Privacy policy

In the event of any discrepancies between the German and the English version of this Privacy Policy, the German version shall prevail.

This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name dreipol.ch. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

We may publish further data privacy policies or other information on data privacy for individual or additional activities and operations.

We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized with decision of July 26, 2000 that Swiss data protection law guarantees adequate data protection. With report of January 15, 2024 the European Commission confirmed this adequacy decision.

Responsible in the sense of data protection law is:

dreipol AG
Langstrasse 113A
8004 Zurich
Switzerland

datenschutz@dreipol.ch

In specific cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties. We are happy to provide data subjects with information about the respective responsibility upon request.

Data protection representative in the European Economic Area (EEA)

We have designated the following data protection representation in accordance with Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

The data protection representative 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.

Data subject: Natural person about whom we process personal data.

Personal data: All information relating to an identified or identifiable natural person.

Particularly sensitive personal data: Data on trade union, political, religious or ideological views and activities, data on health, privacy or ethnic or racial origin, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as retrieving, comparing, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using personal data.

European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Privacy (Data Privacy Act, DPA) and the Ordinance on Data Privacy (Data Privacy Ordinance, DPO).

If and insofar as the European General Data Protection Regulation (GDPR) is applicable, we process personal data 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 and for the implementation of pre-contractual measures.
• Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are in particular the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
• Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill 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 processing of personal data necessary 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 in order to protect the vital interests of the data subject or another natural person.
• Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subject.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

We process the personal data required to carry out our activities and operations in a sustainable, people-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 constitute 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 permitted.

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 fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

We process personal data for the duration required for the respective purpose. We anonymize or delete personal data in particular depending on statutory retention and limitation periods.

We may process personal data automatically or use artificial intelligence to process personal data.

We may use profiling to automatically evaluate certain personal aspects relating to data subjects. Profiling is used, for example, to analyze or predict interests, behavior or personal preferences.

In specific cases, we provide information about decisions that are based exclusively on the automated processing of personal data and are associated with legal consequences for the data subjects or significantly affect them (automated individual decisions).

We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties are, in particular, specialized providers whose services we use.

For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

We process personal data in order to communicate with individuals as well as with authorities, organizations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is correct and may be transmitted.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of data subjects beyond direct communication.

In particular, we use:

• Pipedrive: Customer Relationship Management (CRM); Provider: Pipedrive OÜ (Estonia); Data protection information: Privacy Policy, "Controller and Data Processor" ("Data Controller and Data Processor").

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.

We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR.

We may allow applicants to store their details in our talent pool so that they can be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant may be suitable for a vacancy based on the information provided, we may inform the applicant accordingly.

We use selected services from suitable third parties to advertise vacancies via e-recruitment and to facilitate and manage applications.

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other digital presence is carried out using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport encryption.

Our digital communication - like all digital communication- 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 cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.

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

We may export personal data to all countries on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission.

We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.

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

• Information: Data subjects may 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 claims and ensure transparency. This includes the processed personal data as such, but also 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.
• Possibility for own point of view and human review: In the case of decisions based exclusively on the automated processing of personal data that have legal consequences for them or significantly affect them (automated individual decisions), data subjects can present their own point of view and request a review by a human being.
• Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
• Data surrender and data transfer: Data subjects can request the surrender 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 to the extent permitted by law. We can inform data subjects of any requirements that must be met 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 confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.

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

Data subjects have the right to enforce their data protection claims through the courts or to lodge 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).

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.

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.

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 make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request explicit consent to the use of cookies - at least if and to the extent required by applicable law.

For cookies that are used to measure success and reach 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).

We may log at least the following information for each access to our website and our other digital presence, insofar as this information is transmitted to our digital infrastructure during such accesses: 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 amount of data transferred, last website accessed in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. The information is required to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.

We can 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 usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to record at least the same information as is recorded in log files.

We enable you to publish comments on our website. In this context, we process in particular the information that a commenting person transmits to us themselves, but also the IP address as well as the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.

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

We send notifications and messages with the help of specialized service providers.

We are present on social media platforms and other online platforms in order to communicate with interested parties and 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 data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

We use services from specialized third parties in order to be able to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the IP addresses of users at least temporarily for technically compelling reasons.

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

• Google services: Provider : Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Privacy and Security Principles", "More information about how Google uses personal data", Privacy Policy, "Google is committed to complying with applicable data protection laws", "Google Products Privacy Guide", "How we use data from websites or apps on orwhere our services are used", "Types of cookies and similar technologies Google uses", "Advertising you can control" ("Personalized advertising").

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

We use in particular:

• Medium: Blog hosting; Provider: A Medium Corporation (USA); Data protection information: Privacy policy.

We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on your life situation, we recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences.

We use in particular:

• Google Meet: Video conferencing; Provider: Google; Google Meet-specific information: "Google Meet - Security and privacy for users".

We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply.

We use in particular:

• Asana: Platform for collaboration in companies; Provider: Asana Inc (USA); Data protection information: "Trust in Asana", privacy policy, bug bounty program.
• Miro: Whiteboard platform; Service provider: RealtimeBoard Inc (USA); Data protection information: Privacy policy, "Miro Trust Center".
• Slack: Platform for productive collaboration, in particular via chat; Service provider: Slack Technologies LLC (USA) for users in Canada and the USA / Slack Technologies Limited (Ireland) for users in the rest of the world; Privacy Policy: Privacy Policy, "Trust Center", "Frequently asked questions about data protection", "Data management: transparency and clarity", Cookie Policy.

We use the services of specialized third parties to integrate digital content into our website. Digital content includes, in particular, image and video material, music and podcasts.

We use the option of displaying targeted advertising on third parties such as social media platforms and search engines for our activities and operations.

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 - data to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

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

We use in particular

• Google Ads: Search engine advertising ; Provider: Google; Google Ads-specific data: Advertising based on search queries, among other things, whereby various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - are used for Google Ads, privacy policy for advertising, "Manage displayed advertising directly via ads"., 
• LinkedIn Ads: Social media advertising; Provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Data protection information: Remarketing and targeting, in particular with the LinkedIn Insight tag, "Data protection", privacy policy, cookie policy, objection to personalized advertising.

We try to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence 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.

In most cases, the IP addresses of individual users are recorded to measure success and reach. In this case, IP addresses aregenerally shortened ("IP masking") in order to comply with the principle of data minimization through the corresponding pseudonymization.

Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, 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 pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.

We use in particular:

• Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; Provider: Google; Google Marketing Platform-specific data: Measurement also across different browsers and devices (cross-device tracking) with pseudonymized IP addresses, which are only transmitted in full to Google in the USAin exceptional cases, privacy policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
• Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.

We have created this privacy policy using the privacy policy generator from Datenschutzpartner.

We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.