1. Introduction

Based on Article 13 of the Swiss Federal Constitution and the federal data protection provisions (Federal Act on Data Protection, FADP) as well as the EU General Data Protection Regulation (GDPR), everyone has the right to the protection of their privacy and to protection against the misuse of personal data. The protection of your personal data is important to us. You can expect us to handle your data sensitively and carefully and to ensure a high level of data security.

This Privacy Policy explains the collection and further processing of personal data by the ITRIS Group, insofar as this does not arise from the circumstances or is regulated by law.

2. Name and address of the controller

The controller within the meaning of the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR) is:

ITRIS Group

Industriestrasse 169

8957 Spreitenbach, Switzerland

Telephone: +41 56 418 65 65

Email: datenschutz@itris.ch

Website: www.itris.ch

The ITRIS Group has not appointed a data protection adviser or data protection officer within the meaning of Art. 10 FADP or Art. 37 GDPR. Any enquiries, claims or information relating to data protection law must be directed to the aforementioned contact details of the controller.

3. Categories of personal data processed

We may process the following categories of personal data in connection with our services:

• Master data: Master data refers to the basic data that we need in addition to the contract data (see below) for the processing of our contractual and other business relationships or for marketing and advertising purposes. This includes but is not limited to first name, surname, gender, address (private and/or business), date of birth, details of role and professional or other interests;
• Communication data: If you contact us via the contact form, by email, telephone, letter or other means of communication, we collect the information exchanged between you and us, including contact details and marginal data of the communication. This may include your telephone number; email address (private and/or business); fax number, if applicable; content of the communication (e.g. emails, letters, faxes); preferred communication channel; and language of correspondence;
• Contract data: This is data that arises in connection with the conclusion or execution of a contract. This includes, but is not limited to, information on previous business, information on business transactions, enquiries, quotes, offers, conditions and contracts for products and services delivered and sold as well as ordered and purchased, information in connection with queries, complaints and differences regarding products and services and/or the contracts concluded for this purpose, such as guarantee and warranty claims, withdrawals, etc.;
• Device data that can be unambiguously associated with persons at the customer’s end, such as applications, host name, IP address, domain, location, etc.;
• Financial data, such as payment details, billing and delivery addresses, etc.;
• Data related to the marketing of products and services: This includes, but is not limited to, information on marketing activities, documents received, invitations and participation in events and special activities, etc. In some cases, we also acquire addresses from third parties for our advertising and acquisition activities;
• Data related to the use of the website: This includes, but is not limited to, IP address and other identifiers (e.g. social media username, MAC address of the smartphone or computer, cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies) or other technologies that automatically collect personal data), date and time of the visit or use of the websites, pages and content accessed, referring websites, etc. You can find further information on this below under section 8 ‘Automated data collection and processing on our website’;
• Registration data: Certain offers and services (e.g. free Wi-Fi access) can only be used after registration. When registering, you must provide us with certain data, and we collect data about the use of the offer or service. Registration data may be generated in connection with access controls to certain facilities; depending on the control system this may include biometric data.
• Behavioural and preference data: Depending on our relationship with you, we try to get to know you and tailor our products, services and offers to you better. To do this, we collect and use data about your behaviour and preferences. We do so by evaluating information about your behaviour on our website, and we may supplement this information with information from third parties, including from publicly accessible sources. Based on this, we can calculate, for example, the probability of you using certain services or behaving in a certain way. Some of the data processed for this purpose is already known to us (e.g. when you use our services), or we may obtain this data by recording your behaviour (e.g. how you navigate on our website). Section 8 describes how tracking on our website works.
• Voluntary information: This includes data that you provide to us on a voluntary basis without our express request, such as special marketing preferences, etc.
• Third-party data: If you provide us with personal data of third parties as part of a business transaction (e.g. of subcontractors, employees, etc.), we will also process this data.

We collect and process data from the following persons (hereinafter ‘business partners’):

• Registered and unregistered visitors to our website;
• Contacts and employees of manufacturers, suppliers, traders, sellers and providers of the products and services we request;
• Customers, purchasers and recipients/beneficiaries or interested parties (potential customers) of our products and services (including warranty, repair and customer service) or their points of contact and employees;
• Points of contact and employees of business partners and affiliated companies, employment agencies and temporary employment agencies (as well as placed workers) and other trade and business partners;
• Participants in market research and opinion surveys conducted by us; participants in courses, seminars and events that we offer;
• Users of the Wi-Fi networks offered in our business premises and other locations.

The aforementioned personal data is collected directly from the data subjects in the course of using the website, when requesting or using products or services, participating in market or other surveys, at our events or in direct communication with us by email, telephone or other means.

However, the data may also be collected indirectly, in particular if transactions are carried out for the benefit of a business partner or for delivery to it by another business partner, at the recommendation of third parties (e.g. recommendation by acquaintances of the business partner) or by obtaining or purchasing supplementary information from third-party data sources (e.g. social media, address brokers).

4. Purpose of data processing and legal basis

We process the data of business partners – to the extent permitted by applicable law – for purposes particularly including but not limited to the following:

• To conclude and process your contractual relationship and process your enquiries and orders (Art. 30, Art. 31(1) and (2)(a) FADP/Art. 6(1)(b) GDPR): The purposes of data processing depend on the intended transaction. We collect this data to provide you with our services or to be able to obtain services from you;
• For the operation of our website (Art. 30 and Art. 31(1) and (2)(b) FADP/Art. 6(1)(b) and (f) GDPR): In particular, this includes managing the users of the website and the activities carried out on it, operating and further developing the website, ensuring that a connection can be established smoothly, evaluating system security and stability and other administrative purposes.
• For process and offer optimisation (Art. 30, Art. 31(1) and (2)(e) FADP/Art. 6(1)(a) and (f) GDPR): This includes quality control; the compilation of statistics, budgets and management information as well as their evaluation; market research and the further development of products and services as well as of the company and its processes;
• For marketing and advertising purposes (Art. 30 and Art. 31(1) FADP/Art. 6(1)(a) and (f) GDPR): This includes customer acquisition, customer retention, the implementation of customer loyalty programs, the optimisation of customer offers, market or opinion research, and the organisation of customer events. You can object to any processing or use of your data for direct marketing purposes at any time. The objection must be addressed to the controller;
• For security purposes and for access control (Art. 30 and Art. 31(1) FADP/Art. 6(1)(a) and (f) GDPR): We review and improve the adequate security of our IT and other infrastructure (e.g. buildings) on an ongoing basis. Like all companies, we cannot rule out data security breaches with absolute certainty, but we do what we can to reduce the risks. We therefore process data, for example, for monitoring, controlling, analysing and testing our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backup copies. Access controls include control of access to electronic systems (e.g. logging in to user accounts) and physical access control (e.g. building access). For security purposes (preventative and for investigating incidents), we also keep access logs and visitor lists and use surveillance systems (e.g. security cameras).
• For internal Group administration and support: We aim to structure our internal processes efficiently. We therefore also process personal data for the internal administration of the ITRIS Group (see section 5 on the ITRIS Group). For this purpose, we process master data, contract data and technical data in particular, as well as behavioural, transaction and communication data. Internal Group administration includes, in particular, IT and property management, bookkeeping and accounting, data archiving and the management of our archives, central storage and management of data used by multiple ITRIS Group companies (e.g. CRM), telephony and personnel administration.

• For compliance with legal and regulatory requirements (Art. 30 and Art. 31(1) FADP/Art. 6(1)(c) GDPR): We process your data to comply with the legal obligations to which we are subject. This includes the processing of data in the context of disclosure obligations vis-à-vis authorities and compliance with tax and/or commercial law regulations (e.g. retention obligations for business and accounting documents);
• For the sale or purchase of business divisions, companies or parts of companies and other corporate law transactions (Art. 30 and Art. 31(1) FADP/Art. 6(1)(a) and (f) GDPR).

The aforementioned purposes also constitute our legitimate interest in the processing of personal data pursuant to Art. 31(1) FADP or Art. 6(1)(f) GDPR.

Personal data is only processed for purposes other than those described if a legal provision permits this or if you have consented to the changed purpose of the data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you about these other purposes before further processing and provide you with all relevant information for this purpose.

5. Categories of data recipients

Generally, your personal data is only disclosed to the following recipients without your express prior consent:

• Group companies: You can find a list of our Group companies at https://www.itris.ch/en/unternehmen/. In accordance with this Privacy Policy, the Group companies may use the data for the same purposes as we do (see section 4). However, we primarily share data only in the course of joint operation of CRM, IT infrastructure, telephony, accounting and personnel administration, etc.
• Public bodies and authorities: If required for the investigation of unlawful use of our services or for legal proceedings, personal data will be forwarded to law enforcement authorities and, if necessary, to injured third parties. However, this only happens if there are concrete indications of unlawful behaviour or misuse. Data may also be disclosed if this serves to enforce terms of use or other agreements. We are also legally obliged to provide information on request to certain public bodies. These include law enforcement authorities, authorities that prosecute administrative offences that entail fines, and the tax authorities. This data is disclosed on the basis of our legitimate interest in combating misuse, prosecuting criminal offences, and securing, asserting and enforcing claims in accordance with Art. 30 and Art. 31(1) FADP and Art. 6(1)(f) GDPR.
• Processors: We rely on contractually bound third-party companies and external service providers (‘processors’) to provide our services. In such cases, personal data is disclosed to these processors to enable them to further process that data. We carefully select these processors and regularly review them. The processors may only use the data for the purposes that we specify and are also under contractual obligation to handle your data exclusively in accordance with this Privacy Policy and the applicable data protection laws.

Specifically, we use the following processors in particular:

• Subcontractors and cooperation partners we engage to provide the services owed to you;
• Companies for the purpose of centralised order processing and financial accounting;
• Logistics service providers for shipping the products, marketing documents or other items you have ordered from us;
• Payment service providers for processing payments from you to us or vice versa;
• Service providers for debt collection services, advertising and marketing or for conducting customer surveys;
• IT service providers for the provision of cloud services, software and hardware, and for carrying out maintenance work;
• Software providers for the use of communication services with customers, and in particular for the provision of event services.

Data is disclosed to processors on the basis of Art. 9 FADP or Art. 28 (1) GDPR, or alternatively on the basis of our legitimate interest in the economic and technical benefits associated with the use of specialised processors, provided that your rights and interests in the protection of your personal data do not prevail, Art. 31 (1) FADP or Art. 6(1)(f) GDPR.

• Suppliers: In the course of checks and audits on compliance with manufacturer specifications (e.g. for billing or compliance with credit limits), we allow suppliers to access the data we process (Art. 31(1) and (2)(a) FADP/Art. 6(1)(b) GDPR).

6. Transfer of data abroad

As a rule, your personal data is processed in Switzerland. However, we may transfer your data to trusted recipients in third countries (both in Europe and worldwide).

This is done on the basis of an adequacy decision of the Federal Council or the European Commission. If a recipient is located in a country without adequate statutory data protection, we oblige them to comply with the applicable data protection requirements on the basis of appropriate guarantees in accordance with Art. 16(2) FADP or Art. 46(2) GDPR, in particular through standard contractual clauses, which are also issued by the European Commission or recognised, issued or approved by the Federal Data Protection and Information Commissioner (FDPIC). We can waive such an obligation if we have recourse to a derogation. An exception may apply in the case of legal proceedings abroad, in particular, but also in cases of overriding public interests or if contract execution requires disclosure abroad, if you have consented to it, or if you have made the data in question generally accessible and you have not objected to its processing.

Here it cannot be precluded that we may transfer personal data to recipients in the United States. Please also note that data exchanged via the internet is often routed via third countries. Your data may therefore be sent abroad even if the sender and recipient are located in the same country.

7. Duration of storage

We store your personal data until the purpose for which it was processed (see section 4 above) no longer applies. If we are legally obliged to store personal data, it is stored for as long as the legal obligation is in place. For commercial documents, which include financial accounting and supporting documents (including invoices), this is up to 10 years. Your data may be blocked for ongoing operations during this period, unless there is no other purpose for processing it.

8. Automated data collection and processing on our website

Our website uses the following technologies and tools with which we and third parties commissioned by us can recognise you when you use the website and, in some cases, track you across multiple visits. If you do not wish to use them, we will suggest various options and settings for preventing their use in the respective tool. Unless stated otherwise, the processing of your personal data in this regard is based on the legal basis of your consent in accordance with Art. 31(1) FADP or Art. 6(1)(a) GDPR. In this case, you can withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent prior to withdrawal.

a) Cookies

Our website uses cookies. These are small text files that make it possible to store specific user-related information on the user’s device while they are using the website. In particular, cookies make it possible to determine the frequency of use and the number of users of the pages, to analyse the behaviour of page use, but also to make our service more customer-friendly. Cookies remain stored after the end of a browser session and can be retrieved when you visit the website again. Before we use cookies that go beyond what is necessary (e.g. for performance or marketing), we ask for your consent, which you can withdraw at any time via the cookie settings. Alternatively, you can set your internet browser so that it refuses to accept cookies.

A general objection to the use of cookies for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US website www.aboutads.info or the EU website www.youronlinechoices.com. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may not be able to use all features of this website.

b) SSL/TLS encryption

Our website uses SSL/TLS encryption for security reasons and to protect the transfer of confidential content, such as the enquiries you send to us as the site operator. You can identify an encrypted connection by the fact that the address line of the browser changes from http:// to https:// and by the lock icon in your browser’s address bar.

If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.

c) Contact form

If you send us enquiries via the contact form, we store your details from the enquiry form, including the contact details you provided there, for the purpose of processing the enquiry and in case of follow-up questions.

By activating the request, you consent to the corresponding processing of your data. You can withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent prior to withdrawal. The data from the contact form is not disclosed to third parties without your consent.

d) Google Maps

Our website uses the services of Google Maps. This allows us to display interactive maps directly on the website and enable you to conveniently use the map feature. When you visit the website, Google receives the information that you have accessed the corresponding page of our website. This takes place regardless of whether Google provides a user account through which you are logged in or whether there is no such user account. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or needs-based configuration of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles; however, you must contact Google to exercise this right. You can find further information on the purpose and scope of data collection and processing by Google, as well as further information on your rights in this regard and settings options to protect your privacy, at: https://policies.google.com/privacy.

e) Google Ads

Our website uses Google conversion tracking. If you have accessed our website via an advertisement placed by Google, Google Ads will set a cookie (see section 8 a.) on your computer. The conversion tracking cookie is set when a user clicks on an ad placed by Google. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can identify that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. This means that cookies cannot be tracked across the websites of Ads customers. The information collected using the conversion cookie is used to generate conversion statistics for Ads customers who have opted for conversion tracking. Customers find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

If you do not want to participate in tracking, you can prevent the required cookie from being set – for example by changing your browser settings to generally disable the automatic setting of cookies or setting your browser to block cookies from the domain ‘googleleadservices.com’.

Please note that you should not delete the opt-out cookies if you do not want measurement data to be recorded. If you have deleted all cookies from your browser, you will need to re-enable the opt-out cookie.

The legal basis for the processing of personal data using Google Ads is Art. 30 and Art. 31(1) FADP and Art. 6(1)(f) GDPR

f) Google reCAPTCHA

Our website uses the reCAPTCHA service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland – ‘Google’). The purpose of the query is to distinguish whether the input is made by a human or by automated machine processing. The query includes sending the IP address and any other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transferred to Google and used there. However, your IP address will be truncated beforehand by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the United States and truncated there. In the event of a corresponding order from our site, Google will use this information to evaluate your use of this service. The IP address transferred by your browser as part of reCAPTCHA will not be merged with other Google data. Your data may also be transferred to the United States. By activating the request, you consent to the corresponding processing of your data. The data is processed on the basis of Art. 31(1) FADP or Art. 6(1)(a) GDPR with your consent.

You can find more information about Google reCAPTCHA and the associated privacy policy at: https://policies.google.com/privacy.

g) Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the controller for data processing on our website is located outside the European Economic Area or Switzerland, Google Analytics data is processed by Google LLC (based in the United States). Google LLC and Google Ireland Limited are hereinafter referred to as ‘Google’.

We can use the statistics obtained to improve our offer and make it more interesting for you as a user. Our website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. If you have a Google user account, you can deactivate cross-device analysis of your use under ‘Data and privacy’ and ‘Personal info’.

We have configured the service in such a way that the IP addresses in Europe are truncated by Google before they are forwarded to the United States and thus cannot be traced. We have deactivated the ‘Data sharing’ and ‘Signals’ settings. Although we can therefore assume that the information we share with Google is not personal data for Google, it is possible that Google may draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to that person’s Google accounts. If you consent to the use of Google Analytics, you explicitly consent to such processing, which also includes the transfer of personal data (in particular usage data for the website and app, device information and individual IDs) to the United States and other countries. The legal basis for the use of Google Analytics is therefore your consent in accordance with Art. 31(1) FADP and Art. 6(1)(a) GDPR.

Google Analytics uses cookies. You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, we would like to point out that in this case you may not be able to use all features of our website to their full extent. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout

You can also prevent the use of Google Analytics by clicking on this link. This saves an opt-out cookie on your data carrier, which prevents Google Analytics from processing your personal data. Please note that if you delete all cookies from your device, these opt-out cookies will also be deleted, i.e. you will need to re-enable the opt-out cookies if you want to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/device and must therefore be activated separately for each browser, computer or other end device.

h) LinkedIn and XING

On our website, we use the marketing services of the social networks LinkedIn from LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (‘LinkedIn’) and XING, Grosse Bleichen 27, Kaisergalerie, 20354 Hamburg, Germany (‘XING’).

These use cookies to analyse the use of the website. For example, we can measure the success of our ads and show users products they have previously been interested in. For example, information about the operating system, the browser, the website you previously accessed (referrer URL), which websites the user visited, which offers the user clicked on and the date and time of your visit to our website are collected.

The information that the cookie generates about your use of this website is transferred in pseudonymised form to a LinkedIn and XING server in the European Union and the United States and stored there. LinkedIn and XING therefore do not store the name or email address of the respective user. Instead, the above-mentioned data is only assigned to the user for whom the cookie was created. This does not apply if the user has allowed LinkedIn or XING to process data without pseudonymisation or has a LinkedIn and/or XING account.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please note that in this case you may not be able to use all features of this website to their full extent. You can also object to the use of your data directly on LinkedIn and XING:

LinkedIn:www.linkedin.com/psettings/guest-controls/retargeting-opt-out

XING:https://privacy.xing.com/en/privacy-policy/what-rights-can-you-assert

We use LinkedIn Analytics to analyse the use of our website and make regular improvements. We can use the statistics obtained to improve our offer and make it more interesting for you as a user.

If we ask for consent for the use of ‘LinkedIn’ and ‘XING’, the legal basis for the processing of the corresponding data is Art. 31(1) FADP and Art. 6(1)(a) GDPR. Information of the third-party provider: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland;https://www.linkedin.com/help/linkedin/answer/a1341216.

i) YouTube

Features of the YouTube service are integrated into our website. YouTube belongs to Google Ireland Limited, a company registered and operated under Irish law with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which operates its services in the European Economic Area and Switzerland.

Your legal agreement with YouTube consists of the terms and conditions that you can find at the following link: www.youtube.com/static?template=terms. These terms form a legally binding agreement between you and YouTube regarding the use of the services. Google’s privacy policy explains how YouTube handles your personal data and protects your data when you use the service.

j) Remote support tools

We use remote support tools to support our customers. The remote support tools we use generally collect data that is necessary for establishing a connection. Data may also be collected on the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other ‘contextual information’ related to the communication process (metadata). Furthermore, the remote support tools process all technical data required for the processing of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and connection type. If content is exchanged, uploaded or made available in any other way, it is also stored on the servers of the tool provider. Such content includes, in particular, device and other technical data, cloud recordings, chat/instant messages, voice mail, uploaded photos and videos, files and other information shared while using the service.

k) Vimeo platform

Vimeo content is integrated by embedding a JavaScript tag. By simply inserting code provided by Vimeo into the code of a website, the content is displayed and its layout is loaded from the Vimeo servers. To display Vimeo content, we require your consent (Art. 31(1) FADP or Art. 6(1)(a) GDPR), which you can give via the button in the video in question if you have not already given it in your cookie selection. By clicking on the Play button, you agree that your IP address will be transferred to Vimeo (Vimeo LLC, 555 West 18th Street New York, NY 10011, United States) and that the provider will set cookies in your browser.

l) Microsoft Clarity

This website uses Clarity, a web analytics tool from Microsoft clarity.microsoft.com, to record individual visits (with anonymised IP address only). This creates a log of mouse movements and clicks with the intention of replaying website visits and deriving potential improvements for the website. The information is not personal and is not passed on.

m) Google Fonts

Our website uses fonts from Google Fonts. This allows us to use selected fonts on all of our pages. When you visit our website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, your IP address and the http header including the user agent, which describes the web browser and operating system versions of website visitors, as well as the reference URL, are also transferred to Google. However, Google does not use this data to create profiles of end users or to activate targeted ads. For more information, please visit developers.google.com/fonts/faq/privacy

n) Google Tag Manager

We use Google Tag Manager on our website. The data transferred to Google in this way does not contain any IP addresses or measurement IDs that are linked to a specific person. Google only uses the collected data to monitor the stability of the system and obtain data for diagnostics. You can find more information here: support.google.com/tagmanager/answer/9323295

o) Abacus Umantis

We use the Umantis HR recruitment tool from Abacus Umantis AG for applicant management and to display job vacancies on our websites. When you visit the pages on which our job vacancies are embedded, your access data may be transferred to Abacus Umantis. This includes data such as the domain visited, your IP address, date, time and duration of the visit as well as other information such as the device or browser used. The partner Abacus Umantis AG (in the EU, plus Switzerland and India) has taken the necessary organisational and technical measures to ensure the confidentiality of your application. Your data is transferred securely using automatically activated 128-bit encryption. This data is only stored, evaluated, processed or forwarded internally as part of your application. It is only accessible to employees of the HR department and the persons responsible for the selection within the ITRIS Group. You can find more information on the following page: www.abacus.ch/en/data-protection

p) Newsletter – Mailchimp

The newsletter is sent using the mailing service MailChimp, a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, United States.

The mailing service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, e.g. to technically optimise the mailing and display of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

If we request your consent to use MailChimp, the use of this service is based on your consent in accordance with Art. 31(1) FADP or Art. 6(1)(a) GDPR and a data processing agreement in accordance with Art. 9 FADP or Art. 28(3) GDPR.

9. Copyright

Copyright and all other rights to content, images, photos or other data on our website belong exclusively to the operator of this website or the specifically named rights holders. The written consent of the copyright holder must be obtained in advance for the reproduction of all files.

Anyone who commits a copyright infringement without the consent of the respective rights holder may be liable to prosecution and possibly liable for damages.

10. General disclaimer of liability for our online service

All information on our online service has been carefully checked. We strive to ensure that the information we provide is up to date, accurate and complete. Nevertheless, the occurrence of errors cannot be completely ruled out, which means that we cannot guarantee that information, including journalistic and editorial information, is complete, accurate and up to date. Liability claims for damages of a material or immaterial nature caused by the use of the information provided are excluded, unless wilful intent or gross negligence can be demonstrated.

We may change or delete text at our sole discretion and without notice and are under no obligation to update the content of this website. The use of or access to our website is at the user’s own risk. We and our clients or partners are not liable for damages, including direct, indirect, accidental, pre-specified or consequential damages, allegedly caused by visiting our website and therefore assume no liability for such damages.

We also assume no responsibility or liability for the content and availability of third-party websites that can be accessed via external links on our website. Responsibility for the content of the linked pages lies solely with their operators. We hereby expressly dissociate ourselves from all third-party content that may be relevant under criminal or liability law or that is immoral.

11. Your rights

Right to information (Art. 25 FADP or Art. 15 GDPR): You have the right to request information from us, at reasonable intervals, about your personal data that we process. On request, we will provide you with a copy of the data that is the subject of processing.

Right to rectification (Art. 32 FADP or Art. 16 GDPR): You have the right to request that we rectify incorrectly processed data.

Right to restriction of processing (Art. 30(2)(b) FADP or Art. 18 GDPR): Under certain conditions, you have the right to restrict the processing of your personal data (e.g. with regard to the duration of use, material reference or purpose of processing, etc.). In such a case, we may only continue to process the data in the same way if there is a legally prescribed justification.

Right to erasure (Art. 30 (3) FADP or Art. 17 GDPR): You also have the right to request that we erase your personal data. We are obliged to erase data if you expressly forbid us to process it and there is no justification for further processing, if your personal data is no longer required for the purposes for which it was collected or otherwise processed, if you have withdrawn your consent once granted, or if the data has been processed unlawfully.

Right to withdraw consent (Art. 6(6) and Art. 31(1) FADP or Art. 7(3) GDPR), insofar as our processing is based on your consent.

Right to release and transfer of data (Art. 28 FADP or Art. 20 GDPR): Where we process your data automatically for the purpose of concluding or executing a contract or with your consent, we must provide this data to you in a machine-readable format at your request or – if you so choose – transfer it to a third party.

Right to object (Art. 21 GDPR): If our processing of your data is based on the performance of a task performed in the public interest or in the exercise of official authority (Art. 6(1)(1)(e) GDPR), or if the data processing is based on our legitimate interests, you have the right, on the basis of the GDPR, to object to the processing of your personal data at any time on grounds relating to your particular situation. We will then terminate the processing, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests in terminating the processing.

You can object to the processing of your personal data for direct marketing purposes at any time without restrictions.

If our data processing is based on your consent, you have the right to withdraw your consent at any time. The lawfulness of the processing carried out on the basis of the consent prior to withdrawal remains unaffected by the withdrawal.

Right to report or lodge a complaint (Art. 49 FADP or Art. 77 GDPR): Where applicable to you, you have the right to report or lodge a complaint with a competent data protection authority. You can reach the supervisory authority responsible for Switzerland at the following address: Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Bern, Switzerland.

12. Changes to this Privacy Policy

We may amend this Privacy Policy at any time without prior notice. The latest version published on our website applies. If the Privacy Policy forms part of an agreement with you, we will notify you of any updates by email or by other appropriate means.

13. Questions about data protection

If you have any questions about data protection, please send us an email or contact the data controller in our organisation listed at the beginning of this Privacy Policy directly.