In this privacy statement we describe how we collect and process personal data. This data protection declaration is not an exhaustive description; other declarations relating to data protection may regulate specific matters. For the purposes of this privacy policy, personal data means all information that relates to an identified or identifiable individual.

1. responsible body and contact

The person responsible for the data processing described here is the person named in the imprint, unless otherwise stated in individual cases. Inquiries regarding data protection can be sent to us by e-mail or via the contact form, enclosing a copy of the user's ID or passport for identification purposes: Contact details under the navigation point Contact or in the Footer.

2. collection and processing of personal data

In particular, we process personal data in the following categories of processing:

• In managing customers for whom we provide or have provided services
• In the management of personal data obtained indirectly from our customers in the course of the provision of services
• In the management of personal data of our employees and freelancers
• When visiting our website
• In case of other contractual relationship, e.g. as supplier, service provider or consultant
• For applications
• If we are required to do so for legal or regulatory reasons
• When we are performing our due diligence or other legitimate interests, such as to avoid conflicts of interest, prevent money laundering or other risks, ensure data accuracy, check creditworthiness, ensure security, or enforce our rights

More detailed information can be found in the description of the respective categories of processing in item 4.

3. categories of personal data

The personal data we process depends on your relationship with us and the purpose for which we process it. In addition to your contact information, we also process other information about you to the extent necessary in the context of our relationship.
 We collect the following categories of personal data, depending on the purpose for which we process them:

• Contact information (e.g. last name, first name, address, phone number, e-mail)
• Personal information (e.g. date of birth, nationality, marital status, profession, education, title, job title, passport / ID number, AHV number) for employees or freelancers.
• Risk assessment data (e.g. credit rating information, commercial register data)
• Financial information (e.g. data on bank details)
• Web page data (e.g. IP address, device information (UDI), browser information, web page usage (analysis and use of plugins, etc.)
• Application data (e.g. curriculum vitae, references)
• Security and network data (e.g. visitor lists, access controls, network and mail scanners, telephone call lists)

To the extent permitted and necessary, we also take certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from our customers and their employees, from authorities and other third parties.

4. purposes of data processing and legal basis

4.1 Storage of personal data

Personal data is stored by us solely for the following purposes:

• Management of our customers
• Management of our employees
• Management of our freelancers and partner companies

Personal data is in particular the following information:

• Contact information (e.g. last name, first name, address, phone number, e-mail, other contact information)
• Personal information (e.g. date of birth, nationality, marital status, profession, education, title, job title, AHV number, insurance policies, etc.) for employees
• Financial information (e.g. data on bank details)

We process this personal data for the described purposes based on the following legal bases:

• Conclusion or execution of a contract with the data subject or for the benefit of the data subject.
• Safeguarding legitimate interests, (e.g., for administrative purposes, to improve our quality, ensure safety, manage risk, enforce our rights, defend against claims, or review potential conflicts of interest).

4.2 Use of our website

No personal data need to be disclosed in order to use our website. However, the server collects a number of user information with each call, which are temporarily stored in the log files of the server.
 When using this general information, no assignment to a specific person takes place. The collection of this information or data is technically necessary to display our website and to ensure its stability and security. This information is also collected to improve the website and analyze its use.

In particular, this involves the following information:

• Automatically transmitted to us or our service providers technical information, information on user behavior or website settings (e.g. IP address, UDI, device type, browser, number of clicks on the page, opening of the newsletter, click on links, etc.).

We process this personal data for the purposes described and based on the following legal grounds:

• Safeguarding legitimate interests, (e.g. for administrative purposes, to improve our quality, analyze data or publicize our services).
• Consent (e.g. to the use of cookies)

4.3 Newsletter usage

Insofar as you subscribe to our newsletter, we use your e-mail address and other contact data to send you the newsletter. You can subscribe to our newsletter with your consent. Mandatory data for sending the newsletter are your full name and your e-mail address, which we store after your registration. The legal basis for the processing of your data in connection with our newsletter is your consent to the sending of the newsletter. You can revoke this at any time and unsubscribe from the newsletter.

4.4 Direct communication and visits

If you contact us (e.g. via telephone, e-mail or chat) or if we contact you, we process the personal data required for this purpose. We also process this personal data when you visit us. In this case, you may leave your contact details before your visit or at the reception. We keep this information for a certain period of time to protect our infrastructure and information.

We use the services "Zoom", "Microsoft Teams" or "Skype" to conduct telephone conferences, online meetings, video conferences and/or webinars ("Online Meetings").

In particular, we process the following information:

• Contact information (e.g. last name, first name, address, phone number, e-mail)
• Boundary data for communication (e.g. IP address, duration of communication, communication channel).
• Recordings of conversations, e.g. during video conferences
• Other information uploaded, provided or created by the user during the use of the video conferencing service, as well as metadata used for the maintenance of the service provided. Additional information about the processing of personal data by "Zoom", "Microsoft Teams" or "Skype" can be found in their privacy statements.
• Personal information (e.g. occupation, function, title, employer company)
• Time and reason for the visit

We process this personal data for the described purposes based on the following legal bases:

• Fulfillment of a contractual obligation with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement (provision of a service)
• Safeguarding legitimate interests (e.g. security, traceability, and processing and administration of customer relationships)

4.5 Applications

You can submit your application for a position with us by mail or via the e-mail address provided on our website. The application dossier and all personal data disclosed to us with it will be treated in strict confidence, will not be disclosed to any third party and will only be processed for the purpose of processing your application for employment with us. Without your consent to the contrary, your application file will either be returned to you or deleted/destroyed after the application process has been completed, unless it is subject to a legal obligation to retain it. The legal basis for processing your data is your consent, the fulfillment of the contract with you and our legitimate interests.

In particular, we process the following information:

• Contact information (e.g. last name, first name, address, phone number, e-mail)
• Personal information (e.g. occupation, function, title, employer company)
• Application documents (e.g. letter of motivation, certificates, diplomas, curriculum vitae)
• Assessment information (e.g. assessment of personnel consultants, reference information, assessments)

We process this personal data for the described purposes based on the following legal bases:

• Safeguarding legitimate interests (e.g. hiring new employees)
• Consent

4.6 Suppliers, service providers, other contractual partners

If we enter into a contract with you to provide a service for us, we process personal data about you or your employees. We need this data to communicate with you and to use your services. We may also process this personal data in order to check whether there might be a conflict of interest in connection with our activities and to ensure that we do not enter into any unwanted risks, e.g. with regard to money laundering or sanctions, when working with you.

In particular, we process the following information:

• Contact information (e.g. last name, first name, address, phone number, e-mail)
• Personal information (e.g. occupation, function, title, employer company)
• Financial information (e.g. data on bank details)

We process this personal data for the described purposes based on the following legal bases:

• Conclusion or execution of a contract with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement
• Safeguarding legitimate interests, (e.g. avoiding conflicts of interest, protecting the company, enforcing legal claims).

4.7 Participation in events

If you participate in an event organized by us, we collect personal data in order to organize and conduct the event and, if necessary, to send you additional information afterwards. We also use your information to inform you about other events. You may be photographed or filmed by us at these events and we may publish this footage internally or externally.

In particular, this involves the following information:

• Contact information (e.g. last name, first name, address, phone number, e-mail)
• Personal information (e.g., occupation, position, title, employer company, eating habits).
• Pictures or videos
• Payment information (e.g. bank details)

We process this personal data for the described purposes based on the following legal bases:

• Fulfillment of a contractual obligation with the data subject or for the benefit of the data subject, incl. contract initiation and possible enforcement (enabling participation in the event)
• Safeguarding legitimate interests (e.g. holding events, disseminating information about our event, providing services, efficient organization).
• Consent (e.g. to send you marketing information or to create visual material).

5. tracking technologies

We use cookies on our website. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone or similar) when you visit our site.
 In the cookie, information is stored that arises in each case in connection with the specific end device used. This does not mean, however, that we thereby gain direct knowledge of your identity. The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
 In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These cookies enable us to automatically recognize that you have already been to our site when you visit it again. These cookies are automatically deleted after a defined period of time.
 The data processed by cookies are necessary for the purposes mentioned. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website.

6. web analysis

We use the following web analysis tools and re-targeting technologies in order to obtain information about the use of our website, to improve our Internet offering and to be able to address you with advertising on third-party websites or on social media: Google Analytics.
 These tools are provided by third-party vendors. As a rule, the information collected for this purpose about the use of a website is transmitted to the third-party provider's server through the use of cookies or similar technologies. Depending on the third-party provider, these servers may be located abroad.
 The transmission of the data usually takes place with shortening of the IP addresses, which prevents the identification of individual end devices. A transmission of this information by third-party providers only takes place due to legal regulations or in the context of order data processing.

6.1 Google Analytics

We use Google Analytics on our websites, the web analytics service of Google LLC, Mountain View, California, USA, responsible for Europe is Google Limited Ireland ("Google"). To deactivate Google Analytiscs, Google provides a browser plug-in at tools.google.com/dlpage/gaoptout. Google Analytics uses cookies. These are small text files that make it possible to store specific information related to the user on the user's terminal device. These enable an analysis of the use of our website offer by Google. The information collected by the cookie about the use of our pages (including your IP address) is usually transmitted to a Google server in the USA and stored there. We point out that on this website Google Analytics has been extended by the code "gat._anonymizeIp();" to ensure anonymized collection of IP addresses (so-called IP masking). If anonymization is active, Google truncates IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area, which is why no conclusions can be drawn about your identity. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google may associate your IP address with other data held by Google. For data transfers to the USA, Google has undertaken to sign and comply with the EU standard contractual clauses.

6.2 Google Maps

On our website, we use Google Maps (API) from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; responsible for Europe is Google Limited Ireland, "Google"). Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, our location is displayed to you and a possible approach is facilitated. Already when calling up those sub-pages in which the map of Google Maps is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at Google, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them.
 For data transfers to the USA, Google has undertaken to sign and comply with the EU standard contractual clauses. 

6.3 Social media plugins

So-called social media plugins ("plugins") from third-party providers are used on our website. The plugins are recognizable by the logo of the respective social network. Via the plugins, we offer you the opportunity to interact with the social networks and other users. We use the following plugins on our website: Facebook, Twitter, LinkedIn, YouTube, Vimeo. When you visit our website, your browser establishes a direct connection to the servers of the third-party provider. The content of the plugin (e.g. YouTube videos) is transmitted directly to your browser by the respective third-party provider and integrated into the page.
 The data transfer for the display of content (e.g. publications on Twitter) takes place regardless of whether you have an account with the third-party provider and are logged in there. If you are logged in to the third-party provider, your data collected by us will also be directly assigned to your account with the third-party provider. If you activate the plugins, the information will also be published on the social network and displayed to your contacts there. For the purpose and scope of the data collection and the further processing and use of the data by the third-party providers, as well as your rights in this regard and setting options for protecting your privacy, please refer to the privacy notices of the third-party providers. The third-party provider stores the data collected about you as usage profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. In particular, such an evaluation is also carried out for non-logged-in users for the display of needs-based advertising and to inform other users of the social network about your activities on our website. If you would like to prevent the third-party providers from assigning the data collected via our website to your personal profile in the respective social network, you must log out of the corresponding social network before visiting our website. You can also completely prevent
the loading of the plugins with specialized add-ons for your browser, such as "Ghostery" (https://www.ghostery.com/) or "NoScript" (http://noscript.net/).

6.4 Newsletter Tracking

For sending our newsletters we use the software product [xxx]. Newsletters can be sent with this software. To perform these analyses, we collect device and access data.
 With the help of these technologies, we receive the information whether the newsletter has arrived, has been opened and which contents have been clicked on. We use this information to improve our newsletter and our offers.
 This analysis can be prevented by deactivating HTML in the mail program (varies depending on the mail program).

7. data sharing and data transmission

We will only disclose your data to third parties if this is necessary to provide our service, if these third parties provide a service for us, if we are required to do so by law or by the authorities, or if we have an overriding interest in disclosing the personal data. We will also disclose personal data to third parties if you have given your consent or requested us to do so.
 Not all personal data is transmitted in encrypted form as standard. Unless explicitly agreed otherwise with the customer, the data is transmitted unencrypted.

The following categories of recipients may receive personal data from us:

• Service providers (e.g. IT service providers, hosting providers, suppliers, consultants, trustees, auditors, lawyers, insurance companies)
• Third parties within the scope of our legal or contractual obligations, public authorities, government institutions, courts of law

We conclude contracts with service providers who process personal data on our behalf, obliging them to ensure data protection. The majority of our service providers are located in Switzerland or in the EU / EEA. Certain personal data may also be transferred to the USA (e.g. Google Analytics data) or, in exceptional cases, to other countries worldwide. If data transfer to other countries that do not have an adequate level of data protection is necessary, this will be done on the basis of the EU standard contractual clauses (e.g. in the case of Google) or other appropriate instruments).

8. duration of the retention of personal data

We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. In this context, it is possible that personal data will be retained for the time during which claims can be asserted against our company (i.e. in particular during the statutory limitation period) and to the extent that we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as a matter of principle and as far as possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less apply in principle.

9. data security

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization and controls.

10. obligation to provide personal data

In the context of our business relationship, you must provide those personal data that are necessary for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will not be able to enter into or perform a contract with you (or the entity or person you represent). Also, the website cannot be used if certain traffic-securing information (such as IP address) is not disclosed.

11. your rights

You have the following rights in connection with our processing of personal data:

• Right to information about personal data stored by us about you, the purpose of processing, the origin and about recipients or categories of recipients to whom personal data is disclosed.
• Right to rectification if your data is incorrect or incomplete
• Right to restrict the processing of your personal data
• Right to request the deletion of the processed personal data
• Right to data portability
• Right to object to data processing or to withdraw consent to the processing of personal data at any time without giving reasons
• Right to complain to a competent supervisory authority, if provided for by law

To exercise these rights, please contact us at the address given in section 1.
 Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this) or require it for the assertion of claims. If costs are incurred by you, we will inform you in advance.

12. modification of the privacy policy

We expressly reserve the right to change this privacy policy at any time.

Version 12.4 from 14.08.2023 valid until further notice.