Privacy regulations

Emil Frey Classics AG (hereinafter also referred to as “we” or “us”) collects and processes personal data relating to you or other persons (known as “third parties”). We use the term “data” here as synonymous with “personal data” or “personal information”.

“Personal data” refers to data relating to identified or identifiable persons, i.e. data that can be used to identify individuals either on its own or in combination with other data. “Processing” is used synonymously with “handling” and refers to any handling of personal data, e.g. collection, storage, use, modification, disclosure and deletion.

In this privacy policy, we describe what we do with your data when you use our websites www.emilfreyclassics.ch, www.classicauctions.ch or other online offerings operated by us (hereinafter collectively referred to as “website”), purchase our services or products, are otherwise connected with us within the scope of a contract, communicate with us or otherwise have dealings with us. Where applicable, we will inform you in good time in writing about any additional processing activities not mentioned in this privacy policy. In addition, we may inform you separately about the processing of your data, e.g. in declarations of consent, contractual terms and conditions, additional privacy policies, forms and notices.

If you provide or disclose data about other persons, such as family members, work colleagues, etc., we assume that you are authorised to do so and that this data is correct. By providing data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

This privacy policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR“) and the Swiss Data Protection Act ( “DSG” ). However, whether and to what extent these laws apply depends on the individual case.

In this privacy policy, we inform you about the most important aspects of data processing in our company and about your data protection rights. The privacy policy describes how we collect and process your data when you visit our website or use our services.

Please note that we are in no way legally responsible for the content of the links provided and do not accept any liability for them. Data processing on the linked websites is governed by the data protection regulations of the respective operators of these websites.

The most important points of our privacy policy in brief

1 – Who is responsible for data processing?

The following is responsible for processing your data:

Emil Frey Classics AG

Bahnhofplatz 2

⁠5745 Safenwil⁠ (Switzerland) ⁠⁠

Telephone: +41 (0)62 788 79 20

Email: info@emilfreyclassics.ch

2 – What data do we collect?

Inventory data (e.g. personal master data, names and addresses)
Contact data (e.g. e-mail, telephone numbers)
Content data (e.g. text entries, number entries, photographs, videos)
Usage data (e.g. websites visited, interest in content, access times)
Meta/communication data (e.g. device information, IP addresses)
Payment data (e.g. bank details, payment history, etc.)
Vehicle data (e.g. car registration number)

You provide us with much of the data mentioned yourself (e.g. via forms, in communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. in the context of binding protection concepts (legal obligations). If you wish to conclude contracts with us or make use of our services, you must also provide us with data as part of your contractual obligation under the relevant contract, in particular master data, contract data and registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data. However, you generally have the option to object or withhold your consent with regard to behavioural and preference data.

We only provide certain services to you if you provide us with registration data because we or our contractual partners want to know who is using our services or has accepted an invitation to an event, because it is technically necessary, or because we want to communicate with you. If you or a person representing you (e.g. your employer) wishes to conclude or fulfil a contract with us, we must collect the relevant master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic services for this purpose. If you do not provide us with the data required for the conclusion and execution of the contract, you must expect that we will refuse to conclude the contract, that you will be in breach of contract or that we will not fulfil the contract. Similarly, we can only send you a response to an enquiry if we process the relevant communication data and, if you communicate with us online, any technical data. It is also not possible to use our website without us receiving technical data.

To the extent that this is not inadmissible, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the internet, including social media) or receive data from other companies within our group, from authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analysis 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 learn in connection with official and court proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (insofar as we conduct business with you personally), information about you provided to us by people in your circle (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or involving you (e.g. references, your delivery address, powers of attorney), Information on compliance with legal requirements such as anti-fraud, anti-money laundering and anti-terrorism measures and export restrictions, Information from banks, insurance companies and our distribution and other contractual partners on your use of or provision of services (e.g. payments, purchases, etc.), Information about you from the media and the internet (where appropriate in specific cases, e.g. in the context of a job application, marketing/sales, press review, etc.), your address and, where applicable, interests and other socio-demographic data (especially for marketing and research) and data in connection with the use of third-party websites and online offers where this use can be attributed to you.

3 – Who is affected by our data processing?

Users and visitors to online services, customers at our facilities in Safenwil and Zurich, and service and product purchasers (hereinafter referred to as “users”).

4 – For what purposes do we process your data?

Display and optimisation of website content
At your request, to establish contact and/or provide regular information about our activities and offers (newsletter)
Presentation, provision and delivery of products and services
Establishment, management and processing of contractual relationships
Marketing purposes and relationship management
Applications
Provision of contractual services
Organisation of competitions
Web analysis and remarketing
Needs analysis for direct customer contact and customer acquisition
Analysis of calls
Training and quality assurance purposes
Market and opinion research
Operational and product development

Security purposes, access control and video surveillance to protect infrastructure and affected persons
Risk management and corporate governance

Litigation, arbitration, investigations and other proceedings/legal requirements.

5 – Who do we share your data with?

If we disclose, transfer or otherwise grant access to data to other companies, this is done in particular on the basis of your interests (e.g. processing our business relationship with you), our legitimate interests and for administrative simplification.

We may disclose your data to the following categories of recipients:

Group companies
Business partners and distributors, manufacturers and importers
IT service providers
Credit rating companies
Logistics partners
Subcontractors
Service providers
Market research companies
Domestic and foreign authorities, government agencies or courts

If we use processors to provide our services, we take the necessary technical and organisational measures to protect your privacy in accordance with the relevant applicable data protection regulations.

If you would like more information on this, please feel free to contact us using the details provided in section 1.

6 – Is your personal data also transferred abroad?

As explained in the previous section, we also disclose data to other parties. These are not only located in Switzerland. In particular, you must expect your data to be transferred to all countries in which the Emil Frey Group is represented by group companies, branches or other offices, as well as to other countries worldwide where the service providers we use are located.

If a recipient is located in a country without adequate legal data protection, we contractually oblige the recipient to comply with the applicable data protection regulations (for this purpose, we use the revised standard contractual clauses of the European Commission, available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? ), unless they are already subject to a legally recognised set of rules for ensuring data protection and we cannot rely on an exception. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires such disclosure, if you have given your consent or if the data is data that you have made generally accessible and you have not objected to its processing.

Many countries outside Switzerland, the EU and the EEA do not currently have laws that guarantee an adequate level of data protection from the perspective of the DSG or the GDPR. The contractual arrangements mentioned above can partially compensate for this weaker or lack of legal protection. However, contractual arrangements cannot eliminate all risks (namely from government access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymisation or anonymisation) to minimise it.

Please also note that data exchanged via the internet is often routed through third countries. Your data may therefore be transferred abroad even if the sender and recipient are located in the same country.

Our privacy policy in detail

1 – Collection, processing and use of your data in detail

Which data do we collect in which processes/requests/activities?

1.1 – Visiting our website / server log files

When you visit our websites https://www.emilfreyclassics.ch or https://www.classicauctions.ch (hereinafter referred to as “the website”), our servers temporarily store the following information in a log file, known as a server log file:

IP address of the requesting computer
Date and time of access/retrieval
Name and URL of the data retrieved
Operating system of your computer and the browser you are using
Country from which our website is accessed
Name of your internet service provider
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred
Last visited website
Browser settings
Language and version of browser software
Activated browser plug-ins

We process data on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR. Our legitimate interest lies in enabling the use of our website (connection establishment), ensuring long-term system security and stability, optimising our offering and for internal statistical purposes. No other evaluation takes place.

We process your data for as long as required for our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or as long as storage is necessary for technical reasons. Unless there are any legal or contractual obligations to the contrary, we delete or anonymise your data after the storage or processing period has expired as part of our usual procedures. In the case of the collection of your data for the provision of the website, this is the case when the respective session has ended.

1.2 – Newsletter

You have the option of subscribing to newsletters on our website. This allows us to inform you about us and our offers.

If you subscribe to the newsletter, the fields marked with * are mandatory:

Title*
Surname and first name*
Email address*

The mandatory information is required in order to send you the newsletters and to be able to address you personally.

The sending of the newsletter and the associated performance measurement are based on your consent within the meaning of Art. 6 para. 1 lit. a GDPR.

We use the double opt-in procedure for registration for our newsletter. This means that after registering, you will receive an e-mail in which you must click on a link to confirm your registration. This confirmation e-mail serves to verify that you, as the owner of the e-mail address, have authorised the receipt of the newsletter.

In addition, we store your IP address and the time of registration and confirmation. The purpose of this procedure is to verify your registration and, if necessary, to investigate any possible misuse of your personal data.

You can unsubscribe from the newsletter at any time and revoke your consent. To do so, click on the corresponding button (link) in the newsletter you have received. You will find this unsubscribe link at the end of each newsletter. Please send us your objection by email to: info@emilfreyclassics.ch

We use the Campaign Monitor service from Campaign Monitor Pty Ltd, 404 / 3-5, Stapleton Avenue, Sutherland NSW 2232, Sydney, Australia, which belongs to the Marigold Group, to send our newsletter. If you agree to receive a newsletter, you consent to your personal data being transferred to the United States or another country without adequate data protection.

Please refer to section 4.1 for further information on other data processing in this context, which we or Campaign Monitor may also carry out on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR.

We process your data for as long as required for our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or as long as storage is technically necessary. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our usual procedures. Your registration data will therefore be stored until you unsubscribe from the newsletter or revoke your consent or object.

1.3 – Contact

When you contact us (e.g. via contact form, email, live chat, telephone or social media), the following contact details and the information you provide will be processed for the purpose of handling your enquiry and processing your request:

Title
First name
Surname

Address

Postcode
Town
Email address
Telephone
Your enquiry

The basis for processing contact enquiries is generally our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your enquiry. Our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your request is to communicate with you quickly and respond to your enquiries. If the processing is carried out for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract, this is the basis for processing within the meaning of Art. 6(1)(b) GDPR.

You may object to this data processing at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

We process your data for as long as required for our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or as long as storage is necessary for technical reasons. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our usual procedures. Your data will generally be deleted as soon as your request has been dealt with. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified.

1.4 – Appointment scheduling

When you make an appointment with us (e.g. via online form, email or telephone), the information you provide will be processed for the purpose of processing your appointment request and handling the agreed appointment.

When you contact us, we collect the following information for the purpose of processing your enquiry and handling your request:

Appointment:

Date
Time

Vehicle details:

Make
Model
Registration number
Mileage
Date of registration
Replacement vehicle: (Yes/No)

Your details:

Title
First name
Surname
Street
Postcode
Town
Email
Telephone
Message

The basis for processing appointment requests is our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your request. Our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your request is to arrange an appointment with you quickly. If the processing is carried out for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract, this is the basis for processing within the meaning of Art. 6(1)(b) GDPR.

You can object to this data processing at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

1.5 – Profiling and automated decision-making

We process your personal data automatically with the aim of evaluating certain personal aspects (profiling). This is done on the basis of Art. 6 (2) (f) GDPR. Our legitimate interest in the use of profiling lies in particular in being able to provide you with targeted information and advice about our products and services. We use evaluation tools that enable us to communicate and advertise in line with your needs, including market and opinion research. You can object to this data processing at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

We do not use automated decision-making for the establishment and execution of the business relationship or for any other purpose. If we use such procedures in individual cases, we will inform you separately and explain your rights in this regard, provided that this is required by law.

1.6 – Online auction

To participate in our online auctions, you must create a personal customer account on our online platform. The following information marked with * is mandatory and will be collected during registration and use. The other information is voluntary:

First name*
Surname
Address
Contact details (e-mail, telephone number)*
Copy of identification (ID card, passport, driver’s licence) to verify your identity
Payment information (via Stripe, PayPal or other payment providers integrated into Shopify)
Password* (when opening a customer account)
Bidding behaviour and bid data
Communication content (e.g. messages to and from us)

We require this data to enable you to participate in auctions, to ensure that the process runs smoothly and to process purchases.

Our online auction platform is operated via the services of Shopify International Ltd., Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland.

Shopify processes your personal data on our behalf and may transfer it to affiliated companies and servers in Canada and the USA in the course of its use. Shopify undertakes to comply with appropriate protective measures in accordance with the GDPR and Swiss data protection law.

Further information can be found in Shopify’s privacy policy: https://www.shopify.com/legal/privacy

You can delete your customer account yourself at any time in your account settings or request deletion from us as the responsible body. You can object to this data processing at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

1.7 – Marketing

As part of our marketing activities, we also use your data on the basis of our legitimate interest within the meaning of Art. 6 (1) lit. f GDPR for the following purposes:

to maintain the user relationship with you;
to make your shopping experience customer-friendly and personalised;
to communicate with you about your orders and about specific products or marketing campaigns; and
to recommend products or services that may be of interest to you.

The data you provide in your customer account may be used for the above-mentioned marketing activities. The data you provide in your customer account may be combined with other data you have provided (e.g. competitions, surveys, etc.). You will be notified when your personal data is collected.

The data may be passed on to the respective importer or manufacturer of your vehicle, our group companies and external service providers (e.g. marketing agencies) for the marketing purposes listed above.

If you do not wish this to happen, you can object at any time to the processing of your data for direct marketing purposes, including profiling in connection with such direct marketing. If you object, we will no longer process your data for this purpose. Please send us your objection by email to: info@emilfreyclassics.ch.

1.8 – Competitions

If you participate in competitions, we collect the data necessary to run the competition. This is usually your name and contact details. We may pass on your data to our competition partners, e.g. to send you your prize.

Your data is processed for the purpose of conducting the competition, fulfilling legal obligations and safeguarding our legitimate interests in connection with the competitions and prizes, and may also be used for marketing activities. However, data processing and data transfer may vary depending on the competition and is therefore described in detail in the respective terms and conditions of participation. Participation in the competition and the associated data collection is, of course, voluntary.

Your data is processed for the purpose of conducting the competition and fulfilling legal obligations within the meaning of Art. 6 (1) (c) GDPR. In addition, processing may take place to protect our legitimate interests within the meaning of Art. 6 (1) (f) GDPR in connection with the competitions and prizes. Such a legitimate interest may be, for example, the orderly transfer of the prize. If you have given us your consent to process your data, we will process your data for the purpose specified in the declaration of consent (Art. 6 (1) (a) GDPR). You can revoke your consent at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

Your data will be deleted after the competition has ended, unless it has been collected for other purposes.

1.9 – Downloads

We do not require any data to be provided for downloads.

1.10 – Applications

If you apply for a position with us, the data you provide during the application process will be processed to determine whether we wish to establish an employment relationship with you. Processing may also be carried out electronically. This is particularly the case if you, as an applicant, submit the relevant application documents to us electronically, for example via an online form on our website.

The information marked with an * is generally mandatory and is collected through the use of the online form:

Title*
First name*
Surname
Street, house number*
Postcode, town*
Country
Email address*
Telephone
Information about education and professional experience*
Desired salary*
Earliest start date*
Application documents (cover letter, CV, references, certificates, proof of qualifications, etc.)*

The applicant data marked as mandatory fields is required in order to contact you regarding your application and to assess the prospects of success of your application.

This data will be stored, evaluated and processed exclusively in connection with your application and may be forwarded to the relevant group companies for this purpose. It may also be processed for statistical purposes (e.g. reporting). In this case, no conclusions can be drawn about individual persons.

In the area of online applications, we work with our partner Rexx Systems GmbH, Süderstrasse 75-79, 20097 Hamburg, Germany (Rexx). Rexx may therefore have access to your data if this is necessary for the provision of the software and for support in using the software.

The basis for the processing of application data is the implementation of so-called pre-contractual measures within the meaning of Art. 6 (1) (b) GDPR in order to assess your suitability for the advertised position and our interest in entering into an employment relationship with you as part of the application process.

If you are hired, the data you provide will be stored for the purpose of processing the employment relationship in accordance with the statutory provisions. If the application process ends without employment, your data will be anonymised six months after the rejection so that no conclusions can be drawn about individual persons. At the same time, the documents you sent us will be deleted. After a further twelve months, the anonymised data will also be deleted. Your data will only be stored in an applicant pool if you expressly give us your consent to do so. In this case, processing will be based on your consent within the meaning of Art. 6 (1) (a) GDPR.

Notwithstanding the above, you have the right to object to data processing at any time and to have your electronic data deleted; this may mean that we are unable to consider your application if we no longer have the information required for a corresponding review. Please send us your objection by email to:info@emilfreyclassics.ch .

1.11 – Vehicle valuation

We process your data so that we can evaluate a vehicle upon request and arrange an appointment with you for a vehicle evaluation.

When you contact us, we collect the following information for the purpose of processing your enquiry and handling it: Appointment (if an appointment is desired):

Date
Time
Preferred garage

Vehicle details:

Chassis number
Date of registration
Mileage

Your details:

Title
First
Surname
Email
Telephone
Vehicle registration

The basis for processing the vehicle valuation is our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your enquiry. Our legitimate interest within the meaning of Art. 6(1)(f) GDPR in processing your data is to carry out a vehicle valuation with you in a quick and efficient manner. If we process your data for the purpose of fulfilling a contract to which you are a party or for the purpose of implementing pre-contractual measures, this is the basis for processing in accordance with Art. 6(1)(b) GDPR.

You can object to this data processing at any time. Please send us your objection by email to: info@emilfreyclassics.ch.

1.12 – Provision of contractual services

If we process personal data in connection with the provision of contractual services, this is done to the extent necessary to fulfil our contractual and pre-contractual obligations within the meaning of Art. 6 (1) (b) GDPR and to perform other services requested by you (e.g. repair order or an order for a tyre change). In this context, your data may be used to ask you about your satisfaction with the contractually provided service. In addition, your data may be used for marketing purposes; if this is the case, we use your data on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR (see section 1.9 above).

The data processed in this context, the type, scope and purpose of the respective processing required are therefore determined by the contract agreed with you or the service requested by you.

The data processed includes, in particular, master data (e.g. name, address, etc.), contact details (e.g. email address, telephone number, etc.), contract data (e.g. services used, subject matter of the contract, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history, etc.).

2 – Cookies

Our website uses cookies and technically similar solutions. These are text files that are stored on your device. Cookies and technically similar solutions serve to make our website more user-friendly, effective and secure, and to make your visit to our website as pleasant as possible. They also serve to analyse the use of our website.

Temporary cookies

We use temporary cookies. These are automatically deleted when you log out. These include, in particular, session cookies. These store a so-called session, which can be used to assign various requests from your browser to the web session. This allows your computer to be recognised when you return to the website.

Permanent/persistent cookies

In addition, we use persistent cookies that remain on your computer beyond the respective usage process. When you visit our website again, it will automatically recognise that you have already been here and which entries and settings you prefer. Thanks to this information, it is possible, for example, to display information on the page that is specifically tailored to your interests.

Non-personal cookies

Non-personal cookies do not transmit any data to us. These include, for example, statistics cookies. They help us to understand how visitors interact with the website by collecting and reporting information anonymously.

Preference cookies

Preference cookies enable a website to remember information that affects the way a website behaves or looks, such as your preferred language or the region you are in.

Security cookies

We use security cookies to identify and prevent security risks. For example, we may use these cookies to store information about your web session.

Performance cookies

We use performance cookies to collect information about how you use our services. This helps us to improve our services. For example, we may use these cookies to determine whether you have visited a particular page.

Third-party cookies

We also use the functions of some web analysis services to help us make our website and internet offering more interesting for you. Therefore, when you visit our website, cookies from partner companies are also stored on your hard drive. For more information on the use of third-party cookies, please refer to sections 3 “Analysis tools” and 5 “Other services”.

With regard to the use of cookies, we rely on your consent, unless required by law, unless they are technically necessary cookies. This applies to all cookies that are set when using a service offered or integrated by us on the website.

You can revoke your consent at any time. You can express your objection via your browser settings, e.g. by deactivating the use of cookies. However, this may also restrict the functionality of our online offering.

3 – Analysis tools

On our website and in our apps, we use various services for website analysis and tracking, which we explain in more detail below. If we ask for your consent to the use of third-party providers, the legal basis for this form of data processing is consent. If we do not obtain your consent, your data will be processed on the basis of our legitimate interests, i.e. our interest in providing efficient, economical and recipient-friendly services.

We base the use of the tools on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR, to use the service of the respective service to the extent selected for our purposes.

3.1 – Google analysis tools

We use the following Google analysis tools on our website. For Google services, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google Ireland”) is our contractual partner and our order processor when we use Google services.

We therefore do not have a direct contractual relationship with Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google USA”), although Google USA may act as a processor for Google Ireland.

Google Analytics with Google Tag Manager

Google Analytics allows us to analyse activity on our websites across devices and may use permanent performance cookies for this purpose in order to evaluate the use of our website , compile reports on website activity and provide us with other services relating to website and internet usage. The ability to evaluate the use of our website with the help of Google Analytics corresponds to our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data and is anonymised or truncated before transmission. We also deactivate functionalities that could extend the transmission of data to and use by Google, e.g. “Signals” and “data sharing”.

Information that we share with Google may not be considered personal data by Google, even though it is considered as such under the GDPR or the DSG. It is possible that Google may use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these individuals, especially if you are registered with Google yourself (e.g. through a user account). Your personal data will then be processed in accordance with Google’s own privacy policy. However, we do not receive this information and Google only tells us how our respective website is used (no information about you personally).

Conversion tracking for AdWords

The Google marketing services we use include the online advertising programme Google Ads (formerly Google AdWords). In the case of Google Ads, each Ads customer receives a conversion cookie. Cookies cannot therefore be tracked via the websites of Ads customers. The information collected with the help of the cookie is used to create conversion statistics for us; we do this on the basis of our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. However, we only learn the total number of users who clicked on our ads and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that can be used to personally identify you. For more information about Google Ads, please visit https://ads.google.com/intl/de_ch/home/.

Google Marketing Platform

Another Google marketing service we use is Google Marketing Platform (formerly Google DoubleClick). Google Marketing Platform uses cookies that enable Google and its partner websites to display advertisements based on your visits to our website or other websites on the Internet; This is in our legitimate interest within the meaning of Art. 6 (1) (f) GDPR in order to present you with advertisements that meet your needs. If you do not wish this, you can prevent the placement of advertisements by using an ad blocker. For more information about Google Marketing Platform, please visit https://marketingplatform.google.com/about/enterprise/.

Google Looker Studio

We also use Google Looker Studio. Google Looker Studio enables the summarisation and visualisation of different data in conjunction with other Google services or via external data sources. This service is used in particular for statistical evaluations, forecasts and as a basis for strategic decisions, which corresponds to our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR. All data processed by us with Google Looker Studio is purely statistical in nature. No data is processed, nor is anonymised or pseudonymised data merged with other data.

3.2 – Facebook Pixel, Custom Audiences and Facebook Conversion

We use the so-called “Facebook Pixel” from Meta Platforms Inc., 1601 Willow Avenue, Menlo Park, CA 94025, USA, whereby, according to information from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta Ireland”), Meta Ireland is our direct contractual partner and Meta Platforms Inc., based in the USA, acts as its subcontractor, with which Meta has concluded the standard contractual clauses, Module 3 (Processor-Processor), according to its own information. We use the pixel based on your consent within the meaning of Art. 6 para. 1 lit. a GDPR.

With the help of the Facebook pixel, Facebook is able to identify visitors to our online offerings as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to Facebook users who have also shown an interest in our online offerings or who have certain characteristics (e.g. interests in certain topics or products, which are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and do not appear intrusive. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

Furthermore, when using Facebook pixels, we use the additional “advanced matching” function (which transmits data such as telephone numbers, email addresses or Facebook IDs of users) to create target groups (“custom audiences” or “lookalike audiences”) on Facebook (encrypted). Further information on “extended matching”: https://de-de.facebook.com/business/help/611774685654668.

We also use the “Custom Audiences from File” process. Here, the email addresses of newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload serves solely to determine the recipients of our Facebook ads. We want to ensure that the ads are only shown to users who are interested in our information and services.

Data processing by Facebook is carried out in accordance with Facebook’s data policy. Accordingly, you will find general information on the display of Facebook ads in Facebook’s data policy: https://www.facebook.com/policy.php.

You can object to the collection of data by the Facebook pixel and the use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. To do this, you must be logged in to Facebook.

3.3 – Hotjar

We use Hotjar, a web analytics service provided by Hotjar Ltd. Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta.

Hotjar helps us to better understand the needs of our users and to optimise the content of our website. Hotjar’s technology allows us to track movements on the website (so-called “heat maps”). Hotjar provides us with information about where the mouse is moving, which buttons are being clicked, where users are scrolling, how large the screen of the device being used is, what type of device is being used, and information about the browser type. We also receive information about your location (country only) and your preferred language for displaying our website. This information allows us to make our website even faster and more customer-friendly. Hotjar stores this information in a pseudonymised user profile. The information is not used by Hotjar or by us to identify individual users or to merge it with other data about individual users. Areas of the website where data from you or third parties is displayed are automatically hidden by Hotjar and are therefore not traceable by the tool at any time. The above analysis is carried out for optimisation and marketing purposes as well as for the interest-based design of our website and is therefore based on our legitimate interests in accordance with Art. 6(1)(f) GDPR.

You can object to data processing at any time. Hotjar offers every user the option of using a “Do Not Track Header” to prevent the use of the Hotjar tool, so that no data about the visit to the respective website is recorded. The opt-out option can be found at: https://www.hotjar.com/legal/compliance/opt-out.

3.4 – Fusedeck

We use Fusedeck, a web analysis service provided by Capture Media AG, Löwenstrasse 3, 8001 Zurich, Switzerland, for statistical evaluation of our online offering. To this end, the use of this website is measured in the context of engagements and events.

Fusedeck does not use cookies for this purpose and does not link data across websites. A user ID is generated to evaluate user behaviour. The analysis is therefore anonymous, meaning that no connection can be made to specific or identifiable persons. This information is used, among other things, to compile reports on website activity and analyse user behaviour. We use Fusedeck on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR, which lie in the interest-based design of our website.

The specific storage period for the processed data is not determined by us, but by Capture Media AG. Further information on this and on data protection in general and your rights in connection with Fusedeck, including the option to opt out (object), can be found in Fusedeck’s privacy policy at the following link: https://privacy.fusedeck.net/de/zY3EFXdzg0.

3.5 – Matelso Call Tracking

Based on our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR (i.e. to ensure the quality of our online offerings), we use the call tracking technology of Matelso GmbH, Heilbronnerstr. 150, 70191 Stuttgart (“Matelso”). Any telephone number provided on our website may be a so-called call tracking number, whereby the time, date, call acceptance and duration of the call, as well as the telephone numbers of both participants, are recorded, stored and forwarded to Matelso and the called participant for the purpose of determining advertising effectiveness. If you wish to avoid tracking (for both answered and unanswered calls), please ensure that you suppress your phone number before calling. Further information on this can be found in Matelso’s privacy policy: https://www.matelso.de/datenschutz/.

You can prevent the collection and forwarding of the aforementioned data and the processing of this data by suppressing your phone number before calling us or by calling from an anonymous phone number. You can also disable JavaScript in your browser settings or install a JavaScript blocker, such as www.noscript.net or www.ghostery.com, to prevent the collection of other website analysis data.

4 – What data do we process on our social media pages?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and collect the data about you described above and below. We receive this data from you and the platforms when you contact us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. about your behaviour and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. what content they show you).

We process this data for the purposes described, in particular for communication, marketing purposes (including advertising on these platforms) and market research. We may redistribute content published by you (e.g. comments on an announcement) (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the terms of use (e.g. inappropriate comments).

For further information on the processing of data by the operators of the platforms, please refer to the data protection information provided by the platforms. There you will also find out in which countries they process your data, what rights you have to information, deletion and other rights of data subjects, and how you can exercise these rights or obtain further information.

5 – Other services

Within the scope of our website and for the provision of our services, we use additional services, which we explain in more detail below. If we ask for your consent to the use of third-party providers, the legal basis for this form of data processing is consent within the meaning of Art. 6 para. 1 lit. a GDPR. If we do not obtain your consent, we process your data on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, i.e. in the interest of efficient, economical and recipient-friendly services.

5.1 – Campaign Monitor

We use the service provider “Campaign Monitor” to send the newsletter. The provider is Campaign Monitor Pty Ltd., 11 Lea Ave., Nashville, TN 37210 USA. Campaign Monitor is a service that can be used to organise and analyse newsletter distribution. The data you enter for the purpose of receiving the newsletter (e.g. email address) is transmitted to Campaign Monitor’s servers in the USA and, if applicable, Germany and Australia, where it is stored.

Campaign Monitor uses this information to send and statistically evaluate the newsletters on our behalf. For the evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links have been clicked on, if any. Technical information is also collected (e.g. time of access, IP address, browser type and operating system). The data is collected exclusively in pseudonymised form and is not linked to your other personal data, thus ruling out any direct personal references. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of the recipients.

Campaign Monitor offers extensive analysis options. For example, it collects data on whether the newsletter was opened and which links in the emails were clicked on. However, the analyses of newsletter usage are always carried out on a group basis, i.e. no analyses are carried out on individual newsletter recipients.

Furthermore, Campaign Monitor may use this data itself in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of the newsletters or for statistical purposes to determine which countries the recipients come from, based on its own legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. However, Campaign Monitor does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.

If you wish to object to data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.

We have concluded a data processing agreement with Campaign Monitor in which we oblige Campaign Monitor to protect our customers’ data and not to pass it on to third parties.

The data you provide to us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from both our servers and Campaign Monitor’s servers after you unsubscribe.

You can view the privacy policy here: http://www.campaignmonitor.com/privacy/.

5.2 – Cituro

We use Cituro, a service provided by Cituro GmbH, Peter-Dörfler-Strasse 30, 86199 Augsburg, Germany. Cituro enables us to make appointments with you via our website. In order to process the appointment booking process and operate the platform, the data you enter and technical data (e.g. IP address) may be passed on to the service provider. We use Cituro on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR. Our legitimate interest lies in finding a suitable appointment with you as quickly and efficiently as possible. If the processing is carried out for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract, this is the basis for the processing within the meaning of Art. 6(1)(b) GDPR.

We have concluded a data processing agreement with Cituro. You can find this at the following link: https://www.cituro.com/agb-av.

The data you enter will only be collected when you click on the booking button. We have also made appropriate settings to ensure that your data is automatically deleted after 40 days, unless there are legal obligations to the contrary or you are in a pre-contractual or contractual relationship with us.

Further information on data protection can be found at the following link: https://www.cituro.com/datenschutz.

5.3 – Cloudflare

We use Cloudflare, a service provided by Cloudflare Germany GmbH, Rosenthal 7, c/o Mindspace, 80331 Munich. Cloudflare provides us with the network through which our website is operated. We use Cloudflare on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR. Our legitimate interest lies in providing you with a secure, fast, fail-safe and data protection-compliant network. In order to operate and maintain the network, the service provider may have access to and may process the following data: IP addresses, information about traffic routing and system configuration, and other information related to traffic destined for or originating from our website/network.

We have therefore entered into a data processing agreement with the service provider. You can find this at the following link: https://cf-assets.www.cloudflare.com/slt3lc6tev37/6irgPTeaoaj1J5woivgzER/a9a61395ed36a9da51de8e14b743594c/Cloudflare_Standard_Contractual_Clauses_for_Customers_1_Oct_2020.pdf.

Further information on data protection can be found at the following links: https://www.cloudflare.com/de-de/privacypolicy/ and https://www.cloudflare.com/de-de/trust-hub/gdpr/.

5.4 – Google Maps

We use Google Maps from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google USA”) on our website, with Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google Ireland”) acting as our data processor and Google USA potentially acting as their data processor. This Google service allows us to display interactive maps directly on the website and enables you to conveniently use the map function.

By using Google Maps, information about your use of our website (including your IP address) may be transmitted to a Google server in the USA and stored there. Google may store this data as usage profiles for the purpose of tailoring its services, advertising and market research, which is in our legitimate interest within the meaning of Art. 6(1)(f) GDPR. If you are logged in to Google, your data will be directly associated with your account. If you do not want this to happen, you must log out beforehand. If you do not agree to the processing of your data, you can deactivate the Google Maps service and thus prevent the transfer of data to Google. To do this, you must deactivate the JavaScript function in your browser. However, we would like to point out that in this case you will not be able to use Google Maps or only to a limited extent.

Further information on data processing and data protection by Google Maps can be found at: http://www.google.com/intl/de_de/help/terms_maps.html and https://policies.google.com/privacy.

5.5 – Hygraph CMS

We use Hygraph from Hygraph GmbH, Dircksenstraße 47, 10178 Berlin, as our content management system. This system stores personal data from forms (e.g. contact forms, registration in the customer portal, etc.) and uses it for further processing. We process your personal data on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f GDPR. Our legitimate interest lies in storing the personal data you enter in the forms we provide and processing it directly for the purpose for which you fill out a form. The criterion for the duration of the storage of your data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely deleted, unless it is no longer required for the fulfilment or initiation of a contract or for other legitimate interests.

Further information can be found at https://hygraph.com/privacy

5.6 – Imgix CDN

We use imgix CDN on the basis of Art. 6 (1) lit. f GDPR for the proper provision of the content of our website. imgix CDN is a service provided by Zebrafish Labs Inc., which acts as a content delivery network (CDN) on our website. A CDN helps to deliver content from our online offering, in particular files such as graphics or scripts, more quickly with the aid of regionally or internationally distributed servers, which serves to make the content of our website more user-friendly and, where necessary, to incorporate more functionalities ( ). When you access this content, you establish a connection to servers belonging to Zebrafish Labs Inc., 423 Tehama St, 94103 San Francisco, United States, whereby your IP address and, if applicable, browser data such as your user agent are transmitted. This data is processed exclusively for the above-mentioned purposes and to maintain the security and functionality of imgix CDN.

Further information on data protection can be found at: https://www.imgix.com/privacy.

5.7 – Sinch Engage/Messenger Services

We use Sinch Engage, a service provided by MessengerPeople GmbH (“MessengerPeople”), Seidlstrasse 8, 80335, Munich, Germany. This service allows us to communicate with you efficiently via various messenger services (e.g. WhatsApp) and to process your enquiries as quickly as possible. For this purpose, your personal data and the information provided in connection with your enquiry may be processed and stored by the provider of this service. We use this service on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR, which lie in being able to communicate with you efficiently and quickly.

To ensure the security and protection of your personal data, we have concluded a data processing agreement with the provider of this service. You can find this agreement at the following link: https://www.sinch.com/data-protection-agreement/. You can also request information from us about the data stored by MessengerPeople and have it deleted. To do so, please contact us using the contact form on this website. Further information on data protection can be found at the following link: https://www.sinch.com/privacy-notice/#section23

An active account with the respective provider is required to use the messenger service. We would like to point out that, in addition to our data protection provisions, those of the messenger used (e.g. WhatsApp) also apply. We have no influence on their data protection provisions or the use of your data by the messenger used.

5.8 – Xelon

We use the services of Xelon AG, Poststrasse 15, 6300 Zug, Switzerland. Xelon AG provides us with the infrastructure we need to operate the website. We use the services of Xelon AG on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR. Our legitimate interest is to provide you with a fast, secure and smoothly functioning website. As Xelon AG may have access to data and may also process it in the course of providing this service, we have concluded a data processing agreement with Xelon. You can find this at the following link: https://www.xelon.ch/vereinbarung-zur-auftragsdatenbearbeitung.

5.9 – YouTube

We use YouTube to embed videos. YouTube is a service provided by YouTube LLC (“YouTube”), 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube LLC is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, with Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google Ireland”) acting as our data processor and Google USA possibly acting as their data processor.

When you start a YouTube video on our website, a connection to YouTube’s servers is established. The YouTube server is informed which of our pages you have visited. This information (including your IP address) may be transmitted to a Google server in the USA and stored there. If you are logged into your YouTube account at the same time, you enable YouTube to associate your surfing behaviour directly with your personal profile. Furthermore, it cannot be ruled out that YouTube may process your personal data for its own purposes; in such cases, YouTube’s privacy policy applies.

Further information on data processing and data protection at YouTube can be found at: https://www.youtube.com/t/terms and https://policies.google.com/privacy.

You can prevent this by logging out of your YouTube account before visiting our website.

By watching a video on our website and starting a YouTube video, you consent to the associated data processing, including data transfers to the USA.

5.10 – Vimeo

We use the provider Vimeo to embed videos and live streams. Vimeo is a service provided by Vimeo.com, Inc., 330 West 34th Street, 5th Floor, New York, NY 10001, USA (“Vimeo”).

When you start a Vimeo video on our website, a connection to the Vimeo servers is established. The Vimeo server is informed which of our pages you have visited. This information (including your IP address) may be transmitted to a Vimeo server in the USA and stored there. If you are logged into your Vimeo account at the same time, you enable Vimeo to assign your surfing behaviour directly to your personal profile. Furthermore, it cannot be ruled out that Vimeo may process your personal data for its own purposes. In such cases, Vimeo’s privacy policy applies.

Further information on data processing and data protection at Vimeo can be found at: https://vimeo.com/privacy

You can prevent this by logging out of your Vimeo account before visiting our website.

When you play a video on our website and start a Vimeo video, you consent to the associated data processing, including data transfers to the USA.

5.11 – Payment services and payment procedures

All common payment methods can be processed via the Wordline e-payment platform interface. Worldline is provided by Worldline Schweiz AG, Hardturmstrasse 201, 8005 Zurich. Worldline complies with current security standards, in particular the Payment Card Industry Data Security Standard (PCI DSS).

Further information on data protection can be found in the privacy policy of Worldline Schweiz AG at: https://worldline.com/de-ch/compliancy/privacy.html.

All common payment methods can be processed via the Stripe interface. The provider is Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. Stripe complies with all common security standards, in particular the Payment Card Industry Data Security Standard (PCI DSS).

Further information on data protection can be found in Stripe’s privacy policy at: https://stripe.com/privacy

5.12 – IOVOX

On our websites, we use “IOVOX Virtual Phone Number”, a service provided by IOVOX Limited, 4-6 Canfield Place, London, NW6 3BT, England (“IOVOX”). IOVOX Virtual Phone Numbers are displayed in advertisements, for example. When you call such a virtual telephone number, you are automatically forwarded to the actual telephone number of the person you are calling. IOVOX stores and processes information about your user behaviour on our website, such as: telephone number called; telephone number of the caller, unless suppressed; start of the call and duration.

We use IOVOX for marketing and optimisation purposes, in particular to analyse the use of our website and to continuously improve individual functions and offers as well as the user experience.

You can view the privacy policy here: https://www.iovox.com/gdpr

6 – Links to other websites

Our website may contain links to other websites that are not operated by us and to which this privacy policy does not apply. Once you click on the link, we no longer have any influence on the processing of any data transferred to third parties (such as your IP address), as the behaviour of third parties is naturally beyond our control. We therefore cannot accept any liability for this external content. The respective provider or operator of the linked pages is always responsible for their content.

7 – Social media plug-ins

We also use plug-ins from social networks such as YouTube, Meta (Facebook & Instagram), LinkedIn, Reddit and TikTok on our websites. This is always visible to you (typically via corresponding symbols).

By activating the plug-in elements, you consent to the associated data processing and, if applicable, data transfer to the respective services. The transfer of your personal data is therefore based on your consent within the meaning of Art. 6 (1) (a) GDPR, but the subsequent processing by the respective operator is the responsibility of the respective operator and is governed by their data protection regulations. However, we do not receive any information from them.

8 – Legal basis, storage period and data security

8.1 – Legal basis

The legal basis for the processing of your data, insofar as a legal basis is required under the applicable data protection regulations, is:

Your consent, which you can revoke at any time (e.g. for subscribing to our newsletter or registering for a customer account);
the conclusion or fulfilment of a contract with you or your enquiry in advance thereof (pre-contract) (e.g. by ordering products or services from us or submitting a job application);
the protection of our legitimate interests (e.g. if your professional contact details are recorded when you place an order/contact us on behalf of your employer);
a legal obligation (e.g. for the storage of receipts by us);
where applicable, vital interests / public interests.

8.2 – Storage period

Unless expressly stated in this privacy policy, we process your data for as long as required for our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or as long as storage is technically necessary. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our usual procedures.

8.3 – Data security

We take appropriate security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to counteract the risks of loss, accidental alteration, unintentional disclosure or unauthorised access.

Technical and organisational security measures may include, for example, measures such as data encryption and pseudonymisation, logging, access restrictions, storage of backup copies, instructions to our employees, confidentiality agreements and controls. We protect your data transmitted via our website during transport using appropriate encryption mechanisms. However, we can only secure areas that we control. We also oblige our contractors to take appropriate security measures. However, security risks cannot be completely ruled out; residual risks are unavoidable.

8.4 – Minors

Our website and our services are aimed at an adult audience. Minors, in particular children under the age of 16, are prohibited from transmitting data to us or registering for a service without the consent or approval of their parents or legal guardians. If we discover that such data has been transmitted to us, it will be deleted immediately. The child’s parents (or legal representative) may contact us and request deletion or deregistration.

9 – Your rights as a data subject

To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

The right to request information from us about whether and which data we process about you;
the right to have us correct data if it is inaccurate;
the right to request the deletion of data;
the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
the right to withdraw consent, insofar as our processing is based on your consent;
the right to receive further information necessary for the exercise of these rights upon request.

If you wish to exercise the above rights, please contact us in writing or at our premises, or, unless otherwise specified or agreed, by email; our contact details can be found in section 1. In order to prevent misuse, we must identify you (e.g. with a copy of your ID).

Please note that these rights are subject to conditions, exceptions or restrictions under applicable data protection law (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary. In particular, we may need to further process and store your personal data in order to fulfil a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent permitted by law, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may therefore reject a data subject’s request in whole or in part (e.g. by blacking out certain content relating to third parties or our trade secrets).

If you disagree with our handling of your rights or data protection, please let us know. In particular, if you are located in the EEA, the United Kingdom or Switzerland, you also have the right to contact the data protection supervisory authority in your country; in Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC).

10 – Changes to the privacy policy

We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated on 10 September 2025.