With this privacy policy, we inform you which personal data we process in connection with our activities and operations, including our www.trustlytics.ch website. In particular, we provide information on what personal data we process, for what purpose, how, and where. We also inform you about the rights of individuals whose data we process.

Individual or additional activities and operations may be subject to additional privacy policies as well as other legal documents such as general terms and conditions (GTC), terms of use, or conditions of participation.

We are subject to Swiss data protection law as well as any applicable foreign data protection law, such as, 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 adequate data protection.

• 1.

  Contact addresses

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  Responsibility for the processing of personal data:

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  Simon Jenny

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  Kuvvu GmbH

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  Trustlytics by Kuvvu

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  c/o Stieger Treuhand AG

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  Neuhofstrasse 5

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  8645 Jona

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  Switzerland

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  info@honeytrustlytics.ch

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  We point out if there are other individuals responsible for the processing of personal data in individual cases.

• 1.1

  Data protection officer or data protection advisor

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  We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities for inquiries relating to data protection:

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  Simon Jenny

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  Kuvvu GmbH

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  Trustlytics by Kuvvu

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  c/o Stieger Treuhand AG

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  Neuhofstrasse 5

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  8645 Jona

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  Switzerland

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  info@honeytrustlytics.ch

• 1.2

  Data protection representation in the European Economic Area (EEA)

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

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  Kuvvu GmbH

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  2nd, 3rd, 4th floor

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  Aspazijas bulvaris 20

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  Riga 1050

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  Latvia

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  info@honeykuvvu.com

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

• 2.

  Terms and legal basis

• 2.1

  Terms

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  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.

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  Processing includes any handling of personal data, regardless of the means and procedures used, in particular the querying, matching, adapting, archiving, storing, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying, and using of personal data.

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  The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principalities 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

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  We process personal data in accordance with Swiss data protection law, such as, in particular, the Swiss Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (DPO).

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

• Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject, as well as for the implementation of pre-contractual measures.

• Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms, 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 permanently in a user-friendly, secure, and reliable manner, as well as to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims, and to comply with Swiss law.

• Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data 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 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.

• Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.

• Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

• 3.

  Type, scope, and purpose

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  We process personal data that is necessary to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, and contract and payment data.

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  We process personal data for the duration that is required for the respective purpose(s) or by law. Personal data whose processing is no longer required is anonymized or deleted.

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  We may have personal data processed by third parties. We may process personal data together with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.

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  As a matter of principle, we process personal data only with the consent of the persons concerned. If and to the extent that the processing is permitted for other legal reasons, we may waive the requirement to obtain consent. For example, we may process personal data without consent in order to fulfill a contract, comply with legal obligations, or protect overriding interests

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  In this context, we process in particular information that a data subject voluntarily provides to us when contacting us, for example, by letter, e-mail, 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. If we receive data transmitted by other persons, the transmitting persons are obligated to ensure data protection with respect to these persons as well as the accuracy of this personal data.

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  We also process personal data that we receive from third parties, obtain from publicly available sources, or collect during our activities and operations, if and to the extent that such processing is permitted for legal reasons.

• 4.

  Personal data abroad

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

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  We may export personal data to all countries and territories provided that the law there ensures adequate data protection in accordance with the decision of the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, in accordance with the decision of the European Commission.

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  We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is ensured for other reasons, 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 adequate or appropriate data protection if the specific requirements under data protection law are met, for example, the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees upon request.

• 5.

  Rights of data subjects

• 5.1

  Data protection law claims

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  We grant data subjects all rights in accordance with applicable data protection laws. In particular, data subjects have the following rights:

• Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection rights and ensure transparency. This includes the personal data processed as such but also, among other things, 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.

• Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.

• Surrender of data and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

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  We may suspend, restrict, or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements they must meet in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.

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  We may charge costs for the exercise of the rights by way of exception. We inform affected persons in advance about any costs.

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

• 5.2

  Right to complain

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  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.

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  The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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  Data subjects have, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, the right to lodge a complaint with a competent European data protection supervisory authority.

• 6.

  Data security

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  We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

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  Access to our website is via transport encryption (SSL/TLS, in particular the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

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  Our digital communications, like all digital communications in principle, are subject to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies, and other security authorities.

• 7.

  Use of the website

• 7.1

  Cookies

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  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.

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  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 period. In particular, cookies enable us to recognize a browser the next time it visits our website and thus, for example, measure the reach of our website. However, “permanent cookies” can also be used for online marketing, for example.

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  Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request, at least if and to the extent necessary, the express consent to the use of cookies.

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  For cookies used for success and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via 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).

• 7.2

  Server log files

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  We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time, including time zone, IP address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, individual sub-page of our website accessed, including amount of data transferred, website last accessed in the same browser window (referer or referrer).

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  We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliable and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.

• 7.3

  Tracking pixel

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  We may use tracking pixels on our website. Tracking pixels are also known as “web beacons”. Tracking pixels, also from third parties whose services we use, are small, usually invisible images that are automatically retrieved when you visit our website. With tracking pixels, the same information can be collected as in server log files.

• 8.

  Notifications and communications

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  We send notifications and communications via email and other communication channels, such as instant messaging or SMS.

• 8.1

  Success and reach measurement

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  Notifications and communications may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.

• 8.2

  Consent and objection

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  As a matter of principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure where possible, i.e., you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents, including IP address, date, and time, for evidence and security reasons.

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  In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.

• 8.3

  Service provider for notifications and communications

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  We send notifications and communications using specialized service providers.

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  We use, in particular:

• KuvvuFly: Email delivery platform; Provider: Kuvvu GmbH (Switzerland); Data protection information: Privacy policy.

• 9.

  Social media

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  We are present on social media platforms and other online platforms in order to communicate with interested persons 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).

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  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 each case. These provisions inform, in particular, about the rights of data subjects directly in relation to the respective platform, which include, for example, the right to information.

• 10.

  Third-party services

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  We use the services of specialized third parties to perform our activities and operations in a durable, user-friendly, secure, and reliable manner. With such services, we can, among other things, embed functions and content on our website. In the case of such embedding, the services record the IP addresses of the users at least temporarily for technically compelling reasons.

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  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 offer the respective service.

•  

  We use, in particular:

• Services from Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and in Switzerland; General information on privacy policy: “Principles on data protection and security”, Privacy policy, “Google is committed to compliance with applicable data protection laws”, “Guide to privacy in Google products”, “How we use data from websites or apps on or in which our services are used” (Information from Google), “Types of cookies and other technologies used by Google”, “Personalized advertising” (Enable/Disable/Settings).

• 10.1

  Digital infrastructure

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  We use services from specialized third parties to make use of the required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

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  We use, in particular:

• DigitalOcean: Digital infrastructure; Provider: DigitalOcean LLC (USA); Exclusively for the www.trustlytics.ch website and not for the analytics service (product); Data protection information: Privacy policy, “Trust latform”.

• Hetzner: Hosting and other infrastructure; Providers: Hetzner Online GmbH / Hetzner Cloud GmbH (in each case Germany); Data protection information: Privacy policy, “Data Privacy FAQ”.

• 10.2

  Contact options

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  We use services from selected providers to better communicate with third parties, such as potential and existing customers.

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  We use, in particular:

• supporthub: Customer service; Provider: Kuvvu GmbH (Switzerland); Data protection information: Privacy policy.

• 10.3

  Payments

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  We use specialized service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, also apply to the processing of payments.

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  We use, in particular:

• Paddle: Payments processing; Providers: Paddle.com Market Limited (United Kingdom) / Paddle Payments Limited (Ireland) for users in the European Economic Area (EEA) and in Switzerland / Paddle.com Inc (USA); Data protection information: Privacy policy, “GDPR Readiness”, “Trust center”.

• 10.4

  Advertising

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  We use the option to display targeted advertisements for our activities and operations on third-party platforms such as social media platforms and search engines.

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  In particular, we would like to use such advertising to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding, possibly also personal, information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e., predominantly whether it leads to visits to our website (conversion tracking).

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  Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our website to your profile there.

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  We use, in particular:

• Google Ads: Search engine advertisement; Provider: Google; Google Ads specific information: Advertising based on search queries, among other things, using various domain names, in particular doubleclick.net, googleadservices.com, and googlesyndication.com, for Google Ads, “Advertising” (Google), “Why am I seeing a certain ad?”.

• LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Data protection information: Remarketing and targeting, especially with the LinkedIn Insight Tag, “Data protection”, Privacy policy, Cookie Policy, Objection to personalized advertising.

• 11.

  Success and reach measurement

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  We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. But we can also, for example, try out and compare how different parts or versions of our online offering 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 to our online offering.

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  In most cases, the IP addresses of individual users are stored 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.

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  Cookies may be used for success and reach measurement, and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window, and the (at least approximate) location. In principle, any user profiles are created exclusively in pseudonymous 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 service to the user account or user profile of the respective service.

•  

  We use, in particular:

• Trustlytics: Success and reach measurement; Provider: Kuvvu GmbH, Trustlytics by Kuvvu (Switzerland); Data protection information: Use on own server infrastructure, with pseudonymized IP addresses and no use of cookie, Privacy policy (The web page that you are currently perusing).

• 12.

  Final provisions

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  We can adapt and supplement this data protection declaration at any time. We will inform about such adaptations and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.

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  Rapperswil-Jona, September 2023