Data Protection
Data privacy protection
Data privacy statement
With this privacy policy, we inform which personal data we process in connection with our activities and operations including our www.faulhaber-marketing.ch-Website. We particularly inform about what for, how and where we process which personal data. We also inform about the rights of persons whose data we process.
For individual or additional activities and operations, further data privacy statements as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
We are subject to Swiss data protection law and any applicable foreign data protection law, 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
Responsibility for the processing of personal data:
Julia Faulhaber
Faulhaber Marketing GmbH
Landstrasse 43a
8450 Andelfingen Schweiz
We indicate if there are other persons responsible for the processing of personal data in individual cases.
1.1 Data protection officer resp. data protection advisor
We have the following data protection officer resp. data protection consultant as contact point for concerned persons and authorities in case of inquiries in connection with data protection:
Julia Faulhaber
Faulhaber Marketing GmbH
Landstrasse 43a
8450 Andelfingen Switzerland
1.2 Data Protection Representation in the European Economic Area (EEA)
We have the following data protection representation according to Art. 27 DSGVO:
VGS Data Protection Partner GmbH
Am Kaiserkai 69
20457 Hamburg Germany
The Data Protection Representation serves as an additional point of contact for concerned persons 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 Bases
2.1Terms
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.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, keeping, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, distributing, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The Data Protection Basic Regulation (GDPR) refers to the processing of personal data as processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, such as in particular the Swiss Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPA).
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- 6 para. 1 lit. b DSGVO 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.
- 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and 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 in a permanent, user-friendly, secure and reliable manner and to communicate about them, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- 6 para. 1 lit. c DSGVO for the necessary processing of personal data for the fulfillment of a legal obligation to which we are subject according to any applicable law of member states in the European Economic Area (EEA).
- 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task which is in the public interest.
- 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the person concerned.
- 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3.Type, scope and purpose
We process those personal data that are 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 and usage data, location data, sales data and contract and payment data.
We process personal data for the period of time required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly 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.
In principle, we only process personal data with the consent of the persons concerned. If and insofar as 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, to comply with legal obligations or to protect overriding interests.
In this context, we particularly process 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 to us about other persons, the transmitting persons are obligated to ensure data protection with respect to these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.
4. Applications
We process personal data about applicants to the extent that it is required for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data results particularly from the information requested, for example in the context of a job advertisement. We also process the personal data that applicants voluntarily provide or make public, especially as part of cover letters, resumes and other application documents as well as online profiles.
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 (2) lit. b GDPR.
5.Personal data abroad
We process personal data in Switzerland and in 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 and territories on earth as well as elsewhere in the universe, 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 – provided that adequate data protection is ensured in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do 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 data protection requirements are met, for example the express consent of the concerned persons or a direct connection with the conclusion or performance of a contract. Upon request, we will be happy to provide concerned persons with information about any guarantees or a copy of any guarantees.
6.Rights of Concerned Persons
6.1 Claims under data protection law
We grant concerned persons all claims in accordance with the applicable data protection law. Concerned persons have the following rights in particular:
- Information: Concerned persons can request information as to whether we process personal data about them, and if so, what personal data is involved. Furthermore, the persons concerned receive the information that is necessary to assert their claims under data protection law and to 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: Concerned persons can correct inaccurate personal data, complete incomplete data and restrict the processing of their data.
- Deletion and objection: Concerned persons can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data release and data transfer: Concerned persons can demand the surrender of personal data or the transfer of their data to another data controller.
We may postpone, restrict or refuse the exercise of the rights of concerned persons within the legally permissible framework. We may draw the attention of concerned persons to any requirements that must be fulfilled 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.
We may exceptionally provide for costs for the exercise of rights. We will inform concerned persons in advance of any costs.
We are obliged to take appropriate measures to identify concerned persons who request information or assert other rights. The persons concerned are obliged to cooperate.
6.2 Right to complain
Concerned persons have the right to enforce their data protection claims by legal means or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Concerned persons have the right – if and insofar as the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European data protection supervisory authority.
7.Data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communications – like all digital communications – 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 have any direct influence on the corresponding processing of personal data by secret services, police agencies and other security authorities.
8.Use of the website
8.1 Cookies
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 deleted automatically when the browser is closed. Permanent cookies have a certain 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. Permanent cookies can also be used for online marketing, for example.
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.
In the case of cookies used for performance 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), YourAd- Choices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Server log files
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, Internet Protocol (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 resp. referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to permanently provide our website in a user-friendly and reliable manner 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.
8.3 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – including those 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.
9. Notifications and Messages
We send notifications and messages via email and other communication channels such as instant messaging or SMS.
9.1 Performance and Reach Measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked on. Such web links and tracking pixels may also record the use of notifications and messages on a personspecific basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
9.2 Consent and objection
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. If possible, we will use the “double opt-in” procedure to obtain your consent, i.e. you will receive an e-mail with a web link that you must click on to confirm your consent so that it cannot be misused by unauthorized third parties. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.
9.3 Service providers for notifications and messages
We send notifications and communications using specialized service providers.
In particular, we use:
- Mailchimp: communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); data protection information: privacy policy (Intuit) including “Country and Region-Specific Terms”, “Frequently Asked Questions about Data Protection at Mailchimp“, “Mailchimp and European Data Transfers“, “Security“, cookie policy, “Privacy Rights Requests“, “Legal Provisions“.
10. Social Media
We are present on social media and other online platforms in order to communicate with interested persons and to inform them 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. These provisions inform in particular about the rights of concerned persons directly towards the respective platform, which includes, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called page in- sights, if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use page insights to provide our social media presence on Facebook in an effective and user-friendly manner.
Further information on the type, scope and purpose of data processing, information on the rights of concerned persons and the contact details of Facebook as well as Facebook’s data protection officer can be found in Facebook’s privacy policy. We have concluded the so-called “Responsible Party Addendum” with Facebook and thus agreed in particular that Facebook is responsible for ensuring the rights of concerned persons. For the so-called page insights, the corresponding information can be found on the page “Information on page insights“ including “Information on page insights data“.
11. Third Party Services
We use the services of specialized third parties in order to carry out 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 in our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the 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 particularly use:
- Services of Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles“, data protection statement, “Google is committed to complying with applicable data protection laws“, “Guide to data protection in Google products“, “How we use data from websites or apps on or in which our services are used“ (information provided by Google), “Types of cookies and other technologies used by Google“, “Personalized advertising“ (activation / deactivation).
- Services provided by Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection:
“Data protection at Microsoft“, “Data protection and privacy (Trust Center)“, privacy statement, privacy dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialized third parties to provide the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
- wordpress.com: Blog hosting and website builder; Provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; data protection information: privacy policy, cookie policy.
11.2 Contact options
We use services from selected providers to better communicate with third parties such as potential as well as existing customers.
In particular, we use:
- bexio: Customer Relationship Management (CRM); Provider: bexio AG (Switzerland); Data protection information: Privacy policy, “Cloud and data security“, “Data security – definition and measures for companies“.
11.3 Audio and Video Conferencing
We use specialized audio and video conferencing services to communicate online. We can use them, for example, to hold virtual meetings or to conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as privacy statements and terms of use, additionally apply.
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.
We use in particular:
- Microsoft Teams: platform for audio and video conferencing, among other things; provider: Microsoft; Teams-specific information: “Privacy and Microsoft Teams“.
11.4 Social Media Functions and Social Media Content
We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.
We use in particular:
- Facebook (social plugins): Embedding of Facebook functions and Facebook content, for example “Like” or “Share”; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: data protection declaration.
- Instagram platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); privacy information: privacy policy (Instagram), privacy policy (Facebook).
- LinkedIn Consumer Solutions Platform: Embedding of functions and content from LinkedIn, for example with plug-ins such as the “Share Plugin“; provider: Microsoft; LinkedIn-specific details: “Privacy“, privacy policy, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.
11.5 Digital Audio and Video Content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
We use in particular:
- Vimeo: video platform; provider: Vimeo Inc. (USA); information on data protection: data protection declaration, “Data protection”.
- YouTube: Video platform; provider: Google; YouTube-specific information: “Data protection and security center,” “My data on YouTube.
11.6 Fonts
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
- Adobe Fonts: fonts; provider: Adobe Inc (USA) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Privacy information: “Adobe Privacy Center“, Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), “Questions about privacy?”,
- Google Fonts: Fonts (EB Garamond); Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts“, “Privacy and Data Collection“.
- System fonts: Segoe UI
11.7 Advertising
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular persons 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 may 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 where you are registered as a user can, at most, assign the use of our online offer to your profile there.
We use in particular:
- Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Facebook pixel and Custom Audiences including Lookalike Audiences, data protection statement, “advertising preferences“ (user registration required).
- Google Ads: Search engine advertising; provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, with various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, “Advertising“ (Google), “Why do I see a certain ad?”.
- Instagram Ads: Social media advertising; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: remarketing and targeting, in particular with Facebook pixel and custom audiences including lookalike audiences, data privacy statement (Instagram), data privacy statement (Facebook), “advertising preferences” (Instagram) (user registration required).
- 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.
12. Extensions for the Website
We use extensions for our website in order to be able to use additional functions.
Jetpack: Various functions for the free blog software WordPress in the form of modules; providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among other countries; Privacy information: Privacy Notice for Visitors to Our Users’ Sites, Privacy Policy (from Automattic), “Jetpack Privacy Center“, Cookie Policy (Jetpack), Cookie Policy (Automattic).
13. Success and Reach Measurement
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. We can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data economy through the corresponding pseudonymization.
Cookies may be used for performance 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 pseudonymously and are not used to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online service to the user account or user profile with the respective service.
We use in particular:
- Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, “Privacy Policy.”
“Browser add-on to disable Google Analytics“.
- WordPress.com Stats: Success and reach measurement; Provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; Privacy information: Module of the Jetpack extension for the free blog software WordPress, Privacy Notice for Visitors to Our Users’ Sites, Privacy Policy (from Automattic), “Jetpack Privacy Center“, Cookie Policy.
14. Final Provisions
We have created this data protection declaration with the data protection generator of Datenschutzpartner.
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.
Place of jurisdiction:
Zurich, Switzerland
HR Number:
CH-020.4.076.144-7