- 2. WHO IS THE CONTROLLER FOR PROCESSING YOUR DATA?
- 3. WHAT DATA DO WE PROCESS?
- 4. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
- 5. ON WHAT BASIS DO WE PROCESS YOUR DATA?
- 6. WITH WHOM DO WE SHARE YOUR DATA?
- 7. IS YOUR PERSONAL DATA DISCLOSED ABROAD?
- 8. HOW LONG DO WE PROCESS YOUR DATA?
- 9. HOW DO WE PROTECT YOUR DATA?
- 10. WHAT ARE YOUR RIGHTS?
- 11. DO WE USE ONLINE TRACKING AND ONLINE ADVERTSING TECHNIQUES?
- 12. WHAT DATA DO WE PROCESS ON OUR SOCIAL NETWORK PAGES?
1. WHAT IS THIS PRIVACY NOTICE ABOUT?
iLoy Solutions AG (also "we", "us") collects and processes personal data that concern you but also other individuals ("third parties"). We use the word "data" here interchangeably with "personal data".
2. WHO IS THE CONTROLLER FOR PROCESSING YOUR DATA?
You may contact us for data protection concerns and to exercise your rights under Section 10 as follows:
iLoy Solutions AG
3. WHAT DATA DO WE PROCESS?
We process various categories of data about you. The main categories of data are the following:
- Technical data: When you use our Website or other online offerings, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 11). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, access controls or the performance of a contract.
- Communication data: When you are in contact with us via the contact form, by e-mail, telephone, by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we have to determine your identity, for example in relation to a request for information, we collect data to identify you (for example a copy of an ID document).
- Master data: With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, your date of birth, customer history and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes or for the purposes of a contractual partner (for example as part of marketing and advertising, with invitations to events, with newsletters, etc.). We receive master data from you (for example when you make a purchase), from parties you work for, or from third parties such as contractual partners, associations and address brokers, and from public sources such as public registers or the internet (websites, social media, etc.).
- Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources.
- Behavioral and preference data: Depending on our relationship with you, we try to get to know you better and to tailor our products, services and offers to you. For this purpose, we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior in our domain, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by recording your behavior (for example how you navigate our Website). We describe how tracking works on our Website in Section 11.
- Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation to administrative or judicial proceedings. We may also collect data for health protection (for example as part of health protection concepts).
Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the Website, etc.). You are in general not obliged or required to disclose data to us. If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data and contract data, as part of your contractual obligation under the relevant contract. When using our Website, the processing of technical data cannot be avoided.
As far as it is not unlawful we also collect data from public sources (for example debt collection registers, commercial registers or the internet) or receive data from other companies within our group, from public authorities and from other third parties.
4. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
We process your data for the purposes explained below. Further information is set out in Sections 11 and 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can 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 in relation to responding to inquiries and the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
We process data for the conclusion, administration and performance of contractual relationships.
We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for services from us. This may happen in the form of newsletters, through other channels for which we have contact information from you, but also as part of marketing campaigns. You can object to such contacts at any time or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 11).
We further process your data for market research, to improve our services and operations, and for product development.
We may also process your data for security and access control purposes.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations ("Compliance").
We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.
We may process your data for further purposes, for example as part of our internal processes and administration.
5. ON WHAT BASIS DO WE PROCESS YOUR DATA?
Where we ask for your consent for certain processing activities (for example for marketing mailings), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail or e-mail); see our contact details in Section 2. For withdrawing consent for online tracking, see Section 11. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law.
Where we receive sensitive personal data, we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
6. WITH WHOM DO WE SHARE YOUR DATA?
In relation to our contracts, the Website, our services, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 5, we may disclose 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 your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers).
- Contractual partners including customers: This refers to customers and our other contractual partners (including our sales and marketing partners) as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this regard. These recipients also include contractual partners with whom we cooperate.
- Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities).
7. IS YOUR PERSONAL DATA DISCLOSED ABROAD?
As explained in section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in the US, in exceptional cases, in any country in the world.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
8. HOW LONG DO WE PROCESS YOUR DATA?
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
9. HOW DO WE PROTECT YOUR DATA?
We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.
10. WHAT ARE YOUR RIGHTS?
To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether and what data we process from you;
- The right to have us correct data if it is inaccurate;
- The right to request erasure of data;
- The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- The right to object to the processing of your data;
- The right to withdraw consent, where our processing is based on your consent;
- The right to receive, upon request, further information that is helpful for the exercise of these rights.
If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2.
If you do not agree with the way we handle your rights or with our data protection practices, please let us know. Depending on the applicable data protection law, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
11. DO WE USE ONLINE TRACKING AND ONLINE ADVERTSING TECHNIQUES?
We use various techniques on our Website that allow us and third parties engaged by us to recognize you during your use of our Website, and possibly to track you across several visits. This Section informs you about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the Website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the Website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called "cookie").
We use these technologies on our Website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings via the "Cookie Settings" link in the footer of the Website. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword "Privacy") or on the websites of the third parties set out below.
We distinguish the following categories of cookies (including other technologies such as fingerprinting):
- Necessary cookies: Some cookies are necessary for the functioning of the Website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only ("session cookies"). If you block them, the Website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the Website) if you use this function (for example language settings, consents, automatic login functionality, etc.).
We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), these providers can determine that you are using our website. If you have an account with that social media provider, it can assign this information to you and thereby track your use of online offers. These social media providers process this data as separate controllers.
We currently im particular use offers from the following service providers and advertising partners:
- Google Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service "Google Analytics" and acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both "Google"). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the "Data sharing" option and the "Signals option". Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here [https://support.google.com/analytics/answer/6004245] and if you have a Google account, you can find more details about Google's processing here [https://policies.google.com/technologies/partner-sites? hl=en].
- Google Ads Conversion and Ads remarketing: We use the Google Ads Conversion service provided by Google, to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Ads). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the interest of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs. These advertisements are delivered by Google via so-called "ad servers". For this purpose, we use ad server cookies, which can be used to measure certain parameters for measuring success, such as the display of ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your end device for a certain period. These cookies are not intended to identify you personally. The unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie. These cookies enable Google to recognize your internet browser. If a user visits certain pages of the website of an Ads customer and the cookie stored on his computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked across Ads customers' websites. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. These evaluations enable us to determine which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising tools; in particular, we cannot identify users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Ads Conversion, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your Account. Even if you are not registered with Google or have not logged in, there is the possibility that the provider learns your IP address and stores it. Furthermore, we use Google Ads remarketing. With the remarketing function, we can present users of our website with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called "Google Ads" or on other websites). For this purpose, the interaction of the users on our website is analyzed, e.g. which offers the user was interested in, in order to be able to display targeted advertising to the users on other sites even after they have visited our website. For this purpose, Google stores a number in the browsers of users who visit certain Google services or websites in the Google display network. This number, known as a "cookie", is used to record the visits of these users. This number is used to uniquely identify a web browser on a particular device and not to identify a person, personal data is not stored. Further information on data protection at Google can be found here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.
12. WHAT DATA DO WE PROCESS ON OUR SOCIAL NETWORK PAGES?
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. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.
For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information.
We currently use the platform LinkedIn. LinkedIn is a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, a subsidiary of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA.