Privacy Policy
With this Privacy Policy we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name
For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.
Table of contents
- 1. Contact details
- 2. Definitions and legal bases
- 3. Nature, scope and purpose of the processing of personal data
- 4. Disclosure of personal data
- 5. Communication
- 6. Data security
- 7. Personal data abroad
- 8. Rights of data subjects
- 9. Use of the website
- 10. Notifications and communications
- 11. Social media
- 12. Third-party services
- 13. Measuring success and reach
- 14. Final notes on the privacy policy
1. Contact details
The controller within the meaning of data protection law is:
Lucy Axam
Rte de Suisse 18b
1297 Founex
Switzerland
In individual cases, third parties may be responsible for the processing of personal data, or there may be joint controllership with third parties. On request, we will be happy to provide data subjects with information about the respective responsibility.
2. Definitions and legal bases
2.1 Definitions
Data subject: A natural person about whom we process personal data.
Personal data: All information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data on health, private life or affiliation to an ethnic group or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on measures of social assistance.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, retaining, reading out, disclosing, obtaining, recording, collecting, erasing, revealing, organising, structuring, storing, altering, disseminating, linking, destroying and using personal data.
2.2 Legal bases
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. Nature, scope and purpose of the processing of personal data
We process the personal data that are necessary to carry out our activities and operations on an ongoing basis in a user-friendly, secure and reliable manner. The personal data processed may in particular fall into the categories of browser and device data, content data, communication data, meta data, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of carrying out our activities and operations, insofar as such processing is permitted.
We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to fulfil legal obligations or to safeguard overriding interests. We may also ask data subjects for their consent even if their consent is not required.
We process personal data for the duration that is necessary for the respective purpose. In particular, we anonymise or erase personal data depending on statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have personal data processed by third parties, or process personal data jointly with third parties. Such third parties may, for example, be specialised providers whose services we use.
In the course of our activities and operations, we may in particular disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit agencies and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurers and payment service providers.
5. Communication
We process personal data in order to be able to communicate with individuals as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or using comparable tools.
Third parties that transmit data about other persons to us are obliged to ensure the data protection of those data subjects independently. In particular, they must ensure that such data are accurate and may be transmitted.
6. Data security
We take appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, although we cannot guarantee absolute data security.
Access to our website and our other digital presence is via transport encryption (SSL / TLS, in particular using Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.
Our digital communication is subject – as is in principle any digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police units and other security authorities. Nor can we rule out that a data subject is specifically monitored.
7. Personal data abroad
As a general rule, we process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process them there or have them processed there.
We may disclose personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection in accordance with the decision of the Swiss Federal Council.
We may disclose personal data to countries whose law does not ensure adequate data protection, provided that appropriate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. By way of exception, we may export personal data to countries without adequate or suitable data protection if the specific data protection requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. On request, we will be happy to provide data subjects with information about any safeguards or provide a copy of the safeguards.
8. Rights of data subjects
8.1 Data protection claims
We grant data subjects all rights in accordance with applicable law. In particular, data subjects have the following rights:
- Access: Data subjects may request information as to whether we process personal data about them and, if so, what personal data are involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Rectification and restriction: Data subjects may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Opportunity to present their own viewpoint and human review: In the case of decisions based exclusively on automated processing of personal data that are associated with a legal consequence for them or significantly affect them (automated individual decisions), data subjects may present their own viewpoint and request a review by a human.
- Erasure and objection: Data subjects may have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data release and data portability: Data subjects may request the release of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible scope. We may inform data subjects of any requirements to be met for the exercise of their data protection claims. For example, we may refuse to provide information in whole or in part by reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse the erasure of personal data in whole or in part, in particular by reference to statutory retention obligations.
In exceptional cases, we may provide for costs for the exercise of rights. We inform data subjects in advance about any costs.
We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are obliged to cooperate.
8.2 Legal remedies
Data subjects have the right to enforce their data protection claims in court or to file a report or complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
9. Use of the website
9.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data are not limited to traditional text cookies.
Cookies can be stored temporarily in the browser as "session cookies" or for a certain period as so-called persistent cookies. "Session cookies" are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies make it possible, in particular, to recognise a browser on its next visit to our website and thereby, for example, to measure the reach of our website. Persistent cookies may also be used, for example, for online marketing.
Cookies can be disabled, restricted or deleted in whole or in part at any time in the browser settings. The browser settings often also allow the automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least where and to the extent required under applicable law – express consent to the use of cookies.
For cookies used for measuring success and reach or for advertising, a general objection ("opt-out") is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
9.2 Logging
For each access to our website and our other digital presence, we may log at least the following information, provided that such information is determined or transmitted to our digital infrastructure as standard during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the individual subpage of our website accessed including the amount of data transferred, the last webpage accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. The information is required to provide our digital presence on an ongoing basis in a user-friendly and reliable manner. The information is also required to ensure data security – including by third parties or with the help of third parties.
9.3 Tracking pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when accessing our digital presence. Tracking pixels can capture at least the same information as logging in log files.
10. Notifications and communications
10.1 Measuring success and reach
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links were clicked. Such web links and tracking pixels can also record the use of notifications and communications on a personal basis. We require this statistical recording of use for measuring success and reach in order to be able to send notifications and communications effectively and in a user-friendly manner, and on an ongoing, secure and reliable basis, based on the needs and reading habits of recipients.
10.2 Consent and objection
As a general rule, you must consent to the use of your e-mail address and your other contact details unless the use is permitted for other legal reasons. Where applicable, we may use the "double opt-in" procedure to obtain a doubly confirmed consent. In this case, you will receive a communication with instructions for the double confirmation. We may log consents obtained, including IP address and timestamp, for evidential and security reasons.
As a general rule, you may object at any time to receiving notifications and communications, such as newsletters. With such an objection, you may at the same time object to the statistical recording of use for measuring success and reach. Required notifications and communications in connection with our activities and operations remain reserved.
11. Social media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.
The general terms and conditions (GTC) and terms of use, as well as privacy policies and other provisions of the respective operators of such platforms, also apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
12. Third-party services
We use services from specialised third parties in order to be able to carry out our activities and operations on an ongoing basis in a user-friendly, secure and reliable manner. Among other things, such services enable us to embed functions and content into our website. In the case of such embedding, the services used collect, for technically unavoidable reasons, at least temporarily the IP addresses of users.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to provide the respective service.
We use in particular:
- Services from Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Data Protection and Security Principles", "More information on how Google uses personal data", Privacy Policy, "Google is committed to complying with applicable data protection laws", "Guide to privacy in Google products", "How we use data from sites or apps that use our services", Cookie Policy, "Ads you can control" (settings for personalised advertising).
12.1 Digital infrastructure
We use services from specialised third parties in order to make use of the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
- Squarespace: Website builder; Providers: Squarespace Inc. (USA) for users in the USA / Squarespace Ireland Limited (Ireland) for users in the rest of the world; Data protection information: "Data Protection and Security", Privacy Policy, Cookie Policy.
12.2 Audio and video conferences
We use specialised services for audio and video conferences in order to communicate online. This enables us, for example, to hold virtual meetings or conduct online lessons and webinars. The legal texts of the individual services, such as privacy policies and terms of use, also apply in addition for participation in audio and video conferences.
Depending on your personal circumstances, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or enabling a virtual background.
We use in particular:
- Google Meet: Video conferences; Provider: Google; Google Meet-specific information: "Google Meet – Security and privacy for users".
- TeamViewer Meeting: Video conferences; Provider: TeamViewer Germany GmbH (Germany); Data protection information: Privacy Policy, "First-class data protection".
- Zoom: Platform for collaborative work, in particular with video conferences; Provider: Zoom Video Communications Inc. (USA); Data protection information: "Privacy at Zoom", Privacy Policy, "Legal compliance".
12.3 Social media features and social media content
We use services and plugins from third parties to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and by other means.
We use in particular:
- Instagram platform: Embedding Instagram content; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy Policy (Instagram), Privacy Policy (Facebook).
12.4 Fonts
We use services from third parties to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
- Adobe Fonts: Fonts; Providers: Adobe Inc. (USA) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Data protection information: "Adobe Privacy Center", Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), "Questions about privacy?", "Adobe privacy settings", Cookie Policy.
- Font Awesome: Icons and logos; Provider: Fonticons Inc. (USA); Data protection information: Privacy Policy.
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: "Your privacy and Google Fonts", "Privacy and data collection" (Google Fonts).
12.5 Advertising
We use the option of displaying targeted advertising with third parties, such as social media platforms and search engines, for our activities and operations.
With such advertising, we aim in particular to reach people who are already interested in our activities and operations or might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We may also determine whether our advertising is successful, meaning in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and with whom you are registered as a user may be able to associate your use of our website with your profile there.
We use in particular:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: advertising based, among other things, on search queries, with various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, Privacy Policy for advertising, "Manage ads that you see directly via Ads".
- Meta ads (Meta Ads): Social media advertising on Facebook and Instagram; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: targeting, including retargeting, in particular with the Meta Pixel and with Custom Audiences including Lookalike Audiences, Privacy Policy, "Ad preferences" (registration as a user required).
13. Measuring success and reach
We try to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party notices or check how different parts or versions of our digital presence are used ("A/B testing" method). Based on the results of measuring success and reach, we can, in particular, fix errors, strengthen popular content or make improvements.
For measuring success and reach, in most cases the IP addresses of individual users are recorded. In this case, IP addresses are generally shortened ("IP masking") in order to follow the principle of data minimisation through the corresponding pseudonymisation.
When measuring success and reach, cookies may be used and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window and the – at least approximate – location. As a rule, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are logged in may be able to associate the use of our online offering with the user account or user profile with the respective service.
We use in particular:
- Google Marketing Platform: Measuring success and reach, in particular with Google Analytics; Provider: Google; Google Marketing Platform-specific information: measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only exceptionally transmitted in full to Google in the USA, Privacy Policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further data protection information can be found with the individual integrated and managed services.
14. Final notes on the privacy policy
We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.