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1. What is this Privacy Notice about?

Esther Lauber, real estate agency (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

«Personal data» means data relating to identified or identifiable individuals, which means that the relevant data, in combination with additional data, make it possible to draw conclusions about the identity of these individuals. «Sensitive personal data» is a subset of personal data that is specially protected under applicable data protection law. This includes, for example, data revealing racial or ethnic origin, health data, religious or philosophical beliefs, biometric data for identification purposes, and information relating to trade union membership. In Section 3, you will find information about the data we process in accordance with this Privacy Notice. «Processing» means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.

In this Privacy Notice, we describe what we do with your data when you use www.esther-lauber.ch, our other websites or apps (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA». However, the application of these laws depends on each individual case.

2. Who is the controller for processiong your data?

 Esther Lauber, rue du Léopard 3, 1227 Carouge, Switzerland, This email address is being protected from spambots. You need JavaScript enabled to view it., is the controller for Esther Lauber real estate processing under this Privacy Notice, unless we tell you otherwise in an individual case.

3. What data do we process?

We process various categories of data about you. The main categories of data are the following:

  • Technical data: When you use our website or other online offerings (for example free Wi-Fi), we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.

  • Registration data: Certain offerings, for example services (such as login areas of our website, newsletters, free WLAN access, etc.) can only be used with a user account or registration, which can happen directly with us or through our third-party login service providers. In this regard you must provide us with certain data, and we collect data about the use of the offering or service. Registration data may be required in relation to access control to certain facilities, potentially including biometric data, depending on the control system. Registration data includes the information you provide when you create an account on our website (for example username, password, name, e-mail). It also includes the data that we may require from you before you can use certain free services, such as, for example, our WLAN service, in this case: Name, e-mail and telephone number; or the redemption of vouchers, in this case: Name, address, contact details, time of redemption. You must also register if you wish to subscribe to our e-mail alerte or newsletter.

  • Communication data: When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we record or listen in on telephone conversations or video conferences, for example for training and quality assurance purposes, we will tell you specifically. Such recordings may only be made and used in accordance with our internal policies. You will be informed if and when such recordings take place, for example by an indication during the video conference in question. If you do not want to be recorded, please notify us or leave the (video) conference. If you simply do not want your image to be recorded, please turn off your camera. If we have to determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of an ID document). We generally keep this data for 3 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least10 years. Recordings of (video) conferences we will usually keep for 24 months. Chats are generally stored for 2 years.

  • Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (for example when you make a purchase or as part of a registration), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.). We may also process health data and information about third parties as part of master data. We may also collect master data from our shareholders and investors. We generally keep master data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, usually no more than 2 years from the last contact.

  • Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). This includes health data and information about third parties, for example about hereditary diseases in a family. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.

  • Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings.

Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.

As far as it is not unlawful we also collect data from public sources (for example debt collection registers, land registers, commercial registers, the media, or the internet including social media) or receive from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).

We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services or has accepted an invitation to an event, because it is a technical requirement or because we wish to communicate with you. If you or the person you represent (for example your employer) wishes to enter into or perform a contract with us, we must collect master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offerings for this purpose. If you do not provide us with the data necessary for the conclusion and performance of the contract, you should expect that we may refuse to conclude the contract, that you may commit a breach of contract or that we will not perform the contract. Similarly, we can only submit a response to a request from you if we process communication data and – if you communicate with us online – possibly also technical data. Also, the use of our website is not possible without us receiving technical data.

The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and legal proceedings, information in relation to your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your assistance), information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity), information about you that persons related to you (family members, advisors, legal representatives, etc.) share with us so that we can conclude or perform contracts with you or involving you (for example references, your delivery address, powers of attorney, information about compliance with legal requirements such as those relating to fraud prevention and the combating of money laundering and terrorist financing, export restrictions, information from banks, insurance companies, sales and other contractual partners of us about your use or provision of services (for example payments, purchases, etc.), information from the media and the internet about the use or provision of services by you (for example payments made, purchases made, etc.), information from the media and the internet about you (where appropriate in a specific case, for example in the context of an application, marketing/sales, press review, etc.), your address and potentially interests and other socio-demographic data (especially for marketing and research purposes) and data in relation to the use of third-party websites and online offerings where such use can be linked to you.

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.

We process data for the conclusion, administration and performance of contractual relationships.

We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, contests, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 12). Finally, we also wish to enable our contractual partners to contact our customers and other contractual partners for marketing purposes (see Section 7).

For example, if you consent we may send you information, advertising and product offers from us and from third parties within and outside the group (for example advertising partners), as printed material, electronically or by telephone. For this purpose, we process in particular communication and registration data. As most companies, we personalize communications so that we can provide you with customized information and offers that meet your needs and interests. Therefore, we combine data we process about you and collect preference data and use this data as a basis for personalization (see Section 3). We also process data in relation to contests, competitions and similar events.

Relationship management includes addressing existing customers and their contacts, possibly personalized on the basis of behavioral and preference data. In the context of relationship management, we may also operate a customer relationship management system («CRM») in which we keep the data of customers, suppliers and other business partners that is required for relationship management, for example data about contact persons, relationship history (for example information about products and services purchased or supplied, interactions, etc.), interests, marketing measures (newsletters, invitations to events, etc.) and other information.

All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.

We further process your data for market research, to improve our services and operations, and for product development.We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We therefore analyze, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 12). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioral data and preference data, but also communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the Internet and other public sources. We use pseudonymized or anonymized data for these purposes to the extent possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data in order to conduct media monitoring or to understand and respond to current developments and trends.

We use anonymized location data, for example, to provide our contractual partners with recommendations for avoiding rush hours. With your prior consent, we use non-anonymized location data to point out interesting offers and products to you in the vicinity based on your position, to infer your interests from the position data (dwell time) and to inform you of which products and services other contractual partners with similar interests have used.

We may also process your data for security and access control purposes.

We continuously review and improve the appropriate security of our IT and other infrastructure (for example buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backups. Access controls include electronic system access controls (for example logging into user accounts), as well as physical access controls (for example building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations Compliance»).

This includes, for example, the implementation of health security concepts or the regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers («Know Your Customer») or to report to the authorities. Disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example by a law enforcement or supervisory authority or by a mandated private entity. For all these purposes, we process in particular master data, contract data and communication data, but also, under certain circumstances, behavioral data and data from the category of «other data». The legal obligations may arise under Swiss law but also under foreign regulations to which we are subject, as well as self-regulations, industry standards, our own «corporate governance» and instructions and requests from authorities.

 We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

For these purposes, we process in particular master data, contract data, registration data and technical data, but also behavioral and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyze data for relevant patterns of such activities. We may also conduct profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activity (see also Section 6). In the context of planning our resources and organizing our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (for example outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the exchange and processing of data (including from you, for example as a customer or supplier or as a supplier representative).

We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and trainings.

These further purposes include, for example, training and educational purposes, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and continuously improving IT infrastructure), protecting our rights (for example to enforce claims in or out of court, and before authorities in Switzerland and abroad, or to defend ourselves against claims, for example by preserving evidence, conducting legal assessments and participating in court or administrative proceedings) and evaluating and improving internal processes. We may use recordings of (video) conferences for quality assurance purposes and trainings. These further purposes also include safeguarding other legitimate interests that cannot be named exhaustively.

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for marketing mailings, for personalized motion profiles and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.

Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

6. What applies in case of profiling and automated individual decisions?

We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics. We may also create anonymous and – with your consent – personalized motion profiles of you.

In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.

7. With wohm do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit information agencies, or address verification providers). This may include health data. For the service providers used for the website, see Section 12. Key service providers in the IT area are Microsoft, Extenso, Infomaniak.

    More information on how Microsoft processes data can be found here: https://privacy.microsoft.com/en-us/privacystatement

    More information on how Extens processes data can be found here:
    https://www.extenso.ch/datenschutz

    More information on how Infomaniak processes data can be found here: https://www.infomaniak.com/fr/cgv/reglement-general-protection-donnees

  • Contractual partners including customers: This refers to customers (for example service recipients) and our other contractual partners as this data disclosure results from these contracts.

  • Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests

  • Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4, for example service recipients, the media and associations in which we participate or if you are included in one of our publications.Other recipients include, for example, delivery recipients or third-party payees specified by you, other third parties in relation to agency relationships (for example if we share your data with your lawyer or your bank) or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them (for example photos), this may also affect you depending on the circumstances. The same applies if we publish content (for example photos, interviews, quotes, etc.), for example on our website or in our other publications. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you, for example as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with competitors, industry organizations, associations and other bodies, data may be exchanged that also affects you.All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

8. Is your personal data disclosed abroad?

As explained in section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe in exceptional cases, in any country in the world.

9. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with it (for example in case of backups or document management systems).

10. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.

11. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure 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, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights;
  • The right to express your point of view in case of automated individual decisions (Section 6) and to request that the decision be reviewed by a human.

If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section7 and additional information in Section 12.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

12. Do we use online tracking and online advertising technics?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»).

We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here on your startpage. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):

  • Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.).

  • Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent.  Details can be found on the websites of the third-party providers.

  • Marketing Cookies: We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. If you do not consent to them, you will not see less advertisements, but simply any other advertisement.

    We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):

    Google Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service «Google Analytics» and acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both «Google»). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals option». Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here https://support. google. com/analytics/answer/6004245 and if you have a Google account, you can find more details about Google's processing here https://policies. google. com/technologies/partner-sites? hl=en.

    Bing webmaster tools: Micrrosoft is the provider of the "Webmaster tools" service and acts as our subcontractor. Bing Webmaster tools collects information on the behaviour of visitors to our website (duration, pages viewed, geographical region of access, etc.) by means of performance cookies (see above) and, on this basis, creates reports for us on the use of our website. You can find information on data protection for Microsoft Webmaster tools here: https://privacy.microsoft.com/fr-fr/privacystatement

13. What data do we process on our social network 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 in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We process this data for the purposes set out in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 12) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of 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 their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:Facebook, Instagram, Youtube, Lindedin, Pinterest, X (ex-Twitter).

 14. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Last updated: 04.11.2023, based on template of DSAT.ch