We are subject to Swiss data protection law and any applicable foreign data protection legislation, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
3081 Bern Switzerland
We will indicate if any other people are responsible for processing personal data in individual cases.
Data protection representation within the European Economic Area (EEA)
We have the following data protection representation pursuant to Art. 27 GDPR. The data protection representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries in connection with the GDPR:
VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg Germany
2. Terms and legal bases
Personal data is any information relating to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, irrespective of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as Iceland, Norway, and the Principality of Liechtenstein. The GDPR refers to the processing of personal data as “the processing of personal data”.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act and the Ordinance to the Federal Data Protection Act.
Insofar as the GDPR applies, we process personal data in accordance with at least one of the following legal bases:
- 6 para. 1b GDPR: 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.
- 6 para. 1f GDPR: For the necessary processing of personal data to protect 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 in a sustainable, user-friendly, secure and reliable manner, as well as to communicate about them, to protect the privacy of the data subject, and to protect the rights of third parties.
The main focus is on ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
- 6 para. 1c GDPR: For the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- 6 para. 1e GDPR: For the necessary processing of personal data for the performance of a task that is in the public interest.
- 6 para. 1a GDPR: For the processing of personal data with the consent of the person concerned.
- Article 6 para.1d GDPR: For the necessary processing of personal data to protect the vital interests of the data subject or another natural
3. Nature, scope and purpose
We process the personal data that is necessary 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 as well as 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 transmit it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data privacy for such third parties.
In principle, we only process personal data with the consent of the data subject unless the processing is permitted for other legal reasons, e.g. 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 particularly process information that a data subject voluntarily and personally provides when contacting us (for example, by letter, email, instant messaging, contact form, social media or telephone) or when registering for a user account. For example, we may store such information in an address book, a customer relationship management (CRM) system, or with comparable tools. If we receive data about other persons, the people who pass it on are obliged to ensure data privacy with respect to such persons and to ensure the accuracy of such personal data.
Insofar as such processing is permitted for legal reasons, 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.
We process personal data about applicants to the extent that it is necessary to assess their suitability for a position or for the subsequent performance of an employment contract. In particular, the required personal data results from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide, in particular as part of covering letters, CVs, and other application documents.
Insofar as the GDPR applies, we particularly process personal data about applicants in accordance with Art. 9 para. 2b GDPR.
5. Personal data abroad
In principle, we process personal data 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 any country and territory in the world or elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the assessment of the Federal Data Protection and Information Commissioner or in accordance with the decision of the Swiss Federal Council and – insofar as the GDPR applies - in accordance with the decision of the European Commission.
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 suitable 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. Upon request, we will be happy to provide data subjects with information about any guarantees or a copy of any guarantees.
6. Rights of data subjects
Data subjects whose personal data we process have rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.
Insofar as the GDPR applies, data subjects whose personal data we process may (free of charge) request confirmation as to whether we are processing their personal data and, if so, request information on the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.
Insofar as the GDPR applies, data subjects whose personal data we process may at any time withdraw their consent with effect for the future and object to the processing of their personal data.
Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner.
7. Data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. Unfortunately, we cannot guarantee absolute data security.
Access to our website is via transport encryption (TLS/SSL), in particular via Hypertext Transfer Protocol Secure (HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Like all digital communication in principle, our digital communication is subject to mass surveillance without any reason or cause for suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America, 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, whereas permanent cookies are stored for a specific period. In particular, cookies make it possible to recognize a browser the next time the website is visited and thus, for example, measure our website’s reach. However, permanent cookies can also (for example) be used for online marketing.
In the case of cookies that are used to measure success and reach or for advertising purposes, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance).
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 required 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 Tracking pixels
We may use tracking pixels (also known as web beacons) on our website. Tracking pixels (also from third parties whose services we use) are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can collect the same information as in server log files.
We enable you to publish comments on our website. In this context, we particularly process the information that a commenting person transmits to us, but also the Internet Protocol (IP) address used as well as the date and time. This information is required to enable publication of comments and ensure protection against misuse, which is in our overriding legitimate interest.
We enable you to subscribe to email notifications of new comments from other people. In particular, we need your email address so we can notify you or have you notified by email. You can unsubscribe from such comment notifications at any time.
9. Notifications and messages
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 was opened and which web links were clicked on. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We need this statistical recording of usage in order to measure success and reach so we can send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of recipients, and to do so permanently, securely and reliably.
9.2 Consent and objection
In principle, you must expressly consent to the use of your email address and other contact addresses unless the use is permitted for other legal reasons. Wherever possible, we use the “double opt-in” procedure for any consent, i.e. you will receive an email with a web link which you must click to confirm so that no misuse by unauthorized third parties can take place. We may log such consents, including the Internet Protocol (IP) address, date and time, for evidence and security reasons.
In principle, you may at any time object to receiving notifications and communications such as newsletters. At the same time, you can object to the statistical recording of use in order to measure success and reach. This is subject to any notifications and communications required in connection with our activities and operations.
9.3 Service provider for notifications and messages
We use specialized services to send notifications and messages.
In particular, we use:
- SendGrid: Platform for transactional emails (“emailing made easy”). Provider: Twilio Inc. (USA) / Twilio Ireland Ltd. Data protection information: Data privacy notice
10. Social media
We are present on social media platforms and other online platforms in order to communicate with interested people and inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
Insofar as the GDPR applies, we are jointly responsible with Meta Platforms Ireland Ltd. for our social media presence on Facebook, including so-called Page Insights. Meta Platforms Ireland Ltd. 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 provide our social media presence on Facebook in an effective and user-friendly way.
11. Third party services
We use the services of specialized third parties in order to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Amongst other things, such services enable us to embed functions and content in our website. If this sort of embedding occurs, the services used record users’ Internet Protocol (IP) addresses at least temporarily and for technically compelling reasons.
For any necessary security-related, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized or pseudonymized manner. For example, this is performance or usage data so we can offer the respective service.
In particular, we use:
- Google services: Providers: Google LLC (USA) / Google Ireland for users in the European Economic Area (EEA) and Switzerland. General information on data protection:
- Microsoft services: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Ltd. for users in the European Economic Area (EEA), the United Kingdom and Switzerland. General information on data protection:
11.1 Digital infrastructure
We use the services of specialized third parties to provide the digital infrastructure required in connection with our activities and operations. For example, these include hosting and storage services from selected providers.
11.2 Contact options
We use services from selected providers to improve communication with third parties such as potential and existing customers.
In particular, we use:
- HubSpot: Customer Relationship Management (CRM). Providers: HubSpot Inc. (USA) / HubSpot Ireland Ltd. for users in the European Economic Area (EEA). Information on data protection:
11.3 Audio and video conferences
Depending on one’s personal circumstances, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background superimposed.
In particular, we use:
- Microsoft Teams: Platform for, amongst other things, audio and video conferencing. Provider: Microsoft. Teams-specific information: Microsoft Teams Privacy
- Zoom: video conferencing. Provider: Zoom Video Communications Inc. (USA). Information on data protection:
11.4 Online collaboration
In particular, we use:
- Notion: Team collaboration platform. Provider: Notion Labs Inc. (USA).
Data protection information:
11.5 Social media functions and social media content
We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.
In particular, we use:
- Twitter for websites: Embedding of functions and content from Twitter, for example to display tweets. Provider: Twitter International Company (Ireland) for users in the European Economic Area (EEA) and the United Kingdom / Twitter Inc. (USA) for users in the rest of the world. Privacy information:
11.6 Map material
We use third party services to embed maps on our website. In particular, we use:
11.7 Digital audio and video content
We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.
In particular, we use:
- Vimeo: Video platform. Provider: Vimeo Inc. (USA). Information on data protection:
- YouTube: Video platform. Provider: Google. YouTube-specific information:
We engage in e-commerce and use third parties to successfully provide services, content or goods.
We use specialized service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers (such as the General Terms and Conditions (GTC) or data protection declarations) also apply to the processing of payments.
In particular, we use:
- Stripe: Processing of payments. Providers: Stripe Inc. (USA) / Stripe Payments Europe Ltd. (Ireland) for users in the European Economic Area (EEA) and Switzerland and partly in the UK / Stripe Payments UK Ltd. and Stripe Capital Europe Ltd. (Ireland) partly for users in the UK. Data protection information:
12. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use:
- Google reCAPTCHA: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots and spam). Provider: Google. Google reCAPTCHA-specific information:
13. Success and reach measurement
We use services and programs to determine how our online offering is used. For example, we may measure the success and reach of our activities and operations and the impact of third party links to our website. We can also, for example, test and compare how different versions of our online offering or parts thereof 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 programs for success and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are always shortened ("IP masking") in order to follow the principle of data economy through corresponding pseudonymization and thus improve data protection for users.
When using services and programs for success and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, pages visited or content viewed on our website, information on the size of the screen or browser window, and the (at least approximate) location. As a matter of 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, if necessary, assign the use of our online services to the user account or user profile of the respective service.
In particular, we use:
- Google Analytics: Success 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 transferred in full to Google in the USA in exceptional cases
- Google Tag Manager: Integration and management of other services for success and reach measurement as well as other services from Google and third parties. Provider: Google. Google Tag Manager-specific information: Data collected by Google Tag Manager. Further information on data protection can be found with the individual integrated and managed
14. Final provisions