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Data protec­tion app.smino.ch

Smino AG, Werk­strasse 20, 8645 Rapperswil-Jona, is the operator of the smino app and the services offered on it and is ther­e­fore respon­sible for the coll­ec­tion, proces­sing and use of your personal data (“personal data” in this Privacy Policy) and the compli­ance of the data proces­sing with the appli­cable data protec­tion law.
Your trust is important to us, which is why we take the issue of data protec­tion seriously and pay atten­tion to appro­priate secu­rity. depen­ding on the proces­sing (term in the GDPR) or proces­sing (term in the FADP) (uniformly referred to as “proces­sing” in this privacy policy) of your personal data, in addi­tion to the appli­cable Swiss law (Federal Act on Data Protec­tion of September 25, 2020, in force from September 1, 2023, herein­after referred to as “FADP”). September 2023 (herein­after FADP, SR 235.1), Euro­pean data protec­tion law (Regu­la­tion (EU) 2016/679 (herein­after General Data Protec­tion Regu­la­tion, GDPR)) may also or exclu­si­vely apply, in parti­cular in the context of the use of our app and the moni­to­ring of the beha­vior of data subjects resi­ding in the EU (Art. 3 para. 2 lit. b GDPR).

I. Name and address of the controller

Respon­sible:
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. use of our app

Data proces­sing: When you use our app, your device auto­ma­ti­cally sends infor­ma­tion to the server of our app.
This infor­ma­tion is tempo­r­a­rily stored in a so-called 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 device
  • the name of the owner of the IP address range (usually your Internet access provider)
  • the date and time of access
  • the app from which the access was made (referrer URL) with the search term used, if appli­cable
  • the name and URL of the retrieved file
  • the status code (e.g. error message)
  • the opera­ting system of your device
  • the version of the app you are using
  • If appli­cable, your user name from a registration/authentication

Purpose: The purpose of coll­ec­ting and proces­sing this data is to enable the use of our app (connec­tion estab­lish­ment), to ensure system secu­rity and stabi­lity in the long term, to enable the opti­miza­tion of our offer and for internal statis­tical purposes.

Service provider: Our app is hosted by Micro­soft Azure in Switz­er­land or Germany.
A service of Micro­soft Ireland Opera­tions Ltd. in South County Busi­ness Park, One Micro­soft Place, Carm­an­hall and Leopard­stown, Dublin, D18 P521, Ireland (“Micro­soft”).
The hoster has access to the app and thus to your personal data in the event of support.
Micro­soft is obliged by an agreed order proces­sing contract and the current stan­dard contrac­tual clauses 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 regulations.more infor­ma­tion on the hand­ling of user data by this service provider can be found in the privacy policy at:

Micro­soft: https://privacy.microsoft.com/de-de/privacystatement

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Art. 6 to 8 FADP.
In addi­tion, the proces­sing of your personal data with regard to the US services is carried out with your express consent in accordance with Art. 6 para.
1 sentence 1 lit.
f GDPR.
If you consent to the proces­sing by Micro­soft, you ther­e­fore also consent to your personal data being processed in accordance with Art. 17 FADP and Art. 49 para.
1 lit.
a GDPR to be trans­ferred to the USA.
In addi­tion, our legi­ti­mate inte­rest in the proces­sing of your personal data pursuant to Art. 6 para.
1 sentence 1 lit.
f GDPR would exist.

Neces­sity: This infor­ma­tion is neces­sary for the app to func­tion.

Reten­tion period: The log files created for the purpose of using the app are stored in accordance with the rele­vant legal provi­sions for as long as is neces­sary to fulfill the afore­men­tioned purposes.

2. contact

NOTE: In some cases, personal data is trans­ferred to service provi­ders in third count­ries. Third count­ries are count­ries outside Switz­er­land, the EU and 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 agen­cies (US autho­ri­ties) may access personal data without us or you being aware of this. Legal action may not be successful. Personal data will only be trans­ferred to third count­ries if the requi­re­ments of Art. 16 f. FADP are met or if you have given your consent. If you send us an e‑mail, your personal data will also be processed by Micro­soft, as we use Micro­soft 365. 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 in our app. If you use our live chat, the data you enter will be trans­mitted to Crisp and stored. We use Fire­base to provide push noti­fi­ca­tions. If you have enabled push noti­fi­ca­tions, certain infor­ma­tion such as your device token will be sent to Fire­base. Micro­soft, Slack, Fire­base and Crisp have access to the above-mentioned personal data in the event of support. The data you provide to us for the purpose of cont­ac­ting us will be stored by us until your request has been fully processed. Personal data: The follo­wing personal data may be coll­ected:
  • E‑mail address
  • Salu­ta­tion
  • First name
  • Last name
  • IP address
  • Device token (for push noti­fi­ca­tions)
Purpose: The purpose of proces­sing the personal data provided is to comply with and process your request for advice, bug reporting, execu­tion of contracts or general requests, and to send you push noti­fi­ca­tions if you have acti­vated them. Service provi­ders: We use Micro­soft 365 from Micro­soft Ireland Opera­tions Ltd, South County Busi­ness Park, One Micro­soft Place, Carm­an­hall and Leopard­stown, Dublin, D18 P521, Ireland (“Micro­soft”) to process commu­ni­ca­tions. 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 Fire­base for the provi­sion of push noti­fi­ca­tions. The provider of Fire­base is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Fire­base”). We use the service provider Crisp from the EU for our live chat service. The provider of Crisp is Crisp IM SARL, 149 Rue Pierre Semard, 29200 Brest, France (“Crisp”). Micro­soft, Slack, Fire­base and Crisp are obliged by new, curr­ently agreed stan­dard contrac­tual clauses and/or order proces­sing contracts 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 regu­la­tions. Further infor­ma­tion on the proces­sing of your personal data can be found in the note under section 2 of this privacy policy. You can find more infor­ma­tion on the hand­ling of user data at Micro­soft, Slack, Fire­base and Crisp in the respec­tive privacy poli­cies:

Micro­soft: https://privacy.microsoft.com/de-de/privacystatement

Slack: https://slack.com/intl/de-de/privacy-policy

Firebase/Google: https://firebase.google.com/support/privacy

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

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Art. 6 to 8 FADP.
In addi­tion, the proces­sing of your personal data with regard to the US services is carried out with your express consent in accordance with Art. 6 para.
1 sentence 1 lit.
f GDPR.
If you consent to the proces­sing by Micro­soft, Fire­base and Slack, you ther­e­fore also consent to your personal data being processed in accordance with Art. 17 FADP and Art. 49 para.
1 lit.
a GDPR to be trans­ferred to the USA.
The proces­sing of your personal data would also be neces­sary, at your request, for the perfor­mance of contrac­tual measures pursuant to Art. 6 para.
1 sentence 1 lit.
b GDPR would be lawful.
In addi­tion, in the case of a general request, our legi­ti­mate inte­rest in the proces­sing of your personal data pursuant to Art. 6 para.
1 sentence 1 lit.
f GDPR would exist.

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

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

3. use of external tech­no­lo­gies for marke­ting and analysis purposes

We use cookies and pixel tech­no­lo­gies on our websites for marke­ting and analysis purposes.
You can find the cookie and pixel policy here.

Cookies are small text files that are stored on your end device and can be read.
A distinc­tion is made between session cookies, which are deleted again as soon as you close your browser
, and perma­nent cookies, which are stored beyond the indi­vi­dual session.
Cookies can contain data that makes it possible to reco­gnize the device used.
In some cases, however, cookies only contain infor­ma­tion on certain settings that are not perso­nally iden­ti­fiable.

You can set your browser so that it informs 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 basic 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 Art. 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 plugins

Face­book, Insta­gram, YouTube, Linkedin plugin: 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.
We have also 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 Face­book, Insta­gram, Linkedin or YouTube social media button or embedded images or contact us on Face­book, Insta­gram, Linkedin or YouTube.
The data coll­ected is also anony­mized and then used in the form of statis­tics.
A reco­gnizable marker is also set.

When you click on the YouTube social media button: We use the “extended data protec­tion mode” option provided by YouTube.
Accor­ding to YouTube, in “extended data protec­tion mode” your data, in parti­cular which of our websites you have visited and your IP address, will only be trans­mitted to the YouTube server in the USA when you watch the video.
If you are logged into your YouTube account, you enable YouTube to assign your surfing beha­vior directly to your personal profile.
You can prevent this by logging out of your YouTube account.

Personal data: The follo­wing personal data is processed:

  • User beha­vior
  • IP address
  • Connec­tion data
  • Devices and browser infor­ma­tion
  • Data about the content accessed when clicking on social media buttons
    • User name or first and last name
    • Possibly picture, data that you send us in the course of cont­ac­ting us

Purpose:The Face­book, Insta­gram, Youtube, Linked plugin serve to struc­ture our website and are used to place other web content on our website.The imple­men­ta­tion of Youtube videos also serves to struc­ture our website and is used to place other web content on our website.
By clicking on the respec­tive video or social media button, you will be redi­rected to the website of the respec­tive provider.
We have no influence on the proces­sing of personal data on third-party websites and refer you to the infor­ma­tion in section 2 of this privacy policy.

Service provider: The provider of the 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 plugin is LinkedIn Corp, 1000 W. Maude Avenue, Sunny­vale, CA 94085 USA (“YouTube”).
You can find more infor­ma­tion on how Face­book and Pinte­rest handle user data in the respec­tive privacy poli­cies:

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

Youtube:https://www.google.de/intl/de/policies/privacy

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

Proces­sing principles:We process your personal data in accordance with the proces­sing prin­ci­ples set out in Art. 6 to 8 FADP.
In addi­tion, the proces­sing of your personal data with regard to the US services is carried out with your express consent in accordance with Art. 6 para.
1 sentence 1 lit.
f GDPR.
If you consent to the proces­sing by Face­book, YouTube and LinkedIn, you ther­e­fore also consent to your personal data being processed in accordance with Art. 17 FADP and Art. 49 para.
1 lit.
a GDPR are trans­mitted to the USA.

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

Reten­tion period: With regard to the Face­book, Insta­gram, YouTube and LinkedIn plugins, cookies can be stored on your end device for up to 10 years.
Data processed in connec­tion with your contact via Face­book or Insta­gram or Linkedin will be deleted after 1 year, unless we have a reten­tion obli­ga­tion of 5 or 10 years for the commu­ni­ca­tion.

3. use of external tech­no­lo­gies

(1) Use of cookie and pixel tech­no­lo­gies

We use cookies in our app for marke­ting and analysis purposes.
You can find the cookie policy here.

(2) Use of Mailjet news­letter tech­no­lo­gies

Data proces­sing: We use the news­letter to inform you about us and our offers and promo­tions.
The data stored when you register to receive the news­letter will be trans­mitted to Mailjet and stored.
Mailjet also has access to the above-mentioned personal data in the event of support.
The data you provide us with for the purpose of subscribing to the news­letter will be stored by us until you unsub­scribe from the news­letter and will be deleted from both our servers and Mail­jet’s servers after you unsub­scribe from the news­letter.

Mailjet also offers various options for analy­zing how the news­let­ters sent are opened and used, e.g. how many users an email was sent to, whether emails were rejected and whether users unsub­scribed from the list after recei­ving an email.
These analyses are group-related and are not used by us for indi­vi­dual evalua­tion.
If you consent to the sending of the news­letter, you ther­e­fore also consent to the analysis by Mailjet.

Further­more, we use Mailjet for tran­sac­tional e‑mails, e.g. to inform about the progress of certain processes (e.g. message regar­ding changes to a task, message regar­ding newly uploaded plans).

Personal data: The follo­wing personal data is processed:

  • E‑mail address
  • Salu­ta­tion
  • First name
  • Last name
  • IP address
  • Device token (for push noti­fi­ca­tions)

Purpose: The data in ques­tion is processed for the purpose of sending out news­let­ters and analy­zing news­let­ters.

Service provider: We use the Mailjet service to send our news­letter.
The provider of Mailjet is Mailgun Tech­no­lo­gies, Inc.112
E Pecan St. #1135, San Antonio, 78205 Texas, USA (“Mailjet”).

You can find more infor­ma­tion on how Mailjet handles user data in the respec­tive privacy policy: https://www.mailjet.com/legal/privacy-policy/

Proces­sing prin­ci­ples: We process your personal data in accordance with the proces­sing prin­ci­ples set out in Art. 6 to 8 FADP.
In addi­tion, your personal data is processed with your consent.
If you consent to the proces­sing by Mailjet, you ther­e­fore also consent to your personal data being processed in accordance with Art. 17 FADP and Art. 49 para.
1 lit.
a GDPR to be trans­mitted to the USA.
You can revoke your consent to the storage of your data and email address and their use for sending the news­letter at any time, for example via the “Unsub­scribe” link in the news­letter or by sending an email to hc.onims@ofni.
The lega­lity of the data proces­sing opera­tions that have already taken place remains unaf­fected by the revo­ca­tion.

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

Reten­tion period: The data stored for the purpose of sending news­let­ters, analysis and tran­sac­tional e‑mails will be stored in accordance with the rele­vant legal provi­sions and for as long as is neces­sary to fulfill the afore­men­tioned purposes or you with­draw your consent to the proces­sing of this personal data.

(3) Use of CAD and mapping tech­no­lo­gies
Data proces­sing: We use CAD and mapping tech­no­lo­gies in our app to display models of buil­dings and cons­truc­tion plans. The provi­sion of CAD and mapping tech­no­lo­gies may require us to request your IP address in order to estab­lish a connec­tion to the source device and pass on project data. For the visua­liza­tion of CAD files on smino we use the services of Auto­desk Forge.when acti­vating the Forge Viewer for the first time, your browser connects to Auto­desk’s servers to down­load the script to your browser. In this process, your browser trans­mits your session data to Auto­desk and then func­tions locally in the browser as a third-party script. Personal data: The follo­wing personal data is processed:
  • IP address
  • Project data
Purpose: We process your data in order to provide you with our app in the desired form. Service provider: The provider of Auto­desk is Auto­desk GmbH with its regis­tered office at Balanstr. 71a, 81541 Munich, Germany (“Auto­desk”). The provider for the display of cons­truc­tion plans is MapTiler from MapTiler s.r.o., Klokocná 944/32, Prie­vozská 4D, 821 09 Bratis­lava, Slovakia (“MapTiler”). You can find more infor­ma­tion on how Getsi­te­Con­trol is used in the respec­tive privacy policy: Auto­desk: https://www.autodesk.com/trust/privacy MapTiler: https://www.maptiler.com/privacy-policy/Bearbeitungsgrundsätze: We process your personal data in accordance with the proces­sing prin­ci­ples pursuant to Art. 6 to 8 FADP and, at your request, for the perfor­mance of contrac­tual measures pursuant to Art. 6 para. 1 sentence 1 lit. Auto­desk and Maptiler are also obliged by an agreed order proces­sing contract to process your personal data only in accordance with our instruc­tions, to irre­vo­cably delete it after the order and to comply with the rele­vant data protec­tion regu­la­tions. Neces­sity: This proces­sing acti­vity is not neces­sary for the func­tion­a­lity of the app. Reten­tion period: The data stored for the purpose of displaying CAD and mapping tech­no­lo­gies will be stored in accordance with the rele­vant legal provi­sions and for as long as is neces­sary to fulfill the afore­men­tioned purposes.

III Disclo­sure to third parties

Your personal data will not be trans­ferred to third parties for purposes other than those listed or to contrac­tors other than those listed and their subcon­trac­tors.
Third parties are, for example, tech­no­logy provi­ders for the optimal opera­tion of the app and social media presences as well as for the provi­sion of the services listed above.

An order proces­sing contract has been concluded with third parties who are subject to the FADP or the GDPR and process your personal data on our behalf.
Third parties will only process your personal data on our instruc­tions and will irre­vo­cably delete your personal data after the order and comply with the rele­vant data protec­tion regu­la­tions.

IV. Personal data trans­fers 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 the contrac­tual obli­ga­tion to comply with an adequate level of data protec­tion (EU stan­dard clauses).
Personal data is only trans­ferred to third count­ries if the data protec­tion requi­re­ments of Art. 6 FADP or Art. 44 et seq. GDPR are met.
A third country is a country outside Switz­er­land or the Euro­pean Economic Area (EEA) in which Swiss data protec­tion law or the Euro­pean GDPR is not directly appli­cable.
A third country is considered unsafe if, accor­ding to the FDPIC or the EU Commis­sion, the country does not have an adequate level of data protec­tion.

With the ECJ ruling of July 16, 2020 (C‑311/18), the adequacy decision for the USA was declared invalid.
The FDPIC has also with­drawn adequacy from the USA.
The USA is ther­e­fore a so-called unsafe third country.
If personal data is trans­ferred to the USA, there is a risk that US autho­ri­ties could gain access to the personal data.
Swiss citi­zens have no effec­tive legal protec­tion against such access in the USA.
In this data protec­tion infor­ma­tion, we inform you when and how we transfer personal data to the USA or other inse­cure third count­ries.

V. Data secu­rity

We take appro­priate measures to ensure that your personal data cannot be viewed or stolen by third parties without autho­riza­tion.
In parti­cular, we take appro­priate tech­nical (e.g. fire­wall, pass­word protec­tion, SSL encryp­tion, etc.) and orga­niza­tional (e.g. rest­ric­tion of autho­rized persons, trai­ning of autho­rized persons, etc.) measures to ensure that only autho­rized persons have access to this data.
Our data proces­sing and secu­rity measures are conti­nuously improved in line with tech­no­lo­gical deve­lo­p­ments.
Personal data is 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 the requests you send to us as the site operator.
You can reco­gnize an encrypted connec­tion by the fact that the address line of the browser changes from “http://” to “https://” and by 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 will retain your personal data for as long as we consider it neces­sary or appro­priate to comply with appli­cable laws or for as long as it is neces­sary 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 maximum statu­tory reten­tion period of five or ten years.
Data that is no longer required and for which there is no legal obli­ga­tion to retain it will be destroyed once the purpose and justi­fi­ca­tion no longer apply.
In detail, we store your data for the follo­wing period:

We retain data that we process by law for the statu­tory reten­tion period, for example if this is required by labor, social secu­rity or tax law or the Busi­ness Records Ordi­nance;

We retain data that we require for the perfor­mance of a contract for at least the dura­tion of the contract and for a maximum of 10 years there­after, unless we require the data to assert our rights;

We retain data that we process to protect our legi­ti­mate inte­rests for a maximum 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 in accordance with the appli­cable national and inter­na­tional law. To fulfill these claims, we may process your personal data again. Depen­ding on the appli­cable law, data subjects may assert the follo­wing rights:
  • to request infor­ma­tion about your personal data processed by us. In parti­cular, infor­ma­tion pursuant to Art. 8 FADP or Art. 15 GDPR may contain infor­ma­tion:
    • on the purposes of proces­sing
    • the cate­gory of personal data
    • the cate­go­ries of reci­pi­ents to whom your data has been or will be disc­losed
    • the planned storage period
    • the exis­tence of a right to recti­fi­ca­tion, erasure, rest­ric­tion of proces­sing or objec­tion
    • the exis­tence of a right of appeal
    • the origin of your data, if it was not coll­ected by us
    • the exis­tence of auto­mated decision-making, inclu­ding profiling and, where appli­cable, meaningful infor­ma­tion about its details

  • to imme­dia­tely request the correc­tion of incor­rect or incom­plete personal data stored by us (Art. 5 para. 2 FADP and Art. 16 GDPR);
  • to demand the rest­ric­tion of the proces­sing of your personal data if the accu­racy of the data is disputed by you, the proces­sing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exer­cise or defend legal claims or you have objected to the proces­sing in accordance with Art. 21 GDPR (Art. 15 FADP or Art. 18 GDPR);
  • to receive your personal data, which you have provided to us, in a struc­tured, commonly used and machine-readable format or to request the trans­mis­sion to another controller (Art. 20 GDPR)
  • to request the dele­tion of your personal data stored by us, unless the proces­sing is neces­sary to exer­cise the right to freedom of expres­sion and infor­ma­tion, to fulfill a legal obli­ga­tion, for reasons of public inte­rest or to assert, exer­cise or defend legal claims (Art. 15 FADP or Art. 17 GDPR);
  • to with­draw your consent once given to us at any time. As a result, we may no longer continue the data proces­sing that was based on this consent in the future (Art. 7 para. 3 GDPR);
  • object to the proces­sing if your personal data is processed on the basis of legi­ti­mate inte­rests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR (Art. 21 GDPR) and insofar as there are reasons for this arising from your parti­cular situa­tion or the objec­tion is directed against direct adver­ti­sing. In the latter case, you have a general right to object, which will be imple­mented by us without speci­fying a parti­cular situa­tion;
  • to lodge a complaint with a super­vi­sory autho­rity (see above) (Art. 77 GDPR).

VIII. Up-to-dateness and amend­ment of this privacy policy

We reserve the right to change this privacy policy at any time or to adapt it to new proces­sing methods.

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