1. Privacy at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy set out below.

Data collection on this website

Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. You can find their contact details in the section “Note on the responsible party” in this privacy policy.

How do we collect your data? On the one hand, your data is collected when you provide it to us. This may, for example, involve entering data in a contact form. Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for? Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the data transmitted is also processed for contract offers, orders, or other order requests.

What rights do you have regarding your data? You have the right at any time to receive free information about the origin, recipient, and purpose of your stored personal data. You also have the right to request correction or deletion of this data. If you have given consent to data processing, you may revoke that consent at any time with effect for the future, not retroactively. Furthermore, under certain conditions you have the right to request restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority. For this and for further questions on data protection, you can contact us at any time.

2. Hosting and content delivery networks (CDN)

We host the content of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the host’s servers. This may include, for example, IP addresses, contact requests, metadata and communications data, contract data, contact details, names, website accesses, and other data generated via a website.

External hosting serves fulfilment of contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and Sec. 25(1) TTDSG (German Telecommunications-Telemedia Data Protection Act) insofar as the consent covers storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time with effect for the future.

The hosting provider processes your data only to the extent necessary to fulfil contractual service obligations and follows our instructions regarding this data.

We use the following host(s): DigitalOcean, 105 Edgeview Drive, Ste. 425, Broomfield, CO 80021, USA.

Data processing (hosting)

We have concluded a data processing agreement (DPA) with the provider named above. This contract ensures under data protection law that the provider processes the personal data of our website visitors only on our instructions and in compliance with the GDPR.

Cloudflare

We use the “Cloudflare” service of Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).

Cloudflare provides a globally available content delivery network with DNS. Technically, data transfer between your browser and our website is routed via Cloudflare’s network. Cloudflare can thus analyse the exchange of data between your browser and our website and act as a filter between our servers and the internet to block malicious traffic. In this context, Cloudflare may also use cookies or other technologies for recognising internet users; use is limited to the purposes described here.

Use of Cloudflare is based on our legitimate interest in providing our web offering as free of errors and as securely as possible (Art. 6(1)(f) GDPR). We rely on the European Commission’s standard contractual clauses (SCCs) for transfers to the USA. Details can be found at: https://www.cloudflare.com/privacypolicy/

The company concerned is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards when data is processed in the USA. Further information is available at: https://www.dataprivacyframework.gov/participant/5666

Data processing (Cloudflare)

We have concluded a data processing agreement (DPA) with the service provider named above, which requires that the personal data of website visitors be processed only on our instructions and in compliance with the GDPR.

3. General notes and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection provisions and this privacy policy. When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose that happens. We point out that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Note on the responsible party (controller under the GDPR)

The party responsible for data processing on this website is:

Aiman Demircan
Rue Le Corbusier 12
1208 Geneva
Switzerland

Phone: +41 41 552245-4
Email: [email protected]

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses, or similar).

Storage period

Unless a more specific storage period is stated in this privacy policy, your personal data remains with us until the purpose for processing no longer applies. If you assert a permissible request for deletion or revoke consent to data processing, your data will be deleted unless we have legally permissible grounds for further retention of personal data (e.g. tax or commercial retention periods); in the latter case, deletion takes place after those grounds cease to apply.

General information on the legal bases for data processing

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) or Art. 9(2)(a) GDPR where special categories under Art. 9(1) GDPR are processed. If you consent to transfer to third countries (e.g. the USA), Art. 49(1)(a) GDPR may also serve as the legal basis. If you have agreed to storage of cookies or access to information on your end device (e.g. device fingerprinting) within the meaning of Sec. 25(1) TTDSG, processing also takes place on that basis; revocation is possible at any time. If your data is needed to fulfil a contract or for pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Where we are legally obliged to do so, the legal basis is Art. 6(1)(c) GDPR. Where processing is based on our legitimate interest, the legal basis is Art. 6(1)(f) GDPR. In the following sections of this policy we state, where required, the legal basis applicable in each case.

Recipients of personal data

In the course of our activities we work with various external parties, which may require transfer of personal data to them. We disclose personal data to third parties only where necessary for contract fulfilment, we are legally obliged to do so, we have a legitimate interest within the meaning of Art. 6(1)(f) GDPR, or other legal provisions permit disclosure. Where we use processors, transfers are based on the contract concluded with them. In the case of joint responsibility, an agreement is regularly concluded to that effect.

Revocation of your consent

Many processing operations are possible only with your express consent. You may revoke consent given at any time with effect for the future. The lawfulness of processing carried out until revocation remains unaffected.

Right to object in special cases; objection to direct marketing (Art. 21 GDPR)

Where your personal data is processed on the basis of Art. 6(1)(e) or (f) GDPR, you have the right at any time to object to processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. The extent to which your personal data is processed in each case is set out in this privacy policy. If you object, we will no longer process your personal data concerned unless we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or processing serves the establishment, exercise, or defence of legal claims (objection under Art. 21(1) GDPR).

Where your personal data is processed for direct marketing purposes, you have the right at any time to object to processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will no longer be processed for direct marketing purposes (objection under Art. 21(2) GDPR).

Right to lodge a complaint with a supervisory authority

In the event of breaches of the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to receive data that we process automatically on the basis of your consent or for contract fulfilment, in a commonly used, machine-readable format, either to yourself or to a third party designated by you. If you request direct transfer of the data to another controller, this is done only where technically feasible.

Right to information, correction, and deletion

Within the scope of applicable law, you have the right at any time to request information about your personal data processed by us, its origin and recipients, and the purpose of processing. You may also have the right to correction or deletion of your personal data. Please contact us for this. Contact details can be found above under the responsible party.

Right to restriction of processing

You have the right to request restriction of processing of your personal data. Please contact us for this. The right to restriction of processing exists in particular in the following cases:

• If you contest the accuracy of your data stored with us, we usually need time to verify this. For the duration of the review you may request restriction of processing of your personal data concerned.
• If processing of your personal data was unlawful, you may request restriction instead of full deletion.
• If we no longer need your personal data for a purpose but you need it to establish, exercise, or defend legal claims, restriction of processing instead of deletion may be considered.
• If you have lodged an objection under Art. 21(1) GDPR, your interests and ours must be weighed. Pending clarification of whose interests prevail, you may request restriction.

Where processing of your personal data concerned is restricted, such data may — apart from storage — be processed only with your consent, for the establishment, exercise, or defence of legal claims, for the protection of the rights of natural or legal persons, or on grounds of important public interest of the EU or a member state.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect confidential content. You can recognise an encrypted connection by the fact that the browser address bar changes from http:// to https:// and a lock symbol may appear in the address bar. When encryption is active, data you transmit to us cannot be read by third parties.

4. Data collection on this website

Cookies

Our websites use so-called “cookies”. Cookies are small data packets and do not harm your device. A distinction is made between temporary session cookies, which your browser deletes at the end of your visit, and persistent cookies, which remain on your device longer until deleted or removed by your browser settings.

Cookies may come from us (first-party cookies) or from third-party providers (third-party cookies), for example to integrate payment services into websites. Cookies serve various functions. Many are technically necessary because certain website functions would not work without them (e.g. shopping cart or video display). Others serve, for example, analysis of user behaviour or advertising purposes where described in the relevant sections of this policy. Technically necessary cookies that serve operation, provision of certain functions you request (e.g. shopping cart), or proper optimisation of the website (so-called essential cookies) are stored — unless another legal basis is stated in a given case — on the basis of Art. 6(1)(f) GDPR. The operator has a legitimate interest in storing such technically necessary cookies to provide an offering that is technically and substantively sound and optimised. Where consent to storage of cookies and comparable recognition technologies has been requested, processing takes place exclusively on the basis of consent given (Art. 6(1)(a) GDPR and Sec. 25(1) TTDSG); consent may be revoked at any time with effect for the future. You can configure your browser to notify you when cookies are set, allow acceptance only in individual cases, exclude cookies in certain cases or generally, and activate deletion of cookies when closing the browser. If you disable cookies, functions of this website may be limited. Where further services and cookies are used, we explain this in this privacy policy.

Structured information submission

If you send us information via the contact form on the home page, we process your details including the contact data you provide there to review the submission and ask follow-up questions if needed. We do not pass this information to third parties without your consent.

If your enquiry relates to conclusion of a contract or serves pre-contractual purposes, the legal basis for processing is Art. 6(1)(b) GDPR. Otherwise we rely on our legitimate interest in effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or — where obtained — your consent (Art. 6(1)(a) GDPR); consent may be revoked at any time with effect for the future. Data remaining in the form or correspondence is kept until you request deletion, revoke storage, or the purpose for storage no longer applies (e.g. after your enquiry has been fully answered). This does not apply where statutory obligations, such as retention periods, require otherwise.

Contact by email, telephone, or fax

When you contact us by email, telephone, or fax, we store and process your enquiry together with all personal data arising in connection with it (name, enquiry) to handle your request. Disclosure to third parties takes place only with your express consent.

The legal basis is Art. 6(1)(b) GDPR where your enquiry is linked to fulfilment of a contract or serves pre-contractual measures. In all other cases processing serves our legitimate interest in effective handling of incoming enquiries (Art. 6(1)(f) GDPR) or — where obtained — your consent (Art. 6(1)(a) GDPR; revocation at any time with effect for the future). Data you provide when contacting us remains with us until you request deletion, revoke storage, or the purpose no longer applies (e.g. completed handling of your enquiry). Mandatory statutory provisions — in particular retention periods — remain unaffected.

Communication via Formspree

We sometimes use Formspree, Inc. (2261 Market Street #4603, San Francisco, CA 94114, USA; hereinafter “Formspree”) to receive and technically process information submitted via the contact form. When you submit, your entries (e.g. observation, context, optional email) together with technical data (e.g. IP address, timestamp, metadata) are processed by Formspree and/or by us for the purpose of transmission and handling.

Further information: https://formspree.io/legal/privacy-policy/

The legal basis for use of Formspree is our legitimate interest in straightforward and reliable handling (Art. 6(1)(f) GDPR) or — where obtained — your consent (Art. 6(1)(a) GDPR, revocable with effect for the future). We retain data you provide in this way until you request deletion, revoke storage, or the purpose for storage no longer applies, subject to statutory periods.

5. Online audio and video conferences (conference services)

Data processing

We may use online conference and communication services to stay in contact with our clients and third parties. When you speak with us via audio and video conference on the internet, both the provider of the conference service used and we may process personal data. The services typically record what you provide or share for use (email, telephone number), as well as session duration, start and end time, number of participants, and other context information derivable from the session (metadata). In addition, the provider of the respective tool processes the technical data required for online communication (in particular IP addresses, MAC addresses, device IDs, device and system type, client version, camera, microphone, and connection type). If content is exchanged, uploaded, or otherwise provided during a session, the respective service provider may store it (e.g. cloud recordings, chats, voicemail, photos, files) on its infrastructure as described in its privacy notice. Please note: we generally do not have comprehensive influence over processing by the service providers. Further information can be found in the privacy notices of the respective service used.

Purposes and legal bases

Use of the services serves contractually or pre-contractually required cooperation or service provision to you (Art. 6(1)(b) GDPR) and, where appropriate, expedient and proper communication with you (Art. 6(1)(f) GDPR). Where explicit consent has been requested, use is based on that consent; revocation is possible at any time with effect from the respective point in time.

Storage period

Data we store in our own systems from conferences is deleted when you request deletion, revoke consent to storage, or the purpose for storage ceases, subject to statutory periods. How long provider-side cookies or similar remain on your device depends on your browser settings. How long the respective service provider processes data is set out in their information; if in doubt, contact the provider directly.