Privacy Policy

The controller within the meaning of data protection law is:

In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. On request, we are happy to inform data subjects about the respective responsibility.

Data subject: Natural person about whom we process personal data.

Personal data: All information relating to an identified or identifiable natural person.

Sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data on health, the private sphere or racial or ethnic origin, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative proceedings or sanctions, and data on social assistance measures.

Processing: Any handling of personal data, irrespective of the means and procedures applied, for example the querying, matching, adapting, archiving, retaining, reading out, disclosing, obtaining, recording, collecting, erasing, revealing, arranging, organising, storing, altering, disseminating, linking, destroying and using of personal data.

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

We process those personal data that are necessary in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. The personal data processed may in particular fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar as such processing is permitted.

Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example in order to comply with legal obligations or to protect overriding interests. We may also ask data subjects for their consent where their consent is not required.

We process personal data for the periodnecessary for the respective purpose. We anonymise or erase personal data in particular depending on statutory retention periods and limitation periods.

We may process personal data in an automated manner or use artificial intelligence for the processing of personal data.

We may use profiling to automatically evaluate certain personal aspects relating to data subjects. Profiling serves, for example, to analyse or predict interests, behaviour or personal preferences.

In individual cases, we provide information on decisions that are based exclusively on automated processing of personal data and that have legal consequences for the data subjects or significantly affect them (automated individual decisions).

We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties may, for example, be specialised providers whose services we use.

In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, advisers and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurers and payment service providers.

We process personal data in order to be able to communicate with individual persons as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons to us are obliged to ensure the data protection of these data subjects independently. In particular, they must ensure that such data is accurate and may be transmitted.

We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without, however, being able to guarantee absolute data security.

Access to our website and our other digital presence is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.

Our digital communication is subject, as is generally all digital communication, to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities. Nor can we rule out that a data subject is monitored in a targeted manner.

We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it there or have it processed there.

We may disclose personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures adequate data protection as determined by the Swiss Federal Council in its decision on adequacy.

We may disclose personal data to countries whose law does not ensure adequate data protection, provided that suitable data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other suitable safeguards. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements for this are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. On request, we are happy to inform data subjects about any safeguards or to provide a copy of the safeguards.

We grant data subjects all rights under the applicable law. In particular, data subjects have the following rights:

• Access: Data subjects may request information as to whether we process personal data about them and, if so, which personal data. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the retention period, any disclosure or export of data to other countries and the origin of the personal data.
• Rectification and restriction: Data subjects may have inaccurate personal data rectified, incomplete data completed and the processing of their data restricted.
• Right to state their own position and to human review: In the case of decisions that are based exclusively on automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions), data subjects may state their own position and request review by a human being.
• Erasure and objection: Data subjects may have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
• Data release and data portability: Data subjects may request the release of personal data or the transfer of their data to another controller.

We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may inform data subjects of any conditions to be met for the exercise of their data protection rights. For example, we may refuse access in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. We may also, for example, refuse the erasure of personal data in whole or in part, in particular with reference to statutory retention obligations.

We may exceptionally charge costs for the exercise of rights. We inform data subjects in advance of any costs.

We are obliged to identify data subjects who request access or assert other rights by means of appropriate measures. Data subjects are obliged to cooperate.

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

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

We may use cookies. Cookies, both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies), are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies may be stored in the browser temporarily as “session cookies” or for a certain period 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 recognise a browser on the next visit to our website and thereby, for example, to measure the reach of our website. Permanent cookies may, however, also be used for online marketing, for example.

Cookies may be deactivated, restricted or deleted in whole or in part in the browser settings at any time. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be available to its full extent. We actively request express consent to the use of cookies, at least where and to the extent required under the applicable law.

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).

For each access to our website and our other digital presence, we may log at least the following information, provided that it is determined or transmitted to our digital infrastructure by default during such 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 individual sub-page of our website accessed including the amount of data transferred, and the last web page accessed in the same browser window (referer or referrer).

We log such information, which may also constitute personal data, in log files. The information is necessary in order to provide our digital presence in a sustainable, user-friendly and reliable manner. The information is also necessary in order to ensure data security, including through or with the help of third parties.

We may embed tracking pixels in our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels, including those of third parties whose services we use, are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as logging in log files.

Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We need this statistical recording of use for performance and reach measurement in order to send notifications and communications effectively and in a user-friendly manner, as well as sustainably, securely and reliably, based on the needs and reading habits of the recipients.

You must generally consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. To obtain a double-confirmed consent where applicable, we may use the “double opt-in” procedure. In this case, you receive a communication with instructions for the double confirmation. We may log consents obtained, including IP address and timestamp, for evidence and security reasons.

You may generally object at any time to receiving notifications and communications such as newsletters. With such an objection, you may at the same time object to the statistical recording of use for performance and reach measurement. Necessary notifications and communications in connection with our activities and operations remain reserved.

We send notifications and communications with the help of specialised service providers.

We use in particular:

• Resend: e-mail delivery platform for developers; provider: Plus Five Five Inc. (USA); information on data protection: Privacy Policy, “Security”.

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.

The general terms and conditions (GTC) and terms of use as well as the privacy policies and other provisions of the individual operators of such platforms also apply. In particular, these provisions provide information on the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

We use services of specialised third parties in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Among other things, such services allow us to embed functions and content in our website. In the case of such embedding, the services used capture the IP addresses of users at least temporarily, for technically unavoidable 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, anonymised or pseudonymised form. This concerns, for example, performance or usage data in order to be able to offer the respective service.

We use services of specialised third parties in order to obtain the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

We use specialised service providers in order to process payments securely and reliably. The legal texts of the individual service providers, for example general terms and conditions (GTC) or privacy policies, additionally apply to the processing of payments.

We use extensions for our website in order to use additional functions. We may use selected services from suitable providers or run such extensions on our own digital infrastructure.

We try to measure the performance and reach of our activities and operations. In this context, we may also measure the effect of third-party references or test how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of performance and reach measurement, we may in particular fix errors, strengthen popular content or make improvements.

In most cases, the IP addresses of individual users are recorded for performance and reach measurement. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data minimisation through the corresponding pseudonymisation.

Cookies may be used and user profiles may be created for performance and reach measurement. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window, and the location, at least approximately. Generally, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are logged in may be able to attribute the use of our online offering to the user account or user profile with the respective service.

We may update this privacy policy at any time. We provide information on updates in an appropriate form, in particular by publishing the current privacy policy on our website.