Privacy Policy

With this Privacy Policy, we inform you which personal data we process in connection with our activities and operations, including our swissfeel.com website. In particular, we provide information on what, how, and where we process personal data. We also inform about the rights of individuals whose data we process.

For individual or additional activities and operations, additional privacy policies as well as other legal documents such as General Terms and Conditions (AGB), Terms of Use or Participation Conditions may apply.

We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission acknowledges that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsibility for processing personal data:

SWISSFEEL AG
Leutschenbachstrasse 41
CH-8050 Zurich

info@swissfeel.com

We note that in individual cases there may be other responsible parties for the processing of personal data.

2. Terms and Legal Bases

2.1 Terms

Personal data are all information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, for example querying, matching, adapting, archiving, storing, reading out, disclosing, obtaining, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

The European Economic Area (EEA) includes the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.

2.2 Legal Bases

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data according to at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in carrying out our activities and operations permanently, user-friendly, securely, and reliably, as well as being able to communicate about them, ensuring information security, protecting against misuse, enforcing our own legal claims, and complying with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Type, Extent, and Purpose

We process those personal data that are necessary to permanently, user-friendly, securely, and reliably carry out our activities and operations. Such personal data can in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration that is necessary for the respective purpose or purposes, or as required by law. Personal data that is no longer necessary for processing is anonymized or deleted.

We can have personal data processed by third parties. We can process personal data together with third parties or transfer it to third parties. These third parties are in particular specialized providers whose services we use. We also ensure data protection with such third parties.

We process personal data principally only with the consent of the data subjects. If and to the extent that processing is permissible for other legal reasons, we may waive obtaining consent. For example, we may process personal data without consent to fulfill a contract, to comply with legal obligations, or to safeguard overriding interests.

In this context, we particularly process information that a data subject voluntarily submits to us when making contact – for example, by mail, email, instant messaging, contact form, social media, or phone – or when registering for a user account. For example, we can store such information in an address book, in a customer relationship management system (CRM system), or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection towards these persons and to ensure the accuracy of these personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the exercise of our activities and operations, provided and to the extent such processing is legally permissible.

4. Applications

We process personal data about applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent execution of an employment contract. The required personal data are particularly derived from the information requested, for example in the context of a job advertisement. We also process those personal data that applicants voluntarily provide or publish, particularly as part of cover letters, resumes, and other application documents, as well as online profiles.

To the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants particularly in accordance with Art. 9 Para. 2 lit. b GDPR.

We may allow applicants to store their information in our Talent Pool to consider them for future open positions. We may also use such information to maintain contact and inform about news. If we believe that an applicant may be suitable for an open position based on the information provided, we may accordingly inform the applicant.

5. Personal Data Abroad

We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process or have them processed there.

We may export personal data to all countries and territories on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection according to a decision by the Swiss Federal Council and – to the extent that the General Data Protection Regulation (GDPR) is applicable – according to a decision by the European Commission.

We may transmit personal data to countries whose law does not ensure adequate data protection, provided that data protection is guaranteed for other reasons, particularly based on standard data protection clauses or with other appropriate guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example, the explicit consent of the affected persons or a direct connection with the conclusion or execution of a contract. Upon request, we are happy to provide affected persons with information about any guarantees or a copy of any guarantees.

6. Rights of Data Subjects

6.1 Data Protection Rights

We grant data subjects all claims in accordance with applicable data protection law. In particular, data subjects have the following rights:

  • Access: Data subjects can request information about whether we process personal data about them, and if so, what personal data it is. Furthermore, data subjects receive the information required to assert their data protection rights and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or possible export of data to other countries, and the source of the personal data.
  • Rectification and Restriction: Data subjects can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Deletion and Objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data Release and Data Transfer: Data subjects can request the release of personal data or the transfer of their data to another controller.

We may defer, restrict or deny the exercise of the rights of data subjects within the legally permissible framework. We may point out to data subjects any conditions that must be met to exercise their data protection rights. For example, we may partially or fully refuse access by referring to trade secrets or the protection of other persons. We may also partially or fully refuse deletion of personal data by referring to statutory retention obligations.

We may exceptionally impose costs for the exercise of rights. We will inform data subjects in advance about any potential costs.

We are obliged to identify data subjects who request information or assert other rights by means of appropriate measures. Data subjects are required to cooperate.

6.2 Right to Lodge a Complaint

Data subjects have the right to enforce their data protection rights in court or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Data subjects have – insofar and as far as the General Data Protection Regulation (GDPR) applies – the right to lodge a complaint with a competent European data protection supervisory authority.

7. Data Security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

Access to our website is via encrypted transport (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject to – as is generally the case with any digital communication – mass surveillance without cause or suspicion, as well as other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the corresponding processing of personal data by intelligence agencies, police stations, and other security authorities.

8. Use of the Website

8.1 Cookies

We may use cookies. Cookies – both our own cookies (First-Party-Cookies) and cookies from third parties whose services we use (Third-Party-Cookies) – are data stored in the browser. Such stored data does not have to be limited to traditional cookies in text form.

Cookies can be stored temporarily in the browser as "Session Cookies" or for a specific period as so-called permanent cookies. "Session Cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies, in particular, allow a browser to recognize our website on the next visit, thus, for example, measuring the reach of our website. However, permanent cookies can also be used for online marketing.

Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may not be fully available. We request – at least to the extent required – explicit consent to the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection ("Opt-out") is possible via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Server Log Files

We can collect the following information for each access to our website, provided it is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including timezone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, accessed individual sub-page of our website including transmitted data volume, last webpage called up in the same browser window (referrer).

We store such information, which can also represent personal data, in server log files. The information is necessary to provide our website permanently, user-friendly, and reliably, as well as to ensure data security, and thus in particular the protection of personal data – also by third parties or with the help of third parties.

8.3 Tracking Pixels

We can use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can collect the same information as server log files.

9. Notifications and Messages

We send notifications and messages via email and through other communication channels such as instant messaging or SMS.

9.1 Success and Reach Measurement

Notifications and messages may contain weblinks or tracking pixels that record whether an individual message has been opened and which weblinks were clicked on. Such weblinks and tracking pixels can also capture the use of notifications and messages on a personal basis. We require this statistical recording of usage for success and reach measurement, in order to be able to send notifications and messages effectively and user-friendly based on the needs and reading habits of the recipients, as well as permanently, securely, and reliably.

9.2 Consent and Objection

You must basically expressly consent to the use of your email address and your other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the "Double Opt-in" procedure whenever possible, meaning you will receive an email with a weblink that you must click on to confirm, so that no misuse by unauthorized third parties can occur. We may log such consents including IP address, as well as date and time, for evidence and security reasons.

You can basically object to receiving notifications and messages such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and messages related to our activities and operations remain reserved.

9.3 Service Providers for Notifications and Messages

We send notifications and messages with the help of specialized service providers.

We particularly use:

10. Social Media

We are present on social media platforms and other online platforms to communicate with interested individuals and to inform about our activities and services. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The terms and conditions, as well as privacy policies and other provisions of the individual operators of these platforms, also apply. These provisions particularly inform about the rights of affected individuals directly against the respective platform, which includes, for example, the right to access their data.

For our social media presence on Facebook, including the so-called Page Insights, we are – as far and as long as the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly provide our social media presence on Facebook.

More information about the type, extent, and purpose of data processing, information on the rights of affected individuals, and the contact details of Facebook as well as Facebook’s data protection officer can be found in Facebook’s Privacy Policy. We have concluded the so-called "Controller Addendum" with Facebook, and have particularly agreed that Facebook is responsible for ensuring the rights of affected individuals. For the so-called Page Insights, the relevant information can be found on the page "Information on Page Insights" including "Information about Page Insights Data".

11. Third-Party Services

We use services provided by specialized third parties to be able to carry out our activities and services continuously, user-friendly, securely, and reliably. With such services, we can embed functions and content into our website. In the course of such embedding, the services used technically and mandatorily collect the IP addresses of users temporarily.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and services in an aggregated, anonymized, or pseudonymized manner. This may include, for example, performance or usage data to be able to provide the respective service.

We particularly use:

11.1 Digital Infrastructure

We use services from specialized third parties to be able to utilize the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

11.2 Contact Options

We use services from selected providers to improve our communication with third parties such as potential and existing customers.

We particularly use:

11.3 Audio and Video Conferences

We use specialized services for audio and video conferences to be able to communicate online. This allows us, for example, to hold virtual meetings or conduct online classes and webinars. Additional legal texts of the individual services such as privacy policies and terms of use apply to participation in audio and video conferences.

We recommend, depending on the situation, to mute the microphone by default during participation in audio or video conferences, as well as to blur the background or use a virtual background.

We particularly use:

11.4 Digital Audio and Video Content

We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.

In particular, we use:

12. Success and Reach Measurement

We try to determine how our online offer is used. Within this context, for example, we can measure the success and reach of our activities and actions as well as the impact of third-party links to our website. However, we can also try out and compare how different parts or versions of our online offer are used ("A/B testing" method). Based on the results of the success and reach measurement, we can particularly fix errors, reinforce popular content, or make improvements to our online offer.

For the success and reach measurement, the IP addresses of individual users are mostly stored. In this case, IP addresses are generally shortened ("IP-Masking") to comply with the principle of data minimization.

In the success and reach measurement, cookies may be used, and user profiles can be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, details about the size of the screen or browser window, and the - at least approximate - location. Generally, any user profiles are created pseudonymously and are not used to identify individual users. Some third-party services, where users are logged in, may associate the use of our online offer with the user account or user profile of the respective service.

We particularly use:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement across various browsers and devices (Cross-Device Tracking) as well as with pseudonymized IP addresses, which are only exceptionally transferred in full to Google in the USA, "Privacy", "Browser Add-on to deactivate Google Analytics".
  • Google Tag Manager: Integration and management of other services for success and reach measurement as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: "Data captured by Google Tag Manager"; further privacy information can be found in the individual integrated and managed services.

13. Final Provisions

We have created this privacy statement with the Data Protection Generator from Datenschutzpartner.

We may adapt and supplement this privacy statement at any time. We will inform about such adjustments and supplements in a suitable manner, especially by publishing the current privacy statement on our website.

Privacy policy
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