Privacy Policy

2. PROCESSING OF PERSONAL DATA

2.1 Definitions
Personal data refers to any information that relates to an identified or identifiable individual. A data subject is an individual whose personal data is being processed. Processing encompasses any handling of personal data, regardless of the means and procedures used—in particular storing, disclosing, collecting, recording, deleting, saving, modifying, destroying, and using personal data.
 
The European Economic Area (EEA) includes the EU as well as the Principality of Liechtenstein, Iceland, and Norway. The GDPR refers to the processing of personal data as the “processing of personal data.”
 
 
2.2 Legal Bases 
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (OFADP).
 
If and to the extent that the GDPR is applicable, we process personal data in accordance with at least one of the following legal bases:
 

• Art. 6(1)(b) GDPR – for processing necessary to perform a contract with the data subject or to take pre-contractual measures.

• Art. 6(1)(f) GDPR – for processing necessary to safeguard our legitimate interests or those of third parties, provided such interests are not overridden by the fundamental rights and freedoms of the data subject. Legitimate interests include providing our online services reliably, securely, and user-friendly, advertising them if necessary, ensuring information security, preventing misuse and unauthorized use, enforcing legal claims, and complying with Swiss law.

• Art. 6(1)(c) GDPR – for processing necessary to comply with a legal obligation to which we are subject under EEA law.

• Art. 6(1)(e) GDPR – for processing necessary for the performance of a task carried out in the public interest.

• Art. 6(1)(a) GDPR – based on the consent of the data subject.

• Art. 6(1)(d) GDPR – for processing necessary to protect the vital interests of the data subject or another natural person.

 
 
2.3 Nature, Scope, and Purpose
We process personal data as necessary to provide our online offering in a sustainable, user-friendly, secure, and reliable manner. These data may fall into categories such as master and contact data, browser and device data, content data, metadata or peripheral data, usage data, location data, sales, contract, and payment data.
 
We retain personal data for as long as is necessary for the purposes described or as required by law. Data no longer required will be anonymized or deleted. Data subjects generally have the right to have their data deleted.
 
We typically process personal data only with the data subject’s consent unless permitted by other legal grounds—e.g., for fulfilling a contract, pre-contractual measures, overriding legitimate interests, or where the processing is evident from the circumstances or preceded by notice.
 
This includes information voluntarily provided by a data subject when contacting us (via post, email, contact form, social media, or phone) or during account registration. We may store such data in address books, CRM systems, or similar tools. If you share personal data of third parties, you are responsible for ensuring the protection and accuracy of that data.
 
We may also process personal data that we obtain from third parties, from public sources, or collect during the provision of our services, where such processing is legally permissible.
 

2.4 Processing by Third Parties, Including Abroad
 We may have personal data processed by authorized third parties or jointly with them or transmit data to them. These include service providers whose services we use. We ensure adequate data protection for such third parties.
 
These third parties are generally located in Switzerland or the EEA but may also be located elsewhere, provided they ensure adequate data protection according to the Swiss Federal Data Protection and Information Commissioner (FDPIC) and, where applicable, the European Commission. This can be through standard contractual clauses or certification (e.g., Privacy Shield in the USA). In exceptional cases, third parties may be in countries without adequate protection, in which case we ensure compliance through legal mechanisms such as explicit consent.

3. RIGHTS OF DATA SUBJECTS

Data subjects whose personal data we process have rights under Swiss data protection law. These include the right to information, correction, deletion, or blocking of data.

If and to the extent that the GDPR applies, data subjects also have the right to confirmation of whether their personal data is being processed, to access, restrict processing, exercise the right to data portability, and request correction, deletion (“right to be forgotten”), blocking, or completion of their data.

They may also withdraw previously given consent with future effect and object to the processing of their data at any time.

Data subjects have the right to lodge a complaint with a supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC).

4. DATA SECURITY

We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, the processing of personal data on the internet can still pose security vulnerabilities despite such measures. Therefore, we cannot guarantee absolute data security.

Access to our online offering is secured through transport encryption (SSL/TLS, particularly via Hypertext Transfer Protocol Secure, or HTTPS). Most browsers indicate transport encryption with a padlock icon in the address bar.

Access to our online offering—like any use of the internet in general—is subject to indiscriminate and suspicionless mass surveillance and other forms of monitoring by security authorities in Switzerland, the European Union (EU), the United States of America (USA), and other countries. We have no direct control over the handling of personal data by intelligence services, police departments, or other security authorities.

5. USE OF THE WEBSITE

5.1 Cookies

We may use cookies on our website. Cookies – both our own (first-party cookies) and those from third parties whose services we use (third-party cookies) – are text-based data stored in your browser. Cookies cannot execute programs or transmit malware such as trojans or viruses.

Cookies may be stored in your browser temporarily as “session cookies” or for a specified duration as so-called persistent cookies. Session cookies are automatically deleted when you close your browser. Persistent cookies allow your browser to be recognized the next time you visit our website, enabling features such as reach measurement. Persistent cookies may also be used for online marketing purposes.

You can disable or delete cookies in your browser settings at any time, either completely or partially. Without cookies, some parts of our online offering may no longer be fully functional. Where necessary, we will explicitly request your consent for the use of cookies.

For cookies used in performance and reach measurement or for advertising purposes, many services provide a general opt-out option through:

• Network Advertising Initiative (NAI)

• YourAdChoices (Digital Advertising Alliance)

• Your Online Choices (EDAA)

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5.2 Server Log Files

We may collect the following data for every access to our website, provided it is transmitted by your browser or determined by our web server: date and time including time zone, IP address, access status (HTTP status code), operating system including interface and version, browser including language and version, accessed pages of our website including transferred data volume, and the last page visited in the same browser window (referrer).

We store this data, which may constitute personal data, in server log files. This information is necessary to maintain a reliable, user-friendly, and secure online offering and to ensure data security – including through third parties where applicable.

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5.3 Web Beacons (Tracking Pixels)

We may use web beacons, also known as tracking pixels, on our website. These are small images – sometimes provided by third parties – that are automatically retrieved when visiting our website. Web beacons can collect the same data as server log files.