With this privacy policy we inform which personal data we process in connection with our activities and operations including our https://www.online.ch/-Website. In particular, we inform about what for, how and where we process which personal data. We also inform about the rights of persons whose data we process. Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation. We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. contact addresses
Responsibility for the processing of personal data:
Balz Zürrer
Online Consulting AG
Weststrasse 38
CH – 9500 Wil
marketing@online.ch
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. terms and legal bases
2.1 Terms
Personal data is any information that relates 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, such as querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Swiss Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPA).
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 par. 1 lit. b GDPR for the necessary processing of personal data for the fulfillment of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 par. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure
information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law. - Art. 6 par. 1 lit. c GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
- Art. 6 par. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 par. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 par. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3. nature, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, safe 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, and contract and payment data, in particular. We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required
will be anonymized 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
specialized providers whose services we use. We also ensure data protection with such third parties. As a matter of principle, we only process personal data with the consent of the persons concerned. 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 fulfill a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example by post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information in an address book, in a customer
relationship management system (CRM system) or with comparable tools, for example. if we receive data about other persons, the persons transmitting the data are obliged to guarantee data protection for these persons and to ensure the accuracy of this personal data. We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
4. applications
We process personal data about applicants to the extent that it is necessary for assessing their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process
the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles. We process – insofar as and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 par. 2 lit. b GDPR.
5. personal data abroad
We process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it or have it processed there.
We may export personal data to all countries 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 and – if and insofar as the General Data Protection Regulation (GDPR) is applicable – in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. By way of exception, 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 performance of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide
with a copy of any guarantees.
6. rights of data subjects
6.1 Data protection law claims
We grant data subjects all rights in accordance with the applicable data protection law.
Data subjects have the following rights in particular:
- 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 are also provided with the information necessary to assert their claims under data protection law and to ensure transparency. This includes the processed personal data as such, but also, among other things, 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.
- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, limit or deny the exercise of data subjects’ rights to the extent permitted by law. We may 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. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.
We may, in exceptional cases, provide for costs for the exercise of rights. We inform affected persons in advance about any costs. We are obliged to take appropriate measures to identify data subjects who request information or assert other rights
. Affected persons are obliged to cooperate.
6.2 Right to complain
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 private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC ).
Data subjects have the right – if and insofar as the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European data protection supervisory authority.
7. data security
We take suitable technical and organizational measures to ensure data security that is appropriate to the respective risk. However, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication – like all digital communication – is subject to mass surveillance without cause or suspicion and other surveillance 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 agencies and other security authorities.
8. use of the website
8.1 Cookies
We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data does not have to 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 recognize a browser the next time it visits
our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
cookies can be completely 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 – at least if and to the extent necessary – explicit consent to the use of cookies.
For cookies used for performance and reach measurement or for advertising, a general opt-out is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAd Choices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital
Advertising Alliance, EDAA).
8.2 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: 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-pages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably as well as to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
8.3 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also called web beacons. Counting pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to capture the same information as server log files.
9. notifications and messages
We send notifications and communications via email and other communication channels, such as instant messaging or SMS.
9.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which links were clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.
9.2 Consent and objection
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the “double opt-in” procedure to obtain consent, i.e. you will receive an email with a web link that you must click on to confirm
to prevent misuse by unauthorized third parties. We may log such consents, including the IP address and the date and time, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for performance and reach measurement. This is subject to any required notifications and communications in connection with our activities and operations.
9.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
We use in particular:
- Mailchimp: communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Information on data protection: Privacy Policy (Intuit) including “Country and Region-Specific Terms”, “Frequently Asked Questions about data protection
at Mailchimp”, “Mailchimp and European data transfers”, “Security”, Cookie Policy, “Privacy Rights Requests”, “Legal provisions”.
10. social media
We are present on social media platforms and other online platforms in order to be able to communicate with interested persons as well as to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to
information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights – if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The page
Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook effective and user-friendly.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook’s data protection officer can be found in Facebook’s privacy policy. We have entered into the so-called “Responsible Party Addendum” with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called page insights, the corresponding information can be found on the page “Information on page insights” including “Information on page insights data”.
11. services from third parties
We use services of specialized third parties in order to carry out our activities and operations in a durable, user-friendly, safe and reliable manner. Among other things, such services allow us to embed functions and content on our website. In the case of such embedding, the services used record the IP addresses of users at least temporarily for technically compelling reasons
.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles”, Privacy policy, “Google is committed to complying with applicable data protection laws”, “Privacy policy for Google products”, “How we use data from websites or apps on or in which our services are used” (information from Google), “Types of cookies and other technologies used by Google”, “Personalized advertising” (activation / deactivation / settings).
- Microsoft services: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Data protection at Microsoft”, “Data protection and privacy (Trust Center)”, data protection declaration, data protection dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialized third parties to access required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- Cyon: Hosting; Provider: cyon GmbH (Switzerland); Data protection information: “Data protection”, Privacy policy.
- WordPress.com: blog hosting and website builder; provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among other countries; information on data protection: privacy policy, cookie policy.
11.2 Automation and integration of apps and services
We use specialized platforms to integrate and connect existing third-party apps and services. We can also use such “no-code” platforms to automate processes and activities with third-party apps and services.
We use in particular:
- Microsoft Power Automate including Microsoft Power Platform: Integrated application platform; Provider: Microsoft; Microsoft Power Platform-specific information on data protection: “Compatibility and data protection”, “Data storage and governance”, “Security”.
11.3 Contact options
We use services from selected providers to better communicate with third parties, such as potential and existing customers.
We use in particular:
- Microsoft Dynamics 365: Customer Relationship Management (CRM); Service provider: Microsoft;
Microsoft Dynamics-specific information: “Data protection and personal data
in Microsoft Dynamics 365″.
11.4 Scheduling
We use services of specialized third parties to make appointments online, for example for meetings. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.
We use in particular:
- Calendly: Appointment automation platform; Service provider: Calendly LLC (USA); Information
on data protection: Privacy policy, “Security”.
11.5 Audio and video conferencing
We use specialized audio and video conferencing services to communicate online. For example, we can use it to hold virtual meetings or conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as data protection declarations and
terms of use, also apply. Depending on the life situation, we recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences
.
We use in particular:
- Microsoft Teams: Platform for audio and video conferencing, among other things; Service provider:
Microsoft; Teams-specific information: “Data protection and Microsoft Teams”.
11.6 Digital audio and video content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
We use in particular:
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Privacy and Security Center”, “My Data on YouTube”.
11.7 Fonts
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”.
11.8 Advertising
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
We would like to use such advertising in particular to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine
whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are logged in as a user may be able to assign the use of our website to your profile there.
We use in particular:
- Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting in particular with the Facebook pixel as well as Custom Audiences including Lookalike Audiences, data protection declaration, “advertising preferences” (user registration required).
- Google Ads: search engine advertising; provider: Google; Google Ads-specific data: Advertising based on search queries, among other things, using different domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, “Advertising” (Google), “Why do I see a certainAdvertising?”.
- Instagram Ads: Social media advertising; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Remarketing and targeting, in particular with Facebook pixels and custom audiences including lookalike audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), “Advertising preferences” (Instagram) (registration as a user or
user required), “Advertising preferences” (Facebook) (registration as a user or
user required). - LinkedIn Ads: Social media advertising; Provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Data protection information: Remarketing and targeting in particular with the LinkedIn Insight Tag, “Data protection”, Privacy policy, Cookie policy, Objection to personalized advertising.
12. extensions for the website
We use extensions for our website in order to be able to use additional functions.
We use in particular:
- Jetpack: Various functions for the free blog software WordPress in the form of modules; provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd (Ireland) for users in Europe and elsewhere; Information on data protection: Privacy Notice for Visitors to Our Users’ Sites, Privacy Policy (by Automattic), “Jetpack Privacy Center”, Cookie Policy (Jetpack), Cookie Policy
(Automattic).
13. success and reach measurement
We are trying to determine how our online offering is being used. In this context, we can, for example, measure the success and reach of our activities and operations, as well as the impact of third-party links to our website. However, 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 for the purpose of success and reach measurement. In this case, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach and user profiles may be created. User profiles that may be 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,
user profiles are only created in pseudonymized form and are not used to identify individual users. Individual services of third parties with which users are registered can, at most, assign the use of our online offer to the user account or user profile with the respective service.
We use in particular:
- Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized IP addresses, which are only transmitted in full to Google in the USA as an exception, “Privacy Policy”, “Browser Add-on to deactivate Google Analytics”.
- Google Tag Manager: Integration and management of other services for success and reach measurement as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager”; further information on data protection can be found at the individual integrated
and managed services. - Leadfeeder: identification of companies for possible pre-contractual measures (“lead generation”); provider: Liidio Oy (Finland); data protection information: privacy policy, privacy policy for “Leadfeeder Contacts”, cookie policy.
- WordPress.com Stats: performance and reach measurement; provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe and elsewhere; Data protection information: Module of the Jetpack extension for the free blog software WordPress, Privacy Notice for Visitors to Our
Users’ Sites, Privacy Policy (by Automattic), Jetpack Privacy Center, Cookie Policy.
14. final provisions
We have created this privacy policy with the data protection generator of Datenschutzpartner.
We may amend and supplement this privacy policy at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.
