Privacy policy

With this privacy policy, we provide information on the processing of personal data in connection with our activities and operations, including our website under the domain name riwers.io. In particular, we provide information on what personal data we process, for what purpose, how, and where. We also provide information on the rights of individuals whose data we process.

For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.

We are subject to Swiss law and any applicable foreign law, such as that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized with Decision of 26 July 2000 that Swiss data protection law ensures an adequate level of data protection. With Report of 15 January 2024, the European Commission confirmed this adequacy decision.

Table of contents

1. Contact addresses

Responsible in terms of data protection law is:

Martin Graf
Riwers AG
Speichergasse 19
CH-3011 Bern

info@riwers.io

In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. We will gladly provide affected persons with information about the respective responsibility upon request.

1.1 Data protection officers or data protection advisors

We have the following data protection officer or data protection advisor as a point of contact for affected persons and authorities for inquiries in connection with data protection:

Martin Graf
Riwers AG
Speichergasse 19
CH-3011 Bern
Switzerland

dposwitzerland@riwers.io

1.2 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR:

Marco Dietrich
Riwers s.r.o
Hodžovo Námestie 1/A
SK-811 06 Bratislava – Staré Mesto
Slovakia

dposlovakia@riwers.io

The data protection representation serves affected persons and authorities in the European Union (EU) and in the rest of the European Economic Area (EEA) as an additional point of contact for inquiries in connection with the GDPR.

2. Terms and legal bases

2.1 Terms

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

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

Particularly sensitive personal data: Data on trade union, political, religious or ideological views and activities, data on health, privacy or membership of an ethnic group or race, genetic data, biometric data uniquely identifying a natural person, data on criminal and administrative sanctions or prosecutions, and data on measures of social assistance.

Processing: Any handling of personal data, regardless of the means and procedures used, for example, accessing, comparing, adapting, archiving, storing, reading, disclosing, procuring, capturing, collecting, deleting, disclosing, sorting, organizing, storing, modifying, disseminating, linking, destroying and using personal data.

European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

2.2 Legal bases

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

We process – if and to the extent that the European General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data and the processing of particularly sensitive personal data as processing of special categories of personal data (Art. 9 GDPR).

3. Type, scope, and purpose of the processing of personal data

We process the personal data that is required to be able to carry out our activities and operations permanently, humanely, securely and reliably. The processed personal data can fall in particular into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive personal data.

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

We process personal data, as far as necessary, with the consent of the data subjects. In many cases, we can process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

We process personal data for the duration that is necessary for the respective purpose. In particular, we anonymize or delete personal data depending on statutory retention and limitation periods.

4. Automation and Artificial Intelligence (AI)

We may process personal data automatically or use artificial intelligence for the processing of personal data.

We may use profiling to automatically assess certain personal aspects relating to data subjects. Profiling is used, for example, to analyze or predict interests, behaviors, or personal preferences.

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

5. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties are in particular specialized providers whose services we use.

We may disclose personal data, for example, to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

6. Communication

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

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

We use selected services from suitable providers to enable and improve communication with individual persons and other communication partners. With such services, we can also manage and otherwise process the data of the data subjects beyond direct communication.

We use in particular:

7. Applications

We process personal data about applicants, insofar as they are 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 requested information, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.

We also process the personal data that applicants communicate or publish voluntarily, in particular as part of cover letters, resumes and other application documents as well as online profiles.

We process – if and to the extent that the Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b GDPR.

We may allow applicants to deposit their information in our talent pool in order to be considered for future vacancies. We may also use such information to maintain contact and inform about news. If we assume that an applicant is eligible for a vacancy based on the information provided, we may inform the applicant accordingly.

We use selected services from suitable third parties to be able to advertise jobs by means of e-recruiting as well as to enable and manage applications.

8. Data security

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

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

Our digital communication is subject – like basically any digital communication – to mass surveillance without cause and suspicion by security authorities in Switzerland, in the rest of Europe, in the United States of America (USA) and in other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police stations and other security authorities. We also cannot exclude that a data subject is specifically monitored.

9. Personal data abroad

We process personal data basically in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular in order to process it there or have it processed.

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there guarantees an adequate level of data protection in accordance with the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance with the decision of the European Commission.

We may transfer personal data to countries whose law does not guarantee an adequate level of data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. By way of exception, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. We will gladly provide affected persons with information about any guarantees or provide a copy of any guarantees upon request.

10. Rights of data subjects

10.1 Data protection claims

We grant data subjects all claims in accordance with applicable law. Data subjects have in particular the following rights:

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

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

We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are obliged to cooperate.

10.2 Legal protection

Data subjects have the right to enforce their data protection claims in court or to file a report or complaint with a data protection supervisory authority.

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

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are structured federally, especially in Germany.

11. Use of the website

11.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data does not have to be limited to traditional cookies in text form.

Cookies can be stored temporarily in the browser as «session cookies» or for a certain period of time as so-called permanent cookies. «Session cookies» are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognise a browser the next time it visits our website and thereby, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated, restricted or deleted in the browser settings at any time. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be available to its full extent. We actively request – at least if and to the extent required by applicable law – explicit consent to the use of cookies.

For cookies that are used for success 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).

11.2 Logging

For each access to our website and our other digital presence, we may log at least the following information, provided that it is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, accessed individual subpage of our website including transmitted data volume, last website accessed in the same browser window (referer or referrer).

We log such information, which may also constitute personal data, in log files. The information is necessary to be able to provide our digital presence permanently, in a user-friendly and reliable manner. The information is also necessary to be able to guarantee data security – also by third parties or with the help of third parties.

11.3 Tracking pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – also from third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when accessing our digital presence. With tracking pixels, at least the same information as with logging in log files can be recorded.

12. Notifications and communications

12.1 Success and reach measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and communications on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner as well as permanently, securely and reliably based on the needs and reading habits of the recipients.

12.2 Consent and objection

You must generally consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. For the possible obtaining of a doubly confirmed consent, we can use the «double opt-in» procedure. In this case, you will receive a communication with instructions for the double confirmation. We may log obtained consents including IP address and timestamp for evidentiary and security reasons.

You can generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.

12.3 Service providers for notifications and communications

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

We use in particular:

13. Social media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to be able to provide our social media presence on Facebook effectively and in a user-friendly manner.

Further information about the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as the data protection officer of Facebook can be found in the Facebook Privacy Policy. We have concluded the so-called «Controller Addendum» with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page «Information about Page Insights» including «Information about Page Insights data».

14. Services from third parties

We use services from specialised third parties in order to be able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. With such embedding, the services used collect the IP addresses of the users at least temporarily for technically compelling reasons.

For necessary security-relevant, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This concerns, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

14.1 Digital infrastructure

We use services from specialised third parties in order to be able to make use of the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

14.2 Scheduling

We use services from specialised third parties in order to be able to arrange appointments online, for example for meetings. In addition to this privacy policy, any directly visible terms of the services used, such as terms of use or privacy policies, also apply.

We use in particular:

14.3 Audio and video conferences

We use specialised services for audio and video conferences in order to be able to communicate online. We can use this, for example, to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy policies and terms of use also apply.

Depending on the situation, we recommend that you mute the microphone by default when participating in audio or video conferences and blur the background or have a virtual background displayed.

We use in particular:

14.4 Online collaboration

We use services from third parties to enable online collaboration. In addition to this privacy policy, any directly visible terms of the services used, such as terms of use or privacy policies, also apply.

We use in particular:

14.5 Social Media Functions and Social Media Content

We use services and plugins from third parties to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

We use in particular:

14.6 Maps

We use services from third parties to embed maps in our website.

We use in particular:

14.7 Digital Content

We use services from specialized third parties to integrate digital content into our website. Digital content includes in particular image and video material, music and podcasts.

We use in particular:

14.8 Fonts

We use services from third parties to embed selected fonts as well as icons, logos and symbols in our website.

We use in particular:

14.9 Advertising

We use the possibility to specifically display advertising with third parties such as social media platforms and search engines for our activities and operations.

With such advertising, we would like to reach in particular people who are already interested in our activities and operations or who could be interested in them (Remarketing and Targeting). For this purpose, we can transmit corresponding – possibly also personal – information to third parties who 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 with whom you are registered as a user may be able to assign the use of our website to your profile there.

We use in particular:

15. Extensions for the Website

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

16. Measuring Success and Reach

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

For the success and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are generally shortened («IP masking») in order to follow the principle of data economy through the corresponding pseudonymization.

Cookies can be used and user profiles can be created during the success and reach measurement. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively pseudonymized and not used for the identification of individual users. Individual services from third parties with whom users are registered may be able to assign the use of our online offer to the user account or user profile with the respective service.

We use in particular:

17. Final Notes on the Privacy Policy

We have created this privacy policy with the data protection generator from Datenschutzpartner .

We can update this privacy policy at any time. We provide information about updates in a suitable form, in particular by publishing the current privacy policy on our website.