Privacy Policy

Data­protection­declaration

With this Data­protection­declaration we inform about the processing of personal­data in connection with our activities and operations including our website under the domain­name swant.com. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

For individual or additional activities and operations, we may publish further data protection declarations or other information on data protection.

We are subject to Swiss law and all­applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized in its decision of 26 July 2000 that Swiss data protection law ensures adequate data protection. In its report of January 15, 2024, the European Commission confirmed this adequacy decision.

Table-of-contents

1. contact­addresses

Responsible in the data­protection­legal sense is:

Leuenberger, Michele
Swant AG
Talstrasse 4
CH-3112 Kehrsatz
Switzerland
Email: info@swant.com
Phone: +41 79 781 04 11
Website: swant.com

info@swant.com

In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.

Data­protection representation in the European Economic­area (EEA)

We have the following data protection representation according to Art. 27 GDPR:

VGS Datenschutz­partner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

The Data Protection Officer serves as an additional point of contact for data subjects and public authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the GDPR.

2.1 Terms

Data subject: Natural person about whom we process personal data

.

Personal data: Any information relating to an identified or identifiable natural person.

Personal­data requiring special protection: Data concerning trade, political, religious or philosophical opinions and activities, data concerning health, intim­or racial or ethnic origin, genetic data, biometric data uniquely identifying a natural person, data relating to criminal or administrative sanctions or prosecutions, and data relating to social assistance measures.

Edit: Any handling of personal­data, regardless of the means and procedures used, such as retrieving, matching, adapting, archiving, storing, reading, disclosing­giving, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using personal data.

European Economic­area (EEA): Member­states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data­Protection (Data­Protection­Ordinance, DPO).

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

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre&­contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal related data in order to protect legitimate interests - including the legitimate interests of third parties -, provided that the fundamental freedoms and fundamental rights and interests of the data subject do not prevail. Such interests are, in particular, the permanent, humane, safe and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal related data to fulfill a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
  • Art. 6 para. 1 lit e GDPR for the necessary processing of personal­related data for the performance of a task carried out in the public­interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal­related data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or of another natural person.
  • Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subject.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. type, scope and purpose of the processing of personal data

We process the personal data that is necessary in order to carry out our activities and operations in a permanent, humane, safe and reliable manner. The processed personal data can be divided in particular into the categories of browser and device data, content data, communication data, meta data, usage data, master data, user data and personal data.shy;data, master­data including inventory and contact­data, location­data, transaction­data, contract­data and payment­data. The personal data may also constitute particularly sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar as such processing is permitted.

We process personal data, where necessary, with the consent of the data subjects. We may process personal data without consent in many cases, for example to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

We process personal data for the duration required for the respective purpose. We anonymize or delete personal data, in particular depending on statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties may be, for example, specialized providers whose services we use.

In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, public authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, credit bureaus, credit reference agencies, credit agencies and other organizations.shy;credit agencies, logistics and shipping­companies, marketing and advertising­agencies, media, parent, sister and subsidiary­companies, organi­organizations and associations, social institutions, telecommunication companies, insurance companies and payment service providers.

5. communication

We process personal data in order to be able to communicate with individuals as well as with authorities, organizations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or by comparable means.

Third parties who transmit data about other persons to us are obliged to ensure the data protection of these data subjects at all times. In particular, they must ensure that such data is correct and may be transmitted.

6. Applications

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example as part of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.

We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR.

7. data­security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other digital presence takes place using transport­encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport­encryption.

Our digital communication - as in principle any digital communication - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot exert any direct influence on the corresponding processing of personal data by secret services, police and other security authorities. We also cannot rule out the possibility that a data subject may be subject to targeted surveillance.

8. personal­data abroad

We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.

We may transfer personal data to all countries in the world and elsewhere in the universe, provided that the local law according to decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with decision of the European Commission ensures adequate data protection.

We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data­protection­legal requirements are met;are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information on all guarantees due or provide a copy of all guarantees due.

9. Rights of data subjects

9.1 Data­protection­legal rights

We grant data subjects all claims in accordance with the applicable law. Data subjects have the following rights in particular:

  • Information: Data subjects may request information as to whether we process personal data about them and, if so, which personal data is involved. Data subjects also receive the information required to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
  • Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
  • Possibility for own point of view and human review: Data subjects may object to decisions that are based exclusively on automated processing of personal data and have a legal­or significantly affect them (automated individual decisions), they can present their own point of view and request a review by a human being.
  • Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may defer, restrict or refuse the exercise of data subjects' rights to the extent permitted by law. We may inform data subjects of any requirements to be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to erase personal data, in whole or in part, in particular with reference to legal duties of confidentiality.

We may exceptionally provide for costs for the exercise of rights. We will inform affected persons in advance of any costs due.

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

Data subjects have the right to assert their data protection claims through legal channels or to lodge a complaint with a data protection supervisory authority.

Data subjects have the right to assert their data protection claims through legal channels or to lodge a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Eid­genössische Daten­schutz- und Öffentlich­kauftragte (EDÖB).

European data­protection supervisory­authorities are organized as members of the European Data­Protection­Board (EDPB). In some member states of the European Economic Area (EEA), the data protection authorities are federally structured, especially in Germany.

10. use of the website

10.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as "session cookies" or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request - at least if and to the extent required by applicable law - explicit consent to the use of cookies.

For cookies that are used to measure success and reach or for advertising, a general objection ("opt-out") is possible for numerous services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

10.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access­status (HTTP status code), operating­system including user­interface and version, browser including language and version, individual subpage of our website accessed including amount of data­transferred, the last website accessed in the same browser window (referrer).

We log such information, which may also represent personal data, in log files. The information is required in order to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data­safety­security - also by third parties or with the help of third parties.

10.3 Tracking pixels

We can integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels - also from third parties whose services we use - are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when our digital presence is accessed. Count­pixels can be used to record at least the same information as log­files.

11. social media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - are jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The Page Insights provide with information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and human-friendly way.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Data Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".

12. services from third parties

We use the services of specialized third parties in order to be able to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons.

For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

12.1 Digital infrastructure

We use services from specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We use in particular:

12.2 Audio and video conferences

We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, also apply.

We recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences, depending on the life situation.

We use in particular:

12.3 Online collaboration

We use third-party services to enable online collaboration. In addition to this privacy policy, any directly apparent terms and conditions of the services used, such as terms of use or privacy policies, also apply.

We use in particular:

12.4 Social media features and social media content

We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

We use in particular:

12.5 Map material

We use third-party services to embed maps on our website

.

We use in particular:

12.6 Digital content

We use the services of specialized third parties to integrate digital content into our website. Digital content includes, in particular, image and video material, music and podcasts.

12.7 Documents

We use third-party services to integrate documents into our website. Such documents may include PDF files, presentations, tables and text documents. This allows us to enable not only viewing, but also editing or commenting on such documents.

12.8 Fonts

We use third-party services to embed selected fonts, icons, logos and symbols on our website.

We use in particular:

12.9 E-Commerce

We operate e-commerce and use third-party services to successfully offer services, content or goods.

We use in particular:

12.10 Payments

We use specialized service providers to process payments securely and reliably. The legal­texts of the individual service­providers, for example General Terms and Conditions (GTC) or data protection­declarations, also apply to the processing of payments.

We use in particular:

13. extensions for the website

We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure

.

14. success-and-reach­measurement

We try to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements.

In most cases, the IP addresses of individual users are recorded for success and reach measurement. In this case, IP addresses are basically shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudo­nymization.

Cookies may be used to measure success and reach and user profiles may be created. Any user­profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user­profiles are created exclusively in pseudo­nymized form and are not used to identify individual users. Individual services of third parties with which users are registered may be able to assign the use of our online offer to the user account or user profile with the respective service.

We use in particular:

  • Google Tag Manager: Integration and management of services from Google and third parties, in particular for success and reach measurement; Provider: Google; Google Tag Manager-specific information: Data­protection­declaration for Google Tag Manager; further information on data­protection can be found in the individual integrated and managed services.

15. final notes on the data protection declaration

We may update this privacy policy at any time. We will provide information about updates in an appropriate form, in particular by publishing the current data protection declaration on our website.