenJS Foundation): Free JavaScript library; provider: OpenJS Foundation (USA) using StackPath CDN; privacy information: privacy policy (OpenJS Foundation), cookie policy (OpenJS Foundation).
10. Final provisions
We have created this privacy policy with the data protection generator of Datenschutzpartner.
We may amend and supplement this privacy policy at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.