Privacy policy

Preamble

With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific.

As of March 1, 2024

Overview of content

Responsible person

soblue AG
Dufourstrasse 31
8008 Zurich Switzerland

E-mail address: info@soblue.com

Contact data protection officer

althaus@soblue.com

Overview of the processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Contact data
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  • Content data
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  • Usage data
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  • Meta, communication and process data.

Categories of data subjects

  • Users
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Purposes of the processing

  • Contact requests and communication.
  • Range measurement.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.

Relevant legal bases

Relevant legal bases according to the GDPR: The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.</p

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.</p

Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection ("Swiss DPA" for short). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not stipulate (unlike the GDPR, for example) that a legal basis for the processing of personal data must be specified. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss FADP). Furthermore, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in a way that is compatible with these purposes (Art. 6 para. 3 of the Swiss FADP).

Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.</p

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.</p

TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing Internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person. Our data protection notices may also contain further information on the retention and deletion of data, which take precedence for the respective processing.</p

Rights of the data subjects

Rights of data subjects under the GDPR: As data subjects, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
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  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
  • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:

  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and to obtain the information necessary to assert your rights under this law and to ensure transparent data processing.
  • Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used on an online offer. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offer). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users give their consent, the legal basis for processing their data is the consent given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.</p

Storage period: A distinction is made between the following types of cookies with regard to the storage period:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.</li

General information on revocation and objection (so-called "opt-out"): Users can revoke the consents they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
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Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which the consent of users to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, system and end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
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Web analysis, monitoring and optimization

Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.</p

In addition to web analytics, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser or end device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.</p

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
  • Persons concerned: users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.</li
  • Security measures: IP masking (pseudonymization of the IP address)
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  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
    Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety. google/adsprocessorterms/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.

Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user's computer, in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user's data and can take appropriate measures and provide information directly. If you still need help, you can contact us.</p

  • Types of data processed: Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Persons concerned: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing
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  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
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Further information on processing processes, procedures and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
  • Facebook pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www. facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA.</li
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin. com/legal/privacy-policy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Opt-out: https://www.linkedin. com/psettings/guest-controls/retargeting-opt-out; Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data used for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles.
    This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
    We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which in particular concerns the transfer of the data to the parent company LinkedIn Corporation in the USA.</li
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data protection declaration: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - adequacy decision (Ireland). Option to object (opt-out): https://myadcenter.google.com/personalizationoff.
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third country transfers: Switzerland - adequacy decision (Germany).
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Change and update of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.</p

  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or an identifier (e.g. an IP address).
  • a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and the use of the website). Depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.), to analyze, evaluate or predict them (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.</li
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them to better adapt the content of their websites to the needs of their visitors, for example. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.</li
  • Controller: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
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  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether it is collection, analysis, storage, transmission or erasure.</li

Created with free Datenschutz-Generator.de by Dr. Thomas Schwenke

Privacy policy preamble With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). The terms used are not gender-specific. Status: 1. March 2024 Table of contents - Preamble - Controller - Contact Data Protection Officer - Overview of processing operations - Relevant legal bases - Security measures - Deletion of data - Rights of data subjects - Use of cookies - Web analysis, monitoring and optimization - Presence on social networks (social media) - Amendment and updating of the privacy policy - Definitions of terms Controller soblue AG Dufourstrasse 31 8008 Zurich Switzerland E-mail address: info@soblue.com Contact Data Protection Officer althaus@soblue.com Overview of processing The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects. Types of data processed - Contact details. - Content data. - Usage data. - Meta, communication and procedural data. Categories of data subjects - users. Purposes of processing - contact requests and communication. - Reach measurement. - Feedback. - Marketing. - Profiles with user-related information. - Provision of our online offering and user-friendliness. Relevant legal bases Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy. - Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for a specific purpose or several specific purposes. - Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply. Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection ("Swiss DPA" for short). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not stipulate (unlike the GDPR, for example) that a legal basis for the processing of personal data must be specified. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss FADP). Furthermore, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in such a way that it is compatible with these purposes (Art. 6 para. 3 of the Swiss FADP). Reference to the validity of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA. Security measures We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk. The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings. TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate. Deletion of data The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person. Our data protection notices may also contain further information on the retention and deletion of data, which take priority for the respective processing operations. Rights of data subjects Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR: - Right to object: you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. - Right to withdraw consent: You have the right to withdraw any consent you have given at any time. - Right to information: You have the right to request confirmation as to whether the data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements. - Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements. - Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements. - Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller. - Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR. Rights of data subjects under the Swiss DPA: As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss DPA: - Right of access: you have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing. - Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have disclosed to us in a commonly used electronic format. - Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you. - Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed. Use of cookies Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to analyze visitor flows. Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to users and contains information on the respective use of cookies. Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users give their consent, the legal basis for processing their data is the consent given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures. Storage duration: With regard to the storage duration, a distinction is made between the following types of cookies - Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g. browser or mobile application). - Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years. General information on revocation and objection (so-called "opt-out"): Users can withdraw the consent they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. - Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Further information on processing processes, procedures and services: - Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Web analysis, monitoring and optimization Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization. In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components. Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed. The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes. - Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. .e.g. IP addresses, time data, identification numbers, consent status). - Data subjects: Users (e.g. website visitors, users of online services). - Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness. - Security measures: IP masking (pseudonymization of the IP address). - Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Further information on processing processes, procedures and services: - Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - adequacy decision (Ireland); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data). Presence in social networks (social media) We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us. We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user's computer, in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us. - Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status). - Data subjects: Users (e.g. website visitors, users of online services). - Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing. - Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Further information on processing operations, procedures and services: - Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - adequacy decision (Ireland). - Facebook pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - adequacy decision (Ireland); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA. - LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from users' profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which relates in particular to the transfer of data to the parent company LinkedIn Corporation in the USA. - YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Option to object (opt-out): https://myadcenter.google.com/personalizationoff. - Xing: Social network; service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third country transfers: Switzerland - adequacy decision (Germany). Amendment and updating of the privacy policy We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us. Definitions of terms This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding. - Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. - Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes. - Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer. - Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. - Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether it is collection, analysis, storage, transmission or deletion. Created with free Datenschutz-Generator.de by Dr. Thomas Schwenke