Privacy policy
With this Privacy Policy We provide information about the processing of personal data in connection with our Activities and Tasks including our Website under the domain name
We have drafted this privacy policy in German. If it is published in another language, the German-language privacy policy shall prevail.
For specific or additional activities and operations, we may publish further privacy statements or other information regarding data protection.
We are subject to Swiss law as well as any applicable foreign law, in particular that of the European Union (EU), including the European General Data Protection Regulation (GDPR).
In its decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures an adequate level of data protection. In its report of January 15, 2024, the European Commission confirmed this adequacy decision.
Table of Contents
- 1. Contact Information
- 2. Definitions and Legal Basis
- 3. Nature, Scope, and Purpose of the Processing of Personal Data
- 4. Disclosure of Personal Data
- 5. Communication
- 6. Data Security
- 7. Personal Data Abroad
- 8. Rights of Data Subjects
- 9. Use of the Website
- 10. Notices and Announcements
- 11. Social Media
- 12. Third-Party Services
- 13. Website Extensions
- 14. Measuring Success and Reach
- 15. Final Notes on the Privacy Policy
1. Contact Information
The data controller, as defined by data protection law, is:
Jörg Steiner
Hauptstrasse 104
CH-9657 Unterwasser
In certain cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. Upon request, we are happy to provide data subjects with information regarding the respective responsibility.
2. Definitions and Legal Basis
2.1 Definitions
Data Subject: A natural person whose personal data we process.
Personal data: Any information relating to an identified or identifiable natural person.
Personal data requiring special protection: data regarding trade union, political, religious, or ideological views and activities; data regarding health, privacy, or membership in an ethnic or racial group; genetic data; biometric data that uniquely identifies a natural person; data regarding criminal or administrative sanctions or proceedings, and data regarding social assistance measures.
Processing: Any handling of personal data, regardless of the means and methods used, such as retrieving, comparing, modifying, archiving, retaining, reading, disclosing, obtaining, recording, collecting, deleting, revealing, sorting, organizing, storing, altering, distributing, linking, destroying, and using personal data.
European Economic Area (EEA): Member states of the European Union(EU), as well as the Principality of Liechtenstein, Iceland, and Norway.
2.2 Legal Basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).
We process personal data—to the extent that the European General Data Protection Regulation (GDPR) applies—in accordance with at least one of the following legal bases:
- Article 6(1)(b) of the GDPR regarding the necessary processing of personal data to fulfill a contract with the data subject and to take steps prior to entering into a contract.
- Article 6(1)(f) of the GDPR for the processing of personal data necessary to safeguard legitimate interests—including the legitimate interests of third parties—unless the fundamental freedoms and rights, as well as the interests, of the data subject take precedence. Such interests include, in particular, the sustainable, people-friendly, secure, and reliable conduct of our activities and operations; ensuring information security; protection against misuse; the enforcement of our own legal claims; and compliance with Swiss law.
- Article 6(1)(c) of the GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under the applicable laws of Member States in the European Economic Area (EEA).
- Article 6(1)(e) of the GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
- Article 6(1)(a) of the GDPR regarding the processing of personal data with the consent of the data subject.
- Article 6(1)(d) of the GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.
- Art. 9, para. 2 et seq. of the GDPR regarding the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the handling of personal data as the processing of personal data and the handling of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Nature, Scope, and Purpose of the Processing of Personal Data
We process the personal data necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may include, in particular, the following categories: browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact data), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted.
We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to comply with legal obligations or to safeguard legitimate interests. We may also ask data subjects for their consent even when their consent is not required.
We process personal data for as long as is necessary for the respective purpose. We anonymize or delete personal data, in particular, in accordance with statutory retention and statute of limitations periods.
4. Disclosure of Personal Data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized service providers whose services we use. These third parties, in turn, may disclose personal data to other third parties.
We may disclose personal data in the course of our activities and operations, in particular to banks and other financial service providers, government agencies, educational and research institutions, consultants and attorneys, accounting and fiduciary service providers, debt collection agencies, advocacy groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent companies, sister companies, and subsidiaries, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.
5. Communication
We process personal data in order to communicate with individuals, as well as with government agencies, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example, by mail or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other individuals are legally obligated to ensure the data protection of those individuals on their own. In particular, they must ensure that they are authorized to provide such data and must also guarantee the accuracy of the data provided.
6. Data Security
We implement appropriate technical and organizational measures to ensure data security commensurate with the respective risk. In particular, our measures ensure the confidentiality, availability, traceability, and integrity of the personal data we process; however, we cannot guarantee absolute data security.
Access to our website and our other digital platforms is secured using transport encryption (SSL/TLS, specifically the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers issue a warning before visiting a website that does not use transport encryption.
Our digital communications—like all digital communications, in principle —are subject to mass surveillance without cause or suspicion by security agencies in Switzerland, the rest of Europe, the United States of America (U.S.), and other countries. We have no direct influence over the processing of personal data by intelligence agencies, police departments, and other security agencies. Nor can we rule out the possibility that a data subject may be specifically monitored.
7. Personal Data Abroad
As a general rule, we process personal data in Switzerland and within the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it there or have it processed there.
We may transfer personal data to any country on Earth or elsewhere in the universe, provided that the laws of that jurisdiction ensure an adequate level of data protection in accordance with a decision by the Swiss Federal Council and—if and to the extent that the General Data Protection Regulation (GDPR) applies—also in accordance with a decision by the European Commission.
We may transfer personal data to countries whose laws do not provide adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific legal requirements under data protection law are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information about any such safeguards or to supply a copy of them.
8. Rights of Data Subjects
8.1 Claims Under Data Protection Law
We grant data subjects all rights provided for under applicable law. In particular, data subjects have the following rights:
- Right of Access: Data subjects may request information regarding whether we process personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data being processed as such, as well as, among other things, details regarding the purpose of processing, the retention period, any disclosure or export of data to other countries, and the origin of the personal data.
- Correction and Restriction: Data subjects may correct inaccurate personal data, complete incomplete data, and request that the processing of their data be restricted.
- Opportunity to express one’s own viewpoint and for human review: Individuals affected by decisions that are based solely on the automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions) may present their own point of view and request a review by a human being.
- Deletion and Objection: Data subjects may request the deletion of their personal data (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data Disclosure and Data Transfer: Data subjects may request the disclosure of their personal data or the transfer of their data to another data controller.
We may defer, restrict, or deny the exercise of data subjects’ rights to the extent permitted by law. We may inform data subjects of any prerequisites that must be met for them to exercise their rights under data protection law. For example, we may refuse to provide information, in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other individuals. We may also, for example, refuse to delete personal data, in whole or in part, citing statutory retention requirements.
In exceptional cases, we may charge a fee for the exercise of these rights. We will inform the individuals concerned in advance of any such fees.
We are required to take reasonable measures to identify data subjects who request information or exercise other rights. Data subjects are required to cooperate.
8.2 Legal Protection
Data subjects have the right to enforce their data protection rights through legal action or to file a report or complaint with a data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organized as members of the European Data Protection Board(EDPB). In some member states of the European Economic Area (EEA), data protection supervisory authorities have a federal structure, particularly in Germany.
9. Use of the Website
9.1 Cookies
We may use cookies. Cookies—including our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.
Cookies can be stored temporarily in the browser as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific retention period. In particular, cookies make it possible to recognize a browser the next time it visits our website and, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be disabled, restricted, or deleted—either in whole or in part—at any time in your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively seek your express consent to the use of cookies—at least to the extent required by applicable law.
For cookies used to measure performance and reach or for advertising, many services offer a general opt-out option through 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).
9.2 Logging
For every visit to our website and our other digital platforms, we may log at least the following information, provided that this information is automatically collected or transmitted to our digital infrastructure during such visits: Date and time, including time zone; IP address; access status (HTTP status code); operating system, including user interface and version; browser, including language and version; individual subpages of our website accessed, including the amount of data transferred; and the last webpage accessed in the same browser window (referrer).
We record such information—which may also constitute personal data—in log files. This information is necessary to ensure that our digital presence is available on a long-term basis, in a user-friendly and reliable manner. It is also necessary to ensure data security—including through third parties or with the assistance of third parties.
9.3 Pixel Count
We can embed tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are typically small, invisible images or JavaScript scripts that are automatically loaded when you access our digital presence. Tracking pixels can collect at least the same information as is recorded in log files.
10. Notices and Announcements
10.1 Measuring Success and Reach
Notifications and messages may contain web links or tracking pixels that track whether an individual message has been opened and which web links were clicked within it. Such web links and tracking pixels may also track the use of notifications and messages on a personal basis. We require this statistical tracking of usage to measure effectiveness and reach so that we can send notifications and communications in a way that is effective, user-friendly, sustainable, secure, and reliable, based on the needs and reading habits of the recipients.
10.2 Consent and Objection
You must generally consent to the use of your email address and other contact information, unless such use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent, if necessary. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and timestamp, for evidentiary and security purposes.
You may, in principle, opt out of receiving notifications and communications—such as newsletters—at any time. By opting out, you also consent to the collection of usage data for the purpose of measuring performance and reach. This does not apply to necessary notifications and communications related to our activities and operations.
10.3 Service Provider for Notifications and Announcements
We send out notifications and announcements through specialized service providers.
In particular, we use:
- Mailchimp: Communication platform; Provider: The Rocket Science Group LLC, doing business as Mailchimp (U.S.), a subsidiary of Intuit Inc. (U.S.); Data Protection Information: Privacy Policy (Intuit), including “Country- and Region-Specific Provisions”, “Frequently Asked Questions About Data Protection at Mailchimp, ” “Mailchimp and European Data Transfers, ” “Security, ” Cookie Policy, “Inquiries Regarding Data Protection Rights, ” “Legal Provisions.”
11. Social Media
We maintain a presence on social media and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with these platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC), Terms of Use, privacy policies, and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information, in particular, about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including what are known as Page Insights—to the extent that the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta group of companies (including those in the U.S.). Page Insights provide information about how visitors interact with our Facebook page. We use Page Insights to ensure that our social media presence on Facebook is effective and user-friendly.
Further information regarding the nature, scope, and purpose of data processing, details on the rights of data subjects, and the contact information for Facebook and Facebook’s Data Protection Officer can be found in Facebook’s Privacy Policy. We have entered into the so-called “Addendum for Controllers” with Facebook and have thereby specifically agreed that Facebook is responsible for ensuring the rights of data subjects. For “Page Insights, ” the relevant information can be found on the “About Page Insights” page, including “About Page Insights Data.”
12. Third-Party Services
We use services provided by specialized third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed features and content on our website. When such embedding occurs, the services used collect users’ IP addresses —at least temporarily—for technical reasons.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data necessary to provide the respective service.
In particular, we use:
- Google Services: Providers: Google LLC (U.S.) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and Switzerland; General Information on Data Protection: “Data Protection Practices, ” Privacy Policy, “How Google Uses Personal Data, ” “Google is Committed to Complying with Applicable Data Protection Laws, ” “Data Protection Guide for Google Products, ” “How We Use Data from Websites or Apps Where Our Services Are Used,” Cookie Policy, “Ads You Can Control” (Settings for personalized ads).
- Microsoft Services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / Microsoft Corporation (U.S.) for users in the rest of the world; General Information on Data Protection: “Data Protection at Microsoft, ” “Data Protection and Privacy, ” Privacy Statement, “Data and Privacy Settings.”
12.1 Digital Infrastructure
We use services provided by specialized third parties to access the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
- Hostpoint: Hosting; Provider: Hostpoint AG (Switzerland); Privacy Information: Privacy Policy.
- Microsoft Azure: Storage and other infrastructure; Provider: Microsoft; Microsoft Azure-specific information: “Data Protection in Azure.”
- WordPress.com: Blog hosting and website builder; providers: Automattic Inc. (U.S.) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe and elsewhere; privacy information: Privacy Policy, Cookie Policy.
12.2 Audio and Video Conferences
We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is also subject to the legal terms and conditions of the individual services, such as privacy policies and terms of use.
Depending on your situation, we recommend that you mute your microphone by default when participating in audio or video conferences, and either blur the background or display a virtual background.
12.3 Maps
We use third-party services to embed maps on our website.
In particular, we use:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: “How does Google use location information?”
12.4 Digital Content
We use services provided by specialized third parties to embed digital content on our website. Digital content includes, in particular, images, videos, music, and podcasts.
In particular, we use:
- YouTube: Video platform; provider: Google; YouTube-specific information: “Privacy and Security Center, ” “My Data on YouTube.”
12.5 Fonts
We use third-party services to embed selected fonts, icons, logos, and symbols on our website.
In particular, we use:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts, ” “Data Protection and Data Collection” (Google Fonts).
12.6 E-Commerce
We operate an e-commerce business and use third-party services to successfully offer services, content, or goods.
12.7 Payments
We use specialized service providers to ensure that payments are processed securely and reliably. The legal documents of the individual service providers—such as Terms and Conditions or Privacy Policies—also apply to the processing of payments.
12.8 Advertising
We take advantage of the opportunity to display targeted advertisements for our activities and services on third-party platforms, such as social media platforms and search engines.
With this type of advertising, we aim in particular to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). To this end, we may share relevant information—including, where applicable, personal data—with third parties that enable such advertising. We can also determine whether our advertising is successful; specifically, whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you, as a user, have an account may, in some cases, associate your use of our website with your profile on their platform.
In particular, we use:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: Advertising based, among other things, on search queries, with various domain names—in particular doubleclick.net, googleadservices.com, and googlesyndication.com—used for Google Ads; Privacy Policy for Advertising; “Manage ads displayed directly through Ads.”
- LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (U.S.) / LinkedIn Ireland Unlimited Company (Ireland); Privacy information: Remarketing and targeting, particularly using the LinkedIn Insight Tag, “Privacy, ” Privacy Policy, Cookie Policy, Opt-out of personalized advertising.
- Meta Ads: Social media advertising on Facebook and Instagram; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including those in the U.S.); privacy information: targeting, including retargeting, particularly using the Meta Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy, “Ad Preferences” (user registration required).
- Microsoft Advertising: Search engine advertising on Bing, DuckDuckGo, Yahoo!, and other search engines; provider: Microsoft; Microsoft Advertising-specific information: “Legal, Privacy, and Security, ” “Ad Settings” (opt out of personalized ads).
- TikTok Ads: Social media advertising; Providers: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / TikTok Inc. (U.S.) for users in the U.S. / TikTok Pte. Ltd. (Singapore) for most users in the rest of the world; privacy information: remarketing and targeting, in particular using the TikTok Pixel, Privacy Policy, “Privacy Policy for Children, ” “Privacy Policy for TikTok Partners, ” Cookie Policy.
13. Website Extensions
We use extensions on our website to enable additional features. We may use selected services from appropriate providers or implement such extensions on our own digital infrastructure.
In particular, we use:
- Google reCAPTCHA: Bot protection (distinguishing between desired human activities and undesired bot activities); Provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”
14. Measuring Success and Reach
We strive to measure the success and reach of our activities and operations. As part of this effort, we may also measure the impact of third-party recommendations or test how different parts or versions of our digital presence are used (the “A/B testing” method). Based on the results of these success and reach measurements, we can, in particular, correct errors, enhance popular content, or make improvements.
In most cases, the IP addresses of individual users are collected to measure success and reach. In such cases, IP addresses are always truncated (“IP masking”) in order to comply with the principle of data minimization through pseudonymization.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital platform, information about the size of the screen or browser window, and the user’s location (at least approximately). As a general rule, any user profiles created are exclusively pseudonymized and are not used to identify individual users. Certain third-party services with which users are registered may, in some cases, associate the use of our online offering with the user’s account or profile on the respective service.
In particular, we use:
- Google Marketing Platform: Performance and reach measurement, particularly using Google Analytics; Provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) using pseudonymized IP addresses, which are transmitted in full to Google in the U.S. only in exceptional cases; Google Analytics Privacy Policy; “Browser add-on to disable Google Analytics.”
- Google Tag Manager: Integration and management of Google and third-party services, in particular for measuring performance and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the privacy policies of the individual integrated and managed services.
15. Final Notes on the Privacy Policy
We created this privacy policy using the privacy policy generator from Datenschutzpartner.
We may update this Privacy Policy at any time. We will notify you of any updates by posting the most current version of the Privacy Policy on our website.
