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Data protec­tion smino.com

smino AG, Werk­strasse 20, 8645 Rapperswil-Jona, is the operator of the website and the smino app and the services offered on it. It is ther­e­fore respon­sible for the coll­ec­tion, proces­sing and use of your personal data, or person-related data (referred to in this privacy policy as personal data) and for ensu­ring that data proces­sing complies with appli­cable data protec­tion legis­la­tion. Your trust is important to us, which is why we take the issue of data protec­tion seriously and ensure appro­priate secu­rity.

Depen­ding on the way in which your data is processed, as defined in the GDPR or FADP) (uniformly referred to as proces­sing in this privacy policy), in addi­tion to appli­cable Swiss law (Federal Act of 25 September 2020 on Data Protec­tion, in force since 1 September 2023 (FADP, SR 235.1), Euro­pean data protec­tion law may apply addi­tio­nally or exclu­si­vely. This Regu­la­tion (EU) 2016/679 is referred to below as the General Data Protec­tion Regu­la­tion (GDPR). It is appli­cable in parti­cular in the context of the use of our website and the obser­va­tion of the beha­viour of affected data subjects resi­ding in the EU (Art. 3 para. 2(b) GDPR).

I. Name and address of the controller

smino AG
Werk­strasse 20
8645 Rapperswil-Jona
Switz­er­land
E‑mail: info@smino.com
Tel: +41 55 552 12 50

II. How we process your personal data

1. Visits to our website

Data proces­sing: When our website is accessed, the browser used on your device auto­ma­ti­cally sends infor­ma­tion to the server of our website. This infor­ma­tion is tempo­r­a­rily stored in a log file. Personal data: The follo­wing personal data is coll­ected without any action on your part and stored until it is auto­ma­ti­cally deleted:

  • the IP address of the reques­ting computer

  • the name of the holder of the IP address range (gene­rally your internet access provider)

  • the date and time of access

  • the website from which the access was made (referrer URL), if appli­cable with the search term used

  • the name and URL of the file accessed

  • the status code (e.g. error message)

  • the opera­ting system of your computer

  • the browser you are using (type, version and language)

  • the trans­mis­sion protocol used (e.g. HTTP/1.1)

  • if appli­cable, your user­name from a registration/authentication

Purpose: This data is coll­ected and processed for the purpose of enab­ling the use of our website (estab­li­shing a connec­tion), to ensure long-term system secu­rity and stabi­lity, and to opti­mise our website, as well as for internal statis­tical purposes.

Service provider: Our website is hosted by Kinsta Inc., 8605 Santa Monica Blvd #92581, West Holly­wood, CA 90069, USA (Kinsta). The hoster has access to the website and thus to your personal data for support purposes. More infor­ma­tion on how this service provider handles user data can be found in its privacy policy at: https://kinsta.com/legal/privacy-policy/ Our website is hosted by Cloud­flare Germany GmbH, Rosental 7, c/o Mind­space, 80331 Munich (Cloud­flare). The hoster has access to the website and thus to your personal data for support purposes. More infor­ma­tion on how this service provider handles user data can be found in its privacy policy at: https://www.cloudflare.com/en-gb/privacypolicy/

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: In addi­tion, there is an over­ri­ding private inte­rest in the proces­sing of your personal data in accordance with Art. 31 para. 1 FADP and Art. 6 para 1 (1)(f) GDPR.

Ensu­ring data protec­tion: Your personal data is processed by Kinsta in the USA. Kinsta Inc. is a parti­ci­pant in the EU–US and Swiss–US Data Privacy Frame­work Agree­ments and is certi­fied for non-HR data. As a result, your personal data may be trans­mitted to Kinsta in the USA without the need for addi­tional guaran­tees. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 para. 1(a) FADP and Art. 49 para. 1(a) GDPR. Cloud­flare gene­rally processes your personal data in Germany. The transfer of Euro­pean or Swiss personal data to Cloud­flare may result in this data being trans­ferred to its US parent company Cloud­flare, Inc. in the USA or to third parties in a country that does not have an equi­va­lent level of data protec­tion. Cloud­flare Inc. is a parti­ci­pant in the EU–US and Swiss–US Data Privacy Frame­work Agree­ments Under the EU–US Data Privacy Frame­work Agree­ment. Cloud­flare, Inc. is certi­fied for both HR and non-HR data. With regard to the Swiss–US Data Privacy Frame­work Agree­ment, Cloud­flare, Inc. is certi­fied for non-HR data. As a result, your personal data may be trans­mitted to Cloud­flare in the USA without the need for addi­tional guaran­tees. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 para. 1(a) FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This infor­ma­tion is neces­sary for the func­tio­ning of the website.

Reten­tion period: Log files created for the purpose of visi­ting the website are stored in accordance with the rele­vant statu­tory provi­sions for as long as neces­sary to fulfil the purposes described above.

Use of analy­tics and marke­ting tools: We use various analy­tical and marke­ting tools on our website to analyse the use of our website and to improve our services. Below we inform you about the tools used and the asso­ciated data proces­sing. (See detail under 3. Use of external tech­no­lo­gies for marke­ting and analysis purposes).

2. Contact

NOTE: In some cases, personal data will be trans­mitted to service provi­ders in third count­ries. Third count­ries are count­ries outside Switz­er­land, the EU and outside the EEA. These third count­ries also include the USA. The level of data protec­tion in the USA is not compa­rable to that in Switz­er­land or Europe. In parti­cular, it is possible that govern­ment bodies (US autho­ri­ties) may access personal data without us or you beco­ming aware of it. Legal action may not be successful. Personal data will only be trans­ferred to third count­ries if the requi­re­ments set out in Art. 16 f. FADP are met or if you have given your consent.

a) General enqui­ries, consul­ta­tions, appoint­ments, bug reporting

Data proces­sing: You can contact us by tele­phone, use the contact form or write an e‑mail. The reason for cont­ac­ting us may be a consul­ta­tion or a request of a general nature.

If you send us an e‑mail, your personal data will also be processed by Micro­soft as we use Micro­soft 365.

If you use our contact form, we use the HubSpot service to receive your request. The data entered when using the contact form is trans­mitted to HubSpot Forms and stored.

If you would like to make an appoint­ment with us, you can do so via our service provider HubSpot. The data provided during the appoint­ment will be trans­mitted to HubSpot and stored. The data you provide for the appoint­ment will be stored by us until the appoint­ment is held.

We use Slack for internal commu­ni­ca­tion and for colla­bo­ra­tion within the team, e.g. in the case of a bug report. If you report a bug, your personal data may also be processed by Slack to comply with your request.

We use the Slack service for internal commu­ni­ca­tion and for colla­bo­ra­tion within the team, e.g. in the case of a bug report.
In the case of a bug report, your personal data may also be processed by Slack in order to respond to your request.

We use the Crisp live chat service to provide a direct commu­ni­ca­tion channel on our website. If you use our live chat, the data you enter will be trans­mitted to Crisp and stored.

Micro­soft, HubSpot, Slack and Crisp all have access to the afore­men­tioned personal data where support is provided. We will store the data you provide when you contact us until your request has been processed in full.

Personal data: The follo­wing personal data may be coll­ected:

  • E‑mail address
  • Title
  • First name
  • Last name
  • Company
  • Role in the company
  • City
  • Country
  • Mobile/landline number
  • IP address
  • Appoint­ment infor­ma­tion (date and time)
  • Tele­phone number, if required for the appoint­ment

Purpose: The purpose of proces­sing the personal data provided is to respond to and process your enquiry with regard to advice, bug reporting, the initia­tion or conclu­sion of contracts, or general enqui­ries.

Service provider: We use Micro­soft 365 from Micro­soft Ireland Opera­tions Ltd., South County Busi­ness Park, One Micro­soft Place, Leopard­stown, Dublin 18, D18 P521, Ireland (Micro­soft) to process commu­ni­ca­tions.

The meeting tool service provider is HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA (HubSpot).

We use the Slack service for our commu­ni­ca­tion and colla­bo­ra­tion. The provider of Slack is Slack Tech­no­lo­gies Limited, Sales­force Tower, 60 R801 North Dock, Dublin, Ireland (Slack).

We use EU-based service provider Crisp for our live chat service. Crisp is provided by Crisp IM SARL, 2 Boule­vard de Launay, 44100 Nantes, France (Crisp).

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Your personal data is processed in rela­tion to the US services with your explicit consent. Further­more, the proces­sing of your personal data would be lawful upon your request to prepare contracts or to execute a purchase contract (see Art. 31 para. 2(a) FADP and Art. 6 para. 1 clause 1(b) GDPR). In addi­tion, in the event of a general enquiry we would have an over­ri­ding private inte­rest in proces­sing your personal data, in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR.

Ensu­ring data protec­tion: If you consent to data proces­sing by Micro­soft, HubSpot, Slack and Crisp, you also agree to your personal data being trans­mitted to the USA in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Micro­soft, HubSpot and Crisp are obliged under new, curr­ently agreed stan­dard contrac­tual clauses and order proces­sing agree­ments to process your personal data only in accordance with our instruc­tions, to delete it irre­vo­cably after the order, and to comply with the rele­vant data protec­tion provi­sions. Further infor­ma­tion on the proces­sing of your personal data can be found in the notice under section 2 of this privacy policy. More infor­ma­tion on how Micro­soft, HubSpot and Crisp handle user data can be found in these compa­nies’ own privacy poli­cies:

Micro­soft: https://www.microsoft.com/en-gb/privacy/privacystatement

HubSpot: https://legal.hubspot.com/privacy-policy

Crisp: https://crisp.chat/en/privacy/

Slack: https://slack.com/intl/en-gb/trust/privacy/privacy-policy?geocode=eu-gb

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data stored for the purpose of estab­li­shing contact will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes.

B) Appli­ca­tions

Data proces­sing: You may apply to use by post, via e‑mail or online a contact form. In the latter case, we process all data that you send us with your appli­ca­tion dossier.

Personal data: The follo­wing personal data may be coll­ected:

  • Manda­tory appli­cant master data (first name, last name, e‑mail address, tele­phone number, address, date of birth, natio­na­lity, country of resi­dence)
  • Profes­sional data (cover letter, personal state­ment, CV, previous jobs, profes­sional quali­fi­ca­tions and capa­bi­li­ties)
  • Volun­tary infor­ma­tion, such as title, photo, where you heard of the job or other infor­ma­tion that you volun­t­a­rily provide us with in your appli­ca­tion or upload
  • Addi­tional ques­tions depen­ding on the job being adver­tised (start date and salary expec­ta­tions)
  • Commu­ni­ca­tion between you and us as well as comm­ents and evalua­tions written concer­ning you in the course of your appli­ca­tion process
  • Other data/data cate­go­ries, such as publicly available profes­sional data, e.g. a public profile on profes­sional social media networks such as XING or LinkedIn.

Purpose: The personal data provided is processed to fulfil your enquiry with regard to the initia­tion of an employ­ment contract, or to be stored in our appli­cant pool by your consent. The purpose of consent is to allow us to return to your profile if a suitable vacancy becomes available.

Service provider: We use Personio for the appli­ca­tion process. The provider of these services is Personio GmbH, Radio­funk­platz 4, 80335 Munich, Germany (Personio). More infor­ma­tion on how Personio handles user data can be found in its privacy policy at: https://www.personio.com/privacy-policy/

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: The proces­sing of your personal data would also be lawful due to the initia­tion of an employ­ment contract for the purpose of selec­ting personnel to fill filling vacan­cies in accordance with Art. 31 para. 2(a) FADP and Art. 6 para. 1 clause 1(b) GDPR. Further­more, the proces­sing of your personal data on the basis of our over­ri­ding inte­rest in asser­ting, exer­cising or defen­ding legal claims would be covered by Art. 31 para. 1 FADP and Art. 6(1)(f) GDPR. As part of this you can also consent that we include you in our pool of appli­cants. You can revoke your consent at any time.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data stored for the purpose of the appli­ca­tion will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes. If the appli­ca­tion is unsuc­cessful, we store your personal data to assert, exer­cise or defend our legal claims for six months. If you consent, we store your personal data for the maximum permitted period of 12 months since the last consent or expres­sion of inte­rest, and then delete it.

 

3. Use of external tech­no­lo­gies for marke­ting and analy­tics purposes

On our websites we use cookies and pixel tech­no­lo­gies for marke­ting and analy­tics purposes. The cookie and pixel policy can be found here.

Cookies are small text files that can be stored and read on your device. A distinc­tion is made between session cookies that are deleted as soon as you close your browser, and perma­nent cookies that are stored beyond the indi­vi­dual session. Cookies may contain data that makes it possible to reco­g­nise the device used. However, some cookies only contain infor­ma­tion about specific settings that are not perso­nally iden­ti­fiable.

You can confi­gure your browser to inform you about the place­ment of cookies. This makes the use of cookies trans­pa­rent for you. You can also delete cookies at any time via the corre­spon­ding browser setting, and prevent the setting of new cookies. Please note that our websites will then not be displayed opti­mally and nume­rous elemen­tary func­tions will no longer be tech­ni­cally available.

We use session cookies and perma­nent cookies on our websites. We process your personal data with regard to cookies in accordance with the prin­ci­ples set out in Arts. 6 to 8 FADP. You can find detailed infor­ma­tion in the follo­wing sections of this privacy policy.

 

a) Use of US tech­no­lo­gies

(1) Use of social media plug-ins

Data proces­sing: Face­book, Insta­gram, YouTube and LinkedIn plug-ins: We operate social media profiles on Face­book (https://www.facebook.com/sminocom/), Insta­gram (https://www.instagram.com/smino_culture/), LinkedIn (https://www.linkedin.com/company/smino/) and YouTube (https://www.youtube.com/@sminoag/). You can contact us via these profiles. Also, we have placed social media buttons from Face­book, Insta­gram, LinkedIn and YouTube on our website, so that you can easily link to our Face­book, Insta­gram, LinkedIn and YouTube profiles. Your personal data will only be processed when you click on the corre­spon­ding social media buttons, or on embedded images, or contact us via the social media sites listed. The data coll­ected is also anony­mised and then used in the form of statis­tics. A reco­g­nisable marker is also set.

If you click on the YouTube social media button, we use the Privacy Enhanced Mode provided by YouTube. Accor­ding to YouTube, in this mode your data will only be trans­mitted to the YouTube server in the USA when you watch the video. Here, data refers in parti­cular to which of our websites you have visited and your IP address. If you are logged into your YouTube account, you allow YouTube to link your surfing beha­viour directly with your personal profile. You can prevent this by logging out of your YouTube account.

Personal data: The follo­wing personal data is processed:

  • User beha­viour
  • IP address
  • Connec­tion data
  • Devices and browser infor­ma­tion
  • Data about the content accessed when clicking on social media buttons
    • User­name or first and last name
    • Possibly your picture and data that you provided to us when you cont­acted us.

Purpose: The Face­book, Insta­gram, YouTube and LinkedIn plug-ins are used to struc­ture our website and to place other web content on our website. The use of YouTube videos also helps to struc­ture our website and places other web content on our website. Clicking on the video or social media button concerned redi­rects you to the website of that provider. We have no influence on the proces­sing of personal data on third-party websites. Please refer to the infor­ma­tion in section 2 of this privacy policy.

Service provider: The provider of Face­book and Insta­gram plugins is Meta Plat­forms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Face­book).

The provider of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (YouTube).

The provider of the LinkedIn plug-in is LinkedIn Ireland Unli­mited Company, Wilton Place, Dublin 2, Ireland (LinkedIn). You can find more infor­ma­tion in their indi­vi­dual privacy poli­cies:

Face­book: https://www.facebook.com/about/privacy/

YouTube: https://policies.google.com/privacy?hl=en&gl=de

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: If you contact us via one of our social media profiles, we process your data based on our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR in order to provide a means of commu­ni­ca­tion. In addi­tion, your personal data is processed with regard to US services with your explicit consent (Art. 31 para. 1 FADP and Art. 6 para. 1(a) GDPR).

Ensu­ring data protec­tion: If you consent to proces­sing by Face­book, YouTube and LinkedIn, you ther­e­fore also consent to the transfer of your personal data to the USA in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: With regard to the Face­book, Insta­gram, YouTube and LinkedIn plug-ins, cookies can be stored on your device for up to 10 years. Data processed in connec­tion with your contact via Face­book, Insta­gram or LinkedIn will be deleted after one year, unless we are obliged to retain it for five or 10 years for commu­ni­ca­tion purposes.

(2) Use of HubSpot – CRM tech­no­logy

Data proces­sing: We use HubSpot as a CRM (customer rela­ti­onship manage­ment) tool to orga­nise and analyse our busi­ness rela­ti­onships. The data stored in HubSpot is coll­ected and processed by us. HubSpot also has access to the afore­men­tioned personal data where support is provided. The data you provide to us for the purposes of the busi­ness rela­ti­onship will be stored by us until the end of this rela­ti­onship, after which it is deleted from both our servers and HubSpot servers.

HubSpot offers exten­sive analy­tical capa­bi­li­ties to evaluate client inter­ac­tions, inclu­ding e‑mail tracking, website acti­vity and conver­sion rates. We use these analyses for group-related analyses, but not for indi­vi­dual profiling.

Personal data: The follo­wing personal data is processed:

  • First and last names
  • Contact details (e.g. e‑mail, tele­phone number)
  • Company details
  • Inter­ac­tion history (e.g. e‑mail commu­ni­ca­tion, website visits, form submis­sions)
  • Beha­viour-based data (e.g. clicks, page views, dura­tion of visit, loca­tion)
  • IP address

Purpose: The data in ques­tion is processed for the purpose of mana­ging busi­ness rela­ti­onships, pursuing sales acti­vi­ties, client analysis and auto­ma­ting marke­ting campaigns. This proces­sing acti­vity is of funda­mental importance to the effi­cient orga­ni­sa­tion and main­ten­ance of our busi­ness rela­ti­onships, as well as for targeted marke­ting.

Service provider: We use the HubSpot service for client rela­ti­onship manage­ment. The provider of HubSpot is HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA. More infor­ma­tion on how HubSpot handles user data can be found in its privacy policy:  https://legal.hubspot.com/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: HubSpot gene­rally processes your data in the USA. We have agreed with HubSpot that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data stored for the purpose of busi­ness rela­ti­onship manage­ment and client analysis will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes or until you with­draw your consent to the proces­sing of that personal data.


(3) Use of HubSpot web tracking

Data proces­sing: We use HubSpot’s web tracking tool on our website to analyse user beha­viour on the website.

Personal data: The follo­wing personal data is processed:

  • IP address
  • Inter­ac­tion history (clicks, page views and length of stay)
  • Tech­nical infor­ma­tion (browser type and opera­ting system)
  • Device proper­ties (screen size and reso­lu­tion)
  • Geogra­phical data (origin of access)

Purpose: The data is processed to analyse user beha­viour on our website and to opti­mise our offe­ring and to make it more targeted.

Service provider: The provider of the web tracking tool for the analysis of user beha­viour on our website is HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA. More infor­ma­tion on how HubSpot handles user data can be found in its privacy policy:  https://legal.hubspot.com/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: HubSpot gene­rally processes your data in the USA. We have agreed with HubSpot that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data coll­ected via the web tracking tool will be stored in accordance with the rele­vant statu­tory provi­sions and as long as this is neces­sary to fulfil the afore­men­tioned purposes or until you with­draw your consent to the proces­sing of that personal data.

(4) Use of Micro­soft Clarity

Data proces­sing: We use Micro­soft Clarity to record and evaluate the inter­ac­tions of users of our website. Micro­soft Clarity helps us to opti­mize our website and improve the user expe­ri­ence.

Personal data: The follo­wing personal data is processed:

  • IP address
  • Inter­ac­tion history (clicks, scrol­ling acti­vity, keyboard entries, page views)
  • Tech­nical infor­ma­tion (browser type and opera­ting system)
  • Device proper­ties (screen size and reso­lu­tion)
  • Geogra­phical data (origin of access)

Purpose: Micro­soft Clarity is used to analyse and opti­mise our website. We evaluate usage beha­viour to make our website more user-friendly, iden­tify problem areas and improve the overall perfor­mance of our website.

Service provider: The provider of Micro­soft Clarity, used to capture and evaluate the inter­ac­tions of users of our website, is Micro­soft Corpo­ra­tion, One Micro­soft Way, Redmond, WA 98052–6399, USA. More infor­ma­tion on how Micro­soft Clarity handles user data can be found in its privacy policy:  https://www.microsoft.com/en-gb/privacy/privacystatement

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Micro­soft gene­rally processes your data in the USA. We have agreed with Micro­soft that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The Micro­soft Clarity data you provide to us is stored for up to 12 months and then deleted.

B) Use of EU and Swiss tech­no­lo­gies

NOTE: EU and Swiss tech­no­lo­gies are subject to a similar level of data protec­tion. Data trans­fers to and from Switz­er­land and to and from the EU ther­e­fore comply with data protec­tion regu­la­tions. Order proces­sing agree­ments have been agreed for such data trans­fers.

(1) Use of Lemlist – e‑mail outreach tech­no­logy

Data proces­sing: We use Lemlist to conduct e‑mail outreach campaigns and inform you about us and our offers. The data stored for the e‑mail campaigns is trans­mitted to Lemlist and stored. Lemlist also has access to the afore­men­tioned personal data where support is provided. We store the data you provide to us for the purposes of e‑mail commu­ni­ca­tion, and then deleted from both our servers and Lemlist servers after the end of the e‑mail campaigns.

Further­more, Lemlist offers various options for analy­sing how sent e‑mails are opened and used. Examples are how many users an e‑mail was sent to, whether e‑mails were rejected, and whether users unsub­scribed from the list after recei­ving an e‑mail. These analyses are group-based and are not used by us for indi­vi­dual evalua­tion.

Personal data: The follo­wing personal data is processed:

  • IP address
  • E‑mail
  • Timing of regis­tra­tion
  • If appli­cable, first and last names
  • If appli­cable, tele­phone number
  • Age
  • Gender
  • Occu­pa­tion
  • Address
  • Browser and device data

Purpose: The data in ques­tion is processed for the purpose of e‑mail commu­ni­ca­tion and e‑mail analysis to gene­rate new leads and clients in sales.

Service provider: We use the Lemlist service for our e‑mail campaigns. The provider of Lemlist is LEMPIRE Lemlist SAS, 51 rue de la Répu­blique, 69002 Lyon, France (Lemlist). More infor­ma­tion on how Lemlist handles user data can be found in its privacy policy:  https://www.lemlist.com/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, your personal data will be processed with your consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1(a) GDPR. You can revoke your consent to the storage of data and the e‑mail address, and their use for e‑mail commu­ni­ca­tion, at any time. The lawful­ness of the data proces­sing already carried out remains unaf­fected by the revo­ca­tion.

Ensu­ring data protec­tion: Lemlist processes your data on our behalf and in accordance with our instruc­tions. To ensure that Lemlist takes the protec­tion of your data as seriously as we do, we have concluded an order proces­sing agree­ment with Lemlist. In addi­tion, the Federal Council has decided that France has an adequate level of data protec­tion. As a result, your personal data may be trans­mitted to Lemlist in France without the need for addi­tional guaran­tees.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data stored for the purpose of conduc­ting e‑mail campaigns and analysis will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes or until you with­draw your consent to the proces­sing of that personal data.

(2) Use of Google Tag Manager

Data proces­sing: We use Google Tag Manager (GTM) on our website. GTM is a tag manage­ment system that inte­grates tags in a stan­dar­dised way across a user inter­face. Tags are short sections of source code that track acti­vi­ties and can access other systems to control centrally when certain systems are trig­gered. Google marke­ting plat­forms (Double Click and Google Analy­tics 4), Google Ads Remar­ke­ting, Scarab Rese­arch from Emarsys and Meta Pixel are inte­grated into GTM. GTM is ther­e­fore merely a switch between website and analysis soft­ware. Via your browser settings you can prevent the setting of tags at any time. Further infor­ma­tion on these systems and their data proces­sing can be found in the follo­wing sections.

Personal data: GTM ensures the acti­va­tion of other tools that then collect personal data. Depen­ding on the tool that is inte­grated, GTM coll­ects the IP addresses of website visi­tors and passes these on to the analy­tics programs. More infor­ma­tion on indi­vi­dual data proces­sing can be found in the follo­wing chap­ters.

Purpose: We process your personal data for marke­ting and analysis purposes. We evaluate your user beha­viour, run conver­sion tracking, gene­rate statis­tics and opti­mise our adver­ti­sing chan­nels and approa­ches.

Service provider:  The provider of GTM is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. More infor­ma­tion on how Google Tag Manager handles user data can be found in its privacy policy: https://policies.google.com/privacy?hl=en&gl=de

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: The use of GTM is based on our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Google gene­rally processes your personal data in Ireland. The transfer of Euro­pean or Swiss personal data to Google may result in this data being trans­ferred to its US parent company Google LLC in the USA or to third parties in a country that does not have an equi­va­lent level of data protec­tion. We have agreed with Google that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: Your data will be stored on the terminal device for up to two years unless it is renewed.

(3) Use of Google Analy­tics 4

Data proces­sing: We use Google Analy­tics 4 on our website. Cookies are used to create pseud­ony­mous user profiles. The data is stored on the end device, anony­mised and evaluated in the form of statis­tics.

Personal data: The follo­wing data will be processed by you:

  • Masked IP address of the reques­ting computer
  • Date and time of access
  • Website from which access is made (referrer URL)
  • Browser type and version
  • Number of visits/users
  • Meeting statis­tics

Demo­gra­phics and inte­rests:

  • Age: 18–24, 25–34, 35–44, 45–54, 55–64, 65+
  • Gender: male, female
  • Cate­go­ries of common inte­rests
  • Segments with target groups inte­rested in purcha­sing
  • Other cate­go­ries that provide the most specific view of users

Three perma­nent cookies are used by Google Analy­tics 4 for this purpose (_gat, _gid, _ga). These are auto­ma­ti­cally deleted after a defined period of time.

We also record the Google Analy­tics ID (client ID) as soon as you click on the regis­tra­tion or login button. The client ID can be combined with your user data. Upon successful regis­tra­tion, Google Analy­tics is noti­fied that a conver­sion has taken place. However, no user data is trans­mitted from smino to Google.

The recorded IP addresses are anony­mised by Google Analy­tics 4. This is known as IP masking. Only in excep­tional cases will the full IP address be trans­mitted to a Google server in the USA and trun­cated there.

Purpose: We use Google Analy­tics 4 for error analysis and to make conti­nual impro­ve­ments to the offe­ring on our websites by means of statis­tical analysis.

Service provider: The provider of Google Analy­tics 4 is Google Ireland Limited, based in Gordon House, Barrow Street, Dublin 4, Ireland. More infor­ma­tion on how Google Analy­tics 4 handles user data can be found in its privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion:  Google gene­rally processes your personal data in Ireland. The transfer of Euro­pean or Swiss personal data to Google may result in this data being trans­ferred to its US parent company Google LLC in the USA or to third parties in a country that does not have an equi­va­lent level of data protec­tion. We have agreed with Google that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: Your data will be stored on the end device for up to two years.

(4) Use of Google Ads

Data proces­sing: We have inte­grated Google Ads, inclu­ding Google Remar­ke­ting, on our website. These internet adver­ti­sing services allow adver­ti­sers to place ads both in Google search engine results and on Google adver­ti­sing networks (conver­sion tracking). Google Ads allows an adver­tiser to pre-define specific keywords that mean that an ad is displayed in Google search engine results only when the user uses the search engine to retrieve a keyword-rele­vant search result. In the Google adver­ti­sing network, the ads are distri­buted to rele­vant websites using an auto­matic algo­rithm and taking into account the previously defined keywords. In the case of Google Ads Remar­ke­ting (GA audi­ence), visi­tors to our website are included in lists that allow us to address you again as a poten­tial client. As a user on the remar­ke­ting list, we can display targeted ads for you. 

Personal data: Conver­sion cookies store personal data, such as the websites visited by the data subject. Accor­dingly, the follo­wing personal data is processed every time you visit our website:

  • Click path
  • IP address
  • Cookie IDs
  • Unique iden­ti­fier of the mobile device 
  • Number of visits/users
  • Tran­sac­tions
  • Usage data

Purpose: The purpose of these ad services is to adver­tise our website by displaying rele­vant adver­ti­sing on the websites of third-party compa­nies and in the search engine results of the Google search engine, as well as by displaying third-party adver­ti­sing on our website.

Service provider: The provider of Google Ads, inclu­ding Google Remar­ke­ting, is Google Ireland Limited (Google), Gordon House, Barrow Street, Dublin 4, Ireland. More infor­ma­tion on how Google Ads handles user data can be found in its privacy policy: https://support.google.com/google-ads/answer/12929169?hl=en

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Google gene­rally processes your personal data in Ireland. The transfer of Euro­pean or Swiss personal data to Google may result in this data being trans­ferred to its US parent company Google LLC in the USA or to third parties in a country that does not have an equi­va­lent level of data protec­tion. We have agreed with Google that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: The afore­men­tioned data is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The reten­tion period is gene­rally 13 months.

(5) Use of Lead­info

Data proces­sing: We use the user beha­viour analysis tool Lead­info on our website. Lead­info allows us to iden­tify website visi­tors and leads and to opti­mise our marke­ting and sales acti­vi­ties accor­dingly.

Personal data: The follo­wing personal data is processed when using Lead­info:

  • IP address
  • Inter­ac­tion history (clicks, page views, length of stay)
  • Tech­nical infor­ma­tion (browser type and opera­ting system)
  • Geogra­phical data (origin of access)

Purpose: Lead­info processes data to analyse user beha­viour on our website. This infor­ma­tion is used to iden­tify poten­tial clients, to opti­mise our marke­ting and sales acti­vi­ties, and to conti­nuously improve our offe­ring.

Service provider: Lead­info is a service of Lead­info B.V., Rivium Quadrant 141, 2909LC Capelle aan IJssel, Nether­lands (Lead­info). More infor­ma­tion on how Lead­info handles user data can be found in its privacy policy: https://www.leadinfo.com/en/legal/privacy/

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Lead­info processes your data on our behalf and in accordance with our instruc­tions. To ensure that Lead­info takes the protec­tion of your data as seriously as we do, we have concluded an order proces­sing agree­ment with Lead­info. In addi­tion, the Federal Council has decided that the Nether­lands has an adequate level of data protec­tion. As a result, your personal data may be trans­mitted to Lead­info in the Nether­lands without the need for addi­tional guaran­tees.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data coll­ected will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes.

(6) Use of LinkedIn Insight Tag

Data proces­sing: We have inte­grated the LinkedIn Insight Tag analysis tool on our website.

Personal data: The follo­wing personal data is processed in connec­tion with the use of LinkedIn Insight Tag:

  • Click path
  • URL/referrer URL
  • IP address
  • Timestamp
  • Device and browser proper­ties
  • Page actions (e.g. inter­ac­tions, length of stay, conver­sions)
  • Key profes­sional data for regis­tered LinkedIn users (e.g. posi­tion, industry)

Purpose: We use the LinkedIn Insight Tag to gene­rate detailed campaign reports and gain insights into our website visi­tors. LinkedIn Insight Tag creates a cookie in the visitor’s browser when visi­ting our website and allows data on members’ visits to our website to be coll­ected. This data allows us to better align our website with our target group.

Service provider: The provider of LinkedIn Insight Tag is LinkedIn Ireland Unli­mited Company (LinkedIn), Wilton Place, Dublin 2, Ireland. More infor­ma­tion on how LinkedIn Insight Tag handles user data can be found in its privacy policy:  https://www.linkedin.com/legal/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Accor­ding to its privacy policy, LinkedIn Ireland Unli­mited also shares data with its affi­liated compa­nies such as LinkedIn Corpo­ra­tion (USA), LinkedIn Singa­pore and Micro­soft Corpo­ra­tion (USA). LinkedIn Corpo­ra­tion (USA) is not a parti­ci­pant in the EU–US and Swiss–US Data Privacy Frame­work, and it is also other­wise possible that LinkedIn trans­mits data to third count­ries. Ther­e­fore, if trans­ferred your data may be subject to a level of data protec­tion that is not compa­rable to that in Switz­er­land or the EU. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The reten­tion period for the use of LinkedIn Insight is up to six months.

(7) Use of LinkedIn Ads

Data proces­sing: We have inte­grated LinkedIn Ads on our website. These internet adver­ti­sing services allow adver­ti­sers to place ads on both the LinkedIn plat­form and the LinkedIn adver­ti­sing network (conver­sion tracking).

LinkedIn Ads allows us to place targeted adver­ti­sing on the LinkedIn plat­form and address a rele­vant target audi­ence. This may include spon­sored content, spon­sored messa­ging, dynamic ads or text ads.

Personal data: Conver­sion cookies store personal data, such as the websites visited by the data subject. Accor­dingly, the follo­wing personal data is processed every time you visit our website:

  • Click path
  • IP address
  • Cookie IDs
  • Unique iden­ti­fier of the mobile device
  • Number of visits/users
  • Tran­sac­tions
  • Usage data

Purpose: The purpose of these ad services is to adver­tise our website by displaying rele­vant adver­ti­sing on the websites of third-party compa­nies and on the LinkedIn plat­form, as well as by displaying third-party adver­ti­sing on our website.

Service provider: The provider of LinkedIn Ads is LinkedIn Ireland Unli­mited Company (LinkedIn), Wilton Place, Dublin 2, Ireland. More infor­ma­tion on how LinkedIn Ads handles user data can be found in its privacy policy:  https://www.linkedin.com/legal/privacy-policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Accor­ding to its privacy policy, LinkedIn Ireland Unli­mited also shares data with its affi­liated compa­nies such as LinkedIn Corpo­ra­tion (USA), LinkedIn Singa­pore and Micro­soft Corpo­ra­tion (USA). LinkedIn Corpo­ra­tion (USA) is not a parti­ci­pant in the EU–US and Swiss–US Data Privacy Frame­work, and it is also other­wise possible that LinkedIn trans­mits data to third count­ries. Ther­e­fore, if trans­ferred your data may be subject to a level of data protec­tion that is not compa­rable to that in Switz­er­land or the EU. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The reten­tion period for the use of LinkedIn Ads is up to six months.

(8) Use of Micro­soft Adver­ti­sing (or Micro­soft Ads)

Data proces­sing: We have inte­grated Micro­soft Adver­ti­se­ment (form­erly Bing Ads) on our website. This service helps us place targeted adver­ti­se­ments and analyse the effec­ti­ve­ness of our adver­ti­sing campaigns. These internet adver­ti­sing services allow adver­ti­sers to place ads in both Micro­soft Bing’s search engine results and the Micro­soft Search Network (conver­sion tracking). Micro­soft Adver­ti­sing allows an adver­tiser to pre-define specific keywords that mean an ad is displayed in Micro­soft Bing search engine results only when the user uses the search engine to retrieve a keyword-rele­vant search result. In the Micro­soft adver­ti­sing network, the ads are distri­buted to rele­vant websites using an auto­matic algo­rithm and taking into account the previously defined keywords.

Personal data: Conver­sion cookies store personal data, such as the websites visited by the data subject. Accor­dingly, the follo­wing personal data is processed every time you visit our website:

  • IP address
  • Cookie IDs
  • Date and time of access
  • Inter­ac­tion history (clicks, scrol­ling acti­vi­ties, page views)
  • Tech­nical infor­ma­tion (browser type and opera­ting system)
  • Geogra­phical data (origin of access)
  • Response to adverts (time on target page, actions such as tran­sac­tions and conver­sions)

Purpose: The purpose of these ad services is to adver­tise our website by displaying rele­vant adver­ti­sing on the websites of third-party compa­nies and in the search engine results of the Micro­soft Bing search engine, as well as by displaying third-party adver­ti­sing on our website.

Service provider: The provider of Micro­soft Adver­ti­se­ment is Micro­soft Ireland Opera­tions Ltd. (Micro­soft), South County Busi­ness Park, One Micro­soft Place, D18P521, Leopard­stown, Ireland. More infor­ma­tion on how Micro­soft Ads handles user data can be found in its privacy policy:  https://www.microsoft.com/en-gb/privacy/privacystatement

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Data is processed on the basis of our over­ri­ding private inte­rest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(f) GDPR. In addi­tion, we process your personal data on the basis of your explicit consent in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 clause 1(a)GDPR, which you provide via the cookie banner.

Ensu­ring data protec­tion: Micro­soft gene­rally processes your personal data in Ireland. The transfer of Euro­pean or Swiss personal data to Micro­soft may result in this data being trans­ferred to its US parent company Micro­soft Corp. in the USA or to third parties in a country that does not have an equi­va­lent level of data protec­tion. We have agreed with Micro­soft that a transfer to the USA will take place based on the EU–US or Swiss–US Data Privacy Frame­work or, if the Data Privacy Frame­work is declared invalid, based on stan­dard contrac­tual clauses as well as appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures. By giving your consent via the cookie banner, you also agree to your personal data being trans­mitted to unsafe third count­ries in accordance with Art. 17 FADP and Art. 49 para. 1(a) GDPR.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The reten­tion period for Micro­soft Ads is gene­rally 13 months.

(9) Use of Meta Pixel

Data proces­sing: We have inte­grated Meta Pixel (inclu­ding Face­book Custom Audi­ence) from Meta Plat­forms Ireland Ltd. (Meta), 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, on our website. These internet adver­ti­sing services allow adver­ti­sers to place ads on the Face­book and Insta­gram plat­forms, and on meta adver­ti­sing networks (conver­sion tracking). Meta Pixel allows us to place targeted adver­ti­sing on the Face­book and/or Insta­gram plat­form and address a rele­vant audi­ence. This may include spon­sored content, spon­sored messa­ging, dynamic ads or text ads. In the case of Face­book Custom Audi­ence, visi­tors to our website are included in lists that allow us to address you again as a poten­tial client. As a user on the remar­ke­ting list, we can display targeted ads for you.

Personal data: Conver­sion cookies store personal data, such as the websites visited by the data subject. Accor­dingly, the follo­wing personal data is processed every time you visit our website:

  • IP address
  • Click path
  • Cookie IDs
  • Unique iden­ti­fier of the mobile device
  • Number of visits/users
  • Tran­sac­tions

Purpose: The purpose of these services is to adver­tise our website by displaying rele­vant adver­ti­sing on the websites of third-party compa­nies and on the Face­book plat­form and by displaying third-party adver­ti­sing on our website.

Service provider: The provider of Meta Pixel is Meta Plat­forms Ireland Ltd. (Meta), 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. More infor­ma­tion on how this service provider handles user data can be found in its privacy policy at: https://www.facebook.com/privacy/policy

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples pursuant to Art. 6 to 8 FADP and Art. 5 to 11 GDPR.

Legal basis: If you contact us via one of our social media profiles, we process your data based on our over­ri­ding private inte­rest in accordance with Art. 31 para. 2 FADP and Art. 6 para. 1 clause (1)(f) GDPR in order to provide a means of commu­ni­ca­tion. The personal data coll­ected by the cookies embedded on our website will only be processed by us with your consent (Art. 31 para. 1 FADP and Art. 6 para. 1(a) GDPR), which you give via the cookie banner.

Ensu­ring data protec­tion: Your personal data is processed by Meta Plat­forms Ireland Ltd. in Ireland. Personal data may also be trans­ferred to the US parent company Meta Plat­forms Inc. and to other subcon­trac­tors of Meta Plat­forms Ireland Ltd. or Inc. Meta Plat­forms Inc. is a parti­ci­pant in the EU–US and Swiss–US Data Privacy Frame­work and is certi­fied for non-HR data, i.e. all personal data. As a result, your personal data may be trans­mitted to Meta in the USA without the need for addi­tional guaran­tees.

Neces­sity: The afore­men­tioned data is not neces­sary for the func­tion­a­lity of this website.

Reten­tion period: The reten­tion period for Meta Pixel is gene­rally 90 days.

(10) Use of Hotjar – web analy­tics tool

Data proces­sing: We use the Hotjar service to opti­mise our website and to better under­stand user beha­viour. Hotjar enables us to track the beha­viour of our website users by means of heat­maps and thus make impro­ve­ments. The data coll­ected in this process is trans­mitted to and stored by Hotjar. Hotjar also has access to the afore­men­tioned personal data where support is provided.

Personal data: The follo­wing personal data is processed:

  • IP address (anony­mised)
  • Screen size of the device
  • Device type and browser infor­ma­tion
  • Geogra­phical posi­tion (country only)
  • Preferred display language for our website
  • User inter­ac­tions (e.g. mouse move­ments, clicks, and scrol­ling)

Purpose: We process the afore­men­tioned data to analyse user beha­viour and opti­mise our website.

Service provider: We use the Hotjar service to analyse our user beha­viour. The provider of Hotjar is Hotjar Ltd, Drago­nara Busi­ness Centre, 5th floor, Drago­nara Road, Pace­ville St Julian’s STJ 3141, Malta, Europe (Hotjar). More infor­ma­tion on how Hotjar handles user data can be found in its privacy policy: https://www.hotjar.com/legal/policies/privacy/

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Arts. 6 to 8 FADP and Arts. 5 to 11 GDPR.

Legal basis: Your personal data is processed on the basis of our legi­ti­mate inte­rest in opti­mi­sing our online offe­ring and analy­sing the use of our website in accordance with Art. 6 para. 1(f) GDPR and on the basis of your consent to proces­sing pursuant to Art. 31 para. 1 FADP or Art. 6 para. 1(a) GDPR.

Ensu­ring data protec­tion: Hotjar processes your data on our behalf and in accordance with our instruc­tions. To ensure that Hotjar takes the protec­tion of your data as seriously as we do, we have concluded an order proces­sing agree­ment with Hotjar. In addi­tion, the Federal Council has decided that Malta has an adequate level of data protec­tion. As a result, your personal data may be trans­mitted to Hotjar in Malta without the need for addi­tional guaran­tees.

Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the website.

Reten­tion period: The data stored for the purpose of web analysis will be stored in accordance with the rele­vant statu­tory provi­sions and for as long as neces­sary to fulfil the afore­men­tioned purposes or until you with­draw your consent to the proces­sing of that personal data.

III. Disclo­sure to third parties

Your personal data is not disc­losed to third parties for purposes other than those listed, or to contrac­tors other than those listed and their subcon­trac­tors. Third parties are tech­no­logy provi­ders engaged to ensure optimum website and social media site opera­tion, for example, as well as to offer the services listed above.

Data proces­sing agree­ments have been concluded with third parties that are subject to the FADP or the GDPR and that process your personal data on behalf of us. Third parties process your personal data only in accordance with our instruc­tions. They will irre­vo­cably delete your personal data after the order is complete, complying with the rele­vant data protec­tion provi­sions.

IV. Trans­fers of personal data to third count­ries without an adequate level of data protec­tion

No disclo­sure is made to third count­ries without an adequate level of data protec­tion, or only under a contrac­tual obli­ga­tion to main­tain a suffi­cient level of data protec­tion. This is done by means of the EU’s stan­dard contrac­tual clauses. Personal data will be trans­ferred to third count­ries only if the data protec­tion requi­re­ments set out in Arts. 9 and 16 FADP and Art. 44 et seqq. GDPR are met.  A state is deemed to be a third country if it does not offer a level of data protec­tion equi­va­lent to that under Swiss or EU law. The Federal Council (Ordi­nance on Data Protec­tion (DPO), SR 235.11, Annex 1) or the EU Commis­sion deter­mines those states that offer an appro­priate level of data protec­tion on the basis of an indi­vi­dual adequacy decision, as described in Art. 45 GDPR.

There is a Data Privacy Frame­work between the EU and the USA. This Frame­work ensures GDPR-compliant data transfer to the USA and corre­spon­dingly compliant data proces­sing, in which all of the data subject’s rights under EU law can be safe­guarded. Whether or not the specific data processor in the USA parti­ci­pates in this frame­work can be checked at www.dataprivacyframework.gov/s/. In addi­tion, you will find further infor­ma­tion on the proces­sing of user data in each case in the data proces­sors’ own privacy poli­cies.

There is also a Data Privacy Frame­work between Switz­er­land and the USA. The transfer of your data to the USA is based on the EU–US or Swiss–US Data Privacy Frame­work or, should it be declared invalid or not be appli­cable, based on stan­dard contrac­tual clauses and appro­priate and propor­tio­nate tech­nical and orga­ni­sa­tional measures.

We inform you in this data protec­tion infor­ma­tion of when and how we transfer personal data to the USA or other unsafe third count­ries.

V. Data secu­rity

We take appro­priate measures to ensure that your personal data cannot be accessed unaut­ho­rised, or stolen by, third parties. In parti­cular, we take appro­priate tech­nical (fire­wall, pass­word protec­tion, SSL encryp­tion, etc.) and orga­ni­sa­tional (rest­ric­tion of group of autho­rised persons, trai­ning of autho­rised persons, etc.) measures to ensure that only autho­rised persons have access to this data. Our data proces­sing and secu­rity measures are improved conti­nu­ally in line with tech­no­lo­gical deve­lo­p­ments. Personal data means any infor­ma­tion rela­ting to an iden­ti­fied or iden­ti­fiable natural person, inclu­ding name, address, tele­phone number, or e‑mail or IP address. We use SSL encryp­tion for secu­rity reasons and to protect the trans­mis­sion of confi­den­tial content, such as enqui­ries that you send to us as the site operator. You can reco­g­nise an encrypted connec­tion by the fact that the address line of the browser changes from “http://” to “https://”, and at the lock symbol in your browser line. If SSL encryp­tion is acti­vated, the data you transmit to us cannot be read by third parties.

VI. Reten­tion period

We retain your personal data for as long as we deem neces­sary or appro­priate to comply with appli­cable laws, or for as long as neces­sary to fulfil for the purposes for which it was coll­ected. We delete your personal data as soon as it is no longer required and in any case after expiry of the legally prescribed maximum reten­tion period of five or 10 years. Data that is no longer neces­sary and for which there is no legal reten­tion obli­ga­tion is destroyed once the purpose and justi­fi­ca­tion for its proces­sing no longer exist. Speci­fi­cally, we store your data for the follo­wing periods:

We retain data that we process by law for the statu­tory reten­tion period, for example if required by labour, social secu­rity or tax law, or the Swiss Accounts Ordi­nance;

We retain data that we need to fulfil a contract for at least the dura­tion of that contract and for a maximum period of 10 years after­wards, unless we need the data to assert our rights;

We will retain data that we process to safe­guard our legi­ti­mate inte­rests for a maximum period of ten years after the end of the contrac­tual rela­ti­onship, unless we need the data to assert our rights.

VII. Your rights

As a data subject, you may assert various claims against us and in accordance with appli­cable national and inter­na­tional law. We may process your personal data again to satisfy these claims. Depen­ding on the appli­cable law, data subjects may exer­cise the follo­wing rights:

  • Request infor­ma­tion about your personal data processed by us. In parti­cular, infor­ma­tion as described in Art. 25 et seqq. of the FADP and Art. 15 GDPR may contain the follo­wing:
    • Purposes of proces­sing
    • The cate­gory of personal data
    • The cate­go­ries of reci­pi­ents to whom your data has been or will be disc­losed
    • The planned reten­tion period
    • The exis­tence of a right to recti­fi­ca­tion, erasure, rest­ric­tion of proces­sing or objec­tion
    • The exis­tence of a right to lodge a complaint
    • The origin of your data, if it has not been coll­ected by us.
    • The exis­tence of auto­mated decision-making, inclu­ding profiling and, where appli­cable, meaningful infor­ma­tion on the details of that decision-making.

 

  • The right to demand that personal data stored by us is corrected or completed imme­dia­tely (Art. 32 para. 1 FADP and Art. 16 GDPR).

 

  • The right to request that the proces­sing of your personal data be rest­ricted, where you contest the accu­racy of the data, the proces­sing is unlawful but you do not wish the data to be deleted and we no longer need the data, but you need it to assert, exer­cise or defend legal claims or you have objected to proces­sing in accordance with Art. 21 GDPR (Art. 32 FADP or Art. 18 GDPR).

 

  • The right to receive the personal data that you have provided to us in a struc­tured, commonly used and machine-readable format or to request the transfer of that data to another controller (Art. 28 FADP and Art. 20 GDPR).

 

  • The right to request the erasure of your personal data stored by us, unless its proces­sing is neces­sary for the exer­cise of the right to freedom of expres­sion and infor­ma­tion, to fulfil a legal obli­ga­tion, for reasons of public inte­rest or to assert, exer­cise or defend of legal claims (Art. 32 FADP in conjunc­tion with Art. 28 Swiss Civil Code or Art. 17 GDPR).

 

  • The right to revoke your consent at any time after you have given it to us. As a result, we may no longer process data based on this consent in the future (Art. 30 para. 2(b) FADP and Art. 7 para. 3 GDPR).

 

  • The right to object to proces­sing if your personal data is processed on the basis of legi­ti­mate inte­rests pursuant to Art. 6 para. 1 clause 1(f) GDPR (Art. 21 GDPR) and where there are reasons arising from your parti­cular circum­s­tances or if the objec­tion is to direct marke­ting. In the latter case, you have a general right of objec­tion, which is imple­mented by us without your giving parti­cular circum­s­tances.

 

  • The right to lodge a complaint with a super­vi­sory autho­rity (see above) (Art. 49 FADP and Art. 77 GDPR).

VIII. Up-to-date nature and amend­ment of this privacy policy

We reserve the right to amend this privacy policy at any time or to bring it into line with new proces­sing methods.

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