1. Contact addresses
Responsibility for the processing of personal data:
Mr. Mario Jenni
Co-founder & CEO
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, preserving, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organize, store, modify, disseminate, link, destroy and use personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, such as in particular the Swiss Federal Act on Data Protection (Datenschutzgesetz, DSG) and the Ordinance on Data Protection (Datenschutzverordnung, DSV).
3. Nature, scope and purpose
We process the personal data that is required 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 of time required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
We process personal data only 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 protect 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 voluntarily provides to us when contacting us – for example, by letter, 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 or with comparable tools. If we receive data about other persons, the transmitting persons are obligated to ensure data protection with respect to 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 to the extent that it is required for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process the personal data that applicants voluntarily provide or make public, in particular as part of cover letters, resumes and other application documents as well as online profiles.
We may allow applicants to store their details in our talent pool so that they can be considered for future vacancies. We may also use such information 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 advertise jobs via e-recruitment and to enable and manage recruitment.
5. Personal data abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it or have it processed there.
We may disclose personal data to any country or territory in the world and elsewhere in the universe, provided that the law of that country or territory ensures adequate data protection in accordance with a decision of the Swiss Federal Council.
We may disclose personal data to countries whose laws do not ensure adequate data protection, provided that adequate data protection is ensured for other reasons. Appropriate data protection may be ensured, for example, through appropriate contractual agreements, on the basis of standard data protection clauses or with other appropriate guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate 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 performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.
6. Rights of data subjects
6.1 Claims under data protection law
We grant data subjects all rights in accordance with the applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we process 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 can have incorrect personal data corrected, incomplete data completed and 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 surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements they must meet 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 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 take appropriate measures 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 by legal means or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
7. Data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communications – like all digital communications – are subject to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot have any direct influence on the corresponding processing of personal data by secret services, police agencies and other security authorities.
8. Website use
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 deleted automatically when the browser is closed. Permanent cookies have a certain storage period. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online branding, for example.
In the case of cookies used for performance 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).
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).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably 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 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also referred to 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. With pixel counters, the same information can be collected as in server log files.
9. Third party services
We use services of specialized 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 in 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-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles”, data protection statement, “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 on or in which our services are used” (information provided by Google), “Types of cookies and other technologies used by Google”, “Personalized advertising” (activation / deactivation / settings).
9.1 Digital infrastructure
We use services from specialized third parties in order to make use of 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:
9.2 Map material
We use third party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform: mapping service; provider: Google; Google Maps-specific information: “How Google uses location information”.
9.3 Digital audio and video content
We use services from specialized third parties to enable 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 safety center”, “Your Data in YouTube”.
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
- Google Fonts: Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts”, “Privacy and Data Collection”.
10. Success and reach measurement
We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data economy through the corresponding pseudonymization.
Cookies may be used for performance and reach measurement and user profiles may be created. Any user profiles created include, for example, the individual 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, any user profiles are created exclusively in pseudonymous form and are not used to identify individual users. Individual services of third parties with which users are registered may be able to assign the use of our online service to the user account or user profile of 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 pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, “Safeguarding your data”, “Google Analytics Opt-out Browser Add-on”.
11. Final provisions