Data Privacy Policy
Privacy Policy
This privacy policy informs you about the processing of personal data in connection with our activities and operations, including our website under the domain name sagw-nu.vercel.app. In particular, we explain what personal data we process, how, and where. We also inform you about the rights of individuals whose data we process. We may publish additional privacy policies or other information regarding data protection for specific or additional activities and operations.
This privacy policy explains how we process personal data, for what purpose, and where we process it. Table of Contents
1. Contact Information
2. Terms and Legal Bases
2.1 Terms
2.2 Legal Bases
3. Type, Scope, and Purpose of Personal Data Processing
4. Disclosure of Personal Data
5. Communication
6. Data Security
7. Personal Data Abroad
8. Rights of Data Subjects
8.1 Data Protection Rights
8.2 Legal Remedies
9. Use of the Website
9.1 Cookies
9.2 Logging
9.3 Tracking Pixels
10. Third-Party Services and Documents
11. Final Notes on the Privacy Policy
1. Contact Information
The data controller is:
Félix Terrones Aldana
Unterer Graben 21 – 9000 St. Gallen
Switzerland
felix.terronessaldana@unibe.ch
In individual cases, third parties may be responsible for processing personal data, or joint controllership with third parties may exist. We will gladly provide data subjects with information about the respective responsibility upon request.
2. Definitions and Legal Basis
2.1 Definitions
Data subject: Natural person whose personal data we process. Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data concerning trade union, political, religious or philosophical opinions and activities, data concerning health, privacy or ethnicity or race, genetic data, biometric data that uniquely identifies a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, retaining, retrieving, disclosing, obtaining, recording, collecting, erasing, making available, structuring, organizing, storing, altering, disseminating, linking, destroying, and using personal data.
2.2 Legal Basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (FADP) and the Ordinance on Data Protection (OFA).
3. Type, Scope, and Purpose of Processing Personal Data
We process personal data that is necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact data), location data, transaction data, contract data, and payment data. The personal data may also include particularly sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, insofar as such processing is permissible.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to comply with legal obligations or to protect overriding legitimate interests. We may also request consent from data subjects even if their consent is not required.
We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data, in particular depending on statutory retention and limitation periods.
4. Disclosure of Personal Data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized providers whose services we use. These third parties may, in turn, disclose personal data to other third parties.
In the course of our activities, we may disclose personal data, in particular, to banks and other financial service providers, public authorities, educational and research institutions, consultants and lawyers, accounting and trust service providers, debt collection agencies, advocacy groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media outlets, parent companies, and other third parties.
5. Communication
We process personal data to communicate with individuals as well as with authorities, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example, by mail or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other individuals are legally obligated to ensure the data protection of these individuals independently. They must, in particular, ensure that they are permitted to transmit such data and also guarantee the accuracy of the transmitted data.
6. Data Security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With these measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the processed personal data, although we cannot guarantee absolute data security.
Access to our website and our other digital presence is secured using transport encryption (SSL/TLS, especially with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn users before visiting a website without transport encryption.
Our digital communication—like all digital communication in general—is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the processing of personal data by intelligence services, police forces, and other security authorities. We also cannot rule out the possibility that an individual may be targeted for surveillance.
7. Personal Data Abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it there or have it processed there.
We may disclose personal data to any country on Earth and elsewhere in the universe, provided that the law of that country guarantees an adequate level of data protection in accordance with a decision of the Swiss Federal Council.
We may disclose personal data to countries whose law does not guarantee an adequate level of data protection, provided that suitable data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if the specific data protection requirements are met, for example, the explicit consent of the data subjects or a direct connection to the conclusion or execution of a contract. Upon request, we will gladly provide data subjects with information about any guarantees or a copy of any guarantees.
8. Rights of Data Subjects
8.1 Data Protection Rights
We grant data subjects all rights under applicable law. In particular, data subjects have the following rights:
Right of access: Data subjects can request information as to whether we process personal data concerning them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the processed personal data itself, but also information on the purpose of the processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
Rectification and Restriction: Data subjects can have inaccurate personal data rectified, incomplete data completed, and the processing of their data restricted.
Right to Explain oneself and Human Review: Data subjects can express their own point of view and request a human review in the case of decisions based solely on automated processing of personal data that have legal consequences for them or significantly affect them (automated individual decisions).
Right to Erasure and Objection: Data subjects can have their personal data erased («right to be forgotten») and object to the processing of their data with effect for the future.
Data Portability and Data Transfer: Data subjects can request the release of their personal data or the transfer of their data to another controller.
We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible framework.
We may inform data subjects of any conditions that may need to be met to exercise their data protection rights. For example, we may refuse to provide information, in whole or in part, due to confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse to delete personal data, in particular due to statutory retention obligations, in whole or in part.
We may, in exceptional cases, charge fees for exercising these rights. We will inform data subjects of any such costs in advance.
We are obligated to identify data subjects who request information or assert other rights using appropriate measures. Data subjects are obligated to cooperate.
8.2 Legal Remedies
Data subjects have the right to enforce their data protection rights through legal action or to file a complaint with a 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).
9. Use of the Website
9.1 Cookies
We may use cookies. Cookies—both our own (first-party cookies) and those from third parties whose services we use (third-party cookies)—are data stored in your browser. Such stored data is not limited to traditional text-based cookies.
Cookies can be stored temporarily in your browser as «session cookies» or for a specific period as so-called persistent cookies. Session cookies are automatically deleted when you close your browser. Persistent cookies have a specific storage duration. Cookies allow us, in particular, to recognize your browser on your next visit to our website and thus, for example, to measure the reach of our website. Persistent cookies can also be used for online marketing purposes.
You can disable, restrict, or delete cookies completely or partially at any time in your browser settings. Browser settings often also allow you to automatically delete and otherwise manage cookies. Without cookies, our website may not be fully functional. We actively request – at least where and to the extent required by applicable law – your explicit consent to the use of cookies.
9.2 Logging
For each access to our website and other digital presence, we may log at least the following information, provided it is routinely collected or transmitted to our digital infrastructure during such access: 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 subpage of our website accessed including the amount of data transferred, and the last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. This information is necessary to ensure the continuous, user-friendly, and reliable provision of our digital presence. It is also necessary to guarantee data security – including through or with the assistance of third parties.
9.3 Tracking Pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are typically small, invisible images or scripts written in JavaScript that are automatically retrieved when our website is accessed. Tracking pixels can collect at least the same information as log files.
10. Third-Party Services
We use services from specialized third parties to ensure our activities are carried out in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed functions and content into our website. For technically compelling reasons, these services collect users' IP addresses, at least temporarily, when such content is embedded.
For necessary security, statistical, and technical purposes, third parties whose services we use may process aggregated, anonymized, or pseudonymized data related to our activities. This includes, for example, performance or usage data required to provide the respective service.
Documents
We use third-party services to embed documents on our website. These documents can be PDF files, presentations, spreadsheets, etc. and text documents. This allows us to not only view, but also edit or comment on such documents.
11. Final Notes on the Privacy Policy
We created this privacy policy using the privacy policy generator from Datenschutzpartner.
We may update this privacy policy at any time. We will inform you of updates in an appropriate manner, in particular by publishing the current privacy policy on our website.