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Privacy Policy

 

PRIVACY POLICY

1) Information about the collection of personal data

We are pleased that you are visiting the website (the “Website”) of Nadine Hunkeler Finance Phoenix (the “Company”), and thank you for your interest. In the following, we inform you about the handling of your personal data when using our Website. Personal data is any data by which you can be personally identified.

Your data is collected, used, and saved in accordance with the applicable data protection provisions in Switzerland and in the European Union. This Privacy Policy (the “Policy”) includes information on how the Company collects, uses, processes and, under certain circumstances, passes on personal data.

Please read the Policy carefully before you start to use the Website. By using the Website or by clicking to accept or agree to the Terms and Conditions when this option is made available to you, you accept and agree to be bound and abide by the Policy. If you do not want to agree to the Policy, you must not access or use the Website.

The Company uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or enquiries to the person responsible). You can recognise an encrypted connection by the string "https://" and the lock symbol in your browser line.

2) Use of cookies and pixels

Similar to other commercial websites, our Website may utilize a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.

You may refuse the use of cookies by selecting appropriate settings in your browser software; however, the Company points out that you may not be able to use the full functionality of this Website as a result.

3) Visitors’ GDPR Rights

If the relationship between you and the Company comes under the European General Data Protection Regulation (“GDPR”) and your personal data are processed, then you are a data subject within the meaning of the GDPR. In that case you are entitled to certain information and have certain rights under the GDPR.

We will retain any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.

You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.

You have the right to seek restrictions on the processing of your data.

You have the right to object to the processing of your data and the right to the portability of your data.

To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the GDPR.

4) Data collection when visiting our Website

When you use the Website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our Website, we collect the following data, which is technically necessary for us to display the Website to you:

- Our visited Website

- Date and time at the time of access

- Amount of data sent in bytes

- Source/reference from which you reached the page

- Browser used

- Operating system used

- IP address used (if applicable: in anonymised form)

The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

5) Contacting us

When contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. Your data will be deleted after your request has been processed. This is the case when the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Data processing when opening a customer account and for contract processing

Personal data is collected and processed if you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to our address. We store and use the data you provide for the purpose of processing the contract. After complete processing of the contract or deletion of your customer account, your data will be blocked with regard to tax and commercial law retention periods and deleted after expiry of these periods, unless you have expressly consented to a further use of your data or a legally permitted further use of data has been reserved on our part, about which we inform you accordingly below.

7) Use of your data for direct advertising

7.1 Registration for our e-mail newsletter

By providing us with your personal data, you agree that we may use this data to send you newsletters.

We store your IP address entered by your internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the purpose of advertising in the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending us a corresponding message. After unsubscribing, your e-mail address will be immediately deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use your data for other purposes, which are permitted by law and about which we inform you in this Policy or separately.

7.2 Newsletter-Tracking

The newsletter of the Company contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Company may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent. After a revocation, these personal data will be deleted by the controller. The Company automatically regards a withdrawal from the receipt of the newsletter as a revocation.

7.3 Advertising by letter post

On the basis of our legitimate interest in personalised direct advertising, we reserve the right to store your first and last name, your postal address and - insofar as we have received this additional information from you within the framework of the contractual relationship - your title, academic degree, year of birth and your occupational, industry or business designation and to use this information to send you interesting offers and information about our products by letter post.

You can object to the storage and use of your data for this purpose at any time by sending us a message to this effect.

8) Data processing for order processing

8.1 The personal data collected by us will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We pass on your payment data to the commissioned credit institution within the framework of payment processing, insofar as this is necessary for payment processing. If payment service providers are used, we will explicitly inform you about this below.

8.2 Transfer of personal data to shipping service providers

- Post CH

If the delivery of the goods is carried out by the transport service provider Post CH (Schweizerische Post AG, Wankdorfallee 4, 3030 Bern, Switzerland) or its subcontractors, we will pass on your e-mail address and telephone number to Post CH before the delivery of the goods for the purpose of coordinating a delivery date or for delivery notification, provided that you have given your express consent for this in the ordering process. Otherwise, we will only pass on the name of the recipient and the delivery address to Post CH for the purpose of delivery. This information will only be passed on if it is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with Post CH or the transmission of status information of the shipment delivery is not possible.

The consent can be revoked at any time with effect for the future vis-à-vis the responsible person named above or vis-à-vis the transport service provider Post CH.

8.3 Use of payment service providers (payment services)

- PayPal

When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. This information is only passed on insofar as this is necessary for the processing of the payment.

For the payment methods credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, PayPal reserves the right to carry out a credit check. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit check with regard to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The creditworthiness information may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including information on the credit agencies used, please refer to PayPal's data protection declaration: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.

9) Contacting for rating reminder

9.1 Own rating reminder (no dispatch by a customer rating system)

We use your e-mail address for a one-time reminder to submit a rating of your order for the rating system we use, provided you have given us your express consent to do so during or after your order.

You can revoke your consent at any time by sending us a message.

9.2 Rating reminder by Real Ratings from Net Reviews 

If you have given us your express consent to do so during or after your order, we will send your e-mail address to the rating platform Real Reviews of Net Reviews simplified joint stock company, 18-20 Avenue Robert Schuman, CS 40494, 13002 Marseille, France (www.echte-bewertungen.com), so that it sends you a rating reminder by e-mail.

You may withdraw your consent at any time by sending a message to us or to the review platform.

10) Online marketing and use of Google Ads conversion tracking

The Company uses the online advertising programme "Google Ads" and, within the framework of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). We use Google Ads to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Adwords). 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 the Company more interesting for you and achieving a fair calculation of advertising costs.

The conversion tracking cookie is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Website and the cookie has not yet expired, Google and we will be able to recognise that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked across Google Ads customers' websites. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted in to conversion tracking. Clients learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking, you can block this use by deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics. The use of Google Ads may also result in the transmission of personal data to the servers of Google LLC. in the USA.

You can obtain further information about Google's data protection policy at the following Internet address: https://www.google.de/policies/privacy/.

You can permanently deactivate cookies for ad specifications by preventing them by setting your browser software accordingly or by downloading and installing the browser plug-in available under the following link:

https://www.google.com/settings/ads/plugin?hl=de

Please note that certain functions of the Website may not be available or may be restricted if you have deactivated the use of cookies.

11) Web analytics services

11.1 Google (Universal) Analytics

The Company uses Google (Universal) Analytics, a web analytics service provided by Google. Google (Universal) Analytics uses "cookies", which are text files placed on your computer, to help the Website analyse how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

The Company uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures anonymisation of the IP address by shortening it and excludes direct personal reference. The extension means that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google LLC server in the USA and shortened there. In these exceptional cases, this processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the statistical analysis of user behaviour for optimisation and marketing purposes.

On our behalf, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing us with other services relating to Website activity and internet usage. The IP address transmitted by your browser as part of Google (Universal) Analytics will not be merged with other Google data.

You can prevent cookies from being stored by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of the Website to their full extent. In addition, you can prevent the collection of the data generated by the cookie and related to your use of the Website (including your IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link:

https://tools.google.com/dlpage/gaoptout?hl=de

As an alternative to the browser plug-in or within browsers on mobile devices, please click on the following link to set an opt-out cookie that will prevent Google (Universal) Analytics from collecting data within the Website in the future (this opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you must click this link again): Google Analytics deactivate

Further information on Google (Universal) Analytics can be found here: https://policies.google.com/privacy?hl=de&gl=de

11.2 Kajabi 

The Company uses Kajabi to create, market and sell its digital content. This service is.provided by Kajabi LLC. Kajabi LLC is a limited liability company based in USA (17100 Laguna Canyon Rd Ste 100, Irvine, California, 92603, United States). 

The Kajabi Privacy Policy applies. It can be found at: https://kajabi.com/policies/privacy 

 

11.3 Hotjar (hotjar Ltd.)

The Company uses the web analytics service Hotjar provided by Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe Tel.: +1 (855) 464-6788).

With this tool, movements on the websites on which Hotjar is used can be tracked (so-called heat maps). For example, it is possible to see how far users scroll and how often they click on which buttons. Furthermore, with the help of the tool it is also possible to obtain feedback directly from the users of the Website. In this way, we obtain valuable information to make our Website even faster and more customer-friendly. When using this tool, we pay particular attention to the protection of your personal data. For example, we can only track which buttons you click and how far you scroll. Areas of the Websites in which personal data of you or third parties are displayed are automatically hidden by Hotjar and are therefore not traceable at any time.

Hotjar offers every user the option of using a "Do Not Track header" to prevent the use of the Hotjar tool so that no data is recorded about the visit to the respective website. This is a setting that is supported by all common browsers in current versions. To do this, your browser sends a request to Hotjar with the information to deactivate the tracking of the respective user. If you use the Website with different browsers/computers, you must set up the "Do Not Track header" separately for each of these browsers/computers.

Detailed instructions with information about your browser can be found at: https://www.hotjar.com/opt-out.

Further information about Hotjar Ltd. and about the Hotjar tool can be found at: https://www.hotjar.com.

The privacy policy of Hotjar Ltd. can be found at: https://www.hotjar.com/privacy.

12) Retargeting/ Remarketing/ Referral advertising

12.1 Facebook Custom Audience via the pixel procedure

The Company uses the "Facebook pixel" of Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Facebook"). If explicit consent is given, this allows the behaviour of users to be tracked after they have seen or clicked on a Facebook ad. This procedure is used to evaluate the effectiveness of the Facebook ads for statistical and market research purposes and can help to optimise future advertising measures.

The data collected is anonymous for us, so it does not offer us any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook data usage policy (https://www.facebook.com/about/privacy/). You may enable Facebook and its partners to serve ads on and off Facebook. A cookie may also be stored on your computer for these purposes. These processing operations will only take place if you give your explicit consent.

Consent to the use of the Facebook Pixel may only be given by users who are over 13 years of age. If you are younger, please ask your parent or guardian for permission.

To deactivate the use of cookies on your computer, you can set your internet browser so that no more cookies can be placed on your computer in the future or so that cookies that have already been placed are deleted. However, switching off all cookies may mean that some functions on our Website can no longer be carried out. You can also deactivate the use of cookies by third-party providers such as Facebook on the following website of the Digital Advertising Alliance: http://www.aboutads.info/choices/.

12.2 Google Ads Remarketing

The Company uses the functions of Google Ads Remarketing, with which we advertise for the Website in Google search results, as well as on third-party websites. The provider is Google. For this purpose, Google sets a cookie in the browser of your terminal device, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you visit.

Further data processing will only take place if you have consented to Google linking your internet and app browsing history to your Google Account and using information from your Google Account to personalise the ads you see on the web. In this case, if you are logged into Google while visiting our Website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with Google Analytics data in order to form target groups. In the context of the use of Google Ads Remarketing, personal data may also be transmitted to the servers of Google LLC. in the USA.

You can permanently deactivate the setting of cookies for ad preferences by downloading and installing the browser plug-in available at the following link: https://support.google.com/ads/answer/7395996?

Alternatively, you can obtain information from the Digital Advertising Alliance at the Internet address www.aboutads.info about the setting of cookies and make settings in this regard. Finally, you can set your browser in such a way that you are informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of the Website may be limited.

Further information and the data protection provisions regarding advertising and Google can be viewed here:

https://www.google.com/policies/technologies/ads/

13) Tools and other

On the Website we use Google Maps (API) from Google. Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, you will be shown our location and it will be easier for you to find us.

When you call up those sub-pages in which the Google Maps map is integrated, information about your use of the Website (such as your IP address) is transmitted to Google servers and stored there; this may also involve transmission to the servers of Google LLC. in the USA. This occurs regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want your data to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.

If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely deactivating the Google Maps web service by switching off the JavaScript application in your browser. Google Maps and thus also the map display on the Website can then not be used.

You can view Google's terms of use at https://www.google.de/intl/de/policies/terms/regional.html, and the additional terms of use for Google Maps at https://www.google.com/intl/de_US/help/terms_maps.html.

Detailed information on data protection in connection with the use of Google Maps can be found on the Google website ("Google Privacy Policy"): https://www.google.de/intl/de/policies/privacy/.

14) Data protection provisions about the application and use of Instagram

On the Website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.

The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, UNITED STATES.

With each call-up to one of the individual pages of this Website, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During the course of this technical procedure, Instagram becomes aware of what specific sub-page of our Website was visited by the data subject.

If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our Website by the data subject—and for the entire duration of their stay on our Website—which specific sub-page of our Website was visited by the data subject. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our Website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.

Instagram receives information via the Instagram component that the data subject has visited our Website provided that the data subject is logged in at Instagram at the time of the call to our Website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our Website is made.

Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/ 

15) Data protection provisions about the application and use of LinkedIn

The Company offers the download of white papers and registration for webinars via the social network LinkedIn. The "LinkedIn Lead Generation" service uses forms for this purpose. Other functions and contents of the LinkedIn service can also be integrated. The service is offered by LinkedIn Ireland Unlimited Company, 5 Wilton Park, Dublin 2, Ireland. 

If the users are members of the LinkedIn platform, LinkedIn can link the above-mentioned content and functions to the profiles of the users. For the use of such a service, registration is necessary in advance. Which data is collected in each case can be learnt from the respective input forms. The data collected is also transferred to the Company’s system and stored there with any customer profile. 

The following data in particular is collected as part of the registration process:

- First and last name
- salutation
- email address
- Company name
- Telephone number
- Position
- Country

LinkedIn's privacy policy can be found at https://www.linkedin.com/legal/privacy-policy. The use of these tools serves marketing purposes. These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.

16) Data protection provisions about the application and use of YouTube

On the Website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Website, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our Website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Website was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our Website, if the data subject at the time of the call to our Website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our Website is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

17) Data protection provisions about the application and use of use of the video conferencing solutions Zoom and Microsoft Teams

The Company may use the video conferencing tools Zoom and Microsoft Teams to conduct conference calls, online meetings, video conferences, webinars or online trainings (hereinafter “Online Meeting” or "Online Meetings"). 

Zoom is a service of Zoom Video Communications, Inc. which is based in the USA (“Zoom”). Microsoft Teams is a service of Microsoft Corporation which is also located in the USA (“Microsoft Teams”). 

If you visit the websites of Zoom Video Communications Inc. or Microsoft Corporation to download the Zoom or Microsoft Teams software, the respective provider is responsible for the processing of your personal data. To the extent Zoom Video Communications Inc. or Microsoft Corporation process personal data of Online Meetings’ participants in their own responsibility during the operation or use of Zoom or Microsoft Teams, you will find the respective information in the Zoom Privacy Statement accessible under https://zoom.us/privacy or the Microsoft Teams Privacy Statement for Microsoft 365 users accessible under https://privacy.microsoft.com/en-us/privacystatement.

18) Rights of the data subject

The Swiss Data Protection Act grants you the right to know free of charge whether and what personal data we are storing about you. You also have the right to have incorrect information corrected and deleted. This is subject to statutory retention obligations (cf. in particular Art. 957 and 962 of the Swiss Code of Obligations).

Requests for information must be sent to us in writing. In connection with requests for information or deletion, we reserve the right to demand proof of identity.

19) Policy changes

This Policy was last updated on 13th September 2022. Please be aware that the Company reserves the right to amend this Policy at any time. Such amendments shall become effective immediately upon posting our updated Policy. We may use your contact information to inform you of changes to the Website or its content, or, if requested, to send you additional information about us. Please review this Policy periodically. Continued use of any of information obtained through or on the Website or its content following the posting of changes and/or modifications constitutes acceptance of the revised Privacy Policy.

20) Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the lawyer Mrs. Sanaz Habibian.