Our offer is 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 addresses
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.
1.1 Data protection officer
We have the following data protection officer as a point of contact for data subjects and as a contact for supervisory authorities in the event of data protection-related inquiries:
1.2 Data Protection Representation in the European Economic Area (EEA)
We have the following data protection representation according to Art. 27 DSGVO. The Data Protection Representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the General Data Protection Regulation (GDPR):
VGS Data Protection Partner UG
Am Kaiserkai 69
2. terms and legal bases
Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of 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 – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – 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 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 provide our offer permanently, in a user-friendly, secure and reliable manner, as well as to be able to advertise for it as required, information security as well as protection against misuse and unauthorized use, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 par. 1 lit. c GDPR for the processing of personal data necessary 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. nature, scope and purpose
We process those personal data that are necessary to provide our offer permanently, user-friendly, secure and reliable. In particular, 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, contract data and payment data.
We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary is anonymized or deleted. Persons whose data we process have, in principle, a right to deletion.
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 appropriate data protection with such third parties.
We process personal data basically only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, 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 and personally 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 you transmit personal data to us via third parties, you are obligated to ensure data protection vis-à-vis such third parties as well as to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.
We process personal data about applicants to the extent that it is necessary for assessing their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants provide voluntarily, in particular as part of cover letters, resumes and other application documents.
5. 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 in order to process it or have it processed there.
We can transfer personal data to all States and territories on earth as well as elsewhere in the universe, provided that the law there according to assessment of the Federal Data Protection and Information Commissioner (FDPIC) or in accordance with a decision of the Swiss Federal Council, adequate data protection and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with Decision of the European Commission ensures adequate data protection.
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 by appropriate safeguards in the form of standard data protection clauses. 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.
6. rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. This includes the right to information as well as the right to rectification, deletion or blocking of the processed personal data.
Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.
Data subjects whose personal data we process may – if and insofar as the GDPR applies – revoke any consent they have given at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
7. data security
We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.
Access to our online offer takes place by means of 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.
Access to our online offering is subject – as is any use of the Internet – to mass surveillance without cause and without suspicion, as well as other surveillance by security authorities in Switzerland, the European Union (EU), 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.
8. use of the website
Cookies can be stored in your browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, cookies allow us to recognize your browser the next time you visit 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).
8.2 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 online offer 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.
8.3 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.
9. notifications and messages
We send notifications and communications such as newsletters by email and through other communication channels such as instant messaging.
9.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that capture whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to offer notifications and communications based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.
9.2 Consent and objection
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent to receive e-mails, we use the “double opt-in” procedure whenever possible, which means that 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 evidentiary and security purposes.
In principle, you can unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. Reserved are notifications and communications that are mandatory for our offer.
9.3 Service provider for notifications and messages
We send notifications and communications through third party services or with the help of service providers. Cookies may also be used in the process.
We use in particular:
10. social media
We are present on social media platforms and other online platforms in order to be able to communicate with interested persons and inform them about our offer. Personal data may also be processed outside Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland), if and to the extent that the GDPR is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.
11. services from third parties
We use services of third parties to provide our offer permanently, user-friendly, secure and reliable. Such services may also be used to embed content on our website. Such services require your Internet Protocol (IP) address, otherwise such services cannot transmit the corresponding content.
For their own security, statistical and technical purposes, third parties whose services we use may also process data related to our offer as well as from other sources – including cookies, log files and counting pixels – in aggregated, anonymized or pseudonymized form.
We use in particular:
11.1 Digital infrastructure
We use services from third parties in order to be able to make use of the digital infrastructure required for our offer. These include, for example, hosting and storage services from specialized providers.
We use in particular:
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
We engage in e-commerce and use third-party services to successfully provide services, content or goods.
We use in particular:
We use payment service providers to process payments from our customers securely and reliably. The terms and conditions of the respective payment service providers, such as general terms and conditions (GTC) or data protection declarations, shall apply to the processing in each case.
We use the option of displaying targeted advertising for our offer on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular people who are interested in our offer or already use our offer(remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine whether our advertising is successful, that is, in particular, whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are registered as a user can, if necessary, assign the use of our online offer to your profile there.
We use in particular:
- Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting in particular with the Facebook pixel as well as Custom Audiences including Lookalike Audiences, data protection declaration, “advertising preferences” (user registration required).
- Google Ads: Search engine advertising; Google Ads-specific privacy disclosures: advertising based on search queries, among other things, using different domain names – in particular doubleclick.net, googleadservices.com, and googlesyndication.com – for Google Ads, “Advertising” (Google), ” Why am I seeing a particular ad?”.
12. 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 online offering 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 particularly 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 in order to follow the principle of data economy through the corresponding pseudonymization and to improve the data protection of visitors to our website (“IP masking”).
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 visitors to our website. Individual services with which you are registered as a user may assign the use of our online service to your profile with the respective service, whereby you usually had to give your consent to this assignment in advance.
We use in particular:
- Matomo: Performance and reach measurement; provider: Matomo (free open source software); data protection information: used on own server infrastructure and with pseudonymized Internet Protocol (IP) addresses, “List of all Matomo Features”.
13. final provisions