This privacy policy provides information about how we process personal data in connection with our activities and operations, including our website at the domain name
We may publish additional privacy policies or other information on data protection for individual or additional activities and operations.
We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
In its decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. In its report of January 15, 2024, the European Commission confirmed this adequacy decision.
The data protection officer is:
RT360 AG
Klosbachstrasse 99
8032 Zurich
Switzerland
In individual cases, third parties may be responsible for processing personal data, or joint responsibility with third parties may exist. We will be happy to provide data subjects with information about the respective responsibility upon request.
We have the following data protection representative in accordance with Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries relating to the GDPR.
Data subject: Natural person whose personal data we process.
Personal data: Any information relating to an identified or identifiable natural person.
Sensitive personal data: Data concerning trade union, political, religious, or philosophical beliefs and activities, data concerning health, privacy, or racial or ethnic origin, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or persecution, and data on social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, changing, disseminating, linking, destroying, and using personal data.
European Economic Area (EEA): Member states of the European Union (EU ) as well as the Principality of Liechtenstein, Iceland, and Norway.
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection ( Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
Where and to the extent that the European General Data Protection Regulation (GDPR) applies, we process personal data in accordance with at least one of the following legal bases:
The European General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data ( Art. 9 GDPR).
We process the personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted.
We process personal data with the consent of the data subjects to the extent necessary. In many cases, we may process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also request consent from data subjects if their consent is not required.
We process personal data for the period of time necessary for the respective purpose. We anonymize or delete personal data in particular in accordance with statutory retention and limitation periods.
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.
Within the scope of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.
We process personal data in order to communicate with individuals as well as with authorities, organizations, and companies. In doing so, we process in particular data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals independently. In particular, they must ensure that such data is accurate and may be transferred.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We may also use such services to manage and otherwise process the data of data subjects beyond the scope of direct communication.
We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without however being able to guarantee absolute data security.
Access to our website and our other digital presence is secured by transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn you before you visit a website without transport encryption.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the processing of personal data by secret services, police authorities, and other security authorities. We also cannot rule out the possibility that a data subject may be subject to targeted surveillance.
We generally process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for processing or to be processed there.
We may export personal data to all countries on Earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) applies, also in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection if data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will gladly provide data subjects with information about any guarantees or provide a copy of any guarantees.
We grant data subjects all rights under applicable law. Data subjects have the following rights in particular:
We may defer, restrict, or deny the exercise of data subjects' rights to the extent permitted by law. We may inform data subjects of any conditions that must be met in order for them to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of confidentiality obligations, overriding interests or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular on the grounds of statutory retention obligations.
In exceptional cases, we may charge a fee for exercising these rights. We will inform the persons concerned in advance of any costs.
We are obliged to identify data subjects who request information or assert other rights by taking appropriate measures. Data subjects are obliged to cooperate.
Affected persons have the right to enforce their data protection claims through legal channels or to file a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organized as members of the European Data Protection Board ( EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are structured federally, particularly in Germany.
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in your browser. Such stored data are not necessarily limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as "session cookies" or for a specific period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable, in particular, a browser to be recognized when you next visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be deactivated, restricted, or deleted in whole or in part at any time in your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may not be fully available. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law.
For cookies used for success and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
We may log at least the following information for each access to our website and our other digital presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including the amount of data transferred, the last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is permanent, user-friendly, and reliable. The information is also necessary to ensure data security, including by third parties or with the help of third parties.
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those of third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is logged in log files.
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner, as well as permanently, securely, and reliably, based on the needs and reading habits of the recipients.
You must always consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including your IP address and time stamp, for evidence and security purposes.
You can object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical collection of usage data for the purpose of measuring success and reach. We reserve the right to send you notifications and communications in connection with our activities and operations.
We send notifications and communications with the help of specialized service providers.
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
For our social media presence on Facebook, including so-called page insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland) to the extent that the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook effective and user-friendly.
Further information on the type, scope, and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have entered into the so-called "Supplement for Controllers" with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the "Page Insights Information" page, including "Page Insights Data Information."
We use services provided by specialized third parties to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. These services enable us, among other things, to embed functions and content into our website. When such embedding takes place, the services used collect the IP addresses of users, at least temporarily, for technically necessary reasons.
For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to be able to offer the respective service.
We use the following in particular:
We use services from specialized third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party information or check how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.
In most cases, the IP addresses of individual users are collected for success and reach measurement. In this case, IP addresses are always shortened ("IP masking") in order to comply with the principle of data minimization through pseudonymization.
Cookies may be used and user profiles created for the purpose of measuring success and reach. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services to which users are registered may be able to associate the use of our online offering with the user account or user profile for the respective service.
We use the following in particular:
We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.