Privacy policy

Status: 13 October 2023

Table of contents

Responsible

Dr. Helmut Schwärzler – Schwärzler Attorneys at Law, Austrasse 42, 9490 Vaduz, Principality of Liechtenstein, E-mail address: liechtenstein@s-law.com, Telephone: +423 239 85 40, Imprint: https://concordanz.com/en/imprint/

Contact Data Protection Officer

Dr. Hannah Blecha, Austrasse 42, LI-9490 Vaduz, Tel. +4232398540, datenschutz@s-law.com.

Overview of the processing

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

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Applicant data.

Categories of persons concerned

  • Interested parties.
  • Communication partner.
  • Users.
  • Applicants.
  • Business and contractual partners.
  • Clients.

Purposes of the processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organisational procedures.
  • Remarketing.
  • Conversion measurement.
  • Click tracking.
  • Bildung von Zielgruppen.
  • Managing and responding to enquiries.
  • Application procedure.
  • Content Delivery Network (CDN).
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Relevant legal basis according to the GDPR: The following is an overview of the legal basis 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 be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (1) p. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Contractual performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Rightful interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 p. 1 lit. b) DSGVO) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants within the scope of the application procedure, the data controller or the data subject shall provide the data required of him or her under labour law and social security and ethnic origin law. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to him or her under labour law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO.
  • Processing of special categories of personal data in relation to healthcare, occupation and social security (Art. 9(2)(h) GDPR).
  • Consent to the processing of special categories of personal data (Art. 9 para. 2 lit. a) DSGVO).
  • Processing of special categories of personal data for the protection of vital interests (Art. 9(2)(c) GDPR).

National data protection regulations in Lichtenstein: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Lichtenstein. These include in particular the Data Protection Act (DPA) and the Data Protection Ordinance (DPO).

Applicable legal basis under the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Federal Data Protection Act (the “Swiss DPA” for short). This also applies if our processing of your data otherwise concerns 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 must be stated for the processing of personal data. 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 DPA). Furthermore, personal data is only obtained by us for a specific purpose that is identifiable to the data subject and is only processed in a way that is compatible with those purposes (Art. 6 para. 3 of the Swiss FADP).

Note on applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (DSGVO). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “personal data requiring special protection” used in the Swiss DPA, the terms “processing” of “personal data” as well as “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 its application.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.

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 to, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

TLS/SSL encryption (https): To protect user data transmitted through 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.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Transfer of data within the organisation: We may transfer or provide access to personal data to other entities within our organisation. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or is made where it is necessary for the performance of our contract-related obligations or where there is consent from the data subjects or legal permission.

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 DSGVO), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) of the GDPR), explicit consent or in the case of contractual or legally required transfers (Art. 49 (1) of the GDPR). In all other respects, we will inform you of the basis for third-country transfers in the case of the individual third-country providers, with the adequacy decisions taking precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the EU Commission’s information service: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called ‘Data Privacy Framework’ (DPF), the EU Commission has also recognised the level of data protection for certain companies from the US as secure within the framework of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you in our data protection notice which service providers we use are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the persons concerned is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined that adequate protection is provided (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations that have been pre-approved by the FDPIC or a competent data protection authority in another country.

According to Art. 16 of the Swiss FADP, exceptions may be allowed for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited 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 reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. Within the framework of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing operations.

Rights of the data subjects

Data subjects’ rights 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 at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke consents granted at any time.
  • Right of access: You have the right to request confirmation as to whether 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: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to deletion and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data relating to you be deleted without delay, or alternatively, in accordance with the statutory provisions, to demand restriction of the processing of the data.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another person responsible.
  • Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you violates 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 Data Protection Act:

  • 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 exercise 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 common electronic format.
  • Right to rectification: You have the right to request that inaccurate personal data relating to you be rectified.
  • 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 memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, are absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. Cookies that are strictly necessary usually include cookies with functions that serve the display and operability of the online offer , load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by users. The revocable consent will be clearly communicated to the users and will contain 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 consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his 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. Likewise, user data collected with the help of cookies can 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.

General information on revocation and objection (so-called ‘opt-out’): Users can revoke their consent at any time and object to the processing in accordance with the legal requirements. To do this, users can, among other things, 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/.

Cookie settings/objection option:

Privatsphäre-Einstellungen ändern
  • Types of data processed: Meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further information on processing processes, procedures and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure in which users’ consent to the use of cookies, or the processing and providers specified in the cookie consent management procedure, is obtained and can be managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and so that consent can be proven in accordance with the legal obligation. Storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used; Legal basis: Consent (Art. 6(1)(a) GDPR).
  • Real Cookie Banner: Cookie consent management; Service provider: devowl.io GmbH, Tannet 12, 94539 Grafling, Germany; Legal basis: legitimate interests (Art. 6(1)(f) GDPR); Website: https://devowl.io/de/wordpress-real-cookie-banner/. Privacy policy: https://devowl.io/de/datenschutzerklaerung/.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall begin at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual accounts or the management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category).
  • Persons concerned: Interested parties; business and contractual partners. Clients.
  • Purposes of processing: Providing contractual services and fulfilling contractual obligations; contact requests and communication; office and organisational procedures. Administration and response to requests.
  • Legal basis: Contractual fulfilment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further information on processing processes, procedures and services:

  • Legal advice: We process the data of our clients, interested parties and other clients or contractual partners (collectively referred to as ‘clients’) in order to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship. Provided that the client has given their consent, that it is necessary for the performance of our contract, required by law (e.g. in accordance with the information requirements of money laundering regulations) or for the protection of vital interests, or that it is carried out in accordance with the protection interests of the client on the basis of our legitimate interests in the efficient and secure performance of our activities, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with professional law requirements; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 (1) (b) GDPR).

Provision of the online offer and web hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • 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); content data (e.g. entries in online forms).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); Security measures. Content Delivery Network (CDN).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a server provider (also known as a ‘web host’); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called ‘server log files’. Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks) and to ensure server utilisation and stability. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Content delivery network: We use a content delivery network (CDN). A CDN is a service that helps deliver content from an online offering, especially large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the internet; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Cloudflare: Content delivery network (CDN) service that enables the faster and more secure delivery of online content, in particular large media files such as graphics or program scripts, using regionally distributed servers connected via the Internet; service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.cloudflare.com; Privacy policy: https://www.cloudflare.com/privacypolicy/; Order processing contract: https://www.cloudflare.com/cloudflare-customer-dpa. Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.cloudflare.com/cloudflare-customer-scc).
  • Hostpoint: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Hostpoint AG, Neue Jonastrasse 60, 8640 Rapperswil-Jona, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://support.hostpoint.ch/de/. Privacy policy: https://www.hostpoint.ch/hostpoint/kontakt-agb.html#datenschutz.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • Types of data processed: Inventory data (e.g. names, addresses); 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).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Providing contractual services and fulfilling contractual obligations; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the details of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

  • Types of data processed: Contact details (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 procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • People concerned: Communication partner.
  • Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further information on processing processes, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Application procedure

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

In principle, the required information includes personal information such as the name, address, a means of contact and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services from third party providers in compliance with legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

Processing of special categories of data: Insofar as special categories of personal data (Article 9(1) of the GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure, they are processed so that the controller or the data subject can exercise his or her rights under labour law and social security and social protection law and fulfil his or her obligations in this respect. The processing is carried out in order to enable the data subject to exercise his or her rights and comply with his or her obligations under labour law and social security and social protection law, in the case of the protection of the vital interests of applicants or other persons, or for preventive health or occupational health purposes, for the assessment of the employee’s fitness for work, for medical diagnosis, for health or social care or treatment, or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified withdrawal by the applicants, at the latest after the expiry of a period of six months to enable us to answer any follow-up questions about the application and to comply with our obligations to provide evidence under the Equal Treatment of Applicants Regulations. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Admission to an applicant pool: Admission to an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates as well as further information on their person or qualifications provided voluntarily by applicants or with regard to a specific position).
  • People concerned: Applicants.
  • Purposes of processing: Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 p. 1 lit. b) GDPR); processing of special categories of personal data in relation to healthcare, occupation and social security (Art. 9 para. 2 lit. h) GDPR); consent to the processing of special categories of personal data (Art. 9 para. 2 lit. a) GDPR). Processing of special categories of personal data for the protection of vital interests (Art. 9(2)(c) GDPR).

Promotional communication via e-mail, post, fax or telephone

We process personal data for the purposes of promotional communication, which may be via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.

After revocation or objection, we store the data required to prove the previous entitlement to contact or send up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. Based on the legitimate interest of permanently observing the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers).
  • People concerned: Communication partner.
  • Zwecke der Verarbeitung: Direktmarketing (z. .B. per E-Mail oder postalisch).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Web analysis, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data summarised 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 from it. The information collected includes, in particular, websites visited and 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 agreed 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 the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as 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 purpose of the respective procedures.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time details, identification numbers, consent status).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Remarketing; targeting; reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further information on processing processes, procedures and services:

  • Google Analytics 4: We use Google Analytics to measure and analyse 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 recognise which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log and store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data are used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible and are not used for any other purpose. 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, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms); Possibility of objection (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated. Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).
  • Target grouping with Google Analytics: We use Google Analytics to display the ads placed within Google’s advertising services and those of its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences” or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of the users.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Legal basis: https://business.safety.google/adsprocessorterms/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. DData Processing Terms and Conditions for Google Advertising Products and Standard Contractual Clauses for Third Country Data Transfers: https://business.safety.google/adsprocessorterms.
  • Google Analytics in consent mode: In consent mode, personal data of users are processed by Google for measurement and advertising purposes, depending on the consent of the users. Consent is obtained from users as part of our online services. In the absence of user consent altogether, data will only be processed at an aggregate (i.e. not associated and summarised with individual users) level. If the consent only includes statistical measurement, no personal data of the users will be processed for the ad placement or the measurement of the advertising success (so-called “conversion”); Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Website: https://support.google.com/analytics/answer/9976101?hl=de.
  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms. Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms).

Onlinemarketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation 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 online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time details, identification numbers, consent status).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioural profiling, use of cookies); marketing; profiling with user-related information (creating user profiles); conversion measurement (measuring the effectiveness of marketing measures); remarketing; provision of our online offer and user experience. Click tracking.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Possibility of objection (opt-out):: We refer you to the data protection notices of the respective providers and the options for objection (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Kanada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territorial: https://optout.aboutads.info.

Further information on processing processes, procedures and services:

  • Google Ads and conversion measurement: Online marketing practices for the purpose of placing content and ads within the service provider’s advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
  • Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list so that users can be shown ads on other online services based on their visit to the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
  • Enhanced conversions for Google Ads: When customers click on our Google ads and subsequently use the advertised service (so-called “conversion”), the data entered by the user, such as the email address, name, home address or phone number, can be transmitted to Google. The hash values are then matched with existing Google accounts of the users in order to better evaluate and improve the interaction of the users with the ads (e.g. clicks or views) and thus their performance; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Website: https://support.google.com/google-ads/answer/9888656.
  • UTM Parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the “UTM” parameter. For example, a UTM parameter can be “utm_source=plattformX &utm_medium=video” tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video) . With the help of this information we can e.g. B. check our online visibility or the effectiveness of our campaigns; Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Presences in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example: B. enforcement of users’ rights could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, B. Usage profiles can be created based on usage behavior and the resulting interests of the users. The usage profiles can in turn be used, for example. B. to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (particularly 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 options for objection (opt-out), we 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 the rights of those affected, we would also like to point out that these can most effectively be asserted with the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Contact details (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 procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected persons: 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 basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Changes and updates to the data protection declaration

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us 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 statement, please note that the addresses may change over time and please check the information before contacting us. Supervisory authority responsible for us:

Princely High Court Spaniagasse 1, 9490 Vaduz https://www.gerichte.li/

Definitions

This section provides you with an overview of the terms used in this privacy statement. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to help you understand them.

  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that can be used to deliver the content of an online offering, in particular large media files such as graphics or program scripts, more quickly and securely with the help of regionally distributed servers connected via the Internet.
  • Click tracking: Click tracking allows us to keep track of users’ movements within an entire online experience. Since the results of these tests are more accurate if the interaction of users can be tracked over a certain period of time (e.g., so that we can find out whether a user likes to return), cookies are usually stored on users’ computers for these testing purposes.
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • 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, comprises any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.). e.g. interaction with websites and their content, etc.), or to predict them (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: Range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offers can recognise, for example, at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: We speak of “remarketing” or “retargeting” when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: Tracking is when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: A “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.
  • Processing: “Processing” is any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
  • Custom Audiences: Custom Audiences are defined as target groups for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he or she viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
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