Privacy policy
Preamble

With the following data protection declaration, we would like to explain to you what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Table of contents

  • Person responsible
  • Overview of processing
  • Relevant legal bases
  • Safety measures
  • Transmission of personal data
  • International data transfers
  • Deletion of data
  • Rights of the data subjects
  • Performing tasks in accordance with the Articles of Association or Rules of Procedure
  • Credit check
  • Provision of the online offer and web hosting
  • Communication via Messenger
  • Video conferences, online meetings, webinars and screen sharing
  • Application procedure
  • Cloud services
  • Web analysis, monitoring and optimization
  • Presence in social networks (social media)
  • Plugins and embedded functions and content
  • Management, organization and support tools
  • Amendment and updating of the privacy policy

Person responsible

RAJENDRA & URSULA JOSHI FOUNDATION
Wolleraustrasse 41a
8807 Freienbach SZ

Persons authorized to represent the company:
Rolf Kisseleff

E-mail address: contact@joshi-foundation.ch
Imprint: https://www.joshi-foundation.ch/kontakt–impressum.html

Relevant legal bases

Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (in short “Swiss FADP”, valid from September 01, 2023). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss DPA does not stipulate a legal basis for the processing of personal data (unlike the GDPR, for example). We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss Data Protection Act). Furthermore, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in such a way that it is compatible with these purposes (Art. 6 para. 3 of the Swiss Data Protection Act).

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Payment data.
  • Location data.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Applicant data.

Categories of affected persons

  • Customers.
  • Employees.
  • Interested parties.
  • Communication partner.
  • Users.
  • Applicants.
  • Members.
  • Business and contractual partners.
  • Persons depicted.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organizational procedures.
  • Managing and responding to inquiries.
  • Application procedure.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user-friendliness.
  • Assessment of creditworthiness and credit standing.
  • Information technology infrastructure.

Automated decisions in individual cases

  • Credit report.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. We have also set up procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

As part of our processing of personal data, data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not established adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country.
According to Art. 16 of the Swiss FADP, exceptions for the disclosure of data abroad may be permitted if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
As part of our data protection information, we can provide users with further information on the deletion and storage of data that applies specifically to the respective processing procedure.

Rights of the data subjects

Rights of data subjects under the Swiss DPA:
As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:

  • Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
  • Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

Performing tasks in accordance with the articles of association or rules of procedure

We process the data of our members, supporters, interested parties, business partners or other persons (collectively “data subjects”) if we have a membership or other business relationship with them and perform our tasks and are recipients of services and benefits. Otherwise, we process the data of data subjects on the basis of our legitimate interests, e.g. in the case of administrative tasks or public relations work.
The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying membership or contractual relationship, from which the necessity of any data details also arises (we also refer to necessary data).
We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for business transactions and with regard to any warranty or liability obligations based on our legitimate interest in their regulation. The necessity of storing the data is regularly reviewed; otherwise, the statutory retention obligations apply.

  • Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services); members. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; contact requests and communication. Managing and responding to inquiries.
  • Legal bases (if applicable): Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.
We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
The decision as to whether we make advance payments is made in accordance with the legal requirements solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.
If we obtain express consent from contractual partners, the legal basis for the credit report and the transfer of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the security of our payment claims.

  • Processed data types: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
  • Persons affected: Customers.
  • Purposes of processing: Assessment of creditworthiness and credit standing.
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit check).

Provision of the online offer and web hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Provision of contractual services and fulfillment of contractual obligations.
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Collection of access data and log files: Access to our online offering is recorded in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

    The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
    Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Weebly: Hosting platform for e-commerce / websites;
    Service provider: Square, Inc, 1455 Market Street Suite 600 San Francisco, CA 94103, USA;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.weebly.com/de.
    Privacy policy: https://www.weebly.com/de/privacy/.

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.
You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.

Reservation of reference to other communication channels: Finally, we would like to point out that, for your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, internal contractual details require special confidentiality or a reply via Messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partner.
  • Purposes of processing: contact requests and communication. Direct marketing (e.g. by e-mail or post).
  • Legal bases (if applicable): Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Apple iMessage: Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.apple.com/de/.
    Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • WhatsApp: WhatsApp Messenger with end-to-end encryption;
    Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.whatsapp.com/;
    Privacy policy: https://www.whatsapp.com/legal.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF).

Video conferences, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants listed below. The scope of the processing depends on the one hand on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants’ data for security purposes or service optimization. The processed data includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data can be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be communicated transparently to the participants in advance and they will be asked for their consent where necessary.

Data protection measures for participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the optimum security and data protection settings for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using the function to make the background unrecognizable, if technically possible). Links to the conference rooms and access data may not be passed on to unauthorized third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; contact requests and communication. Office and organizational procedures.
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Google Hangouts / Meet: conferencing and communication software;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://hangouts.google.com/;
    Privacy policy: https://policies.google.com/privacy;
    Order data processing contract: https://cloud.google.com/terms/data-processing-addendum.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF), standard contractual clauses(https://cloud.google.com/terms/eu-model-contract-clause).
  • Skype: Messenger and conference software;
    Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.skype.com/de/;
    Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF).
  • TeamViewer: conferencing and communication software;
    Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.teamviewer.com/de.
    Privacy policy: https://www.teamviewer.com/de/datenschutzerklaerung/.
    TeamViewer: conferencing and communication software;
    Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.teamviewer.com/de.
    Privacy policy: https://www.teamviewer.com/de/datenschutzerklaerung/.

Application procedure

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.
In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. On request, we will be happy to provide you with additional information.
If provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Applicants are welcome to contact us about how to submit their application or send it to us by post.

Processing of special categories of data: Insofar as special categories of personal data (where applicable, Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure, they are processed so that the controller or the data subject can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard. In the case of the protection of vital interests of applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion takes place, subject to a justified revocation of the applicants, at the latest after the expiry of a period of six months, so that we can answer any follow-up questions about the application and fulfill our obligations to provide evidence from the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements are archived in accordance with tax regulations.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms). Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
  • Persons concerned: Applicants.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal bases (if applicable): Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 p. 1 lit. b) GDPR); processing of special categories of personal data relating to health, employment and social security (Art. 9 para. 2 lit. h) GDPR); consent to the processing of special categories of personal data (Art. 9 para. 2 lit. a) GDPR). Processing of special categories of personal data for the protection of vital interests (Art. 9 para. 2 lit. c) GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and to optimize their services.
If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties. Communication partner.
  • Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Tresorit: Tresorit is a Swiss content collaboration platform. Built according to the zero-knowledge principle and with end-to-end encryption, it protects the digital assets of companies and private individuals in accordance with the highest standards for cloud encryption; service provider: Tresorit AG
    Franklinstrasse 27
    8050 Zurich
    Switzerland; Website: https://tresorit.com/.
    Privacy policy: https://tresorit.com/de/legal/privacy-policy.
  • Dropbox: Cloud storage service;
    Service provider: Dropbox, Inc, 333 Brannan Street, San Francisco, California 94107, USA;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://www.dropbox.com/de;
    Privacy policy: https://www.dropbox.com/privacy;
    Order data processing contract: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF), standard contractual clauses(https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf).
  • Microsoft cloud services: cloud storage, cloud infrastructure services and cloud-based application software;
    Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://microsoft.com/de-de;
    Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter;
    Order data processing contract: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF), standard contractual clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas need to be optimized.
In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored for web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content the users have called up within one or more usage processes, which search terms they have used, which they have called up again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city’s inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). In the case of EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://marketingplatform.google.com/intl/de/about/analytics/;
    Privacy policy: https://policies.google.com/privacy;
    Order data processing contract: https://business.safety.google/adsprocessorterms/;
    Basis for third country transfers (if applicable): EU-US Data Privacy Framework (DPF), standard contractual clauses(https://business.safety.google/adsprocessorterms);
    Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
    Further information: https://privacy.google.com/businesses/adsservices (types of processing and processed data).

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union / Switzerland. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
  • Legal bases (where applicable Legitimate interests): (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Plugins and embedded functions and content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Location data (information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The processed data may include, in particular, IP addresses and user location data;
    Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland;
    Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https: //mapsplatform.google.com/;
    Privacy policy: https://policies.google.com/privacy.
    Basis for third country transfer (if applicable): EU-US Data Privacy Framework (DPF).

Management, organization and support tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

  • Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partner. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Legal bases (if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on editing processes, procedures and services:

  • DATA Security Manager: Our DATA Security Manager software solution is a virtual “data protection companion” that guides you through the pragmatic implementation of the revDSG and the EU GDPR. This helps you to recognize the gaps in the area of data protection and to close them sustainably. Create your individual data protection manual, risk analyses, service provider checks and much more with little effort;
    Service provider: DATA Security AG
    Färberstrasse 9
    CH-8832 Wollerau
    +41 44 552 23 55
    info@data-security.ch;
    Website: https://data-security.ch/.
    Privacy policy: https://data-security.ch/datenschutz.html.
  • Sage 50: Order processing, merchandise management and financial accounting all from a single source;
    Service provider: Marketing Communication
    Franklinstrasse 61-63
    60486 Frankfurt am Main
    Phone: 069 50007-0
    E-mail: info@sage.de; Website: https://www.sage.com/.
    Privacy policy: https://www.sage.com/de-de/rechtliches/datenschutz-cookies/.
  • ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information and make predictions (“AI”, i.e. “artificial intelligence”, is to be understood in the applicable legal sense of the term);
    Service provider: OpenAI OpCo, LLC, 3180 18th St., San Francisco, CA 94110 USA;
    Legal bases(if applicable): Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);
    Website: https://openai.com/product;
    Privacy policy: https://openai.com/policies/privacy-policy.
    Option to object (opt-out): https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.

Changes and updates to the privacy policyWe ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.