We are 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 recognises that Swiss data protection law ensures an adequate level of 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 or Data Protection Advisor
We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities for enquiries relating to data protection:
1.2 Data Protection Representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 DSGVO:
Podchod Hodžovo Námestie 1/A
SK-811 06 Bratislava – Staré Mesto
The DPA serves as an additional point of contact for data subjects and public authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries related to the GDPR.
2. Terms and legal bases
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we are processing personal data.
Processing includes any handling of personal data, independently of the means and procedures used, such as retrieving, matching, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, erasing, disclosing, arranging, organising, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal basis
We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to safeguard 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 carry out our activities and operations permanently, in a user-friendly, secure and reliable manner and to communicate about them, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data for the fulfilment of a legal obligation to which we are subject pursuant to any applicable law of Member States in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data in order to protect vital interests of the data subject or of another natural person.
3. Nature, scope and purpose
We process those personal data that are necessary in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular 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 and contract and payment data.
We process personal data for the period that is required for the respective purpose(s) or by law. Personal data that is no longer required to be processed will be anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order 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 provides to us voluntarily when contacting us – for example by letter post, 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, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.
We process personal data about applicants insofar as it is necessary for the assessment of suitability for an employment relationship or for the subsequent implementation of an employment contract. The necessary 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 or publish voluntarily, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process – if and insofar as the General Data Protection Regulation (DSGVO) is applicable – personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b DSGVO.
We may allow applicants to submit their details to our talent pool to be considered for future vacancies. We may also use such details to maintain contact and provide updates. If we believe that an applicant is eligible for a vacancy based on the information provided, we may inform the applicant accordingly.
We use third party services to post jobs through E-Recruitment and to enable and manage applications.
5. Personal data abroad
We process personal data in principle 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 may export personal data to all states and territories on Earth as well as elsewhere in the universe, provided the law there is compliant with decision of the Swiss Federal Council provides for adequate data protection and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to European Commission Decision ensures adequate data protection.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other appropriate guarantees. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information on any guarantees or a copy of any guarantees on request.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects can request information as to whether we are processing personal data about them, and if so, what personal data is involved. Data subjects also receive the information required to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed and have the processing of their data restricted.
- Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data release and data transfer: Data subjects may request the release of personal data or the transfer of their data to another controller.
We can postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We can draw the attention of data subjects to any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to legal obligations to retain data.
We may provide for costs for the exercise of rights exceptionally. We will inform affected persons in advance of any costs.
We are obliged to take reasonable steps to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
6.2 Right to complain
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent 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).
Data subjects have – if and to the extent that the General Data Protection Regulation (GDPR) applies – the right to lodge a complaint with a competent European data protection supervisory authority.
7. Data security
We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject to – as basically all digital communication – mass surveillance without cause and suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, 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 the browser temporarily 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. Cookies make it possible in particular to recognise a browser the next time it visits 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 many services via the 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 website in a permanent, user-friendly and reliable manner and 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 Counter pixel
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking 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 record the same information as in server log files.
9. Notifications and communications
We send notifications and messages via email and other communication channels such as instant messaging or SMS.
9.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. 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 performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
9.2 Consent and objection
You must basically 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, we use the “double opt-in” procedure where possible, i.e. you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorised third parties can take place. We may log such consents, including Internet Protocol (IP) address, date and time, for evidence and security reasons.
You can basically 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 use for performance and reach measurement. This is without prejudice to necessary notifications and communications in connection with our activities and operations.
9.3 Notifications and notifications-service-providers
We send notifications and messages with the help of specialised service providers.
10. 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 Switzerland and the European Economic Area (EEA)
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our Social Media presence on Facebook, including the so-called Page Insights – if and to the extent that the General Data Protection Regulation (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 help us deliver our social media presence on Facebook in an effective and user-friendly way.
Further information on the nature, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook’s data protection officer can be found in the Data Protection Statement of Facebook. We have entered into the so-called “Responsible Party Addendum” with Facebook and have thereby 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 “Page Insights Information” including “Page Insights Data Information”.
11. Third party services
We use services provided by specialised third parties in order to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymised or pseudonymised manner. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Services provided by Microsoft: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Privacy at Microsoft”, “Data protection and privacy (Trust Center)”, privacy statement, privacy dashboard (data and privacy settings).
11.1 Digital infrastructure
We use the services of specialised third parties to provide the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- Cyon: hosting; provider: cyon GmbH (Switzerland); data protection information: “Data protection”, Data protection declaration.
- Google Cloud including Google Cloud Platform (GCP): Storage and other infrastructure; Google Cloud-specific providers: Google/ LLC (USA) for users in, inter alia, the USA / Google Ireland Limited or Google Commerce Limited (both Ireland) for users in, inter alia, the European Economic Area (EEA) and Switzerland (see “Contracting Entity on the side of Google” [“Google Contracting Entity”] for providers in other countries); Google Cloud-specific information: “Privacy Resource Center” (“Privacy Resource Center”), “Privacy”, “Compliance Resource Centre”, “Trust and Security”.
11.2 Contact options
We use services from selected providers in order to better communicate with third parties, such as potential and existing customers.
We use in particular:
- HubSpot: Customer Relationship Management (CRM); Provider: HubSpot Inc. (USA) / HubSpot Ireland Limited (Ireland) for users in the European Economic Area (EEA); data protection information: Data protection declaration.
11.3 Audio and video conferencing
We recommend muting the microphone by default and blurring the background or fading in a virtual background when participating in audio or video conferences, depending on your life situation.
We use in particular:
- Google Meet: Video conferencing; Provider: Google; Google Meet-specific disclosures: “Google Meet – Security and Privacy for Users”.
- Microsoft Teams: Platform for audio and video conferencing, among other things; Provider: Microsoft; Teams-specific information: “Privacy and Microsoft Teams”.
11.4 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.
We use in particular:
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Privacy and Security Centre”, “My Data on YouTube”.
We use third-party services to embed selected fonts as well as icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”.
12. Extensions for the website
We use extensions for our website to be able to use additional functions.
13. Performance and reach measurement
We use services and programmes to determine how our online offering is used. For example, we can measure the success and reach of our activities and operations and the impact of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offer or parts of our online offer are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
When using services and programmes for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are basically shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymisation and thus to improve the data protection of the users.
When using services and programmes 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. In principle, user profiles are only created pseudonymously. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, at most, assign the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Google Analytics: Performance and reach measurement; Provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, “Privacy”, “Browser Add-on to disable Google Analytics”.
- Google Tag Manager: Integration and administration of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager”; further information on data protection can be found with the individual integrated and managed services.
14. Final Provisions
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.