Privacy Policy

With this privacy policy, we inform you about the personal data we process in connection with our activities and operations, including our website. We specifically inform about the purposes for which, 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, further privacy policies as well as other legal documents such as General Terms and Conditions (GTC), terms of use, or terms of participation may apply.

1. Contact addresses

Responsibility for the processing of personal data:

Stefan Velthuys
required gmbh
Stadthofstrasse 3
6004 Luzern

We point out if there are other responsible parties for the processing of personal data in individual cases.

2. Terms and legal bases

2.1 Terms

Personal data are all information related to a specific or identifiable natural person. An affected person is an individual whose personal data we process.

Processing encompasses any handling of personal data, regardless of the means and methods used, for example, accessing, comparing, adapting, archiving, storing, retrieving, disclosing, obtaining, collecting, gathering, deleting, revealing, organizing, organizing, storing, modifying, distributing, linking, destroying, and using 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 (Datenschutzgesetz, DSG) and the Ordinance on Data Protection (Datenschutzverordnung, DSV).

3. Type, scope, and purpose

We process those personal data that are necessary to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data can fall into categories including 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 necessary for the respective purpose or purposes, or as required by law. Personal data that are no longer necessary to process are anonymized or deleted.

We may have personal data processed by third parties. We may process personal data together with third parties or transmit them to third parties. Such third parties are particularly specialized providers whose services we use. We also ensure data protection with such third parties.

We generally process personal data only with the consent of the affected individuals. If and insofar as the processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent to fulfill a contract, comply with legal obligations, or protect overriding interests.

Within this framework, we specifically process information that an affected person voluntarily transmits to us when making contact – for example, via postal mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a Customer-Relationship-Management system (CRM system), or with similar tools. When we receive data about other individuals, the transmitting individuals are obligated to ensure data protection towards these individuals and to verify the accuracy of this personal data.

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

4. Applications

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

5. Personal data abroad

We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process them or have them processed there.

We may disclose personal data to any state and territory on Earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection according to the decision of the Swiss Federal Council.

We may disclose personal data to countries whose law does not ensure adequate data protection, provided that suitable data protection is ensured for other reasons. Suitable data protection can, for example, be guaranteed by corresponding contractual agreements, based on standard data protection clauses, or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the special data protection legal requirements are met, such as the explicit consent of the affected individuals or a direct connection with the conclusion or processing of a contract. We are happy to provide affected individuals with information about any guarantees upon request or to deliver a copy of such guarantees.

6. Rights of affected individuals

6.1 Data protection legal claims

We grant affected individuals all claims according to applicable data protection law. In particular, affected individuals have the following rights:

  • Datenherausgabe und Datenübertragung: Betroffene Personen können die Herausgabe von Personendaten oder die Übertragung ihrer Daten an einen anderen Verantwortlichen verlangen.
  • Right to information: Affected individuals can request information on whether we process personal data about them, and if so, what personal data is involved. Affected individuals also receive further information necessary to assert their data protection legal claims and ensure transparency. This includes the processed personal data themselves, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
  • Right to correction and restriction: Affected individuals can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Right to deletion and objection: Affected individuals can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Right to data portability: Affected individuals can request the release of personal data or the transfer of their data to another controller.

We may delay, restrict, or deny the exercise of rights by affected individuals within the legally permissible framework. We may inform affected individuals about any conditions that must be met to exercise their data protection rights. For example, we may partially or fully refuse to provide information with reference to trade secrets or the protection of other individuals. Similarly, we may partially or fully refuse to delete personal data with reference to statutory retention obligations.

Exceptionally, we may impose costs for the exercise of rights. We will inform affected individuals in advance about any potential costs.

We are obligated to identify affected individuals who request information or assert other rights using appropriate measures. Affected individuals are required to cooperate.

6.2 Right to lodge a complaint

Affected individuals have the right to enforce their data protection claims through legal proceedings or to file 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).

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 secured through transport encryption (SSL/TLS, particularly with Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other states, as is generally the case with any digital communication. 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 those of third parties whose services we use (Third-Party Cookies) – are data stored in the browser. Such stored data are not limited to traditional text-form cookies.

Cookies can be stored in the browser temporarily 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 be recognized on the next visit to our website, thereby, for example, measuring the reach of our website. However, permanent cookies can also be used for online marketing.

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

For cookies used for performance and reach measurement or for advertising, a general objection (“Opt-out”) is possible for many services 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

For each access to our website, we may collect the following information, provided it is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including timezone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, called individual sub-page of our website including the amount of data transferred, the last page called in the same browser window (referer or referrer).

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

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when visiting our website. Tracking pixels can capture the same information as server log files.

9. Notifications and communications

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

9.1 Performance and reach measurement

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

9.2 Consent and objection

You must generally give explicit consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. Where possible, we use the “Double Opt-in” procedure for any consent, meaning you will receive an email with a web link that you must click to confirm, preventing misuse by unauthorized third parties. We may log such consents, including Internet Protocol (IP) address, date, and time, for proof and security reasons.

You can generally object to receiving notifications and communications, such as newsletters, at any time. With such an objection, you can simultaneously object to the statistical recording of use for performance and reach measurement. This does not affect necessary notifications and communications related to our activities and operations.

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 operations. In connection with such platforms, personal data may also be processed outside of Switzerland.

The general terms and conditions (GTC), terms of use, privacy policies, and other provisions of the individual operators of such platforms also apply. These provisions specifically inform about the rights of affected individuals directly against the respective platform, which includes, for example, the right to information.

11. Third-Party services

We utilize services from specialized third parties to effectively, user-friendly, securely, and reliably carry out our activities and operations. With such services, we can embed functions and content into our website. For such embedding, the services used necessarily collect at least temporarily the Internet Protocol (IP) addresses of users for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data to offer the respective service.

We particularly use:

11.1 Digital infrastructure

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

11.2 Audio and video conferences

We use specialized services for audio and video conferences to communicate online. With these services, we can hold virtual meetings, conduct online classes, and webinars, for example. For participation in audio and video conferences, the legal texts of the individual services such as privacy policies and terms of use also apply.

We recommend, depending on the situation, muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences.

We particularly use:

11.3 Online collaboration

We use services from third parties to enable online collaboration. In addition to this privacy policy, the terms and conditions of the services used, such as terms of use or privacy policies, also apply.

We particularly use:

11.4 Map material

We use services from third parties to embed maps into our website.

We particularly use:

11.5 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.

We particularly use:

12. Website extensions

We use extensions for our website to enable additional functions.

We particularly use:

  • Gravity Forms Zero Spam: Spam protection (distinguishing between desired comments from humans and undesired comments from bots as well as spam); Provider: Katz Web Services Inc. (USA); Privacy information: Used on our own server infrastructure, Privacy Policy.

13. Success and reach measurement

We aim to determine how our online offerings are used. In this context, we can measure the success and reach of our activities and operations as well as the impact of third-party links to our website. Additionally, we may experiment and compare how different parts or versions of our online offerings are utilized (using the “A/B test” method). Based on the results of success and reach measurement, we can address errors, enhance popular content, or make improvements to our online offerings.

For success and reach measurement, the Internet Protocol (IP) addresses of individual users are typically stored in most cases. IP addresses are generally truncated (“IP masking”) in this case to follow the principle of data minimization through appropriate pseudonymization.

Cookies may be used in success and reach measurement, and user profiles may be created. Any user profiles created may include, for example, visited individual pages or viewed content on our website, information on screen size or browser window, and—at least approximately—location. Generally, any user profiles created are exclusively pseudonymized and not used to identify individual users. Some third-party services, where users are logged in, may potentially attribute the use of our online offerings to the user account or user profile with the respective service.

We particularly use:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement across different browsers and devices (Cross-Device Tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, “Privacy”, “Browser Add-on to Disable Google Analytics.”
  • Google Tag Manager: Integration and management of other services for success and reach measurement as well as additional services from Google and third parties; Provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager”; further information on data protection can be found with the individual integrated and managed services.

14. Final provisions

We have created this privacy policy using the Privacy Policy Generator of Datenschutzpartner.

We reserve the right to adjust and supplement this privacy policy at any time. We will inform about such adjustments and supplements in an appropriate manner, especially by publishing the current privacy policy on our website.

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