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Disclaimer

 

This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

 

Responsible

Top Line Group
Heinrichstrasse 239
8005 Zurich

Types of data processed

Inventory data (e.g. names, addresses)
Contact data (e.g. e-mail, telephone numbers)
Content data (e.g., text entries, photographs, videos)
Usage data (e.g. websites visited, interest in content, access times)
Meta/communication data (e.g. device information, IP addresses)

Purpose of processing

Provision and optimization of the online offer, its functions and contents.
Answering contact requests and communication with users
Security measures
Reach measurement/marketing

Terms used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data. "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

Relevant legal bases

In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing for the performance of our services and implementation of contractual measures and answering inquiries is Art. 6(1)(b) DSGVO, the legal basis for processing for the performance of our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing for the protection of our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.

Safety measures

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Cooperation with processors and third parties

If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 DSGVO.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

Rights of the data subjects

You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 of the GDPR. You have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you. You have the right, in accordance with Art. 17 DSGVO, to request that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 DSGVO, to request restriction of the processing of the data. You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request that it be transferred to other data controllers. You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

Right of withdrawal

You have the right to revoke given consents according to Art. 7 para. 3 DSGVO with effect for the future

Right of objection

You may object to the future processing of data concerning you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against the processing for purposes of direct marketing.

Cookies and right to object to direct advertising

Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login jam. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies" are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as "first-party cookies"). We may use temporary and permanent cookies and provide information about this in our privacy policy. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer. A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Data deletion

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Hosting

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online offering. In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).

Agency services

We process our customers' data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services. In this context, we process inventory data (e.g. customer master data, such as names or addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), contract data (e.g. subject matter of contract, term), payment data (e.g. bank details, payment history), usage data and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of a commissioned processing operation. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of contractual services and indicate the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements of a commissioned processing pursuant to Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

Business analyses and market research

In order to operate our business economically and to be able to identify market trends, customer and user requirements, we analyze the data we have on business transactions, contracts, inquiries, etc. We use this data for the following purposes. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details of, for example, their purchase transactions. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values. If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the user, otherwise after two years from the conclusion of the contract. In other respects, the overall business analyses and general trend analyses are prepared anonymously wherever possible.

Data protection information in the application process

We process the applicant data only for the purpose and within the scope of the application procedure in accordance with the legal requirements. The applicant data is processed to fulfill our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO insofar as the data processing becomes necessary for us, e.g. in the context of legal procedures. The application procedure requires applicants to provide us with applicant data. The necessary applicant data are marked, if we offer an online form, otherwise result from the job descriptions and basically include the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, resume and the certificates. In addition, applicants may voluntarily provide us with additional information. By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in the manner and to the extent set out in this privacy policy. Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are voluntarily communicated within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a DSGVO (e.g. health data, if this is necessary for the exercise of the profession). If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art.

Applicants can also send us their applications by e-mail. However, please note that e-mails are generally not encrypted and applicants must ensure encryption themselves. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using an online form or sending by post. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post. In the event of a successful application, the data provided by the applicants may be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the deletion will take place after the expiry of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b) DSGVO. The user's details may be stored in a customer relationship management system ("CRM system") or comparable inquiry organization. We delete the inquiries if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are authoritative for the consent of the users. Otherwise, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there. Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data. We only use Google Analytics with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user's browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. For more information about Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated). The personal data of the users will be deleted or anonymized after 26 months.

Online presence in social media

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply. Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages.

Integration of third-party services and content

Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content"). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus necessary for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.

Youtube

We integrate the videos of the platform "YouTube" of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts

We integrate the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Twitter

Within our online offer, functions and contents of the service Twitter, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can announce their liking of the content, the authors of the content or subscribe to our posts. If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

Instagram

Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can make known their liking regarding the content, the authors of the content or subscribe to our posts. If the users are members of the Instagram platform, Instagram can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of Instagram: http://instagram.com/about/legal/privacy/.

LinkedIn

Within our online offer, functions and contents of the service LinkedIn, offered by inkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can announce their liking of the content, the authors of the content or subscribe to our posts. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Top Line Group | Heinrichstrasse 239 | 8005 Zurich | Phone: +41 (0)44 749 25 25 | E-mail: info@topline.ch