Privacy policy

With this Privacy Policy, we provide information on which personal data we process in connection with our activities and operations, including our rwcg.ch website. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

For individual or additional activities and operations, further data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

1. contact addresses

Responsibility for the processing of personal data:

René Wasmer
René Wasmer CONFORMITY & GOVERNANCE GmbH
Rainackerweg 2
3067 Boll
Switzerland

info@rwcg.ch

We point out if there are other controllers for the processing of personal data in individual cases.

2.1 Terms

Personal data means any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, for example the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, recording, erasure, disclosure, structuring, organisation, storage, modification, dissemination, linking, destruction and use of personal data.

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

3. type, scope and purpose

We process the personal data that is required in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.

We process personal data for the duration required for the respective purpose(s) or by law. Personal data that no longer needs to be processed is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.

We only process personal data in principle with the consent of the data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.

4. Communication

We process data in order to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, for example by post or email. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. Among other things, the accuracy of the personal data transmitted must be ensured.

5. data security

We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication – like in principle all digital communication – is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. We also cannot rule out the possibility that individual data subjects may be subject to targeted surveillance.

6. Personal data abroad

We process personal data in principle in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it or have it processed there.

We can export personal data to all states and territories on Earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council.

We may disclose personal data to countries whose laws do not guarantee adequate data protection, provided that suitable data protection is guaranteed for other reasons. Adequate data protection can be ensured, for example, through corresponding contractual agreements, on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees on request.

7. Rights of data subjects

7.1 Claims under data protection law

We grant data subjects all rights in accordance with the applicable data protection law. In particular, data subjects have the following rights

  • Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data, among other things.
    • Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
  • Erasure and objection: Data subjects can have their personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data surrender and data transfer: Data subjects can request the surrender of personal data or the transfer of their data to another controller.

We may defer, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

We may charge costs for the exercise of rights in exceptional cases. We will inform affected persons of any costs in advance.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

7.2 Legal protection

Data subjects have the right to enforce their data protection claims through the courts or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for complaints by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

8. Use of the website

8.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be fully or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies – at least if and to the extent necessary.

For cookies that are used to measure success and reach or for advertising, a general objection (“opt-out”) is possible for numerous services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Logging

We may log at least the following information for each access to our website and our other online presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. The information is required in order to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security – also by third parties or with the help of third parties.

8.3 Tracking pixels

We can integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as log files.

9. Services from third parties

We use services from specialised third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.

For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

9.1 Digital infrastructure

We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

9.2 Audio and video conferencing

We use specialised audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, also apply.

Depending on your life situation, we recommend muting the microphone by default when taking part in audio or video conferences and blurring the background or displaying a virtual background.

We use in particular:

9.3 Map material

We use third-party services to embed maps on our website.

We use in particular:

9.4 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:

9.5 Fonts

We use third-party services to embed selected fonts, icons, logos and symbols on our website.

We use in particular:

10. Extensions for the website

We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own server infrastructure.

We use in particular:

11. success-and-reach-measurement

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the IP addresses of individual users are stored to measure success and reach. In this case, IP addresses are generally truncated (“IP masking”) in order to comply with the principle of data minimisation through the corresponding pseudonymisation.

Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile with the respective service.

We use in particular:

  • Matomo: Performance and reach measurement; Service provider: Matomo (free open source software); Data protection information: Use on own server infrastructure and with pseudonymised IP addresses, “List of all Matomo features”..

12. final provisions

We have created this privacy policy using the privacy policy generator from privacy partners.

We may amend and supplement this privacy policy at any time. We will inform you of such amendments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.

Address

René Wasmer CONFORMITY & GOVERNANCE GmbH
Rainackerweg 2
3067 Boll | Bern | Switzerland
Phone +41 31 839 69 86
info@rwcg.ch

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