• General notice

  Based on Article 13 of the Swiss Federal Constitution and the data protection regulations of the Swiss Confederation (FADP), every person has the right to protection of their privacy as well as protection against misuse of their personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations as well as this privacy policy.

  In cooperation with our hosting providers, we make every effort to protect the databases as well as possible against unauthorized access, loss, misuse or falsification.

  We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.

  By using this website, you consent to the collection, processing and use of data in accordance with the following description. This website can generally be visited without registration. Data such as pages accessed or names of files accessed, date and time are stored on the server for statistical purposes without this data being directly related to your person. Personal data, in particular name, address or e-mail address are collected as far as possible on a voluntary basis. Without your consent, the data will not be passed on to third parties.

• Processing of personal data

  Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, deletion, storage, modification, destruction and use of personal data.

  We process personal data in accordance with Swiss data protection law. Furthermore, to the extent and insofar as the EU GDPR is applicable, we process personal data in accordance with the following legal bases in connection with Art. 6 (1) GDPR:

  • lit. a) Processing of personal data with the consent of the data subject.
  • lit. b) Processing of personal data for the fulfillment of a contract with the data subject as well as for the implementation of corresponding pre-contractual measures.
  • lit. c) Processing of personal data for the fulfillment of a legal obligation to which we are subject under any applicable law of the EU or under any applicable law of a country in which the GDPR is applicable in whole or in part.
  • lit. d) Processing of personal data in order to protect the vital interests of the data subject or another natural person.
  • lit. f) Processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject are overridden. Legitimate interests include, in particular, our business interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.

  We process personal data for the duration required for the respective purpose or purposes. In the case of longer-term retention obligations due to legal and other obligations to which we are subject, we restrict processing accordingly.

• Privacy policy for cookies

  This website uses cookies. These are small text files that make it possible to store specific information related to the user on the user’s terminal device while the user is using the website. Cookies make it possible, in particular, to determine the frequency of use and number of users of the pages, to analyze behavior patterns of page use, but also to make our offer more customer-friendly. Cookies remain stored beyond the end of a browser session and can be retrieved when you visit the site again. If you do not wish this to happen, you should set your Internet browser so that it refuses to accept cookies.

  A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.

• Privacy policy for SSL/TLS encryption

  This website uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the site operator. You can recognize an encrypted connection by having the address line of your browser change from “http://” to “https://” and by the lock symbol in your browser line.

  If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

• Privacy policy for server log files

  The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request

  This data cannot be assigned to specific persons. This data is not merged with other data sources. We reserve the right to check this data retrospectively if we become aware of specific indications of illegal use.

• Third party services

  This website may use Google Maps for embedding maps, Google Invisible reCAPTCHA for protection against bots and spam, and YouTube for embedding videos.

  These services of the American Google LLC use, among other things, cookies and, as a result, data is transferred to Google in the USA, although we assume that no personal tracking takes place in this context solely through the use of our website.

  Google has undertaken to ensure adequate data protection in accordance with the US-European and the US-Swiss Privacy Shield.

  Further information can be found in Google’s privacy policy.

• Privacy policy for contact form

  If you send us inquiries via the contact form, your data from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

• Privacy policy for newsletter data

  If you would like to receive the newsletter offered on this website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data will not be collected. We use this data exclusively for sending the requested information and do not pass it on to third parties.

  You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter.

• Privacy policy for unsolicited advertising mails

  The use of contact data published within the scope of the imprint obligation for the transmission of not expressly requested advertising and information materials is hereby contradicted. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

• Google AdWords

  This website uses Google Conversion Tracking. If you have reached our website via an ad placed by Google, Google AdWords will set a cookie on your computer. The cookie for conversion tracking is set when a user clicks on an ad placed by Google. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies can therefore not be tracked across AdWords customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

  If you do not wish to participate in the tracking, you can refuse the setting of a cookie required for this – for example, by means of a browser setting that generally deactivates the automatic setting of cookies or by setting your browser so that cookies from the domain “googleleadservices.com” are blocked.

  Please note that you may not delete the opt-out cookies as long as you do not want any measurement data to be recorded. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.

• Use of Google reCAPTCHA

  This website uses the reCAPTCHA service provided by Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland “Google”). The purpose of the query is to distinguish whether the input is made by a human or by automated, machine processing. The query includes the sending of the IP address and possibly other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transmitted to Google and further used there. However, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other data from Google. Your data may also be transmitted to the USA in the process. For data transfers to the USA, there is an adequacy decision of the European Commission, the “Privacy Shield”. Google participates in the “Privacy Shield” and has submitted to the requirements. By pressing the query, you consent to the processing of your data. The processing is based on Art. 6 (1) lit. a GDPR with your consent. You can revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation.

  You can find more information about Google reCAPTCHA and the associated privacy policy at: https://policies.google.com/privacy.

• Privacy policy for Google Analytics

  This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the data controller on this website is located outside the European Economic Area or Switzerland, then Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as “Google”.

  The statistics obtained enable us to improve our offer and make it more interesting for you as a user. This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your usage in the settings there under “My data”, “Personal data”.

  The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f GDPR. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. We would like to point out that on this website Google Analytics has been extended by the code “_anonymizeIp();” to ensure anonymized collection of IP addresses. This means that IP addresses are processed in abbreviated form, which means that they cannot be linked to a specific person. If the data collected about you is related to a person, this is immediately excluded and the personal data is deleted immediately.

  Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

  Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: Disable Google Analytics.

  In addition, you can also prevent the use of Google Analytics by clicking on this link: Disable Google Analytics. This will save a so-called opt-out cookie on your data carrier, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your terminal device, these opt-out cookies will also be deleted, i.e. you will have to set the opt-out cookies again if you wish to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/end device and must therefore be activated separately for each browser, computer or other end device.

• Privacy policy for Google Ads

  This website uses the online marketing tool Google Ads by Google (“Google Ads”). Google Ads uses cookies to serve ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Via a cookie ID, Google records which ads are displayed in which browser and can thus prevent them from being displayed more than once. In addition, Google Ads can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees a Google Ads ad and later calls up the advertiser’s website with the same browser and buys something there. According to Google, Google Ads cookies do not contain any personal information.

  Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. Through the integration of Google Ads, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that Google will obtain and store your IP address.

  You can prevent participation in this tracking process in various ways:

  • by adjusting your browser software accordingly; in particular, the suppression of third-party cookies will result in you not receiving ads from third-party providers;
  • by disabling conversion tracking cookies by setting your browser to block cookies from the domain “www.googleadservices.com”, https://adssettings.google.com, which setting will be deleted when you delete your cookies;
  • by disabling interest-based ads from the providers that are part of the “About Ads” self-regulatory campaign, via the link https://www.aboutads.info/choices, with this setting being deleted when you delete your cookies;
  • by permanently disabling them in your Firefox, Internetexplorer or Google Chrome browsers at the link https://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this offer in full.

  The legal basis for the processing of your data is a balancing of interests, according to which the processing of your personal data described above is not opposed by any overriding interests on your part (Art. 6 para. 1 p. 1 lit. f GDPR). You can find more information about Google Ads from Google at https://ads.google.com/intl/en_US/home/, as well as about data protection at Google in general: https://www.google.de/intl/en/policies/privacy. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org.

• Google Tag Manager

  Google Tag Manager is a solution that allows us to manage so-called website tags via an interface, enabling us to integrate Google Analytics and other Google marketing services into our online offering, for example. The Tag Manager itself, which implements the tags, does not process any personal data of the users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/tagmanager/use-policy.html.

• Privacy policy for Facebook

  This website uses functions of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA . When you call up our pages with Facebook plug-ins, a connection is established between your browser and the Facebook servers. In the process, data is already transmitted to Facebook. If you have a Facebook account, this data can be linked to it. If you do not want this data to be associated with your Facebook account, please log out of Facebook before visiting our site. Interactions, in particular the use of a comment function or the clicking of a “Like” or “Share” button are also passed on to Facebook. You can learn more at https://www.facebook.com/about/privacy.

• Privacy policy for Twitter

  This website uses functions of Twitter, Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. When you call up our pages with Twitter plug-ins, a connection is established between your browser and the servers of Twitter. In the process, data is already transferred to Twitter. If you have a Twitter account, this data can be linked to it. If you do not want this data to be associated with your Twitter account, please log out of Twitter before visiting our site. Interactions, in particular clicking on a “re-tweet” button, are also passed on to Twitter. You can learn more at https://twitter.com/privacy.

• Privacy policy for LinkedIn

  We use the marketing services of the social network LinkedIn of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”) within our online offer.

  These use cookies, i.e. text files that are stored on your computer. This enables us to analyze your use of the website. For example, we can measure the success of our ads and show users products in which they were previously interested.

  For example, information on the operating system, the browser, the website you previously visited (referrer URL), which websites the user visited, which offers the user clicked on, and the date and time of your visit to our website is collected.

  The information generated by the cookie about your use of this website is transferred pseudonymously to a LinkedIn server in the USA and stored there. LinkedIn therefore does not store the name or email address of the respective user. Rather, the above-mentioned data is only assigned to the person for whom the cookie was generated. This does not apply if the user has allowed LinkedIn to process without pseudonymization or has a LinkedIn account.

  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also object to the use of your data directly at LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

  We use LinkedIn Analytics to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user. All LinkedIn companies have adopted the standard contractual clauses to ensure that the data traffic to the USA and Singapore necessary for the development, implementation and maintenance of the services takes place in a lawful manner. If we ask users for consent, the legal basis for processing is Art. 6 (1) lit. a GDPR. Otherwise, the legal basis for the use of LinkedIn Analytics is Art. 6 para. 1 p. 1 lit. f GDPR

  Third-party provider information: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2 Ireland; User Agreement and Privacy Policy.

• Audio and video conferencing

  We use audio and video conferencing services to communicate with our users and others. In particular, we can use them to conduct audio and video conferences, virtual meetings, and training sessions such as webinars.

  We only use services for which an appropriate level of data protection is guaranteed. In addition to this privacy policy, any terms and conditions of the services used, such as terms of use or privacy statements, also apply.

  In particular, we use Zoom, a service of the American Zoom Video Communications Inc. Zoom also grants the rights under the European General Data Protection Regulation (GDPR) to users in Switzerland. Further information about the type, scope and purpose of data processing can be found in the data protection guidelines and on the “Legal Provisions and Data Protection” page of Zoom in each case.

• Contractual services

  We process the data of our contractual partners and interested parties as well as other clients, customers, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with the data protection provisions of the German Federal Data Protection Act (Datenschutzgesetz, DSG) and the GDPR pursuant to Art. 6 para. 1 lit. b. GDPR, in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.

  The data processed includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contractual data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

  As a matter of principle, we do not process special categories of personal data, unless these are components of a commissioned or contractual processing.

  We process data that are required for the justification and fulfillment of contractual services and point out the necessity of their disclosure, unless this is evident to the contractual partners. Disclosure to external persons or companies is made only if it is necessary in the context of a contract. When processing data provided to us in the context of an order, we act in accordance with the instructions of the client as well as the legal requirements.

  In the context of the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims pursuant to Art. 6 para. 1 lit. f. GDPR or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR.

  The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed at irregular intervals. In all other respects, the statutory retention obligations shall apply.

• Note on data transfer to the USA

  Among other things, tools from companies based in the USA are integrated on our website. If these tools are active, your personal data may be transferred to the US servers of the respective companies. We would like to point out that the USA is not a safe third country in the sense of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.

• Copyrights

  The copyrights and all other rights to content, images, photos or other files on the website, belong exclusively to the operator of this website or the specifically named rights holders. For the reproduction of any files, the written consent of the copyright holder must be obtained in advance.

  Anyone who commits a copyright infringement without the consent of the respective copyright holder may be liable to prosecution and possibly to damages.

• Your rights

  In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. You have the possibility to withdraw consent. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon.

  In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided on the legal notice page.

  In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

• General disclaimer

  All information on our website has been carefully checked. We make every effort to ensure that the information we provide is up-to-date, correct and complete. Nevertheless, the occurrence of errors cannot be completely ruled out, which means that we cannot guarantee the completeness, correctness and up-to-dateness of information, including journalistic and editorial information. Liability claims regarding damage caused by the use of any information provided, including any kind of information which is incomplete or incorrect, will therefore be rejected.

  The publisher may change or delete texts at his own discretion and without notice and is not obliged to update the contents of this website. The use of or access to this website is at the visitor’s own risk. The publisher, its clients or partners are not responsible for damages, such as direct, indirect, incidental, consequential or punitive damages, allegedly caused by the visit of this website and consequently assume no liability for such damages.

  The publisher also accepts no responsibility or liability for the content and availability of third-party websites that can be accessed via external links on this website. The operators of the linked sites are solely responsible for their content. The publisher thus expressly distances itself from all third-party content that may be relevant under criminal or liability law or that may offend common decency.

• Amendments

  We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.

• Questions about data protection

  If you have any questions about data protection, please e-mail us at privacy@ctmodule.com.

Belp, 1 January 2022
Source of original German version: SwissAnwalt