General Information
This Privacy Notice describes how Unpaired AG, Rigistrasse 2, 6300 Zug, Switzerland –
until the incorporation of the PairedWorld Foundation – («we», «us» or «our») collects,
protects, and uses your personal data when you use our website (whereby the term
«website» also includes our w3meet App), obtain products or services from us, interact
with us in relation with a contract, communicate with us or otherwise deal with us. We
explain what we do with your personal data, for what purposes and on what legal
foundation we do so, and what rights you have on that basis. When appropriate we will
provide just-in-time notice to cover any additional processing activities not mentioned in
this Privacy Notice. In addition, we may inform you about the processing of your data
separately, for example in consent forms, terms and conditions, additional privacy
notices, forms and other notices. We use the word «data» here interchangeably with
«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; «sensitive personal data» is a subset of personal data and revealing e.g.
racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union
membership, genetic data, biometric data, health data or data concerning a natural
person's sex life or sexual orientation.
«Processing» means any operation or set of operations which is performed on personal
data or on sets of personal data, whether or not by automated means, such as collection,
recording, organisation, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure or destruction.
If you provide information to us about any person other than yourself, your employees,
counterparties, your advisers or your suppliers, you must ensure that the data is accurate
and that they understand how their information will be used, and that they have given
their permission for you to disclose it to us and for you to allow us, and our outsourced
service providers, to use it.
This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»)
and the Swiss Data Protection Act («DPA»). However, the application of these laws
depends on each individual case.
Name and Address of the Controller and the Data Protection Officer/Data
Protection Advisor
The responsible person for processing your data under this Privacy Notice («Controller»)
unless we tell you otherwise in an individual case is:
Unpaired AG
Rigistrasse 2
6300 Zug
Please note that Unpaired AG is Controller only until the incorporation of the PairedWorld
Foundation, which then will be the only responsible person for processing of your data.
https://paired.world
ak@unpaired.com
You may contact us regarding data protection matters and to exercise your rights at:
ak@unpaired.com
Categories of Data we Process
The processing of personal data is limited to data that is required to operate a functional
website and for the provision of content, products and services. The processing of
personal data of our users is based on the purposes agreed or on a legal basis. We only
collect personal data that is necessary to implement and process our tasks and services
or if you provide data voluntarily. Depending on the reason and purpose of the
processing, we process different data about you:
Technical Data
When you use our website, or other online offerings, we collect the IP address of your
terminal device and other technical data in order to ensure the functionality and security
of these offerings. This data includes logs with records of the use of our systems. We
generally keep technical data for 6 months. In order to ensure the functionality of these
offerings, we may also assign an individual code to you or your device (for example as a
cookie, see Section XV ). Technical data as such does not permit drawing conclusions
about your identity. However, technical data may be linked with other categories of data
(and potentially with your person) in relation with user accounts, registrations, access
controls or the performance of a contract.
Technical data includes
• the IP address and information about the operating system of your device
• name and URL of any visited page
• the date and time of access, GMT time difference
• information, whether the access was successful (access status/http status code)
• amount of data transferred
• websites that are accessed via our website
• website form which any access takes place (so-called referrer URL)
• the type of browser that you use to access our online offerings
• name of your internet provider
• browser type and version used, and other information provided by the browser (such as
geographical origin, language setting, add-ons used, screen resolution, etc.).
• logs that are created in our systems (e.g. the log of user logins to our website) and
possibly the number of clicks.
This may help us to provide an appropriate layout of the website or, for example, to
display a sub-page for your region. We know through which provider you access our
offerings (and therefore also the region) because of the IP address, but usually this does
not tell us who you are. However, this changes for example when you create a user
account, because personal data can then be linked with technical data (for example, we
can know the browser you use to access an account through our website).
User Account and Registration Data
Some of our services can only be used with a user account or a registration (e.g. custody
services, staking services, exchange services, competitions, newsletters, etc.). Such data
will be kept for 12 months from the date of the use of the services ceases or the user
account is closed.
When you use our services, you might have to register and to set up a user account.
Such data will be kept for 12 months from the date of the use of the services ceases or
the user account is closed.
We collect the following user account and registration data from you:
• Your wallet address
• First and last name
• Email address
• credit card information
• KYC data if you use our custody, staking, exchange services (see Master Data).
Communication Data
When you get in contact with us via contact form, e-mail, telephone, chat, or by letter or
other means of communication, we collect the data exchanged between you and us,
including your contact details and the metadata of the communication. If we record
telephone conversations, we will tell you specifically. If we have to confirm your identity,
for example in relation with a request for information, a request for press access, etc., we
collect data to identify you (for example a copy of an ID document). We generally keep
this data for 12 months from the last exchange between us. This period may be longer
where required for evidentiary purposes, to comply with legal or contractual requirements,
or for technical reasons. E-mails in personal mailboxes and written correspondence are
generally kept for at least 10 years. Chats are generally stored for 2 years.
Communication data includes
• your name and contact details
• the means, place and time of communication and usually also its contents (i.e. the
contents of e-mails, letters, chats, etc.). This data may also include information about
third parties. For identification purposes, we may also process your ID document number
or a password set by you.
Master Data
Master data is the basic data that we need, in addition to contract data (see below), for
the performance of our contractual and other business relationships or for marketing and
promotional purposes, such as name and contact details, and information about, for
example, your role and function, your bank details, your date of birth, customer history,
powers of attorney, signature authorizations and declarations of consent, as well as Know
Your Customer (KYC) data, Know Your Business (KYB) data and further data relating to
fraud prevention and the combating of money laundering and terrorist financing, export
restrictions, sanctions and embargoes. We process your master data if you are a
customer or other business contact or work for one (for example as a contact person of
the business partner), or because we wish to address you for our own purposes or for the
purposes of a contractual partner (for example as part of marketing and advertising, for
invitations to events, for vouchers, newsletters, etc.). We receive master data from you
(for example when you make use of our services provided online), from parties you work
for, or from third parties such as contractual partners, associations and address brokers,
and from public sources such as public registers or the internet (websites, social media,
etc.) or from activity that is publicly visible and/or accessible on blockchains (e.g.
Blockchain address, information regarding purchases, sales, or transfer of NFTs, which
may then be associated with other data you have provided to us). We generally keep
master data for 10 years from the last exchange between us but at least from the end of
the contract. This period may be longer if required for evidentiary purposes, to comply
with legal or contractual requirements, or for technical reasons. For contacts used only for
marketing and advertising, the period is usually much shorter, usually no more than 2
years from the last contact.
Master data is not comprehensively collected for all contact. Rather, the collection of
master data depends on the individual case and purpose of the processing. In general, it
may include:
• Your name
• Address
• e-mail address
• telephone number and other contact details
• gender
• date of birth
• nationality
• data about related persons
• websites
• social media profiles
• photos and videos
• copies of ID cards
• details of your relationship with us (e.g. customer, supplier, visitor, service provider or
service recipient, etc.)
• details of your status, allocations, classifications and mailing lists
• details of interactions with you
• reports
• official documents (e.g. excerpts from the commercial register, permits)
payment information (e.g. bank details, account number and credit card data)
declarations of consent and opt-out information
• Know Your Customer (KYC) data, Know Your Business (KYB) data and data required
with regard to the prevention of and combating of money laundering (AML) and terrorist
financing such as but not limited to transaction data, business relationships relevant for
AML purposes, declarations of beneficial ownership, etc. including further data required
for the whitelisting process.
• As regards customers, suppliers and partners, master data also includes information
about the role or function in the company, qualifications and information about superiors,
co-workers and information about interactions with these persons.
Contract Data
We collect contract data in relation with the conclusion or performance of a contract, e.g.
information about the products and the services provided or to be provided, as well as
data from the period leading up to the conclusion of a contract, information required or
used for performing a contract, and information about feedback (e.g. complaints,
feedback about satisfaction, etc.). We generally collect this data from you, from
contractual partners and from third parties involved in the performance of the contract,
but also from third-party sources (for example credit information providers) and from
public sources. We generally keep this data for 10 years from the last contract activity but
at least from the end of the contract. This period may be longer where necessary for
evidentiary purposes, to comply with legal or contractual requirements, or for technical
reasons.
Contract data includes:
• information about the conclusion of the contract, about your contracts, for example, the
type and date of conclusion and its duration
• the performance and administration of the contracts, for example information in relation
with billing, customer service, technical assistance and the enforcement of contractual
claims
• information about deficiencies, complaints and changes of a contract as well as customer
satisfaction information that we may collect for example through surveys
• financial data, such as credit information (meaning information that allows to draw
conclusions about the likelihood that receivables will be paid), information about
reminders and debt collection.
We receive this data partly from you (for example when you make payments), but also
from credit agencies and debt collection companies and from public sources (for example
a commercial register).
Behavioural and preference data
Depending on our relationship with you, we try to get to know you better and to tailor our
products, services and offers to you. For this purpose, we collect and process data about
your behavior and preferences. We do so by evaluating information about your behaviour
and we may also supplement this information with third-party information, including from
public sources. Based on this data, we can for example determine the likelihood that you
will use certain services or behave in a certain way. The data processed for this purpose
is already known to us (for example where and when you use our services), or we collect
it by recording your behaviour (for example how you navigate our website. We anonymize
or delete this data when it is no longer relevant for the purposes pursued, which may be –
depending on the nature of the data – between 2-3 weeks and 24 months (for product
and service preferences). This period may be longer as for evidentiary purposes, to
comply with legal or contractual requirements, or for technical reasons. We describe how
tracking works on our website in Sections XVI et seq.
Behavioural data includes:
• information about certain actions, such as your response to electronic communications
(for example if and when you have opened an e-mail) or your location, as well as your
interaction with our social media profiles and your participation in sweepstakes,
competitions and similar events.
For example, we may collect your location data wirelessly through unique codes that your
cell phone emits or when you use our website. We will use signage at the relevant
locations to tell you about the collection of such anonymous motion profiles, and we will
only create personalised motion profiles with your consent.
Preference data provides information on your needs, which products or services you
might be interested in. We obtain this information by analysing existing data, such as
behavioural data, so that we get to know you better and can better tailor our products and
services to you. Such data also contributes to a general improvement of our products and
services. We combine this data with other data we obtain from third parties, such as
address broker, administrative office and publicly available sources (e.g. the internet),
such as information about your household size, income bracket and purchasing power,
shopping behaviour, contact data of relatives, and anonymous information from statistical
offices.
Behavioural and preference data may be analysed on a personally identifiable basis (for
example to show you personalized advertising), but also on a non-identifiable basis (for
example for market research or product development). Behavioural and preference data
may also be combined with other data (for example, motion data may be used for contact
tracing as part of a health protection concept).
Other Data
We also collect data from you in other situations. For example, data that may relate to
you (such as files, evidence, etc.) is processed in relation with administrative or judicial
proceedings. We may also collect data for health protection (for example as part of health
protection concepts). We may obtain or create photos, videos and sound recordings in
which you may be identifiable (for example at events, with security cameras, etc.). We
may also collect data about who enters certain buildings, and when or who has access
rights (including in relation with access controls, based on registration data or lists of
visitors, etc.), who participates in events or campaigns, e.g. competitions and who uses
our infrastructure and systems and when. The retention period for this data depends on
the processing purpose and is limited to what is necessary. This ranges from one or two
days for many of the security cameras, to usually a few weeks in case of data for contact
tracing and visitor data that is usually kept for 3 months, to several years or longer for
reports about events with images.
Much of the data set out in this Section is provided to us by you, e.g. through forms, in
relation with communication with us, in relation with contracts, when you use the website,
etc. You are not obliged or required to disclose data to us except in individual cases, for
example within the framework of binding health protection concepts (legal obligations). If
you wish to enter into contracts with us or use our services, you must also provide us with
certain data, in particular master data, contract data and registration data, as part of your
contractual obligation under the relevant contract. When using our website, the
processing of technical data cannot be avoided. If you wish to gain access to certain
systems or buildings, you must also provide us with registration data. However, in the
case of behavioural and preference data, you have the option of objecting or not giving
consent.
We provide certain services to you only if you provide us with registration data, because
we or our contractual partners wish to know who uses our services or has accepted an
invitation to an event, because it is a technical requirement or because we wish to
communicate with you. If you or the person you represent (for example your employer)
wishes to enter into or perform a contract with us, we must collect master data, contract
data and communication data from you, and we process technical data if you wish to use
our website or other electronic offerings for this purpose. If you do not provide us with the
data necessary for the conclusion and performance of the contract, you should expect
that we may refuse to conclude the contract, that you may commit a breach of contract or
that we will not perform the contract. Similarly, we can only submit a response to a
request from you if we process communication data and – if you communicate with us
online – possibly also technical data. Also, the use of our website is not possible without
us receiving technical data.
As far as it is not unlawful we also collect data from public sources (for example debt
collection registers, land registers, commercial registers, the media, or the internet
including social media) or receive data from other companies within our group, from
public authorities and from other third parties (such as credit agencies, address brokers,
associations, contractual partners, internet analytics services, etc.).
The categories of personal data that we receive about you from third parties include, in
particular, information from public registers, information that we receive in relation with
administrative and legal proceedings, information in relation with your professional
functions and activities (so that we can, for example, conclude and process transactions
with your employer with your assistance), information about you in correspondence and
meetings with third parties, credit information (where we conduct business with you in a
personal capacity), information about you that persons related to you (family, advisors,
legal representatives, etc.) share with us so that we can conclude or perform contracts
with you or involving you (for example references, your delivery address, powers of
attorney, information about compliance with legal requirements such as those relating to
fraud prevention and the combating of money laundering and terrorist financing and
Know Your Customer (KYC) data, Know Your Business (KYB) data, sanctions, export
restrictions, information from banks, insurance companies, sales and other contractual
partners of us about your use or provision of services (for example payments, purchases,
etc.), information from the media and the internet about the use or provision of services
by you (for example payments made, purchases made, etc.), information from the media
and the internet about you (where appropriate in a specific case, e.g. in the context of an
application, marketing/sales, press review, etc., your address and potentially interests
and other socio-demographic data (especially for marketing and research purposes) and
data in relation with the use of third-party websites and online offerings where such use
can be linked to you.
Purposes of the Processing
We process your data for the purposes explained below. Further information is set out in
Sections XIV et seq. for online services. These purposes and their objectives represent
interests of us and potentially of third parties. You can find further information on the legal
basis of our processing in Section V.
Communication
We process your data for communication purposes, in order to communicate with you, in
particular, when you contact us in order, to respond to your queries or when you exercise
your rights. For this purpose, we use in particular communication data, master data and
registration data to enable us to communicate with you and provide our services or
respond to requests. We keep this data to document our communication with you, for
training purposes and quality assurance.
Performance of a Contract
We process your data for entering into a contract with you, perform and administer it. In
particular, we process communication data, master data, registration data and contract
data about you. This might include data about third parties, e.g. if you order products or
services for the benefit of a third party. This also includes data about potential customers,
that we receive from communication with you, on a trade fair or any other business event.
As regards the conclusion of a contact, we use this data to assess your creditworthiness
and to open up a business relationship with you. Administering and performing the
contract with your might involve third parties, such as logistic companies, advertising
service providers, banks, insurance companies or credit information providers in order to
provide our products and services to you.
Marketing and Relationship Management
We process your data for marketing and relationship management purposes. For
example, we send personalized newsletters for products and services from us and, if
applicable from selected third parties (e.g. advertising partners). Marketing and
relationship management might include contacting you via e-mail, telephone or other
channels for which we have contact information from you. We and, if applicable, selected
third parties, only display personalized content or advertising based on your usage
behaviour or send e-mails for marketing purposes (e.g. newsletter) if and to the extent
you give your consent to us if required under applicable law. You can object to such
marketing activities or withdraw your consent at any time (please see Section XII and
XIII).
As regards relationship management, we may use a customer relationship management
system («CRM») to store and process your data as described in this Privacy Notice (e.g.
about contact persons, products and services provided to you, interactions, interests,
marketing measures, newsletters, invitations to events and other information). In order to
provide you with the best products and services and to use our resources as effectively
as possible we may use the CRM together with any potential company group. If so, a list
of the subsidiaries and group companies can be found here.
Product/Service Improvement and Innovation
We process your data for market research and to improve our products and services
(including our website).
Safety or Security Reasons
We process your data to protect our IT and other infrastructure (e.g. buildings). For
example, we process data for monitoring, analysis and testing of our networks and IT
infrastructures including access controls. We might also use surveillance systems, e.g.
cameras for security purposes. In such a case, we will inform you at the relevant
locations separately.
Compliance with Law
We process your data to comply with legal requirements, e.g. health security concepts,
money laundering and terrorist financing, tax obligations etc. and we might have to
request further information from you to comply with such requirements (“Know Your
Customer”, “KYC”; “Know Your Business”, “KYB”) or as otherwise required by law and
legal authorities.
Risk Management, Corporate Governance and Business Development
We process your data as part of our risk management and corporate government in order
to protect us from criminal or abusive activity. As part of our business development, we
might sell businesses, parts of businesses or companies to others or acquire them from
others or enter into partnerships and this might result in the exchange and processing of
data based on your consent, if necessary.
Legal Basis for Processing your Data
Where we asked for your consent (e.g. for receiving newsletters and for personalized
content or advertising based on your usage behaviour or for processing sensitive data),
we process your data based on such consent. You may withdraw your consent at any
time with effect for the future by providing us written notice (e-mail sufficient), see our
contact details in Section II . If you like to withdraw your consent for online tracking,
please see Section XV . Withdrawal of your consent does not affect the lawfulness of the
processing that we have carried out prior to your withdrawal, nor does it affect the
processing of your data based on other processing grounds.
Where we did not ask for your consent, we process your data on other legal grounds,
such as:
• a contractual obligation
• a legal obligation
• a vital interest of the data subject or of another natural person
• to perform a public task
• a legitimate interest, which includes compliance with applicable law and the marketing of
our products and services, the interest in better understanding our markets and in
managing and further developing our company, including its operations, safely and
efficiently.
Profiling and Automated Decision Taking
We might analyse aspects of your individual’s personality, behaviour, interest and habits
make predictions or decisions about them for the purposes laid out in Section IV , e.g to
perform statistical analysis or to prevent misuse and security risks. This analysis identifies
correlations between different behaviours and characteristics to create profiles for
individuals. For example, we may use profiling to determine in which products or services
you might be interested. We may also use profiling to assess you creditworthiness. We
do not use profiling that can produce legal effects concerning you or similarly significantly
affect you without human review.
In certain circumstances, automated decision taking might be necessary for reasons of
efficiency and consistency. In such cases, we will inform you accordingly and take the
measures required by applicable law.
On-Chain Data
By using our blockchain-based services you acknowledge that your wallet address and
related transactions, which are considered personal data if relating to an identified or
identifiable natural person, are permanently and publicly stored on the blockchain,
publicly available to anyone, and neither we, nor any third party, has any power to delete
such data published by its users to the blockchain. If you want to ensure that your privacy
rights are not affected in any way, you should not transact on blockchains as certain
rights may not be fully available or exercisable by you or us due to the technological
infrastructure of the blockchain.
You hereby release and indemnify us of any data privacy liability associated with data that
you published to the blockchain by using our services.
Disclosure of Data to Third Parties and Social Plug-ins
In order to perform our contracts, fulfil our legal obligations, protect our legitimate interest
and the other purposes and legal grounds set out above, we may disclose your data to
third parties, in particular to the following categories of recipients:
Group companies
Please find a list of our group companies (if an) here. Group companies process the data
for the same purposes as we use it, including advertising for their own range of products
and services.
Offerings of Third Parties
Our Website may contain third-party offerings. If you click on such an offer, we will
transfer data to the respective third party to the extent necessary (e.g. the information
that you found this offer on our website or app and, if applicable, further information that
you provided for this purpose on our website or app). We have no control over, do not
review and cannot be responsible for these third-party websites or their content. Please
be aware that the terms of this Privacy Notice do not apply to these third-party websites
or their content, or to any collection of your data after you click on links to such third-party
websites. We encourage you to read the privacy policies of every website you visit. Any
links to third-party websites or locations are for your convenience and do not signify our
endorsement of such third parties or their products, content, or websites.
Third-Party Wallets
To use our services, you may use a third-party wallet which allows you to engage in
transactions on public blockchains. Your interactions with any third-party wallet provider
are governed by the applicable terms of service and privacy policy of that third party.
Service Providers
We may share your information with service providers and business partners around the
world with whom we collaborate to fulfil the above purposes (e.g. IT provider, shipping
companies, advertising service provider, security companies, banks, insurance
companies, telecommunication companies, credit information agencies, address
verification provider, lawyers) or who we engage to process personal data for any of the
purposes listed above on our behalf and in accordance with our instructions only.
Contractual Partners Including Customers
In case required under the respective contract we share your data with other contractual
partners. If we sell or buy any business or assets, we may disclose your data to the
prospective seller or buyer of such business or assets to whom we assign or novate any
of our rights and obligations.
Legal Authorities
If legally obliged or entitled to make disclosures or if it appears necessary to protect our
interests, we may disclose your data to courts, law enforcement authorities, regulators,
government officials or other legal authorities in Switzerland or abroad, e.g. in criminal
investigations and legal proceedings including alternative dispute resolution as well as to
prevent and combat money laundering and terrorist financing (e.g. duties in the event of a
suspicion of money laundering, duty to report to Money Laundering Reporting Offices
Switzerland or abroad) or due to further reporting duties.
Social Plug-ins
We do not use social media plug-ins on our website. If our website contains icons of
social media providers (e.g. [name of social media providers with icons of company’s
website], we use these only for as passive links to the websites of the respective social
media platforms.
Integration of Google Maps
We use Google Maps on our website. Google Maps allows us to display its interactive
maps directly on our website for your convenient use of the Google Maps functions. Legal
basis for the use of Google Maps is your consent, that means, any transfer of data only
takes place after your consent. Once you provided your consent, Google receives the
information that you accessed our website. Furthermore, the above-mentioned technical
data such as IP address and timestamp are transmitted. This occurs, regardless of
whether Google provided a user account through which you are logged in or whether no
user account exists. If you are logging in to Google, your data will be directly assigned to
your account. If you do not want an assignment to your profile at Google, you must log
out before providing consent to use Google Maps. Google stores your data as usage
profiles and uses them for the purposes of advertising, market research and/or demand-
orientated design of its website. Such evaluation is carried out in particular (even for
users who are not logged in) to provide targeted advertising and to inform other user of
the social network about your activities on our website. You have the right to object to the
creation of these user profiles. Please contact Google to exercise this right.
The information collected is stored on Google servers, also in the US, which is
considered not to provide adequate data protection from a Swiss/EU perspective.
Therefore, we have agreed to so-called standard data protection clauses (SCCs) with
Google, in order to ensure compliance with an appropriate level of data protection in third
countries.
For more information on the purpose and scope of data collection and its processing by
Google, please review Google’s privacy notice. It will provide further information about
your rights and the setting options for protecting your privacy:
www.google.de/intl/de/policies/privacy.
Transfer of Data Abroad
As we have explained in Section VIII, we disclose data to other parties, not all of them
located in Switzerland. Your data may be processed in the European Economic Area
(EEA) and in exceptional circumstances also in countries outside the EEA and around the
world, which includes countries that do not provide the same level of data protection as
Switzerland or the EEA and are not recognized as providing an adequate level of data
protection. We only transfer data to these countries when it is necessary for the
performance of a contract or for the exercise or defence of legal claims, or if such transfer
is based on your explicit consent or subject to safeguards that assure the protection of
your data, such as the European Commission approved standard contractual clauses.
How Long We Keep your Personal Data
We only process your data for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of complying with legal retention requirements and where
required to assert or defend against legal claims, until the end of the relevant retention
period or until the claims in question have been settled. Upon expiry of the applicable
retention period we will securely destroy your data in accordance with applicable laws
and regulations.
Security of your Personal Data
We take appropriate organisational and technical security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed.
However, we and your personal data can still become victims of cyber-attacks,
cybercrime, brute force, hacker attacks and further fraudulent and malicious activity
including but not limited to viruses, forgeries, malfunctions and interruptions which is out
of our control and responsibility.
We have also put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are legally required
to do so.
Your Rights
You have various rights in relation with our processing of your personal data, depending
on the applicable data protection law:
Right of Access
You have the right to request a copy of the personal data that we hold about you. There
are exceptions to this right, so that access may be denied if, for example, making the
information available to you would reveal personal data about another person, or if we
are legally prevented from disclosing such information.
Right to Rectification
We aim to keep your personal data accurate, current, and complete. We encourage you
to contact us to let us know if any of your personal data is not accurate or changes, so
that we can keep your personal data up to date.
Right to Erasure
You have the right to require us to erase your personal data when the personal data is no
longer necessary for the purposes for which it was collected, or when, among other
things, your personal data have been unlawfully processed.
Right to Restriction
You have the right to ask us to restrict the processing of your personal information in
certain circumstances.
Right to Data Portability
You have the right to ask that we transfer the personal information you gave us to another
controller or to you, in certain circumstances.
Right to Withdraw Consent
Where we process data based on your consent, you have the right to withdraw your
consent. Once we have received notification that you have withdrawn your consent, we
will no longer process your information for the purpose(s) to which you originally
consented unless there is another legal ground for the processing.
Complaints
If you believe that your data protection rights might have been breached, please let us
know our contact the applicable supervisory authority. The Federal Data Protection and
Information Commissioner is the competent data protection authority in Switzerland. The
contact details are available here: www.edoeb.admin.ch.
If you are residing in the European Union, you also have the right to complain to your
local data protection supervisory authority. You can find some contact details of the
respective authorities of the Member States of the European Union here:
https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Right to Object
Under applicable data protection law you have the right to object at any time to the
processing of personal data pertaining to you under certain circumstances, in particular
where your data is processed in the public interest, on the basis of a balance of interests
or for direct marketing purposes.
If you like to exercise the above-mentioned rights, please contact us at our contact
details provided above unless otherwise specified or agreed. Please note that we need to
identify you to prevent misuse, e.g. by means of a copy of your ID card or passport,
unless identification is possible otherwise.
Newsletter
If you subscribe to one of our newsletters offered, you may cancel the subscription at any
time by using the option to unsubscribe contained in the newsletter.
Cookies
We use cookies on our website and may allow certain third parties to do so as well.
Cookies are small files that your browser automatically creates and that are stored on
your device (laptop, tablet, smartphone, etc.) when you visit our website.
However, depending on the purpose of these cookies, we may ask for your express prior
consent before they are used. You can access your current settings by clicking on the
«Change Your Cookies» - button below and/or at our website and you can withdraw your
consent under the same link at any time. You can also set your browser to block or
deceive certain types of cookies or alternative technologies, or to delete existing cookies.
You can also add software to your browser that blocks certain third-party tracking. You
can find more information on the help pages of your browser (usually with the keyword
«Privacy») or on the websites of the third parties set out in our Consent Management
Tool.
Necessary Cookies
Necessary cookies are necessary for the functioning of the website or for certain
features. They make the use of our website more pleasant for you. For example, they
help make a website usable by enabling basic functions such as page navigation and
access to secure areas of the website. They also ensure that you can move between
pages without losing information that was entered in a form and that you stay logged in.
These cookies exist temporarily only («session cookies»). The session cookies are
automatically deleted after leaving our pages. If you block them, the website may not
work properly. Other cookies are necessary for the server to store options or information
(which you have entered) beyond a session (i.e. a visit to the website) if you use this
function (for example language settings, consents, automatic login functionality, etc.).
These cookies have an expiration date of up to 12 months. The legal basis for such cookies
is our legitimate interest according to provide you with all functions of our website. A list
of necessary cookies is provided in our Consent Management Tool.
Performance Cookies
In order to optimize our website and related offers and to better adapt them to the needs of
the users, we use cookies to record and analyse the use of our website, potentially
beyond one session. We use third-party analytics services for this purpose that are
listed below (see Section XVI «Monitoring Tools»). For example, we analyse which page
a user accesses most often and whether error messages are displayed. These cookies
do not store any information beyond this. They are used exclusively to increase user-
friendliness and to tailor websites more specifically to the user. Before we use such
cookies, we ask for your express prior consent. You can withdraw consent at any time
through the cookie settings. Performance cookies also have an expiration date of up to
12 months. Details can be found on the websites of the third-party providers specified in
our Consent Management Tool.
Marketing Cookies
We and our advertising partners have an interest in targeting advertising as precisely as
possible, i.e. only showing it to those we wish to address. For this purpose, we and our
advertising partners – if you consent – use cookies that can record the content that has
been accessed or the contracts that have been concluded. This allows us to optimize our
content (see Section XVI «Monitoring Tools») and it allows us and our advertising
partners to display advertisements that we think will interest you on our website, but
also on other websites that display advertisements from us or our advertising partners
(see Section XVII «Tracking Tools»). If you consent to the use of these cookies, you will
be shown related advertisements. If you do not consent to them, you will not see
less advertisements, but simply any other advertisement. You can withdraw consent at
any time through the cookie settings. Marketing cookies have an expiration period of a few
days to 12 months, depending on the circumstances. Details can be found on the
websites of the third-party providers specified in our Consent Management Tool.
You can change your cookie settings at any time under the link provided below:
Change Cookie Settings
Tracking Tools
Based on your consent we use tracking tools to ensure a tailored design and the
continuous optimisation of our website. We also use the following tracking tools to
statistically record the use of our website and evaluate it for the purpose of optimising the
content we show you:
Google Analytics:
Google Ireland (based in Ireland) is our provider of “Google Analytics” and acts as our
processor. Google Ireland relies on Google LLLC (based the USA) as a processor for its
services (both “Google”). Google uses performance cookies (see above) to track the
behaviour of visitors to our website (duration, frequency of pages viewed, geographic
origin of access, etc.) and compiles reports for us on the use of our website on this basis.
We have configured the service so that the IP addresses of visitors are shortened by
Google in Europe before being forwarded to the US and thus cannot be traced. We have
turned off the "Data Forwarding" and "Signals" settings. Although we can assume that the
information we share with Google is not personal data for Google, it is possible that
Google can draw conclusions about the identity of visitors from this data for its own
purposes, create personal profiles and link this data to the Google accounts of these
persons. If you consent to the use of Google Analytics, you explicitly agree to such
processing, which also includes the transfer of personal data (in particular usage data for
the website and app, device information and individual IDs) to the US and other countries
not offering adequate data protection from a Swiss/EU perspective. Information on the
data protection of Google Analytics can be found
here and if you have a Google account,
you can find further details on processing by Google
here.
Updating and changing this Privacy Notice
Due to continuous development of our website and the contents thereof, changes in law
or regulatory requirements, we might need to change this privacy notice from time to
time. Our current privacy notice can be found at our website.
