Privacy policy of the Swiss Beauty AG

The Swiss Beauty AG (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA». However, the application of these laws depends on each individual case.

Type of personal data

General personal data

We process general personal data about you.

Example: Your contact details to send you an invoice.

Financial data

We process your financial data.

Example: Your invoice data as well as the payment history for collection.

Source of personal data

Provided Data

We process personal data that you provide to us.

Example: When they fill in a contact form or sign up for the newsletter.

Collected Data

We process personal data that we collect about you.

Example: IP address when you access the website.

Received Data

We process personal data about you that we receive from third parties.

Example: From public registers such as the debt enforcement register or the commercial register.

Purpose of processing

Marketing

We use your personal data for marketing and advertising.

Example: The sending of a newsletter.

Product Development

We use your personal data for the development and improvement of products and services.

Example: We analyse data about click behaviour on the website to improve the user experience.

Other Purposes

We use your personal data for other purposes without direct connection with the core service.

Example: For the creation of a contract.

Passing on to third parties

Data sharing

We share your personal data with other companies or authorities who can decide for themselves how they use the data.

Example: We hand over an unpaid bill to a debt collection agency.

Place of processing

Switzerland

We only process your personal data in Switzerland.

Example: We use the services of a cloud provider from Switzerland.

01 What is this Privacy Notice about?

In this Privacy Notice, we describe what we do with your data when you use swissbeauty.net, our other websites or apps («website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

02 Who is the controller for processing your data?

The Swiss Beauty AG, 9030 Abtwil, is the controller for The Swiss Beauty AG’s processing under this Privacy Notice, unless we tell you otherwise in an individual case

You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:

Swiss Beauty AG
Bildstrasse 34
CH-9030 Abtwil

info@swissbeauty.net

03 What data do we process?

We process various categories of data about you. The main categories of data are the following:

Technical data: When you use our website or other online offerings (for example free Wi-Fi), we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for 12 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.

Technical data includes, among other things, the IP address and information about the operating system of your terminal device, the date, region and time of use, as well as the type of browser you use to access our electronic offerings. This can help us to provide the correct formatting of the website or to show you a website adapted for your region, for example. Based on the IP address, we know which provider you use to access our offers (and thus also the region), but we cannot usually deduce who you are from this. This changes when you create a user account, for example, because personal data can then be linked to technical data (e.g. we can see which browser you use to access an account via our website). Examples of technical data also include logs that occur in our systems (e.g. the log of user logins on our website).

Registration data: Certain offerings, for example competitions, and services (such as login areas of our website, newsletters, free WLAN access, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. Registration data may be required in relation to access control to certain facilities, potentially including biometric data, depending on the control system. We generally keep registration data for 12 months from the date the use of the service ceases or the user account is closed.

Registration data includes, among other things, the information you provide when you create an account on our website (e.g. user name, password, name, e-mail). However, registration data also includes the data we may require from you before you can use certain free services such as our Wi-Fi service, in which case: name, email and telephone number; or the redemption of vouchers, in which case: name, address, contact details, time of redemption. You also need to register if you want to subscribe to our newsletter.

Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we have to determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of an ID document). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years.

Communication data is your name and contact details, the manner and place and time of communication and usually also its content (i.e. the content of emails, letters, chats, etc.). This data may also include details of third parties. For identification purposes, we may also process your ID number or a password set by you.

Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process health data and information about third parties as part of master data. We may also collect master data from our shareholders and investors. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.

Master Data includes, for example, data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, details of associated persons, websites, social media profiles, photographs and videos, copies of identification documents; also details of your relationship with us (customer, supplier, visitor, service recipient etc.), details of your status with us, allocations, classifications and distributions, details of our interactions with you (if any, a history of these with appropriate entries), reports (e.g. from the media), information about your relationship with us (e.g. from the media). ), details of your status with us, allocations, classifications and distribution lists, details of our interactions with you (if applicable, a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. excerpts from the commercial register, authorisations etc.) which concern you. As payment information, we collect e.g. your bank details, account number and credit card data. Consent or blocking notices are also part of the master data, as are details about third parties, e.g. contact persons, recipients of services, advertising recipients or representatives.

In the case of contact persons and representatives of our customers, suppliers and partners, we process as master data e.g. name and address, information on role, function in the company, qualifications and, if applicable, information on superiors, employees and subordinates and information on interactions with these persons.

Master data is not collected comprehensively for all contacts. Which data we collect in detail depends in particular on the purpose of the processing.

Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). This includes health data and information about third parties, for example about hereditary diseases in a family. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.

Contract data includes information about the conclusion of the contract, about your contracts, e.g. the type and date of the conclusion of the contract, information from the application process (such as an application for our products or services) and information about the contract in question (e.g. its duration) and the processing and administration of the contracts (e.g. information relating to invoicing, customer service, assistance with technical matters and the enforcement of contractual claims). Contract data also includes information about defects, complaints and adjustments to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contractual data also includes financial data such as information about creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood that debts will be paid), about reminders and about debt collection. We receive this data partly from you (e.g. when you make payments), but also from credit agencies and debt collection companies and from publicly accessible sources (e.g. a commercial register).

We only provide certain services to you if you provide us with registration data because we or our contractual partners want to know who is using our services or has accepted an invitation to an event, because it is technically necessary or because we want to communicate with you. If you or a person you represent (e.g. your employer) want to conclude or fulfil a contract with us, we must collect corresponding master, contract and communication data from you, and we process technical data if you want to use our website or other electronic offers for this purpose. If you do not provide us with the data required for the conclusion and performance of the contract, you must expect that we will refuse to conclude the contract, that you will commit a breach of contract or that we will not perform the contract. Similarly, we can only send you a response to an enquiry from you if we process the relevant communication data and, if you communicate with us online, technical data where applicable. It is also not possible to use our website without us receiving technical data.

04 For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

This is for all purposes in relation to which you and we communicate, whether in customer service or consultation, authentication in the event of use of the website or for training and quality assurance (e.g. in the area of customer service). We further process communication data so that we can communicate with you by email and telephone, as well as messenger services, chat, social media, letter and fax. Communication with you is usually in connection with other processing purposes, e.g. so that we can provide services or respond to a request for information. Our data processing also serves to provide evidence of the communication and its content.

We process data for the purpose of establishing, managing and processing contractual relationships.

We conclude contracts of various kinds with our business and private clients, with suppliers, subcontractors or other contractual partners such as partners in projects or with parties in legal disputes. In doing so, we process in particular master data, contract data and communication data and, depending on the circumstances, also registration data of the client or the persons to whom the client procures a service.

In the context of initiating business, personal data – in particular master data, contract data and communication data – is collected from potential customers or other contractual partners (e.g. in an order form or contract) or results from a communication. We also process data in connection with the conclusion of a contract to check creditworthiness and to open the customer relationship. In some cases, this information is checked for compliance with legal requirements.

In the context of the processing of contractual relationships, we process data for the administration of the customer relationship, for the provision and collection of contractual services (which also includes the involvement of third parties, for advice and for customer care. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the processing, as is accounting, termination of contracts and public communication.

We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, contests, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 12).

For example, with your consent, we will send you information and product offers from us in printed form, electronically or by telephone. For this purpose, we mainly process communication and registration data. Like most companies, we personalise communications so that we can provide you with personalised information and offers that meet your needs and interests. To do this, we combine data that we process about you with preference data and use this data as the basis for personalisation (see section 3).

Relationship management also includes addressing existing customers and their contacts, possibly personalised on the basis of behavioural and preference data. In the context of relationship management, we may also operate a customer relationship management system (“CRM”) in which we store the data on customers, suppliers and other business partners necessary for the relationship management, e.g. on contact persons, on the relationship history (e.g. on products and services purchased or supplied, interactions, etc.), interests, wishes, marketing measures (newsletters, invitations to events, etc.) and other information.

All this processing is important for us not only to promote our offers as effectively as possible, but also to make our relationships with customers more personal and positive, to focus on the most important relationships and to use our resources as efficiently as possible.

We further process your data for market research, to improve our services and operations and for product development.

We strive to continuously improve our products and services (including our website) and to be able to react quickly to changing needs. We therefore analyse, for example, how you navigate through our website or which products are used by which groups of people and how new products and services can be designed (for further details see section 12). This provides us with information on the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioural data and preference data, but also communication data and information from customer surveys, polls and studies and other information, e.g. from the media, from social media, from the Internet and from other public sources. Where possible, we use pseudonymised or anonymised information for these purposes. We may also use media monitoring services or carry out media monitoring ourselves and process personal data in the process in order to carry out media work or to understand and respond to current developments and trends.

With your consent, we use non-anonymised location data to point you to interesting offers and products in the vicinity based on your position, to infer your interests from the position data (dwell time) and to tell you which products and services other contractual partners with similar interests have used.

We may also process your data for security and access control purposes.

We continuously review and improve the appropriate security of our IT and other infrastructure (e.g. buildings). Like all companies, we cannot rule out data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, controls, analyses and tests of our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of security copies. Access controls include, on the one hand, controlling access to electronic systems (e.g. logging into user accounts), but also physical access control (e.g. building access).

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

This includes, for example, the implementation of health and safety concepts or the legally regulated fight against money laundering and terrorist financing. In certain cases, we may be obliged to make certain inquiries about customers (“Know Your Customer”) or to report to the authorities. The fulfilment of obligations to provide information or to report, e.g. in connection with supervisory and tax obligations, also requires or entails data processing, e.g. the fulfilment of archiving obligations and the prevention, detection and clarification of criminal offences and other violations. This also includes the receipt and processing of complaints and other reports, the monitoring of communications, internal investigations or the disclosure of documents to an authority if we have sufficient reason to do so or are legally obliged to do so. We may also process personal data about you in the course of external investigations, for example, by a law enforcement or regulatory agency or an appointed private body. For all these purposes, we process in particular your master data, your contract data and communication data, but possibly also behavioural data and data from the category of other data. The legal obligations may be Swiss law, but also foreign regulations to which we are subject, as well as self-regulations, industry standards, our own “corporate governance” and official instructions and requests.

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

For these purposes, we process in particular master data, contract data, registration data and technical data, but also behavioural and communication data. For example, we need to monitor our debtors and creditors as part of our financial management, and we need to avoid becoming victims of crime and abuse, which may require us to analyse data for relevant patterns. We may also carry out profiling and create and process profiles for these purposes and for your and our protection against criminal or abusive activities (see also section 6). In the context of planning our resources and organising our operations, we need to evaluate and process data on the use of our services and other offers or exchange information on this with others (e.g. outsourcing partners), which may also include your data. The same applies with regard to services provided to us by third parties. As part of the development of our business, we may sell or acquire businesses, parts of businesses or companies to or from others or enter into partnerships, which may also result in the exchange and processing of data (including from you, e.g. as a customer or supplier or as a supplier representative).

We may process your data for further purposes, for example as part of our internal processes and administration.

05 On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for marketing mailings, for personalized motion profiles and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiatingor performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).

06 What applies in case of profiling and automated individual decisions?

We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics.

In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.

07 With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers
Contractual partners including customers: This refers to customers (for example service recipients) and our other contractual partners as this data disclosure results from these contracts. For example, they receive registration data in relation to issued and redeemed vouchers, invitations, etc. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. This may include health data.
Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.
Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4, for example service recipients, the media and associations in which we participate or if you are included in one of our publications.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if we are required to do so by law). Notwithstanding the foregoing, your data will continue to be subject to adequate data protection in Switzerland and the rest of Europe, even after disclosure. For disclosure to other countries, the provisions of Section 8 apply. If you do not wish certain data to be disclosed, please let us know so that we can review if and to what extent we can accommodate your concern (Section 2).

In addition, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example press photographers, providers of tools on our website, etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 12 for the website.

08 Is your personal data disclosed abroad?

As explained in section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in Switzerland; in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Many countries outside of Switzerland or the EU and EEA do not currently have laws that guarantee an adequate level of data protection from the perspective of the DPA or the GDPR. The aforementioned contractual arrangements can partially compensate for this weaker or missing legal protection. However, contractual precautions cannot eliminate all risks (namely of state access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymisation or anonymisation) to minimise it.

Please also note that data exchanged via the internet is often routed via third countries. Your data may therefore end up abroad even if the sender and recipient are in the same country.

09 How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in the event of legal claims, discrepancies, IT and infrastructure security purposes and evidence of good corporate governance and compliance. Retention may be technically necessary if certain data cannot be separated from other data and we therefore need to retain it with them (e.g. in the case of backups or document management systems).

10 How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

Security measures of a technical nature and of an organisational nature may include, for example, measures such as the encryption and pseudonymisation of data, logging, access restrictions, the storage of backup copies, instructions to our employees, confidentiality agreements and controls. We protect your data transmitted via our website in transit using appropriate encryption mechanisms. However, we can only secure areas that we control. We also oblige our contract processors to take appropriate security measures. However, security risks cannot generally be completely ruled out; residual risks are unavoidable.

11 What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

The right to request information from us as to whether and what data we process from you;
The right to have us correct data if it is inaccurate;
The right to request erasure of data;
The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
The right to withdraw consent, where our processing is based on your consent;
The right to receive, upon request, further information that is helpful for the exercise of these rights;

If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

12 Do we use online tracking and online advertising techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).

Cookies are individual codes (e.g. a serial number) that our server or a server of our service providers or advertising contract partners transmits to your system when you connect to our website and that your system (browser, mobile) accepts and stores until the programmed expiry time. With each subsequent access, your system transmits these codes to our server or the server of the third party. In this way, you are recognised even if your identity is unknown.

Other techniques may also be used to recognise you with a greater or lesser degree of probability (i.e. to distinguish you from other users), e.g. “fingerprinting”. Fingerprinting combines your IP address, the browser you use, the screen resolution, the language choice and other information that your system communicates to each server), resulting in a more or less unique fingerprint. In this way, cookies can be dispensed with.

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can therefore be “tracked” (traced). If we integrate the provider of an analysis tool on our website, it can track you in the same way, even if you cannot be identified in individual cases.

We use these technologies on our website and may allow certain third parties to do so as well. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to [24] months.
Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.

We currently use offers from the following service providers

Google Analytics

If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The responsible entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).Google Analytics uses cookies, which enable an analysis of your use of our website. The information collected by means of the cookies about your use of this website is generally transmitted to a Google server in the USA and stored there.

We use the User ID function. With the help of the User ID, we can assign a unique, permanent ID to one or more sessions (and the activities within these sessions) and analyse user behaviour across devices.

In Google Analytics 4, the anonymisation of IP addresses is activated by default. Due to IP anonymisation, your IP address will be truncated by Google within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.During your website visit, your user behaviour will be recorded in the form of “events”. Events can be:

Page views
First visit to the website
Start of session
Your “click path”, interaction with the website
Scrolls (whenever a user scrolls to the bottom of the page (90%))
Clicks on external links
Internal search queries
Interaction with videos
file downloads
ads seen / clicked on
language setting

In addition, the following is recorded:

Your approximate location (region)
Your IP address (in shortened form)
Technical information about your browser and the terminal devices you use (e.g. language setting, screen resolution)
your internet service provider
the referrer URL (via which website/advertising medium you came to this website)

On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, and compiling reports on website activity. The reports provided by Google Analytics are used to analyse the performance of our website and the success of our marketing campaigns.

Recipients of the data are/may be

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (als Auftragsverarbeiter nach Art. 28 DSGVO)
Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

It cannot be ruled out that US authorities will access the data stored by Google.

Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not have any legal remedies against access by authorities.

The data sent by us and linked to cookies are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

The legal basis for this data processing is your consent pursuant to Art.6 Para.1 S.1 lit.a DSGVO.

You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. The lawfulness of the processing carried out on the basis of the consent until the revocation remains unaffected.

You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, functionalities on this and other websites may be restricted. You can also prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) by Google and the processing of this data by Google by

1. not giving your consent to the setting of the cookie or

b. downloading and installing the browser add-on to deactivate Google Analytics HERE.

You can find more information on the terms of use of Google Analytics and on data protection at Google at https://marketingplatform.google.com/about/analytics/terms/de/ and at https://policies.google.com/?hl=de.

Google AdWords and Google Conversion Tracking

This website uses Google AdWords. AdWords is an online advertising programme of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Within the framework of Google AdWords, we use so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the internet browser stores on the user’s computer. These cookies lose their validity after 30 days and are not used to personally identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we will be able to recognise that the user clicked on the ad and was redirected to this page.

Each Google AdWords customer receives a different cookie. The cookies cannot be tracked across AdWords customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking, you can object to this use by easily deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.

The storage of “conversion cookies” and the use of this tracking tool are based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.

More information on Google AdWords and Google conversion tracking can be found in Google’s privacy policy: https://www.google.de/policies/privacy/.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.

Google reCAPTCHA

We use the reCAPTCHA service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) on our website. The purpose of the query is to distinguish whether the input is made by a human or by automated, machine processing. The query includes the sending of the IP address and, if applicable, further data required by Google for the reCAPTCHA service to Google. For this purpose, your input will be transmitted to Google and further used there. However, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the service. The IP address transmitted by your browser as part of reCaptcha will not be merged with other Google data. Your data may also be transmitted to the USA. An adequacy decision of the European Commission, the “Privacy Shield”, exists for data transfers to the USA. Google participates in the “Privacy Shield” and has submitted to the requirements. By pressing the button, you consent to the processing of your data. The processing is based on Art. 6 (1) lit. a DSGVO with your consent. You can revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent up to the revocation. You can find more information on Google reCAPTCHA and the associated data protection declaration at: https://www.google.com/privacy/ads/

Malcare

WordPress Sicherheit und Backup; bereitgestellt von Inactiv.com Media Solutions Private Limited, Bangalore, Indien;

Website: https://www.malcare.com/;

Datenschutzerklärung: https://www.malcare.com/privacy/;

DSGVO: https://www.malcare.com/gdpr/

Consent with Borlabs Cookie

Our website uses Borlabs Cookie Consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs). When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not shared with the Borlabs cookie provider. The collected data will be stored until you request us to delete it or until you delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at

https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

. Borlabs Cookie Consent Technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c DSGVO.

Google Maps with Borlabs Cookie

We integrate the maps of the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The Google Map is hidden by a cookie message and must be explicitly accepted.

Opt-Out: https://adssettings.google.com/authenticated

Youtube

We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

Privacy and Security Centre: https://support.google.com/youtube/topic/2803240?hl=de

My data on YouTube: https://support.google.com/youtube/answer/9315727?hl=de

Opt-Out: https://adssettings.google.com/authenticated

Vimeo

We embed the videos of the platform “Vimeo” of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA.

Opt-Out: https://tools.google.com/dlpage/gaoptout

Google Fonts

We integrate the fonts (“Google Fonts”, etc.) locally via our server.

UpdraftPlus

Wir verwenden den Backup-Service “UpdraftPlus”. UpdraftPlus, Warenzeichen der Simba Hosting Ltd.

UK registered company number: 8570611, VAT number: 202 1260 80, Produktentwicklung und Marketing in Zusammenarbeit mit XIBO Ltd, Cardiff, UK.

Datenschutzerklärung: https://updraftplus.com/data-protection-and-privacy-centre/

Datenschutzrichtlinie für die Verwendung der integrierten Dropbox-App:

https://updraftplus.com/faqs/what-is-your-privacy-policy-for-the-use-of-your-dropbox-app/

13 What data do we process on our social network pages?

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We receive data about you when you communicate with us via online presences or view our content on the corresponding platforms, visit our online presences or are active on them (e.g. publish content, submit comments). These platforms also collect, among other things, technical data, registration data, communication data, behavioural data and preference data from you or about you (for the terms see section 3). These platforms regularly evaluate the way in which you interact with us, how you use our online presences, our content or other parts of the platform (what you look at, comment on, “like”, pass on etc.) and link this data to other information about you (e.g. information on age and gender and other demographic information). In this way, they also create profiles about you and statistics on the use of our online presences. They use this data and profiles to show you our or other advertising and other content on the platform in a personalised way and to control the behaviour of the platform, but also for market and user research and to provide us and other bodies with information about you and the use of our online presence. We may partially control the analyses that these platforms generate regarding the use of our online presences.

We process this data for the purposes described in section 4, in particular for communication, marketing purposes (including advertising on these platforms, see section 12) and market research. You will find information on the relevant legal basis in section 5. Content published by you (e.g. comments on an announcement) may be disseminated by us (e.g. in our advertising on the platform or elsewhere). We or the platform operators may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further details on the edits made by the operators of the platforms, please refer to the platforms’ data protection notices. There you will also find out in which countries they process your data, what rights you have to information, deletion and other data subjects and how you can exercise these or obtain further information.

14 Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Sources:

This privacy statement was created, reviewed, adapted and supplemented on the basis of the publicly available “DSAT Privacy Self Assessment Tool” (dsat.ch).

For additional transparency, we use the privacy icons of the PRIVACY ICONS association.

Last update: 10.12.2023