Mandatropa Ltd – Administration, Finance and Trustee Company

1. what is this privacy policy about?

Mandatropa AG (hereinafter also referred to as "we", "us") obtains and processes personal data concerning you or other persons (so-called "third parties"). We use the term "data" here synonymously with "personal data" or "personal data".

"Personal data" refers to data that relates to specific or identifiable persons, i.e. it is possible to draw conclusions about their identity on the basis of the data itself or with corresponding additional data. "Particularly sensitive personal data" is a category of personal data that is particularly protected by the applicable data protection law. For example, data revealing racial and ethnic origin, health data, information on religious or philosophical beliefs, biometric data for identification purposes and information on trade union membership are considered to be particularly sensitive personal data. Section 3 contains information on the data that we process within the scope of this privacy policy. "Processing" means any handling of personal data, e.g. obtaining, storing, using, adapting, disclosing and deleting.

In this Privacy Policy, we describe what we do with your data when you use www.mandatropa.ch, other websites of ours or our apps (hereinafter collectively referred to as the "Website"), purchase our services or products, are otherwise in contact with us under a contract, communicate with us or otherwise deal with us. Where appropriate, we will provide you with timely written notice of additional processing activities not mentioned in this Privacy Policy. In addition, we may inform you separately about the processing of your data, e.g. in declarations of consent, contractual terms, additional data protection declarations, forms and notices.

If you transmit or disclose data about other persons, e.g. family members, work colleagues, etc., we assume that you are authorised to do so and that this data is correct. By transmitting data about third parties, you confirm this. Please also ensure that these third parties have been informed of this privacy policy.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DSG") and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.

2 Who is responsible for processing your data?

Mandatropa AG - Verwaltungs-, Finanz- und Treuhand-Gesellschaft, Zurich ("Mandatropa AG"), is responsible under data protection law for the data processing activities of Mandatropa AG described in this data protection declaration, unless otherwise communicated in individual cases, e.g. in other data protection declarations, on forms or in contracts. However, unless otherwise communicated, this Privacy Policy also applies to cases in which Mandatropa AG is not the controller, but rather a group company of the Mandatropa AG Group. This is particularly the case where your data is processed by such a group company in connection with its own legal obligations or contracts or where you share data with such a group company. In these cases, this group company is the controller and only if you share your data with other group companies for their own purposes (see section 7) do these other group companies also become controllers.

For each data processing operation, there are one or more entities that are responsible for ensuring that the processing complies with the requirements of data protection law. This body is called the controller. It is responsible, for example, for responding to requests for information (section 11) or ensuring that personal data is secured and not used in an unauthorised manner.

Other bodies may also be jointly responsible for the data processing described in this privacy policy if they are involved in deciding on the purpose or organisation. All Group companies come into question. If you would like details of the individual controllers for a specific data processing operation, you are welcome to request information from us within the scope of the right to information (Section 11). Mandatropa AG remains your primary contact, even if there are other joint controllers.

In section 3, section 7 and section 12 you will find further information on third parties with whom we work and who are responsible for their processing. If you have any questions or wish to exercise your rights vis-à-vis these third parties, please contact them directly.

You can contact us as follows for your data protection concerns and to exercise your rights in accordance with section 11:

Mandatropa AG
Bahnhofstrasse 106
CH-8001 Zurich
inaef@mandatropa.ch

3 What data do we process?

We process different categories of data about you. The most important categories are as follows:

Technical data: When you use our website or other electronic services, we collect the IP address of your end device and other technical data to ensure the functionality and security of these services. This data also includes logs in which the use of our systems is recorded. We generally store technical data for 6 months. To ensure the functionality of these services, we may also assign you or your end device a personalised code (e.g. in the form of a cookie, see section 12).The technical data itself does not allow any conclusions to be drawn about your identity.However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other categories of data (and thus possibly to your person).

The technical data includes, among other things, the IP address and information about the operating system of your end device, the date, region and time of use as well as the type of browser you use to access our electronic offers.This can help us to transmit the correct formatting of the website or, for example, to show you a website customised for your region. Although we know from the IP address which provider you are using to access our website (and therefore also the region), we cannot usually deduce who you are from this.This changes if you create a user account, for example, because personal data can then be linked to technical data (e.g. we can see which browser you are using to access an account via our website).Examples of technical data include protocols ("logs") that are generated in our systems (e.g. the log of user logins on our website).

Registration data:Certain offers, e.g. of competitions and services (e.g. login areas of our website, newsletter dispatch, free WLAN access, etc.) can only be used with a user account or registration, which can be done directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data on the use of the offer or service.Registration data may be collected during access controls to certain systems; depending on the control system, biometric data may also be collected.We generally retain registration data for 12 months after the end of the use of the service or the cancellation of the user account.

Registration data includes the information you provide when you create an account on our website (e.g. user name, password, name, e-mail address). However, registration data also includes the data that we may require from you before you can make use of certain free services, such as the redemption of vouchers, in this case: name, address, contact details, time of redemption. You must also register if you wish to subscribe to our newsletter. As part of access controls, we may need to register you with your data (access codes in badges, biometric data for identification) (see the "Other data" category).

Communication data: If you are in contact with us via the contact form, by e-mail, telephone or chat, by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we record or listen in on telephone conversations or video conferences, e.g. for training and quality assurance purposes, we will make you aware of this. Such recordings may only be made and used in accordance with our internal guidelines. You will be informed if and when such recordings take place, e.g. by a display during the video conference in question. If you do not wish to be recorded, please let us know or end your participation. If you simply do not wish your image to be recorded, please switch off your camera. If we want or need to establish your identity, e.g. if you request information, apply for media access, etc., we will collect data to identify you (e.g. a copy of your ID). We generally store this data for 12 months from the last exchange with you. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. Emails in personal mailboxes and written correspondence are generally stored for at least 10 years. Recordings of (video) conferences are generally stored for 24 months. Chats are generally stored for 2 years.

Communication data includes your name and contact details, the manner, place and time of communication and, as a rule, its content (i.e. the content of emails, letters, chats, etc.). This data may also contain information about third parties. For the purpose of identification, we may also process your ID number or a password specified by you or your press card. For secure identification, the following mandatory information must be provided for media enquiries: Publisher, name of the publication, title, first name, surname, postal address, e-mail address and telephone number of the person submitting the report.

Master data:We define master data as the basic data that we require in addition to the contractual data (see below) for the processing of our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details and information, e.g. about your role and function, your bank account(s), your date of birth, customer history, powers of attorney, signature authorisations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (e.g. as a contact person of the business partner), or because we want to contact you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.).We receive master data from you (e.g. when you make a purchase or register), from organisations for which you work or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the internet (websites, social media, etc.).We may also process health data and information about third parties as part of master data.We may also collect master data from our shareholders and investors.We generally store this data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.In the case of pure marketing and advertising contacts, the period is normally much shorter, usually no more than 2 years from the last contact.

Master data includes, for example, data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, details of associated persons, websites, social media profiles, photos and videos, copies of ID cards; furthermore, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status with us, details of your relationship with us (customer, supplier, visitor, service recipient, etc.) and details of your relationship with us (customer, supplier, visitor, service recipient, etc.). We also collect information about your relationship with us (customer, supplier, visitor, service recipient, etc.), information about your status with us, allocations, classifications and distribution lists, information about our interactions with you (possibly a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. extracts from the commercial register, authorisations, etc.) that relate to you.We collect payment details such as your bank details, account number and credit card details. Consent or blocking notices are also part of the master data, as is information about third parties, e.g. contact persons, recipients of services, advertising recipients or representatives.

For contact persons and representatives of our customers, suppliers and partners, we process master data such as name and address, information on role, function in the company, qualifications and, if applicable, information on superiors, employees and subordinates and information on interactions with these persons.

Master data is not collected comprehensively for all contacts. Which data we collect in detail depends in particular on the purpose of the processing.

Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g. information on contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information on reactions (e.g. complaints or information on satisfaction, etc.). This also includes health data and information about third parties, e.g. about hereditary diseases in the family. We generally collect this data from you, from contractual partners and from third parties involved in the fulfilment of the contract, but also from third-party sources (e.g. providers of creditworthiness data) and from publicly accessible sources. We generally store this data for 10 years from the last contractual activity, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.

Contract data includes information about the conclusion of the contract, about your contracts, e.g. type and date of conclusion of the contract, information from the application process (such as an application for our products or services) and information about the contract in question (e.g. its duration) and the processing and administration of the contracts (e.g. information in connection with invoicing, customer service, support with technical matters and the enforcement of contractual claims). Contract data also includes information on defects, complaints and adjustments to a contract, as well as information on customer satisfaction, which we can collect e.g. by means of surveys. Contract data also includes financial data such as information on creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood of claims being settled), reminders and debt collection. We receive some of this data from you (e.g. when you make payments), but also from credit agencies and debt collection agencies and from publicly accessible sources (e.g. a commercial register).

Behavioural and preference data: Depending on the relationship we have with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behaviour and preferences.We do this by evaluating information about your behaviour in our area, and we may also supplement this information with data from third parties, including from publicly accessible sources.Based on this, we can, for example, calculate the probability that you will use certain services or behave in a certain way.Some of the data processed for this purpose is already known to us (e.g. when you use our services), or we obtain this data by recording your behaviour (e.g. how you navigate our website or by determining your movement profile, e.g. by using your mobile phone).We anonymise or delete this data when it is no longer relevant for the purposes pursued, which can be between 2-3 weeks (for movement profiles) and 24 months (for product and service preferences), depending on the type of data.This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.We describe how tracking works on our website in section 12.

Behavioural data is information about certain actions, e.g. about your reaction to electronic messages (e.g. whether and when you opened an email) or about your location as well as about your interaction with our social media profiles and about your participation in competitions, contests and similar events. For example, we may collect your location data wirelessly through unique codes sent by your mobile phone or when you use our website. We will inform you of the collection of anonymous movement profiles at the relevant locations by means of appropriate signs; we will only create a personalised movement profile with your consent.

Preference data provides us with information about your needs, which products or services might be of interest to you or when and how you are likely to react to messages from us.We obtain this information from the analysis of existing data, such as behavioural data, so that we can get to know you better, tailor our advice and offers more precisely to you and generally improve our offers. In order to improve the quality of our analyses, we can link this data with other data that we also obtain from third parties such as address dealers, government agencies and publicly accessible sources such as the Internet, e.g. with information on your household size, income bracket and purchasing power, shopping behaviour and contact details of relatives and anonymous information from statistical offices.

Other data: We also collect data from you in other situations. In connection with official or court proceedings, for example, data is collected (such as files, evidence, etc.) that may also relate to you. We may also collect data for health protection reasons (e.g. as part of protection concepts). We may receive or produce photos, videos and audio recordings in which you may be recognizable (e.g. at events, through security cameras, etc.). We may also collect data about who enters certain buildings or has access rights to them and when (including during access controls, based on registration data or visitor lists, etc.), who takes part in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems and when. Finally, we collect and process data about our shareholders and other investors; in addition to master data, this includes information for the relevant registers, regarding the exercise of their rights and the holding of events (e.g. general meetings). The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and usually a few weeks for contact tracing data to visitor data, which is usually stored for 3 months, to reports on events with images, which may be stored for several years or longer. Data about you as a shareholder or other investor will be retained in accordance with the requirements of company law, but in any case for as long as you are invested.

You provide us with much of the data mentioned in this Section 3 yourself (e.g. via forms, in the context of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. in the context of binding protection concepts (legal obligations). If you wish to conclude contracts with us or make use of services, you must also provide us with data as part of your contractual obligation in accordance with the relevant contract, in particular master data, contract data and registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data. In the case of behavioral and preference data, however, you always have the option of objecting or not giving your consent.

We will only provide you with certain services if you provide us with registration data because we or our contractual partners want to know who is using our services or has accepted an invitation to an event, because it is technically necessary or because we want to communicate with you. If you or a person you represent (e.g. your employer) wishes to conclude or fulfill a contract with us, we must collect corresponding master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offers for this purpose. If you do not provide us with the data required for the conclusion and execution of the contract, you must expect that we will refuse to conclude the contract, that you will commit a breach of contract or that we will not fulfill the contract. Similarly, we will only be able to send you a response to an inquiry from you if we process the relevant communication data and - if you communicate with us online - possibly also technical data. It is also not possible to use our website without providing us with technical data.

Insofar as this is not inadmissible, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the internet, including social media) or receive data from other companies within our group, from authorities and from other third parties (such as credit reference agencies, address dealers, associations, contractual partners, internet analysis services, etc.).

The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-fraud, anti-money laundering, anti-terrorism and export restrictions, information from banks, insurance companies and sales and other contractual partners of ours on the use or provision of services by you (e.g. payments, purchases, etc.), information from the media and the Internet on the use or provision of services by you (e.g. payments, purchases, etc.) ), personal data from the media and the Internet (where this is appropriate in a specific case, e.g. in the context of a job application, marketing/sales, press review, etc.), your address and, where applicable, interests and other socio-demographic data (in particular for marketing and research) and data in connection with the use of third-party websites and online offers where this use can be attributed to you.

4 For what purposes do we process your data?

We process your data for the purposes explained below. Further information for the online area can be found in sections 12 and 13. These purposes and the underlying objectives represent our legitimate interests and those of third parties where applicable. You will find further information on the legal basis of our processing in section 5. We process your data for purposes related to communication with you, in particular to answer enquiries and assert your rights (section 11) and to contact you in the event of queries. In particular, we use communication data and master data for this purpose and, in connection with offers and services used by you, also registration data. We retain this data in order to document our communication with you, for training purposes, for quality assurance and for enquiries.

This relates to all purposes in connection with which you and we communicate, whether in customer service or counselling, authentication in the event of use of the website or for training and quality assurance (e.g. in the area of customer service). We further process communication data so that we can communicate with you by e-mail and telephone, as well as messenger services, chat, social media, letter and fax. Communication with you usually takes place in connection with other processing purposes, e.g. so that we can provide services or respond to a request for information. Our data processing also serves as proof of communication and its content.

We process data for the establishment, administration and fulfilment of contractual relationships.

We conclude contracts of various kinds with our business and private customers, with suppliers, subcontractors or other contractual partners, such as partners in projects or with parties in legal disputes. In particular, we process master data, contract data and communication data and, depending on the circumstances, registration data of the customer or the persons to whom the customer provides a service. This includes, for example, the recipients of our products or services who receive vouchers and invitations from our customers and who may become our customers when they redeem them. In this case, we process data for the fulfilment of the contract with these recipients, but also with the contractual partners who have invited them.

As part of the business initiation process, personal data - in particular master data, contract data and communication data - is collected from potential customers or other contractual partners (e.g. in an order form or contract) or results from communication. We also process data in connection with the conclusion of the contract to check creditworthiness and to open the customer relationship. In some cases, this information is checked for compliance with legal requirements. As part of the processing of contractual relationships, we process data for the administration of the customer relationship, for the provision and collection of contractual services (which also includes the involvement of third parties, such as logistics companies, security services, advertising service providers, banks, insurance companies or credit agencies, which may in turn provide us with data), for advice and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of processing, as are accounting, termination of contracts and public communication.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalised advertising about our products and services and those of third parties (e.g. advertising contractual partners). This may, for example, take the form of newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions, etc.) and may also include free services (e.g. invitations, vouchers, etc.). You can refuse such contacts at any time (see the end of this section 4) or refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the Internet more specifically to you (see section 12). Finally, we also want to enable our contractual partners to contact our customers and other contractual partners for advertising purposes (see section 7).

For example, with your consent, we will send you information, advertising and product offers from us and from third parties within and outside the Group (e.g. advertising contract partners), as printed matter, electronically or by telephone. For this purpose, we mainly process communication and registration data. Like most companies, we personalise communications so that we can send you individual information and make you offers that meet your needs and interests. To do this, we combine data that we process about you and determine preference data and use this data as the basis for personalisation (see section 3). We also process data in connection with competitions, prize draws and similar events. Relationship management also includes addressing existing customers and their contacts in a personalised manner - where applicable, on the basis of behavioural and preference data. As part of relationship management, we may also operate a customer relationship management system ("CRM"), in which we store the data on customers, suppliers and other business partners necessary for the relationship management, e.g. about contact persons, relationship history (e.g. about products and services purchased or supplied, interactions, etc.), interests, wishes, marketing measures (newsletters, invitations to events, etc.) and other information. All this processing is not only important for us to advertise our offers as effectively as possible, but also to personalise and improve our relationships with customers and other third parties, to focus on the most important relationships and to use our resources as efficiently as possible. We continue to process your data for market research, to improve our services and operations and for product development.

We endeavour to continuously improve our products and services (including our website) and to be able to react quickly to changing needs. We therefore analyse, for example, how you navigate through our website or which products are used by which groups of people and in what way, and how new products and services can be designed (for further details, see section 12). This gives us an indication of the market acceptance of existing products and services and the market potential of new products and services. In particular, we process master data, behavioural data and preference data, but also communication data and information from customer surveys, polls and studies and other information, e.g. from the media, social media, the internet and other public sources. Where possible, we use pseudonymised or anonymised data for these purposes. We may also use media monitoring services or carry out media monitoring ourselves and process personal data in order to carry out media work or to understand and respond to current developments and trends. We use anonymised location data, for example, to make recommendations to our contractual partners on how to avoid peak times. With your consent, we use non-anonymised location data to inform you of interesting offers and products in the vicinity based on your position, to infer your interests from the location data (dwell time) and to inform you which products and services other contractual partners with similar interests have used. We may also process your data for security purposes and for access control.

We continually review and improve the appropriate security of our IT and other infrastructure (e.g. buildings). Like all companies, we cannot rule out data security breaches with absolute certainty, but we do what we can to reduce the risks. We therefore process data e.g. for monitoring, controls, analyses and tests of our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of backup copies. Access controls include controlling access to electronic systems (e.g. logging in to user accounts) as well as physical access control (e.g. building access). For security purposes (preventive and to investigate incidents), we also keep access logs and visitor lists and use surveillance systems (e.g. security cameras). We will inform you of surveillance systems at the relevant locations by means of appropriate signs. We process personal data to comply with laws, instructions and recommendations from authorities and internal regulations ("compliance").

This includes, for example, the implementation of health and safety concepts or the legally regulated fight against money laundering and terrorist financing. In certain cases, we may be obliged to make certain enquiries about customers ("Know Your Customer") or to submit reports to authorities. The fulfilment of disclosure, information or reporting obligations, e.g. in connection with regulatory and tax obligations, also requires or entails data processing, e.g. the fulfilment of archiving obligations and the prevention, detection and clarification of criminal offences and other violations. This also includes the receipt and processing of complaints and other reports, the monitoring of communications, internal investigations or the disclosure of documents to an authority if we have sufficient reason to do so or are legally obliged to do so. Your personal data may also be processed in the event of external investigations, e.g. by a law enforcement or supervisory authority or an authorised private body. We also process data to support our shareholders and other investors and fulfil our obligations in this regard. For all these purposes, we process in particular your master data, your contract data and communication data, but possibly also behavioural data and data from the category of other data. The legal obligations may relate to Swiss law, but also to foreign regulations to which we are subject, as well as self-regulation, industry standards, our own corporate governance and official instructions and requests. We also process data for the purposes of our risk management and in the context of prudent corporate governance, including business organisation and corporate development.

For these purposes, we process master data, contract data, registration data and technical data in particular, but also behavioural and communication data. For example, we need to monitor our debtors and creditors as part of our financial management, and we need to avoid falling victim to offences and abuses, which may require the evaluation of data for corresponding patterns. We may also carry out profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activities (see also section 6). As part of the planning of our resources and organisation of our operations, we must evaluate and process data on the use of our services and other offers or exchange information with others (e.g. outsourcing partners), which may also include your data. The same applies to services provided to us by third parties. As part of our corporate development, we may sell or acquire businesses, parts of businesses or companies to or from others or enter into partnerships, which may also lead to the exchange and processing of data (including from you, e.g. as a customer or supplier or as a supplier representative).

We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

These other purposes include, for example, training and education purposes, administrative purposes (such as the management of master data, accounting and data archiving and the testing, management and ongoing improvement of IT infrastructure), the protection of our rights (e.g. to enforce claims in court, in or out of court and before authorities in Switzerland and abroad or to defend ourselves against claims, for example by preserving evidence, legal clarifications and participation in court or official proceedings) and the evaluation and improvement of internal processes. We may use recordings of (video) conferences for training and quality assurance purposes. The protection of other legitimate interests is also one of the other purposes, which cannot be listed exhaustively.

5 On what basis do we process your data?

If we ask for your consent for certain processing (e.g. for the processing of particularly sensitive personal data, for marketing mailings, for the creation of personalised movement profiles and for advertising control and behaviour analysis on the website), we will inform you separately about the corresponding purposes of the processing. You can withdraw your consent at any time with effect for the future by sending us written notification (by post) or, unless otherwise stated or agreed, by email; our contact details can be found in Section 2. For the withdrawal of your consent in the case of online tracking, see Section 12. If you have a user account, you can also withdraw your consent or contact us via the relevant website or other service. Once we have received notification of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Where we do not ask for your consent for processing, we base the processing of your personal data on the fact that the processing is necessary for the initiation or fulfilment of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in it, in particular to pursue the purposes and associated objectives described above under section 4 and to be able to carry out corresponding measures. Our legitimate interests also include compliance with statutory provisions, insofar as this is not already recognised as a legal basis by the applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and Switzerland). However, this also includes the marketing of our products and services, the interest in better understanding our markets and the secure and efficient management and further development of our company, including its operations.

If we receive sensitive data (e.g. health data, information on political, religious or ideological views or biometric data for identification purposes), we may also process your data on the basis of other legal grounds, e.g. in the event of disputes due to the necessity of processing for possible litigation or the enforcement or defence of legal claims. In individual cases, other legal grounds may apply, which we will communicate to you separately if necessary.

6 What applies to profiling and automated individual decisions?

We may automatically evaluate certain of your personal characteristics for the purposes mentioned in Section 4 using your data (Section 3) ("profiling") if we want to determine preference data, but also to determine abuse and security risks, carry out statistical analyses or for operational planning purposes. For the same purposes, we can also create profiles, i.e. we can combine behavioural and preference data, but also master and contract data and technical data assigned to you in order to better understand you as a person with your different interests and other characteristics. However, we can also create anonymous and - with your consent - personalised movement profiles of you.

If you are one of our customers, we can, for example, use "profiling" to determine which other products you are likely to be interested in based on your purchases. We can also use this to check your creditworthiness before offering you a purchase on account. For your protection, an automated analysis of data can also check the likelihood of a particular transaction being fraudulent. This allows us to stop the transaction for clarification. This is to be distinguished from "profiles". This refers to the linking of various data in order to gain information about key aspects of your personality (e.g. what you like or how you behave in certain situations) from the totality of this data. Profiles can also be used for marketing and security purposes, for example.

We use anonymous movement profiles in a non-personalised manner, for example to provide our contractual partners with recommendations on how to avoid peak times. For personalised movement profiles, we use personal data, for example, to draw attention to interesting offers and products in your vicinity, to infer your interests from the position data (dwell time) and to inform you which products and services other contractual partners with similar interests have used or, for example, where health-related protection concepts specify contact tracing.

In both cases, we pay attention to the proportionality and reliability of the results and take measures to prevent misuse of these profiles or profiling. If these can have legal consequences or significant disadvantages for you, we always provide for a manual review.

In certain situations, for reasons of efficiency and consistency of decision-making processes, it may be necessary for us to automate discretionary decisions concerning you with legal effects or potentially significant disadvantages ("automated individual decisions"). In this case, we will inform you accordingly and take the measures required by applicable law.

An example of an automated individual decision is the automatic acceptance of an order by an online shop. Pure if-then decisions are not meant (e.g. if the computer allows you to access your user account after checking your password), but discretionary decisions (e.g. the decision to conclude a contract). We will inform you on a case-by-case basis if an automated decision leads to negative legal consequences or a comparable significant impairment for you. If you do not agree with the result of such a decision, you will be able to communicate with a person who will review the decision.

7 To whom do we disclose your data?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes listed in section 4, we also transfer your personal data to third parties, in particular to the following categories of recipients:

Service providers: We work with service providers in Switzerland and abroad who process data about you on our behalf or under joint responsibility with us or who receive data about you from us under their own responsibility (e.g. IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit agencies, or address verifiers). This may also include health data. For the service providers used for the website, see section 12. Our central service providers in the IT sector are Microsoft and Gnädinger & Davoli AG.

In order to provide our products and services efficiently and to enable us to concentrate on our core competences, we procure services from third parties in numerous areas. These services include IT services, the dispatch of information, marketing, sales, communication and printing services, facility management, security and cleaning, the organisation and staging of events and receptions, debt collection, credit agencies, address verifiers (e.g. to update address databases when relocating), anti-fraud measures and services from consulting firms, lawyers, banks, insurers and telecommunications companies. We provide these service providers with the data required for their services, which may also relate to you. These service providers may also use such data for their own purposes, e.g. information on outstanding debts and your payment behaviour in the case of credit agencies or anonymised information to improve services. In addition, we conclude contracts with these service providers that include provisions for the protection of data, insofar as this does not arise from the law. Our service providers may also process data on how their services are used and other data generated in the course of using their services as independent controllers for their own legitimate interests (e.g. for statistical analyses or billing). Service providers provide information about their independent data processing in their own data protection declarations. You can find more information on how Microsoft processes data here: https://privacy.microsoft.com/de-de/privacystatement; for the use of Microsoft Teams in particular here https://docs.microsoft.com/de-de/microsoftteams/teams-privacy.

Contractual partners including customers: This initially refers to customers (e.g. service recipients) and other contractual partners of ours, as this data transfer arises from these contracts. For example, you receive registration data for vouchers issued and redeemed, invitations, etc. If you work for such a contractual partner yourself, we may also transmit data about you to them in this context. This may also include health data. Recipients also include contractual partners with whom we cooperate or who advertise for us and to whom we therefore transmit data about you for analysis and marketing purposes (these may in turn be service recipients, but also sponsors and providers of online advertising, for example). We require these partners to only send you advertising or display it based on your data if you have consented to this (for the online area, see section 12). Our online advertising contract partners are listed in section 12.

If you act as an employee for a company with which we have concluded a contract, the fulfilment of this contract may result in us informing the company, for example, how you have used our service. Cooperation and advertising contract partners receive selected master, contract, behavioural and preference data from us so that they can carry out non-personal evaluations in their area (e.g. about the number of our customers who have viewed their advertising) and also use data for advertising purposes (including targeting you). For example, advertising contract partners should be able to communicate with suitable other customers of ours and send them advertising.

Public authorities: We may disclose personal data to offices, courts and other authorities in Switzerland and abroad if we are legally obliged or authorised to do so or if this appears necessary to protect our interests. This may also include health data. The authorities process data about you that they receive from us on their own responsibility.

Use cases include criminal investigations, police measures (e.g. health protection concepts, combating violence, etc.), regulatory requirements and investigations, legal proceedings, reporting obligations and pre- and extrajudicial proceedings as well as statutory information and co-operation obligations. Data may also be disclosed if we wish to obtain information from public authorities, e.g. to justify an interest in obtaining information or because we need to say about whom we require information (e.g. from a register).

Other persons: This refers to other cases where the inclusion of third parties arises from the purposes set out in section 4, e.g. recipients of services, media and associations in which we are involved or if you are part of one of our publications.

Other recipients are, for example, delivery recipients or third-party payment recipients other than those specified by you, other third parties also in the context of agency relationships (e.g. if we send your data to your lawyer or bank) or persons involved in official or court proceedings. If we work with the media and send them material (e.g. photos), you may also be affected by this under certain circumstances. The same applies to the publication of content (e.g. photos, interviews, quotes, etc.) on our website or in other publications. As part of our corporate development, we may sell or acquire businesses, parts of businesses, assets or companies or enter into partnerships, which may also result in the disclosure of data (including your data, e.g. as a customer or supplier or as a supplier representative) to the persons involved in these transactions. In the course of communication with our competitors, industry organisations, associations and other bodies, data may also be exchanged that also concerns you.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict the processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.). We reserve the right to disclose this data even if it concerns confidential data (unless we have expressly agreed with you that we will not disclose this data to certain third parties, unless we are legally obliged to do so). Irrespective of this, your data will continue to be subject to appropriate data protection even after disclosure in Switzerland and the rest of Europe. The provisions of Section 8 apply to disclosure to other countries. If you do not wish certain data to be disclosed, please let us know so that we can check whether and to what extent we can accommodate you (Section 2).

In many cases, it is also necessary to disclose confidential data in order to fulfil contracts or provide other services. Confidentiality agreements do not generally exclude such data disclosures, nor do they exclude disclosure to service providers. However, depending on the sensitivity of the data and other circumstances, we ensure that these third parties handle the data appropriately. We cannot comply with your objection to the disclosure of data where the relevant data disclosures are necessary for our activities.

We also allow certain third parties to collect personal data from you on our website and at our events (e.g. media photographers, providers of tools that we have integrated on our website, etc.). Insofar as we are not significantly involved in this data collection, these third parties are solely responsible for it. If you have any concerns and wish to assert your data protection rights, please contact these third parties directly. See section 12 for the website.

8. will your personal data also be transferred abroad?

As explained in section 7, we also disclose data to other organisations. These are not only located in Switzerland. Your data can therefore be processed both in Europe and in the USA; in exceptional cases, however, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection regulations (we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption clause. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the fulfilment of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

Many countries outside Switzerland, the EU and the EEA do not currently have laws that guarantee an adequate level of data protection from the perspective of the FADP or the GDPR. This weaker or lacking legal protection can be partially compensated for with the aforementioned contractual precautions. However, contractual precautions cannot eliminate all risks (in particular from state access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymisation or anonymisation) to minimise it.

Please also note that data exchanged via the Internet is often routed via third countries. Your data may therefore be sent abroad even if the sender and recipient are located in the same country.

9 How long do we process your data?

We process your data for as long as required by our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes, or for as long as storage is technically necessary. Further information on the respective storage and processing periods can be found for the individual data categories in section 3 or for the cookie categories in section 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our normal processes.

Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in the event of legal claims, discrepancies, IT and infrastructure security purposes and proof of good corporate governance and compliance. Retention may be technically necessary if certain data cannot be separated from other data and we therefore need to retain it with them (e.g. in the case of backups or document management systems).

10. how do we protect your data?

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to counteract the risks of loss, unintentional alteration, unwanted disclosure or unauthorised access.

Security measures of a technical and organisational nature may include, for example, measures such as the encryption and pseudonymisation of data, logging, access restrictions, the storage of backup copies, instructions to our employees, confidentiality agreements and controls. We protect your data transmitted via our website in transit using suitable encryption mechanisms. However, we can only secure areas that we control. We also oblige our contract processors to take appropriate security measures. However, security risks cannot be completely ruled out; residual risks are unavoidable.

11 What rights do you have?

Under certain circumstances, the applicable data protection law grants you the right to object to the processing of your data, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing.

To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

The right to request information from us as to whether we are processing your data and, if so, which data;
the right to have us correct data if it is incorrect;
the right to request the deletion of data;
the right to request that we provide you with certain personal data in a commonly used electronic format or transfer it to another controller
the right to withdraw consent where our processing is based on your consent
the right to request further information necessary to exercise these rights
the right to express your point of view on automated individual decisions (Section 6) and to request that the decision be reviewed by a natural person.

If you wish to exercise the above rights against us (or against one of our group companies), please contact us in writing, at our premises or, unless otherwise stated or agreed, by e-mail; our contact details can be found in Section 2. In order to rule out misuse, we must identify you (e.g. with a copy of your ID, unless otherwise possible).

You also have these rights vis-à-vis other organisations that work with us on their own responsibility - please contact them directly if you wish to exercise rights in connection with their processing. You will find information on our key cooperation partners and service providers in section 7, and further information in section 12. Please note that these rights are subject to conditions, exceptions or restrictions under the applicable data protection law (e.g. to protect third parties or business secrets). We will inform you accordingly if necessary.

In particular, we may need to further process and store your personal data in order to fulfil a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defence of legal claims, or to comply with legal obligations. To the extent permitted by law, in particular to protect the rights and freedoms of other data subjects and to protect legitimate interests, we may therefore refuse a data subject's request in whole or in part (e.g. by blacking out certain content that concerns third parties or our business secrets).

If you do not agree with our handling of your rights or data protection, please let us or our data protection officer (Section 2) know. In particular, if you are located in the EEA, the United Kingdom or Switzerland, you also have the right to lodge a complaint with the data protection supervisory authority in your country. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_de. You can contact the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can contact the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/adresse.html.

12. do we use online tracking and online advertising technologies?

We use various technologies on our website with which we and third parties engaged by us can recognise you when you use our website and, under certain circumstances, track you over several visits. We will inform you about this in this section. Essentially, this is so that we can distinguish between your access (via your system) and access by other users, so that we can ensure the functionality of the website and carry out analyses and personalisation. We do not want to infer your identity, even if we can, if we or third parties engaged by us can identify you by combining this with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you visit the site, for example by our server (or the servers of third parties) assigning you or your browser a specific identification number (so-called "cookie").

Cookies are individual codes (e.g. a serial number) that our server or a server of our service provider or advertising contract partner transmits to your system when you connect to our website and that your system (browser, mobile) accepts and stores until the programmed expiry date. Each time you access our website again, your system transmits these codes to our server or the server of the third party. This allows you to be recognised, even if your identity is unknown.

Other techniques can also be used to recognise you with a greater or lesser degree of probability (i.e. to distinguish you from other users), e.g. "fingerprinting". Fingerprinting combines your IP address, the browser you use, screen resolution, language selection and other information that your system communicates to each server, resulting in a more or less unique fingerprint. In this way, cookies can be dispensed with.

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can therefore be "tracked". If we integrate offers from a contractual advertising partner or provider of an analysis tool on our website, they can track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do the same. However, depending on the purpose of these technologies, we may ask for your consent before using them. You can programme your browser to block or deceive certain cookies or alternative technologies or to delete existing cookies. You can also add software to your browser that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the heading "Data protection") or on the websites of the third parties listed below.

A distinction is made between the following cookies (technologies with similar functions such as fingerprinting are included here):

Necessary cookies: Some cookies are necessary for the functioning of the website as such or certain functions. They ensure, for example, that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond a session (i.e. a visit to the website) if you use this function (e.g. selected language, consent given, the function for automatic log-in, etc.). These cookies have an expiry date of up to 24 months.

Performance cookies: We use cookies to optimise our website and corresponding offers and to better tailor them to the needs of users,to record and analyse the use of our website, possibly even beyond the session. We do this by using third-party analytics services. We have listed these below. Performance cookies also have an expiry date of up to 24 months. Details can be found on the websites of the third-party providers.

Marketing cookies: We and our advertising contract partners have an interest in targeting adverts, i.e. only displaying them to those we wish to address. We have listed our advertising contract partners below. For this purpose, we and our advertising contract partners - if you consent - also use cookies with which the content accessed or contracts concluded can be recorded. This enables us and our advertising contract partners to display adverts that we can assume are of interest to you on our website, but also on other websites that display adverts from us or our advertising contract partners. Depending on the situation, these cookies expire after a few days or up to 12 months. If you consent to the use of these cookies, you will be shown the relevant adverts. If you do not consent to these cookies, you will not see fewer adverts, but simply any other adverts.

In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we can transmit the email addresses of our users, customers and other people to whom we want to display adverts to operators of advertising platforms (e.g. social media). If these people are registered there with the same email address (which the advertising platforms determine through a comparison), the operators display the adverts we have placed to these people in a targeted manner. The operators do not receive personal email addresses of people who are not already known. In the case of known e-mail addresses, however, they will learn that these people are in contact with us and what content they have accessed.

We may also integrate other third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking a button), the relevant providers can recognise that you are on our website. If you have an account with the social media provider, they can assign this information to you and thus track your use of online services. These social media providers process this data on their own responsibility.

We do not currently use any such third-party services.

13 What data do we process on our pages in social networks?

We may operate pages and other online presences ("fan pages", "channels", "profiles", etc.) on social networks and other platforms operated by third parties and collect the data about you described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presence and link this data with other data about you known to the platforms (e.g. about your behaviour and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. which content they display to you).

We process this data for the purposes described in section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see section 12) and for market research. You will find information on the relevant legal bases in section 5. We may redistribute content published by you (e.g. comments on an announcement) ourselves (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments). For further information on the processing of the platform operators, please refer to the privacy policies of the platforms. There you can also find out in which countries they process your data, which rights of access, erasure and other rights of data subjects you have and how you can exercise these or obtain further information. We do not currently use any of these platforms.

14. can this privacy policy be amended?

This privacy policy is not part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last update: 10.01.2024