This privacy statement informs users about what personal data we process in connection with our website and other online offerings, as well as how, where and why. This privacy statement also provides information about the rights of people whose data we process.
For individual or additional offerings or services, special, additional or further privacy statements and other legal documents such as terms and conditions of business, use or participation may apply.
Our online offering is subject to Swiss data protection low and any other applicable foreign data protection laws, in particular those of the European Union (EU) in the form of the General Data Protection Regulation (GDPR). The European Commission acknowledges that Swiss data protection law provides adequate data protection.
1. Contact Addresses
Responsible for the online presence:
Im Hölderli 19
2. Processing Personal Data
Personal data includes all information that relates to a specific or identifiable person. The data subject is the person whose personal data is being processed. Processing covers any handling of personal data, regardless of the means and procedure used, in particular the storage, disclosure, collection, gathering, deletion, saving, alteration destruction or use of personal data.
The European Economic Area (EEA) covers the European Union (EU) plus the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) uses the terminology ‘processing of personal data’.
2.2 Legal Bases
If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
- Art. 6(1)(b) GDPR if processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Art. 6(1)(f) GDPR if processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Legitimate interests notable include our interests in being able to provide our online presence in a permanent, user-friendly, secure and reliable way, and where required, to promote information security, protection against misuse and unauthorised use, enforcement of our own legal requirements and compliance with Swiss law.
- Art. 6(1)(c) GDPR if processing is necessary for compliance with a legal obligation to which we are subject according to the applicable law of member states of the European Economic Area (EEA).
- Art. 6(1)(e) GDPR if processing is necessary for the performance of a task carried out in the public interest.
- Art. 6(1)(a) GDPR if the data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Art. 6(1)(d) GDPR if processing is necessary in order to protect the vital interests of the data subject or of another natural person.
2.3 Type, Scope and Purpose
We process the personal data required to provide our online presence in a permanent, user-friendly, secure and reliable way. This personal data may be in the categories of inventory and contact data, browser and device data, content data, metadata, marginal and usage data, location data, or purchasing, contract and payment data.
We process personal data for the duration for which they are required for the relevant purpose(s) or for which is legally required. Personal data for which processing is no longer required will be anonymised or deleted. People whose data we process have a fundamentalright of erasure.
We fundamentally only process personal data with the data subject’s consent, unless processing is permitted for legal reasons, for example for performance of a contract with the data subject, or for appropriate precontractual measures to preserve our legitimate interests, where processing is apparent from the circumstances or previous notice is given.
In this context, we particularly process tasks that a data subject has voluntarily and independently submitted to us when making contact – e.g. by letter, email, contact form, social media or telephone – or when registering for a user account. Tasks such as these can for example be stored in an address book or comparable resource. If you provide us with the personal details of third parties, you are obligated to ensure data protection as regards these third parties and ensure that such personal data is accurate.
We also process personal data that we receive from third parties, from publicly accessible sources or in the supply of our online presence, if and to the extent that such processing is legally permitted.
Personal data from applications is only processed to the extent required to assess suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required to execute an application procedure comes from the details retrieved or communicated, for example as part of a job description. Applicants can voluntarily provide further information for their particular applications.
2.4 Processing of Personal Data by Third Parties, Including Abroad
We may arrange for personal data to be processed by commissioned third parties, process it together with or with the help of third parties, or transfer it to third parties. These third parties in particular include providers whose services we are using. We also ensure appropriate data protection for such third parties.
These third parties are generally located in Switzerland or the European Economic Area (EEA). However, said third parties may also be located in other countries and territories on the planet or elsewhere in the universe, provided that their data protection law is assessed by the Federal Data Protection and Information Commissioner (FDPIC) and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable –by the European Commission’s adequacy decisions to provide appropriate data protection, or if appropriate data protection is ensured by other means, such as by a corresponding contractual agreement, in particular one based on standard contractual clauses, or by corresponding certification. For third parties in the United States of America, (USA), appropriate data protection may be ensured by certification under the Privacy Shield. In exceptional circumstances, these third parties may be located in a country without appropriate data protection, provided that data protection requirements such as the data subject’s express permission have been met.
3. The Rights of Data Subjects
Data subjects whose personal data we process have rights under Swiss data protection law. These include a right of access as well as the right to rectify, erase or block the personal data being processed.
Data subjects whose personal data we process are entitled (if and to the extent that the General Data Protection Regulation, or GDPR, is applicable) to receive confirmation free of charge of whether we are processing their personal data, and if yes, receive information about the processing their personal data, restrict processing of their personal data, exercise their right to data portability, or correct, delete (the ‘right to be forgotten’), block or complete their personal data.
Data subjects whose personal data we process are entitled (if and to the extent that the General Data Protection Regulation, or GDPR, is applicable) to revoke approval already granted at any time with future effect, and object to the processing of their personal data at any time.
Data subjects whose personal data we are processing have a right of appeal to a responsible supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
4. Data Security
We undertake appropriate and suitable technical and organisational measures to ensure data protection and in particular data security. However, the processing of personal data via the internet may always have security vulnerabilities despite such measures being taken. We are therefore unable to guarantee absolute data security.
Access to our online presence is via transport encryption (SSL / TLS, in particular via Hypertext Transfer Protocol Secure, HTTPS for short). Most browsers indicate encryption with a padlock in the address bar.
Access to our online presence – like internet use in general – is subject to mass surveillance without suspicion or cause, as well as other surveillance by security authorities in Switzerland, the European Union (EU), the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police services or other security authorities.
5. Website Use
Cookies can be temporarily stored in your browser as ‘session cookies’ when visiting our website, or stored as permanent cookies for a set period of time. Session cookies are automatically deleted when you close your browser. Permanent cookies in particular enable our website to recognise your browser on your next visit, and thus for example to assess our website’s reach. However, permanent cookies can also be used for purposes such as online marketing.
As regards cookies that are used for success and reach measurement or advertising purposes, numerous services offer a general opt-out via the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
5.2 Server Logs
For all access to our website, we may record the following data if it has been communicated by your browser to our server infrastructure or if it 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 subpages accessed from our website including the volume of data transferred, and websites accessed using the same browser window (referrers).
We store this information, which may constitute personal data, in server logs. The information is required to provide our online presence in a permanent, user-friendly and reliable way, as well as to ensure data security and thus in particular the protection of personal data – including by or with the help of third parties.
5.3 Tracking Pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when visiting our website. Tracking pixels can be used to record the same information as is found in server logs.
6. Notifications and Communications
We send notifications and communications, e.g. newsletters, by email and other communications channels such as instant messaging.
6.1 Performance and Reach Measurement
Notifications and communications may contain web links or tracking pixels that record if a particular message is opened and which web links within it are clicked on. These web links and tracking pixels can also record personal use of notifications and communications. We require this statistical recording of use for the purposes of success and reach measurement, in order to be able to permanently, securely and reliably provide notifications and communications in an effective, user-friendly way based on the needs and reading habits of recipients.
6.2 Consent and Opposition
You must fundamentally provide express consent to the use of your email address and other contact addresses unless their use is permitted for other legal reasons. As far as possible we use a double opt-in procedure for all consent to receiving emails, meaning that you receive an email with a web link that you have to click on, to avoid misuse by unauthorised third parties. We may log these consents, including internet protocol (IP) address, date and time, for proof and security reasons.
You can fundamentally unsubscribe from notifications and communications such as newsletters at any time. Notifications and communications that are necessary for our online presence remain reserved. By unsubscribing, you can in particular object to the statistical recording of use for success and reach management.
6.3 Service Providers for Notifications and Communications
7. Social Media
We have a presence on social media and other online platforms in order to communicate with interested individuals and inform them of our online services. This may include processing personal data outside of Switzerland and the European Economic Area (EEA).
The terms and conditions of business and of use and the privacy statements and other provisions of the individual operators of such online platforms shall also apply. These provisions in particular provide information about the rights of data subjects, notably the right of access.
For our social media presence on Facebook, if and to the extent that the GDPR applies, we are jointly responsible with Facebook for page ‘insights’. Page insights provide information about how visitors interact with our Facebook presence. We use page insights to ensure an effective and user-friendly social media presence on Facebook. Facebook has published information about page insights data and a page controller addendum.
8. Services by Third Parties
We use third-party services to provide our online presence in a permanent, user-friendly, secure and reliable way. These services are also used to enable us to embed content in our online presence. These services – such as hosting and storage services, video services or payment services – require your internet protocol (IP) address, as otherwise such services are unable to transmit the corresponding content. Such services may be located outside of Switzerland and the European Economic Area (EEA), provided that appropriate data protection is ensured.
Third parties whose services we use may also collect, anonymise or pseudonymise data in connection with our online presence and from other sources – including cookies, log files and tracking pixels – for their own safety-related, statistical and technical purposes.
8.3 Performance and Reach Measurement
8.3.1 Google Analytics
We use Google Analytics to analyse how our website is used, enabling us to for example measure our website’s reach and the success of third-party links to our website. This is a service provided by the American company Google LLC. The Irish company Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland.
Google also attempts to track individual users of our website when they use different browsers or devices (cross-device tracking). Cookies may also be used for this purpose. Google Analytics requires your internet protocol (IP) address, but this is not matched with other Google data.
We will always anonymise your internet protocol (IP) address before analysis by Google. Your full IP address will fundamentally not be communicated to Google in the USA in the resulting data.
We use Google Analytics with Google Signals. This provides us with expanded statistics regarding visitors to our website who have activated personalised advertising as registered users. Despite these expanded statistics, we are not able to establish links with individual Google user accounts.
We use Google Tag Manager to integrate third-party Google Analytics or Advertising services into our website and administer them. This is a service provided by the American company Google LLC. The Irish company Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland. No cookies are used for this, but cookies may be used as part of the services embedded and administered as part of this process. We provide information about how such services process your personal data in this privacy statement.
8.4.1 Facebook Ads
With this advertising, we are particularly seeking to reach people who are interested in or already use our online presence. Using the Facebook Pixel in particular, we thus transmit (ideally personal) information to Facebook (Custom Audiences including Lookalike Audiences). We can also identify if our advertising is successful, i.e. if it results in visits to our website (conversion tracking).
Further information about the type, scope and purpose of data processing can be found in Facebook’s Data Policy. Facebook users can also use their advertising preferences to adjust what advertising they see on Facebook and what advertising they will be shown on Facebook in the future.
8.4.2 Google Ads
With this advertising, we are particularly seeking to reach people who are interested in or already use our online presence. To this end, we transmit (ideally personal) information to Google (remarketing). We can also identify if our advertising is successful, i.e. if it results in visits to our website (conversion tracking).
8.4.3 Instagram Ads
With this advertising, we are particularly seeking to reach people who are interested in or already use our online presence. Using the Facebook Pixel in particular, we thus transmit (ideally personal) information to Facebook (Custom Audiences including Lookalike Audiences