1. contact addresses
Responsibility for the processing of personal data:
Online Consulting AG
CH – 9500 Wil
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. terms and legal bases
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 out, disclosing, procuring, recording, collecting, 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) plus 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 permanently, in a user-friendly, secure and reliable manner, as well as to communicate about them, ensuring
of information security, protection against misuse, enforcement of its own legal claims, and compliance 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
is required, are 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
around 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 mail, e-mail, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a Customer-
If we receive data about other persons, the transmitting persons are obligated to ensure data protection with respect to 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.
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 edit
furthermore, those personal data that applicants voluntarily communicate or publish, in particular as part of cover letters, resumes 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 in order to process it or have it processed there.
We may export personal data to all states and territories on Earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection in accordance with the decision of the Swiss Federal Council and – if and to the extent that 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 laws do not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may transfer Personal Data to countries without adequate or appropriate
data protection, if the special data protection requirements for this 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
a copy of any guarantees.
6. rights of data subjects
6.1 Data protection law claims
We grant data subjects all claims in accordance with 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 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 can point out to data subjects any requirements they may have to meet in order to exercise their rights under data protection law.
For example, we may refuse to provide information in whole or in part on the grounds of trade secrets or the protection of others. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.
We may exceptionally provide for costs for the exercise of the rights. We inform affected persons in advance about any costs. We are obligated to notify data subjects who request information or assert other rights
with appropriate measures. Affected persons are obliged to cooperate.
6.2 Right to complain
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – the right 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.
Access to our website takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communications – like all digital communications in principle – are subject to mass surveillance without cause or suspicion and other monitoring 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
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 allow a browser to be used on the next visit
of our website and thereby, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for many 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) is possible.
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-page of our website called up including amount of data transferred, website last called up in the same browser window (referer).
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. For any consent, we use the “double opt-in” method whenever possible, which means that you will receive an e-mail with a web link that you must click to confirm
to prevent misuse by unauthorized third parties. We may log such consents including IP address, date and time for evidentiary and security purposes.
In principle, 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:
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 of Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are – if and insofar as the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The side
Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.
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 an embedding, the services used record for technically compelling reasons at least temporarily
the IP addresses of the users.
For necessary security, statistical and technical purposes, third parties whose services we use may process data related to 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:
- 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:
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:
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); Provider: Microsoft;
Microsoft Dynamics-specific information: “Privacy and personal data
in Microsoft Dynamics 365″.
We use in particular:
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
mute the microphone by default and blur the background or fade in a virtual background.
We use in particular:
11.6 Digital audio and video content
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”.
We use the option to display targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.
We would like to use such advertising to reach in particular 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 state,
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 registered 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?”.
User required), “Advertising preferences” (Facebook) (login as user.
12. extensions for the website
We use extensions for our website in order to be able to use additional functions.
We use in particular:
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. But we can also, for example, try out and compare how different parts or versions of our
online offer are used (“A/B test” method). Based on the results of the performance 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 performance and reach measurement. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.
Cookies may be used for performance and reach measurement 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. Basically
any user profiles are created exclusively on a pseudonymous basis 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 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 with the individual integrated services.
and managed services.
14. final provisions