Privacy policy
With this privacy policy, we explain which personal data we process in connection with our activities and operations, including our compliant-concept.ch website. In particular, we explain for what purpose, how, and where we process which personal data. We also provide information about the rights of individuals whose data we process.
For specific or additional activities and operations, further privacy policies as well as other legal documents such as general terms and conditions (GTC), terms of use, or terms of participation may apply.
We are subject to Swiss data protection law as well as to any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures an adequate level of data protection.
1. Contact addresses
Responsibility for the processing of personal data:
compliant concept AG
Jurastrasse 58
CH-5430 Wettingen
info@compliant-concept.ch
We will indicate if, in an individual case, there are other parties responsible for the processing of personal data.
2. Terms and legal bases
2.1 Terms
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing comprises any handling of personal data, regardless of the means and procedures applied, for example the querying, matching, adapting, archiving, retaining, reading out, disclosing, obtaining, recording, collecting, deleting, revealing, ordering, organizing, storing, modifying, disseminating, linking, destroying, and using of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of at least one of the following legal grounds:
Art. 6(1)(b) GDPR for the necessary processing of personal data in order to perform a contract with the data subject and to carry out pre-contractual measures.
Art. 6(1)(f) GDPR for the necessary processing of personal data in order to safeguard the legitimate interests of ourselves or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations on a permanent, user-friendly, secure, and reliable basis and to communicate about them, ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
Art. 6(1)(c) GDPR for the necessary processing of personal data in order to comply with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
Art. 6(1)(e) GDPR for the necessary processing of personal data in order to perform a task carried out in the public interest.
Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
Art. 6(1)(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.
3. Nature, scope, and purpose
We process the personal data that is necessary in order to carry out our activities and operations on a permanent, user-friendly, secure, and reliable basis. Such personal data may fall, in particular, into the categories of master and contact data, browser and device data, content data, meta and marginal data and usage data, location data, sales data, as well as contract and payment data.
We process personal data for as long as is required for the respective purpose or purposes or as required by law. Personal data whose processing is no longer necessary is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We ensure data protection with such third parties as well.
As a general rule, we process personal data only with the consent of the data subjects. Where and to the extent that the processing is permissible on other legal grounds, we may refrain from obtaining consent. For example, we may process personal data without consent in order to perform a contract, to comply with legal obligations, or to safeguard overriding interests.
In this context, we process in particular information that a data subject voluntarily transmits to us when making contact – for example by postal mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system), or with comparable tools. Where we receive transmitted data about other persons, the transmitting persons are obliged to ensure data protection vis-à-vis those persons and to ensure the accuracy of that personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, where and to the extent that such processing is permissible on legal grounds.
4. Applications
We process personal data about applicants insofar as it is necessary to assess their suitability for an employment relationship or for the subsequent performance of an employment contract. The necessary personal data results, in particular, from the information requested, for example in the context of a job posting. We also process the personal data that applicants voluntarily disclose or publish, in particular as part of cover letters, resumes, and other application documents, as well as online profiles.
Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular pursuant to Art. 9(2)(b) GDPR.
We use third-party services in order to advertise positions by means of e-recruiting and to enable and manage applications.
In particular, we use:
JOIN: e-recruiting; provider: JOIN Solutions AG (Switzerland); data protection information: privacy policy.
5. Personal data abroad
As a general rule, we process personal data 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 there or have it processed.
We may export personal data to all countries and territories on Earth as well as elsewhere in the universe, provided that the law there, pursuant to a decision of the Swiss Federal Council, ensures an adequate level of data protection and – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – pursuant to a decision of the European Commission ensures an adequate level of data protection.
We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured on other grounds, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without an adequate or appropriate level of data protection where the special data protection requirements for doing so are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we will gladly provide data subjects with information about any safeguards or supply a copy of any safeguards.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all claims under the applicable data protection law. Data subjects have, in particular, the following rights:
Access: Data subjects may request information as to whether we process personal data about them and, if so, which personal data is concerned. Data subjects also receive the information that is necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but among other things also information about the purpose of processing, the duration of retention, any disclosure or export of data to other countries, and the origin of the personal data.
Rectification and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.
Erasure and objection: Data subjects may have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
Data release and data portability: Data subjects may request the release of personal data or the transfer of their data to another controller.
We may defer, restrict, or refuse the exercise of the rights of data subjects within the legally permissible scope. We may inform data subjects of any conditions to be met for the exercise of their data protection claims. For example, we may refuse access in whole or in part by reference to business secrets or the protection of other persons. For example, we may also refuse the erasure of personal data in whole or in part by reference to statutory retention obligations.
By way of exception, we may charge costs for the exercise of these rights. We will inform data subjects in advance of any costs.
We are obliged to identify, by appropriate measures, data subjects who request access or assert other rights. Data subjects are obliged to cooperate.
6.2 Right to lodge a complaint
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, data subjects have the right to lodge a complaint with a competent European data protection supervisory authority.
7. Data security
We take appropriate technical and organizational measures in order to ensure a level of data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website takes place by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject – as is, in principle, all digital communication – to mass surveillance without cause or suspicion as well as to other surveillance by security authorities in Switzerland, in the rest of Europe, in the United States of America (USA), and in other countries. We cannot exert any direct influence on the corresponding processing of personal data by intelligence services, police agencies, and other security authorities.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies of third parties whose services we use (third-party cookies) – are data that is stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies may be stored in the browser temporarily as "session cookies" or for a specific period as so-called permanent cookies. "Session cookies" are deleted automatically when the browser is closed. Permanent cookies have a specific storage duration. Cookies make it possible, in particular, to recognize a browser on its next visit to our website and thereby, for example, to measure the reach of our website. Permanent cookies may, however, also be used for online marketing, for example.
Cookies can be deactivated and deleted in whole or in part at any time in the browser settings. Without cookies, our website may no longer be available in full. We actively request – at least where and to the extent necessary – explicit consent to the use of cookies.
8.2 Server log files
For each access to our website, we may record the following information, provided that it is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the individual subpage of our website accessed including the volume of data transferred, the web page last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. This information is necessary in order to provide our website on a permanent, user-friendly, and reliable basis and to ensure data security and thus, in particular, the protection of personal data – including by third parties or with the help of third parties.
8.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those of third parties whose services we use – are small, usually invisible images that are retrieved automatically when our website is visited. With tracking pixels, the same information as in server log files can be recorded.
8.4 Comments
We make it possible for you to publish comments on our website. In this context, we process in particular the information that a commenting person transmits to us directly, but also the Internet Protocol (IP) address used as well as the date and time. This information is required in order to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.
In order to enable you to publish comments, we use in particular:
Gravatar (Globally Recognized Avatar): service for a uniform avatar across various websites; providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; data protection information: Automatische E-Mail-Adressen-basierte Avatar- bzw. Gravatar-Anzeige, Datenschutzerklärung, Cookie-Richtlinie.
9. Social media
We maintain a presence on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such platforms also apply in each case. These provisions inform, in particular, about the rights of data subjects directly vis-à-vis the respective platform, which include, for example, the right of access.
For our social media presence on Facebook, including the so-called page insights, we are – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (in the USA, among others). The page insights provide information about how visitors interact with our Facebook presence. We use page insights in order to provide our social media presence on Facebook effectively and in a user-friendly manner.
Further information about the nature, scope, and purpose of the data processing, information about the rights of data subjects, and the contact details of Facebook as well as of Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook and thereby agreed, in particular, that Facebook is responsible for ensuring the rights of data subjects. For the so-called page insights, the corresponding information can be found on the page "Informationen zu Seiten-Insights" including "Informationen zu Seiten-Insights-Daten".
10. Third-party services
We use the services of specialized third parties in order to carry out our activities and operations on a permanent, user-friendly, secure, and reliable basis. With such services we can, among other things, embed functions and content in our website. With such embedding, the services used record, for technically compelling reasons, at least temporarily the Internet Protocol (IP) addresses of the users.
For necessary security-related, 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 provide the respective service.
In particular, we use:
Google services: providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and in Switzerland; general data protection information: "Grundsätze zu Datenschutz und Sicherheit", Datenschutzerklärung, "Google ist der Einhaltung der anwendbaren Datenschutzgesetze verpflichtet", "Leitfaden zum Datenschutz in Google-Produkten", "Wie wir Daten von Websites oder Apps verwenden, auf bzw. in denen unsere Dienste genutzt werden" (information from Google), "Von Google verwendete Cookie-Arten und sonstige Technologien", "Personalisierte Werbung" (activation / deactivation / settings).
Microsoft services: providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), in Great Britain, and in Switzerland; general data protection information: "Datenschutz bei Microsoft", "Datenschutz und Privatsphäre (Trust Center)", Datenschutzerklärung, Datenschutz-Dashboard (Daten- und Datenschutz-Einstellungen).
10.1 Digital infrastructure
We use the services of specialized third parties in order to make use of the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
Hostpoint: hosting; provider: Hostpoint AG (Switzerland); data protection information: privacy policy.
10.2 Contact options
We use the services of selected providers in order to communicate better with third parties such as, for example, potential and existing customers.
10.3 Audio and video conferences
We use specialized services for audio and video conferences in order to communicate online. With these, we can, for example, hold virtual meetings or conduct online teaching and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, apply additionally.
We recommend, depending on your circumstances, muting the microphone by default when participating in audio or video conferences and blurring the background or having a virtual background displayed.
In particular, we use:
Microsoft Teams: platform for, among other things, audio and video conferences; provider: Microsoft; Teams-specific information: "Datenschutz und Microsoft Teams".
10.4 Maps
We use third-party services in order to embed maps in our website.
In particular, we use:
Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific information: "Wie Google Standortinformationen verwendet".
10.5 Digital audio and video content
We use the services of specialized third parties in order to enable the direct playback of digital audio and video content, such as music or podcasts.
In particular, we use:
Vimeo: video platform; provider: Vimeo Inc. (USA); data protection information: Datenschutzerklärung, "Datenschutz".
YouTube: video platform; provider: Google; YouTube-specific information: "Datenschutz- und Sicherheitscenter", "Meine Daten auf YouTube".
10.6 Fonts
We use third-party services in order to embed selected fonts as well as icons, logos, and symbols in our website.
In particular, we use:
Font Awesome: icons and logos; provider: Fonticons Inc. (USA); data protection information: privacy policy.
Google Fonts: fonts; provider: Google; Google Fonts-specific information: "Datenschutz und Google Fonts" ("Privacy and Google Fonts"), "Datenschutz und Datenerfassung".
11. Final provisions
We created this privacy policy with the privacy policy generator from Datenschutzpartner.
We may adapt and supplement this privacy policy at any time. We will provide information about such adaptations and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.