This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as “online offer”). With regard to the terminology used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (DSGVO).
swiss innotech ag
Managing Directors: Jens Lautenschläger, Patrick Cakarun
9434 Au (SG)
Tel. +41 (0)71 520 75 85
Fax +41 (0)71 520 75 86
Data Protection Officer:
Patrick Cakarun, Rosenbergsaustrasse 12
9434 Au (SG), Switzerland, Tel: +41 71 727 13 85
E-mail address: firstname.lastname@example.org
Types of data processed:
Usage data (e.g., websites visited, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses).
Processing of special categories of data (Art. 9 para. 1 DSGVO):
In principle, no special categories of data are processed, unless they are supplied for processing by the users, e.g. in online forms or direct e-mail transmission.
Categories of data subjects:
Visitors and users of the online offer.
Hereafter, we also refer to the data subjects collectively as “users”.
Purpose of processing:
Provision of the online offer, its contents and functions.
Provision of contractual services, service and customer care.
Answering contact requests and communication with users.
Acquisition of new employees/transfer of application documents.
Marketing, advertising and market research.
1 Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6(1)(b) DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing in order to protect our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) DSGVO serves as the legal basis.
2. changes and updates to the data protection declaration
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us 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.
3. security measures
3.1 We take appropriate technical and organisational measures in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk 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 access to the data, as well as access relating to it, input, disclosure, safeguarding availability and its separation. We also have procedures in place to ensure the exercise of data subject rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 DSGVO).
3.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
4 Cooperation with processors and third parties
4.1 If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
4.2 If we commission third parties with the processing of data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 DSGVO.
5 Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. DSGVO are met. This means, for example, that the processing is carried out on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
6. rights of the data subjects
6.1 You have the right to obtain confirmation as to whether or not data relating to you is being processed and to be informed of such data and to obtain further information and a copy of the data in accordance with Article 15 of the GDPR.
6.2 You have the right according to Art. 6.2. you have the right, in accordance with Article 16 of the GDPR, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
6.3 In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay or, alternatively, to demand that the processing of the data be restricted in accordance with Article 18 of the GDPR.
6.4 You have the right to request that the data relating to you that you have provided to us be received in accordance with Article 20 of the GDPR and to request that it be transferred to other data controllers.
6.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
7. right of revocation
You have the right to revoke your consent in accordance with Art. 7 Para. 3 DSGVO with effect for the future.
8. right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against the processing for purposes of direct advertising.
9 Cookies and right to object to direct advertising
10 Deletion of data
10.1 The data processed by us will be deleted or its processing restricted in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
10.2 In accordance with legal requirements, data is stored in particular for 6 years pursuant to § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years pursuant to § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
11. contacting and applications
11.1 When contacting us (via contact form or e-mail), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.
11.2 The user’s details may be stored in our customer relationship management system (“CRM system”) or comparable enquiry organisation.
11.3 Applications are stored centrally on our file server. Only the management and the person responsible for the specific position to be filled have access there. The data will be deleted from the server and from the local recipient mailbox of the e-mail programme after the probationary period of the filled position has expired.
12 Collection of access data and log files
12.1 We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
12.2 Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for the duration of the last complete calendar year and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
13. online presence in social media
13.1 We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there.
13.2 We would like to point out that user data may be processed outside the European Union. This may result in risks for the users, because it could, for example, make it more difficult to enforce the rights of the users. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the EU’s data protection standards.
13.3 Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the usage profiles irrespective of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
13.4 The processing of the users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers for consent to data processing (i.e. declare their consent e.g. by ticking a checkbox or confirming a button), the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
13.5 For a detailed description of the respective processing and the opt-out options, please refer to the information provided by the providers linked below.
13.6 In the case of requests for information and the assertion of user 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 users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
14 Cookies & Reach Measurement
14.1 Cookies are pieces of information that are transmitted from our web server or third-party web servers to the users’ web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage.
14.2 We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. in order to be able to store your login status or the shopping cart function and thus enable the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.
14.4 If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
15 Google Analytics
15.2 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
15.3 Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles of the users can be created from the processed data.
15.4 We use Google Analytics to display the ads placed within Google’s advertising services and those of its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences” or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our advertisements correspond to the potential interest of the users and do not have a harassing effect.
15.5 We only use Google Analytics with IP anonymisation activated. This means that the IP address of users is shortened 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.
15.6 The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
15.7 You can find out more information about Google’s use of data, setting and objection options on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information Google uses to show you ads”).
16 Google Re/Marketing Services
16.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (in short “Google marketing services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
16.2 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
16.3 Google’s marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has shown interest on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he or she is interested in and which offers he or she has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transmitted in full to a Google server in the USA and shortened there. The IP address will not be merged with user data within other Google offerings. The aforementioned information may also be combined by Google with such information from other sources. If the user subsequently visits other websites, he or she may be shown ads tailored to his or her interests.
16.4 The user’s data will be processed pseudonymously as part of the Google marketing services. This means that Google does not store and process the name or email address of the user, for example, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
16.5 The Google marketing services we use include the online advertising programme “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information obtained with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. The AdWords 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 will not receive any information that personally identifies users.
16.8 If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com/authenticated.
17 Facebook, Custom Audiences and Facebook Marketing Services
17.1 Within our online offer, the so-called “Facebook Pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used due to our legitimate interests in the analysis, optimisation and economic operation of our online offer and for these purposes.
17.2 Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
17.3 With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).
17.4 The processing of data by Facebook is carried out within the framework of Facebook’s data use policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook Pixel and how it works can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.
17.5 You can object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To adjust which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
18 Integration of third-party services and content
18.1 We use content or service offers of third party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO). DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavour 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. The “pixel tags” can be used to evaluate 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 on the browser and operating system, referring websites, time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.
18.2 The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in part already mentioned here, options for objection (so-called opt-out):
External fonts from Adobe Typekit, https://typekit.com/?locale=de-DE. The integration of Adobe Typekit fonts takes place via a server call at Adobe (usually in the USA).
Maps provided by the “Google Maps” service of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Videos from the “YouTube” platform of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Within our online offer, functions of the Twitter service or platform may be integrated (hereinafter referred to as “Twitter”). Twitter is a service of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the display of our posts within Twitter within our online offer, the link to our profile on Twitter as well as the possibility to interact with the posts and the functions of Twitter, as well as to measure whether users reach our online offer via the advertisements placed by us on Twitter (so-called conversion measurement). Twitter is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active).