
Privacy Policy
This privacy policy provides information about how we process personal data in connection with our activities and operations, including our website. In particular, we provide information about what personal data we process, how we process it and where we process it. We also provide information about the rights of individuals whose data we process. We may publish additional privacy policies or other information about data protection for individual or additional activities and operations.
1. Contact details
The data controller within the meaning of data protection law is:
Lateltin AG
Im Hölderli 19
CH-8405 Winterthur
info@lateltin.com
In individual cases, third parties may be responsible for processing personal data or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.
2. Terms and legal basis
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.
Sensitive personal data: Data about trade union, political, religious or philosophical views and activities, data about health, privacy or ethnic or racial origin, genetic data, biometric data that uniquely identifies a natural person, data about criminal and administrative sanctions or persecution, and data about social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organising, saving, changing, disseminating, linking, destroying and using personal data.
2.2 Legal basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. Type, scope and purpose of processing personal data
We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. The personal data processed may fall into the following categories: 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 available sources or collect in the course of our activities and operations, insofar as such processing is permissible.
We process personal data with the consent of the data subjects to the extent necessary. In many cases, we may process personal data without consent, for example to fulfil legal obligations or to protect overriding interests. We may also seek the consent of data subjects where their consent is not required.
We process personal data for the period of time required for the respective purpose. We anonymise or delete personal data in particular in accordance with statutory retention and limitation periods.
4. 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 may include, for example, specialised providers whose services we use.
Within the scope of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and economic information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent companies, sister companies and subsidiaries, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. Communication
We process personal data in order to communicate with individuals, authorities, organisations and companies. In doing so, we process in particular data that a data subject provides to us when contacting us, for example by post or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other persons are obliged to ensure the data protection of these data subjects independently. In particular, they must ensure that such data is accurate and may be transferred.
6. Applications
We process personal data about applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent execution of an employment contract. The personal data required is derived in particular from the information requested, 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 personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents, as well as online profiles.
7. Data security
We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk.
Our measures ensure, in particular, the confidentiality, availability, traceability and integrity of the personal data processed, but we cannot guarantee absolute data security.
Access to our website and our other digital presence is secured by transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn you before you visit a website without transport encryption.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the processing of personal data by secret services, police agencies and other security authorities. We also cannot rule out the possibility that a data subject may be subject to targeted surveillance.
8. Personal data abroad
We process personal data in Switzerland as a matter of principle. However, we may also disclose or export personal data to other countries, in particular for processing or to be processed there.
We may disclose personal data to all countries on Earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with a decision by the Swiss Federal Council.
We may disclose personal data to countries whose laws do not guarantee adequate data protection if adequate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific 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. Upon request, we will gladly provide data subjects with information about any guarantees or a copy of the guarantees.
9. Rights of data subjects
9.1 Data protection claims
We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:
- Information: Data subjects may request information about whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also 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 correct inaccurate personal data, complete incomplete data and restrict the processing of their data.
- Right to express their own point of view and right to human review: Data subjects may express their own point of view and request human review in decisions based solely on automated processing of personal data that have legal consequences for them or significantly affect them (automated individual decisions).
- Deletion and objection: Data subjects may have personal data deleted (‘right to be forgotten’) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of data subjects' rights within the limits permitted by law. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of confidentiality obligations, overriding interests or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge a fee for exercising these rights. We will inform data subjects in advance of any costs.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
9.2 Legal protection
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a 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 (EDÖB).
10. Use of the website
10.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in your browser. Such stored data are not necessarily limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as ‘session cookies’ or for a specific 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 enable, in particular, a browser to be recognised when you next 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.
Cookies can be deactivated, restricted or deleted in whole or in part at any time in the browser settings. The browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be available in its entirety. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law.
For cookies 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).
10.2 Logging
We may log at least the following information for each access to our website and our other digital presence, provided that this information 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, individual subpages of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is available on a permanent, user-friendly and reliable basis. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
10.3 Tracking pixels
We may incorporate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is logged in log files.
11. Notifications and communications
11.1 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 may also record the use of notifications and communications on a personalised 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 people-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of the recipients.
11.2 Consent and objection
You must always consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the ‘double opt-in’ procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including your IP address and time stamp, for evidence and security purposes.
You can object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical collection of usage data for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.
11.3 Service providers for notifications and communications
We send notifications and communications with the help of specialised service providers.
In particular, we use:
- Mailchimp: communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); information on data protection: Privacy Policy (Intuit) including ‘Country and Region Specific Terms’ (‘Country and Region-Specific Terms’), ‘Frequently Asked Questions About Mailchimp's Privacy Policy’ (‘Mailchimp Privacy FAQs’), ‘Mailchimp and European Data Transfers’, “Security”, Cookie Policy, ‘Requests Regarding Privacy Rights’, ‘Legal Terms’.
12. Social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.
The general terms and conditions (GTC) and terms of use as well as the privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
13. Third-party services
We use the services of specialised third parties in order to be able to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users at least temporarily for technical reasons.
For necessary security-related, 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 includes, for example, performance or usage data in order to be able to offer the respective service.
We use the following in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in part for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles‘, ’More information about how Google uses personal data‘, Privacy policy, ’Google is committed to complying with applicable data protection laws‘, ’Guide to data protection in Google products‘, ’How we use data from websites or apps that use our services‘, Cookie policy, ’Advertising you can control" (settings for personalised advertising).
13.1 Digital infrastructure
We use services from specialised third parties to enable us to use the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
- METANET: Hosting; provider: METANET AG (Switzerland); information on data protection: Privacy Policy, ‘Legal’ including ‘Technical and organisational measures’.
13.2 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols in our website.
We use the following in particular:
- Google Fonts: fonts; provider: Google; Google Fonts-specific information: ‘Your privacy and Google Fonts’, ‘Data protection and data collection’ (Google Fonts).
13.3 E-commerce
We operate an e-commerce business and use third-party services to successfully offer services, content or goods.
13.4 Payments
We use specialised service providers to process payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, apply in addition to the processing of payments.
13.5 Advertising
We use the option of displaying targeted advertising for our activities and operations on third-party websites, such as social media platforms and search engines.
We use such advertising in particular to reach people who are already interested in our activities and operations or who may be interested in them (remarketing and targeting). To this end, we may transfer relevant information, including personal data, to third parties who enable such advertising. We can also determine whether our advertising is successful, i.e. 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 link your use of our website to your profile there.
We use the following in particular:
- Google Ads: Search engine advertising; provider: Google; Google Ads-specific information: Advertising based, among other things, on search queries, whereby various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, Privacy policy for advertising, ‘Manage ads displayed directly via ads’.
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: targeting, including retargeting, in particular with Meta Pixel and Custom Audiences, including Lookalike Audiences, privacy policy, ‘Advertising preferences’ (registration as a user required).
14. Measuring success and reach
We try to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party information or test how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content or make improvements.
In most cases, the IP addresses of individual users are collected for the purpose of measuring success and reach. In this case, IP addresses are always shortened (‘IP masking’) in order to comply with the principle of data minimisation through appropriate pseudonymisation.
Cookies may be used and user profiles created for success and reach measurement. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services to which users are registered may be able to assign the use of our online offering to the user account or user profile with the respective service.
We use the following in particular:
- Google Marketing Platform: Performance and reach measurement, in particular with Google Analytics; provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only transferred in full to Google in the USA in exceptional cases, Privacy policy for Google Analytics, ‘Browser add-on to disable Google Analytics’.
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for performance and reach measurement; provider: Google; Google Tag Manager-specific information: Privacy policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.
15. Video surveillance
We use video surveillance to prevent criminal offences, to secure evidence in the event of criminal offences and to exercise our right to protect our property.
We store recordings from our video surveillance for as long as they are necessary for the preservation of evidence or for another specified purpose.
We may store recordings from our video surveillance and transfer them to competent authorities, such as courts or law enforcement agencies, if the transfer is necessary for a specified purpose, in our overriding interest or due to legal obligations.
16. Final notes on the privacy policy
We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.