With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").
The terms used are not gender-specific.
Last Update: 13. July 2024
Preamble
Controller
Overview of processing operations
Relevant legal bases
Security Precautions
Transmission of Personal Data
International data transfers
General Information on Data Retention and Deletion
Rights of Data Subjects
Business services
Business processes and operations
Payment Procedure
Provision of online services and web hosting
Use of Cookies
Registration, Login and User Account
Contact and Inquiry Management
Communication via Messenger
Artificial Intelligence (AI)
Newsletter and Electronic Communications
Commercial communication by E-Mail, Postal Mail, Fax or Telephone
Web Analysis, Monitoring and Optimization
Customer Reviews and Ratings
Profiles in Social Networks (Social Media)
Processing of data in the context of employment relationships
Changes and Updates
Terminology and Definitions
Skorokhod Yuliia, Blossom Nail & Beauty RoomScheitergasse 3 8001 Zürich
E-mail address: blossom@gmail.com
The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
Inventory data.
Employee Data.
Payment Data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and process data.
Social data.
Images and/ or video recordings.
Log data.
Performance and behavioural data.
Working hours data.
Creditworthiness Data.
Salary data.
Health Data.
Religious or philosophical beliefs.
Trade union membership.
Service recipients and clients.
Employees.
Prospective customers.
Communication partner.
Users.
Business and contractual partners.
Third parties.
Customers.
Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Direct marketing.
Web Analytics.
Office and organisational procedures.
Organisational and Administrative Procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and usability.
Assessment of creditworthiness.
Establishment and execution of employment relationships.
Information technology infrastructure.
Financial and Payment Management.
Public relations.
Sales promotion.
Business processes and management procedures.
Artificial Intelligence (AI).
Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR) - processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as "Swiss DPA"). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).
Reference to the applicability of the GDPR and the Swiss DPA: These privacy policy serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss FADP such as "processing" of "personal data", "predominant interest", and "particularly sensitive personal data", the terms used in the GDPR, namely "processing" of "personal data", as well as "legitimate interest" and "special categories of data" are used. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP within its scope of application.
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user's browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.
In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.
Data Transfer within the Organization: Data Transfer within the Corporate Group: We may transfer personal data to other companies within our corporate group or grant them access to it. If the data is shared for administrative purposes, it is based on our legitimate business and commercial interests or occurs if necessary to fulfil our contractual obligations, or when consent from the individuals concerned has been obtained or a legal permission exists.
Data Processing in 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 the processing is done within the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is only done in accordance with legal requirements. If the data protection level in the third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from individual third-country providers, with adequacy decisions primarily serving as the foundation. "Information regarding third-country transfers and existing adequacy decisions can be obtained from the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure within the adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/s/. We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.
Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council does not determine that there is an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures. These measures may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection regulations previously recognised by the FDPIC or a competent data protection authority of another country.
Under Art. 16 of the Swiss DSG, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data or data from a legally provided register. Such disclosures always comply with the legal requirements.
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing processes.
In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.
If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.
Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.
Further information on processing methods, procedures and services used:
Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:
10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).
6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).
3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).
Data Retention and Deletion: The following general deadlines apply for retention and archiving according to Swiss law:
10 Jahre - Aufbewahrungsfrist für Bücher und Aufzeichnungen, Jahresabschlüsse, Inventare, Lageberichte, Eröffnungsbilanzen, Buchungsbelege und Rechnungen sowie alle erforderlichen Arbeitsanweisungen und sonstigen Organisationsunterlagen (Art. 958f des Schweizerischen Obligationenrechts (OR)).
10 Jahre - Daten, die zur Berücksichtigung potenzieller Schadenersatzansprüche oder ähnlicher vertraglicher Ansprüche und Rechte notwendig sind, sowie für die Bearbeitung damit verbundener Anfragen, basierend auf früheren Geschäftserfahrungen und den üblichen Branchenpraktiken, werden für den Zeitraum der gesetzlichen Verjährungsfrist von zehn Jahren gespeichert, es sei denn, eine kürzere Frist von fünf Jahren ist maßgeblich, die in bestimmten Fällen einschlägig ist (Art. 127, 130 OR). Mit Ablauf von fünf Jahren verjähren die Forderungen für Miet-, Pacht- und Kapitalzinse sowie andere periodische Leistungen, aus Lieferung von Lebensmitteln, für Beköstigung und für Wirtsschulden, sowie aus Handwerksarbeit, Kleinverkauf von Waren, ärztlicher Besorgung, Berufsarbeiten von Anwälten, Rechtsagenten, Prokuratoren und Notaren und aus dem Arbeitsverhältnis von Arbeitnehmern (Art. 128 OR).
Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right of withdrawal for consents: You have the right to revoke consents at any time.
Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of the data subjects under the Swiss DPA:
As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:
Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Special categories of personal data: Health Data.
Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Online shop, order forms, e-commerce and delivery.: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or performance of other services. If necessary for the execution of an order, we use service providers, in particular postal, freight and shipping companies, in order to carry out the delivery or execution to our customers. For the processing of payment transactions we use the services of banks and payment service providers. The required details are identified as such in the course of the ordering or comparable purchasing process and include the details required for delivery, or other way of making the product available and invoicing as well as contact information in order to be able to hold any consultation; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Cosmetic services: The processes within the scope of cosmetic services include the acquisition and management of customer data, encompassing the collection, storage, and use of contact information, appointment scheduling, and customer-specific preferences. For the execution of treatments and applications, the collection and documentation of health-related information, such as allergies, pre-existing conditions, or medications, are required. The processing of these sensitive data demands particular care and adherence to strict confidentiality standards. The management of customer appointments involves the coordination of treatment dates, follow-up appointments, and reminders, for which personal data are also utilized. The marketing and distribution of cosmetic products or services necessitate the processing of customer data, for example for targeted advertising campaigns or customer loyalty programs. Additionally, providing customer advice and support requires the processing of personal data to accommodate individual needs and preferences; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties - are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.
Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Creditworthiness Data (e.g. received credit score, estimated default probability, risk classification based on this, historical payment behaviour).
Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Customers; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Security measures; Provision of our online services and usability; Communication; Marketing; Sales promotion; Public relations; Assessment of creditworthiness; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).).
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).
Further information on processing methods, procedures and services used:
Customer Management and Customer Relationship Management (CRM): Processes required in the context of customer management and Customer Relationship Management (CRM) include customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and targeting; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Customer Account: Customers can create an account within our online offer (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, customers will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers' responsibility to back up their data when terminating the customer Account; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Product List/ Wishlist: Customers can create a products/wish list In this case, the products are stored within the context of the fulfillment of our contractual obligations until the deletion of the account, unless the product list entries are removed by the customer or we expressly inform the customer of deviating storage periods; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Customer loyalty program: Within the framework of the customer loyalty program, the controller processes the data of participating customers for the purpose of providing services offered within this program. For this purpose, the controller stores information provided by the customers, as necessary and marked as such, in a customer profile. Within this profile, information about the use of the customer loyalty program as well as about the utilisation of associated services and benefits is also processed. This information is shared with third parties (e.g., service providers) only when it is necessary for the mentioned purposes. The customer profiles are deleted after participation in the program ends. The archiving of respective data occurs only to the extent that it may be necessary for legal retention purposes or for fulfilling legal (up to eleven years for tax information from the end of their creation year) or contractual claims (up to three years from the end of the year in which participation ended). This is recorded in the Records of Processing Activities; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Economic Analyses and Market Research: To fulfill business management purposes and to identify market trends, desires of contractual partners, and users, the present data regarding business transactions, contracts, inquiries, etc., are analyzed. The group of affected individuals may include contractual partners, interested parties, customers, visitors, and users of the online service managed by the responsible entity. The execution of these analyses serves the purposes of business economic evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, profiles of registered users along with their information on services utilized are considered. The analyses are exclusively for the use of the responsible entity and are not disclosed externally unless they pertain to anonymous analyses with aggregated, thus anonymized values. Moreover, user privacy is accounted for; data is processed for analysis purposes in as pseudonymized a manner as possible and anonymized when feasible (e.g., as aggregated data); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Contact data (e.g. postal and email addresses or phone numbers).
Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and management procedures.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
American Express: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.americanexpress.com/; Privacy Policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/. Basis for third-country transfers: Switzerland - Adequacy decision (Germany).
Apple Pay: Payment services provider; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.apple.com/apple-pay/. Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.
Google Pay: Payment services provider; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://pay.google.com/intl/en_uk/about/; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: Switzerland - Adequacy decision (Ireland).
Mastercard: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.mastercard.co.uk; Privacy Policy: https://www.mastercard.co.uk/en-gb/vision/terms-of-use/commitment-to-privacy/privacy.html. Basis for third-country transfers: Switzerland - Adequacy decision (Belgium).
PayPal: Payment-Service-Provider (technical integration of online-payment-methods) (e.g. PayPal, PayPal Plus, Braintree, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. Basis for third-country transfers: Switzerland - Adequacy decision (Luxembourg).
Stripe: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://stripe.com/de; Privacy Policy: https://stripe.com/en-de/privacy. Basis for third-country transfers: EEA - Data Privacy Framework (DPF).
Visa: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Visa Europe Services Inc., Zweigniederlassung London, 1 Sheldon Square, London W2 6TT, UK; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/datenschutz. Basis for third-country transfers: EEA - Adequacy decision (UK), Switzerland - Adequacy decision (UK).
We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.
Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).). Security measures.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz; Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/. Basis for third-country transfers: Switzerland - Adequacy decision (Germany).
Cookies are small text files or other types of storage markers that store information on end devices and read information from them. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used of an online offer. Furthermore, cookies can be used for various concerns, such as for the functionality, security, and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on Consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless it is not required by law. Permission is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service (i.e., our online offer) expressly requested by the users. The revocable consent is clearly communicated to them and contains information on the respective cookie usage.
Notes on the legal basis for data protection: The legal basis on which we process users' personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are based on our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or, if this occurs within the fulfillment of our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used by us in the course of this data protection declaration or within the scope of our consent and processing processes.
Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:
Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a site. Similarly, user data collected via cookies can be used for reach measurement. Unless we provide users with explicit information about the nature and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and the storage duration can be up to two years.
General notes on revocation and objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.
Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and usability.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users' consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users' devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
Cookie-Opt-Out: In the footer of our website you will find a link that allows you to change your cookie settings as well as revoke corresponding consents; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).
Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Registration with a real name: Due to the nature of our community, we ask users to use our services only with their real names. This means that the use of pseudonyms is not permitted; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Users' profiles are public: The users' profiles are not publicly visible or accessible.
Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.
You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.
In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.
However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner's device used and, depending on the settings of their device, also location information (so-called metadata).
Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.
Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.
Reservation of reference to other means of communication: For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.
Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Communication. Direct marketing (e.g. by e-mail or postal).
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Switzerland - Adequacy decision (Ireland).
Facebook-Messenger: Sending and receiving text messages, making voice and video calls, creating group chats, sharing files and media, transmitting location information, synchronising contacts, encrypting messages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).
Telegram: Sending and receiving messages, voice calls, and video calls; creating groups and channels; sharing files and media; using bots for automation; end-to-end encryption for secret chats; synchronisation across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy. Basis for third-country transfers: Switzerland - Adequacy decision (Belgium).
WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat functionality, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).
TikTok: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to accounts; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.tiktok.com. Privacy Policy: https://www.tiktok.com/de/privacy-policy.
We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.
When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.
To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
Data subjects: Users (e.g. website visitors, users of online services). Third parties.
Purposes of processing: Artificial Intelligence (AI).
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users' consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions and offers.
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Direct marketing (e.g. by e-mail or postal).
Retention and deletion: 3 years - Contractual claims (AT) (Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 1478, 1480 of the Austrian Civil Code).). 10 years - Contractual claims (CH) (Data required to consider potential compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the statutory limitation period of ten years, unless a shorter period of 5 years is applicable, which is relevant in certain cases. This period begins at the end of the calendar year in which the claim arose (Articles 127 and 128 Swiss Code of Obligations (CO))).
Legal Basis: Consent (Article 6 (1) (a) GDPR).
Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
The recipients have the right to withdraw their consent at any time or to object to the advertising communication at any time.
After revocation or objection, we store the data required to prove the past authorization to contact or send up to three years from the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation, respectively objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Direct marketing (e.g. by e-mail or postal); Marketing. Sales promotion.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called "cookies") or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (Creating user profiles).
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
Security measures: IP Masking (Pseudonymization of the IP address).
Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
We participate in review and rating procedures to evaluate, optimise and advertise our performance. If users rate us via the participating rating platforms or methods or otherwise provide feedback, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective provider.
In order to ensure that the evaluators have actually made use of our services, we transmit, with the consent of the customer, the necessary data relating to the customer and the service or products used to the respective rating platform (this includes the name, e-mail address, order number or article number). This data is used solely to verify the authenticity of the user.
Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Inventory data (For example, the full name, residential address, contact information, customer number, etc.). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form); Public relations. Provision of our online services and usability.
Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Instagram: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).
Facebook Pages: Profiles within the social network Facebook - We are jointly responsible (so called "joint controller") with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see "Things that you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How we use this information?" Facebook also collects and uses information to provide analytics services, known as "page insights," to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook ("Information about Page-Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).
Telegram Channels: We use the Telegram platform to send messages to subscribers of our Telegram channel; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy/de; Basis for third-country transfers: Switzerland - Adequacy decision (Belgium). Further Information: We process the subscribers' personal data only to the extent that we can view and delete the subscribers as recipients of the channel. Beyond that, i.e. in particular for the sending of the messages, the evaluation and provision of anonymous sending statistics for the channel operators and the administration of the subscribers, Telegram is responsible under data protection law.
TikTok: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to accounts; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.tiktok.com. Privacy Policy: https://www.tiktok.com/de/privacy-policy.
In the context of employment relationships, the processing of personal data aims to effectively manage the establishment, execution, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.
The data processing covers various aspects ranging from contract initiation to termination. Included are the organization and management of daily working hours, management of access rights and permissions, as well as handling personnel development measures and staff appraisals. The processing also serves payroll accounting and management of wage and salary payments, which represent critical aspects of contract execution.
Additionally, the data processing considers legitimate interests of the responsible employer, such as ensuring workplace safety or capturing performance data for evaluating and optimizing operational processes. Moreover, the data processing includes disclosing employee data in external communication and publication processes where necessary for operational or legal purposes.
The processing of this data always takes place with due regard for the applicable legal frameworks, aiming always to create and maintain a fair and efficient working environment. This also includes considering the privacy of affected employees, anonymizing or deleting data after fulfilling the processing purpose or according to legal retention periods.
Processed data types: Employee Data (Information about employees and other individuals in an employment relationship); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Social data (Data subject to a special social confidentiality obligation and processed, for example, by social insurance institutions, social welfare institutions or pension authorities.); Log data (e.g. log files concerning logins or data retrieval or access times.); Performance and behavioural data (For example, performance and behavioural data aspects such as performance evaluations, feedback from supervisors, training attendance, compliance with company policies, self-assessments, and behavioural assessments.); Working hours data (e.g. start of work time, end of work time, actual working hours, target working hours, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); Salary data (e.g. basic salary, bonus payments, premiums, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net payout amount); Images and/ or video recordings (e.g. photographs or video recordings of a person); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Special categories of personal data: Health Data; Religious or philosophical beliefs. Trade union membership.
Data subjects: Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
Purposes of processing: Establishment and execution of employment relationships (Processing of employee data in the context of the establishment and execution of employment relationships); Business processes and management procedures; Provision of contractual services and fulfillment of contractual obligations; Public relations; Security measures. Office and organisational procedures.
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR). Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
Time Recording: Processes for recording employees' working hours include both manual and automated methods, such as the use of punch clocks, time tracking software, or mobile apps. Activities involved include entering clock-in and clock-out times, break times, overtime, and absences. To verify and validate the recorded working hours, they are compared with deployment or shift schedules, checked for absences, and approved for overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide work time records, overtime reports, and absence statistics for management and the human resources department; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Authorization Management: Procedures required for the definition, management, and control of access rights and user roles within a system or an organisation (e.g., creation of authorisation profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Special categories of personal data: Special categories of personal data are processed in the context of employment relationships or to fulfil legal obligations. The processed special categories of personal data include information concerning the health, trade union membership, or religious affiliation of employees. This data may be transferred to health insurance companies or processed for assessing the employees' work capacity, for corporate health management, or for declarations to the tax authorities; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Sources of Processed Data: Personal data received during the application process and/or employment relationship will be processed. Furthermore, where required by law, personal data will be collected from other sources. These may include financial authorities for tax-related information, the respective health insurance company for information on work incapacity, third parties such as employment agencies, or publicly accessible sources like professional social networks in the context of application procedures; Legal Basis: Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Purposes of Data Processing: The personal data of employees are primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, the processing of this data is necessary to fulfil legal obligations in the field of tax and social security law. In addition to these primary purposes, the data of employees are also used to meet regulatory and supervisory requirements, to optimise processes of electronic data processing, and to compile company-internal or cross-company data, possibly including statistical data. Moreover, the data of employees may be processed for the assertion of legal claims and defense in legal disputes; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Transmission of Employee Data to Third Countries: The transfer of employee data to third countries, meaning countries outside the European Union (EU) and the European Economic Area (EEA), occurs only if it is necessary for the fulfilment of the employment relationship, legally required, or if employees have given their consent. Employees will be informed about the details separately, as far as legally required; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Transmission of Employee Data: The data of employees is processed internally only by those departments that require it to fulfil operational, contractual, and legal obligations. The transfer of data to external recipients only occurs if it is legally required, or if the affected employees have given their consent. Possible scenarios for this can include requests for information from authorities or in the case of asset formation benefits. Furthermore, the controller may transfer personal data to further recipients as far as this is necessary for fulfilling his contractual and legal obligations as an employer. These recipients can include: a) banks b) health insurance companies, pension insurance institutions, providers of old-age provisions and other social insurance carriers c) authorities, courts (e.g., tax authorities, labour courts, further supervisory authorities within the framework of fulfilling reporting and information obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other entities to which legally obligatory declarations must be made.In addition, data can be transferred to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples include details in the sender area of emails or letterheads as well as creating profiles on external platforms; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Business Travel and Travel Expense Settlement: Procedures required for planning, executing, and accounting for business trips (e.g., booking of travel, organizing accommodations and transportation, managing travel expense advances, submitting and reviewing travel expense reports, controlling and recording incurred costs, compliance with travel policies, handling of the travel expense management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).
Payroll and wage accounting: Procedures required for calculating, disbursing, and documenting wages, salaries, and other remuneration for employees (e.g., recording of working hours, calculation of deductions and surcharges, remittance of taxes and social security contributions, preparation of payroll statements, management of wage accounts, reporting to the tax authorities and social security institutions); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR).
Deletion of Employee Data: Employment data will be deleted under German law when it is no longer required for the purpose for which it was collected, unless there is a legal obligation to retain or archive it, or it needs to be kept for the interests of the employer. The following retention and archiving obligations are observed:Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).
General personnel records - General personnel records (such as employment contracts, references, supplementary agreements) are retained for up to three years after the termination of the employment relationship (§ 195 German Civil Code (BGB)).Tax-relevant documents - Tax-relevant documents in the personnel file are kept for six years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).Information on wages and working hours - Information on wages and working hours for (accident) insured with wage proof are kept for five years (§ 165 I 1, IV 2 Social Code Book VII (SGB VII)).
Payrolls including lists for special payments - Payrolls including lists for special payments, if a booking receipt is available, are kept for ten years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
Wage lists for interim, final, and special payments - Wage lists for interim, final, and special payments are kept for six years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
Documents on employee insurance - Documents on employee insurance, if booking receipts are available, are kept for ten years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
Contribution statements to social security institutions - Contribution statements to social security institutions are kept for ten years (§ 165 Social Code Book VII (SGB VII)).Wage accounts - Wage accounts are kept for six years (§ 41 I 9 Income Tax Act (EStG)).
Applicant data - Kept for a maximum of six months from the receipt of rejection.
Working time records (for more than 8 hours on workdays) - Kept for two years (§ 16 II Working Time Act (ArbZG)).
Application documents (following online job advertisement) - Kept for three to a maximum of six months from the receipt of rejection (§ 26 Federal Data Protection Act (BDSG) n.F., § 15 IV General Act on Equal Treatment (AGG)).
Certificates of incapacity for work (AU) - Kept for up to five years (§ 6 I Act on the Compensation of Expenses (AAG)).
Documents on company pension schemes - Kept for 30 years (§ 18a Act to Improve Occupational Pensions (BetrAVG)).
Sickness data of employees - Kept for twelve months from the start of the illness, if the absence in a year does not exceed six weeks.
Documents on maternity protection - Kept for two years (§ 27 para. 5 Maternity Protection Act (MuSchG)).
Deletion of Employee Data: Employee data in Switzerland is deleted when it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following retention and archiving obligations are observed:
10 years - Retention period for ledgers and records, annual accounts, inventories, management reports, opening balances, accounting vouchers, and invoices, as well as all required work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (OR)).
10 years - Data necessary for considering potential claims for damages or similar contractual claims and rights, as well as for processing associated inquiries, based on past business experiences and usual industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 OR). Claims expire after five years for rental, lease and capital interest payments, and other periodic services, from the supply of food, for catering and innkeeper debts, as well as from craftsmanship, retail sale of goods, medical care, professional work of lawyers, legal agents, solicitors, and notaries, and from the employment relationship of employees (Art. 128 OR). .
10 years - Mandatory retention period for finance-related accounting documents and corresponding business correspondence as per the Business Recordkeeping Ordinance (GeBüV), specifically pertaining to financial documents of employees (e.g., payroll, social insurance) and clients (e.g., accounts receivable management, pension contracts).
5 years - Mandatory retention period for employment-related documents as per Art. 73 of Ordinance 1 on the Labour Law (ArGV1), specifically for documents relating to personal details, type of employment, entry/exit, work/break/rest periods, salary supplements, and medical evaluations.
Personnel file management: Procedures required for the organisation, updating, and management of employee data and records (e.g., recording of basic personnel data, retention of employment contracts, certificates and attestations, updating data upon changes, compilation of documents for employee discussions, archiving of personnel files, compliance with data protection regulations); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).
Personnel development, performance evaluation, and staff appraisals: Procedures required in the area of employee promotion and development, as well as in assessing their performance and during employee discussions (e.g., needs analysis for further training, planning and implementation of training measures, creation of performance evaluations, conducting goal-setting and feedback discussions, career planning and talent management, succession planning); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).
Obligation to Provide Data: The person in charge informs the employees that the provision of their data is required. This is generally the case when the data are necessary for the establishment and execution of the employment relationship, or when their collection is mandated by law. The provision of data may also be required when employees assert claims or are entitled to claims. The implementation of these measures or fulfilment of services depends on the provision of such data (for example, providing data for the receipt of wages); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Publication and Disclosure of Employee Data: The data of employees will only be published or disclosed to third parties if it is necessary for the performance of work tasks according to the employment contract. This applies, for example, when employees are named as contact persons in correspondences, on the website, or in public registers following an agreement or specified job description, or if their field of work includes representative functions. Similarly, this may occur if representation or communication with the public takes place as part of performing these tasks, such as image recordings during public relations activities. Otherwise, employee data is published only with their consent or based on the legitimate interests of the employer, for example, in the case of stage or group photographs taken during a public event; Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.
In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.
Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.
Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Employees: As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an employer and an employee, established through an employment contract or agreement. It entails the obligation of the employer to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various stages, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.
Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
Performance and behavioural data: Performance and behavioral data refer to information related to how individuals perform tasks or behave within a certain context, such as in an educational, work, or social setting. This data may include metrics such as productivity, efficiency, quality of work, attendance, and adherence to policies or procedures. Behavioral data could encompass interactions with colleagues, communication styles, decision-making processes, and responses to various situations. These types of data are often used for performance evaluations, training and development purposes, and decision-making within organizations.
Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.
