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Data protection

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Responsible: Frey & Frey AG, Industriestrasse 26, CH-3175 Flamatt, Switzerland

Any data subject can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

Status: 27.11.2020

1. BASIC INFORMATION ON DATA PROCESSING AND LEGAL BASIS
1.1

This privacy policy clarifies the nature, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and content (hereinafter collectively referred to as "online offer" or "website").

1.2

We refer to the definitions in Art. 4 of the EU General Data Protection Regulation (GDPR) for the terms used, such as "personal data", pseudonymization, consent, controller or their "processing".

1.3

The terms used, such as "user", are to be understood as gender-neutral.

1.4

We only process users' personal data in compliance with the relevant data protection regulations (Swiss data protection law and, in the case of an application of Art. 3 EU GDPR, the EU GDPR). This means that user data will only be processed if we have legal permission to do so. This means, in particular, if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services or is required by law.

1.5

Persons under the age of 18 should not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and young people. We do not knowingly collect such data and do not pass it on to third parties.

2. COLLECTION OF ACCESS DATA AND LOG FILES
2.1

We collect a range of general data and information each time a person or an automated system accesses the website. This general data and information is stored in the server log files. The name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider may be recorded.
If users leave comments or other contributions, their IP addresses are stored.

2.2

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum period of one month and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

3. DISCLOSURE OF DATA TO THIRD PARTIES AND THIRD-PARTY PROVIDERS
3.1

Data recorded when accessing our website will only be transmitted to third parties if we are obliged to do so by law, contract or court order or on the basis of legitimate interests.
If you order information material, brochures or products, we will only use the personal information you enter within our company or, if necessary, pass it on to the companies commissioned to process the order. The information will not be passed on to third parties for commercial or non-commercial purposes without your express consent.

3.2

If we use subcontractors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

3.3

If content, tools or other means from other providers (hereinafter jointly referred to as "third-party providers") are used within the scope of this privacy policy and their registered office is located in a third country, it is to be assumed that data is transferred to the countries in which the third-party providers are based. Third countries are countries in which the GDPR is not directly applicable law, i.e. generally countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or other legal permission.

4. DATA PROCESSING IN THE CONTEXT OF THE PROVISION OF CONTRACTUAL SERVICES
4.1

We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR.

5. CONTACT AND ORDERING
5.1

When contacting us (via contact form or e-mail), the user's details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

5.2

When ordering information material, brochures or products, you will be asked for your name and other personal information. You are free to decide whether you wish to provide this data. When you place an order, the personal data you provide will only be used to process the order. This includes passing it on to sales companies commissioned by us.
Your data will only be used for direct correspondence with you.

6. COOKIES & REACH MEASUREMENT
6.1

Cookies are pieces of information that are transferred from our web server or third-party web servers to the user's web browser and stored there for later retrieval. Cookies may be small files or other types of information storage.

6.2

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

6.3

You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative (
http://optout.networkadvertising.org/)
and additionally the US website (
http://www.aboutads.info/choices)
or the European website (
http://www.youronlinechoices.com/uk/your-ad-choices/)
.

7. GOOGLE ANALYTICS
7.1

We use Google Analytics (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data about the behavior of visitors to websites. Among other things, a web analysis service collects data about the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of internet advertising.
The anonymization function means that your IP address is shortened and thus anonymized before it is transmitted to the USA. This means that Google cannot associate your IP address with any other data held by Google.
The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

7.2

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active)
.

7.3

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

7.4

We only use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

7.5

The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

7.6

For more information about Google's use of data, settings and opt-out options, please visit Google's websites:
https://www.google.com/intl/de/policies/privacy/partners
("Google's use of data when you use our partners' websites or apps"), https://www.google.com/policies/technologies/ads ("Use of data for advertising purposes"),
https://www.google.de/settings/ads ("Manage information that Google uses to show you advertising").
Further information and the applicable data protection provisions of Google can be found at
https://www.google.de/intl/de/policies/privacy/
and at
https://www.google.com/analytics/terms/de.html
.
Further information on Google Analytics can be found at this link:
https://www.google.com/intl/de_de/analytics/

8. INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT
8.1

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

8.2

The following presentation provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, opt-out options:

8.3

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

9. RIGHTS OF THE DATA SUBJECT
9.1

Every data subject has the right to request confirmation from us as to whether we are processing personal data relating to them.

9.2

Any person affected by the processing of personal data may at any time request information from us free of charge (a fee may be charged in the event of repeated or abusive claims) about the personal data we have stored about them. We also provide the following information:

  • the purposes of processing
  • the categories of personal data that are processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
    the existence of the right to lodge a complaint with a supervisory authority
  • if the personal data is not collected from the data subject: All available information about the origin of the data
  • the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

9.3

Any person affected by the processing of personal data has the right to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

9.4

Any person affected by the processing of personal data has the right to demand that the personal data concerning them be deleted immediately, provided that there are legal reasons for the deletion and insofar as the processing is not necessary.

9.5

Any person affected by the processing of personal data has the right to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to the processing and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
9.6

Any person affected by the processing of personal data has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller. Provided that the data is processed by automated means.

9.7

Any person affected by the processing of personal data has the right to object to the processing of personal data concerning them at any time for reasons arising from their particular situation.

9.8

Any person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.
If a data subject wishes to exercise one or more data subject rights, they can contact our data protection officer at any time.

10. DELETION OF DATA
10.1

The data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the user's data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

11. RIGHT OF OBJECTION
11.1

Users can object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against processing for direct marketing purposes.

12. SECURITY MEASURE
12.1

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.

13. CHANGES TO THE PRIVACY POLICY
13.1

In the course of the further development of our websites and the implementation of new technologies, changes to this privacy policy may become necessary. We therefore recommend that you read this privacy policy again from time to time.

13.2

Users are requested to inform themselves regularly about the content of the privacy policy.