Privacy Policy

PRIVACY POLICY

With this privacy policy we inform you which personal data we process in connection with our activities and operations, including our website. In particular, we provide information on what personal data we process, for what purpose, how and where. We also provide information about the rights of persons whose data we process.

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

We are subject to Swiss data protection law and any applicable foreign data protection law, such as in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.

1. CONTACT ADDRESSES

Responsibility for the processing of personal data:

GRUEBER AG
Scheideggstrasse 73
CH-8038 Zurich

reception@grueber-ag.ch

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

2. TERMS AND LEGAL BASIS

2.1 Terms

Personal data is 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, such as retrieving, matching, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organising, 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 the processing of personal data.

2.2 Legal basis

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

We process personal data – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with at least one of the following legal bases:

–      Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.

–      Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order 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, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.

–      Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data 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 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task which is in the public interest.

–      Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.

–      Art. 6 (1) (d) GDPR for the processing of personal data necessary to protect the 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 sustainable, user-friendly, secure and reliable manner. In particular, 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.

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 is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit 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 with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the fulfilment of a contract with the data subject and for corresponding pre-contractual measures, in order to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example, by letter, email, 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 relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection with regard 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.

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 performance of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process 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.

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular in accordance with Art. 9 Para. 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 local law 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 – adequate data protection in accordance with the decision of the European Commission.

We may transfer personal data to countries whose law does not ensure 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 appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees on request.

6. RIGHTS OF DATA SUBJECTS

6.1 Data protection rights

We grant data subjects all rights under 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 that personal data is. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed 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 disclosure 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, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can inform data subjects of any requirements they must meet 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 exceptionally provide for costs for the exercise of rights. We inform data subjects in advance of any costs.

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

6.2 Right of appeal

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 the right – if and to the extent that 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 appropriate technical and organisational measures to ensure data security commensurate with the risk involved. 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 HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication is subject – as is basically all digital communication – 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

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 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. Cookies make it possible in particular to recognise 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 your express consent to the use of cookies – at least if and to the extent necessary.

8.2 Server log files

We may record 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, Internet Protocol (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, website last accessed in the same browser window (referer or referee).

We may store such information in server log files, which may also constitute personal data. This information is necessary in order to provide our website in a permanent, user-friendly and reliable manner and 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 pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those 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 collect the same information as in server log files.

8.4 Comments

We may allow you to post comments on our website. In this context, we process in particular the information that a commenting person transmits to us him/herself, but also the Internet Protocol (IP) address used as well as the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.

9. NOTIFICATIONS AND MESSAGES

We send notifications and communications by email and via other communication channels such as instant messaging or SMS.

9.1 Performance and reach measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner based on the needs and reading habits of the recipients, 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 such use is permitted for other legal reasons. For any consent we use the “double opt-in” procedure where possible, i.e. you receive an e-mail with a web link which you must click to confirm so that no misuse by unauthorised third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.

In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is without prejudice to necessary notifications and communications in connection with our activities and operations.

10. SOCIAL MEDIA

We are present on social media platforms and other online platforms as required in order to communicate with interested persons and to provide information 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. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

11. SERVICES OF THIRD PARTIES

We use the services of specialised third parties in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed features and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the 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, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

–      Services from Google: Providers: 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”, data protection statement, “Google is committed to complying with applicable data protection laws”, “Guide to data protection in Google products”, “How we use data from websites or apps on or in which our services are used” (information provided by Google), “Types of cookies and other technologies used by Google”, “Personalised advertising” (activation / deactivation / settings).

11.1 Digital infrastructure

We use the services of specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers. We will provide information about our infrastructure if there is a justified interest. The existing providers have been evaluated and implemented with due diligence and are operated in this way.

11.2 Contact options

We use services from selected providers in order to better communicate with third parties such as potential as well as existing customers.

11.3 Audio and video conferencing

We use specialised audio and video conferencing services to communicate online. For example, we can 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 apply in addition.

Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences as well as blurring the background or having a virtual background superimposed.

We use in particular:

–      Zoom: video conferencing; provider: Zoom Video Communications Inc. (USA); information on data protection: data protection declaration, “Data Protection at Zoom”, “Legal Compliance Centre”.

12. ENHANCEMENTS TO THE WEBSITE

Our websites are built using modern CMS technology and are enhanced with the following plugins: Advanced Custom Fields Multilingual | Advanced Custom Fields PRO | Classic Editor | Customizer Remove All Parts | Google XML Sitemaps | Regenerate Thumbnails | WPML Multilingual CMS | WPML String Translation | Enable Media Replace | Google Search Console.

We neither collect nor analyse data from website visits.

13. FINAL PROVISIONS

We may amend and supplement this Privacy Policy at any time. We will inform you about such adjustments and amendments in an appropriate manner, in particular by publishing the respective current data policy on our website.

Version: September 2023