Data privacy statement Kummler+Matter Ltd.
We take protection of your personal data very seriously. Protecting your privacy and trustworthy handling of your personal data is a very important matter for us.
This data privacy statement describes what we do with your personal data when you visit our website, use our online shop, set up an account or subscribe to our newsletter, make a request, make a media enquiry, apply for a job, interact with us in another way as part of a contract, communicate with us or have any other interaction with us.
This data privacy statement is compiled in accordance with the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection (“FADP”) and the Swiss Revision of the Federal Data Protection Act (“revFADP”). However, whether and insofar as these laws are applicable depends on the individual situation.
1. Controller
The controller for data processing is:
Kummler+Matter AG
Rietstrasse 14
8108 Dällikon
Switzerland
privacy@kummlermatter.ch
kummlermatter.ch
2. What types of personal data are processed and what are they used for?
2.1 Types of processed personal data
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Basic data (e.g. names and addresses)
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Contact data (e.g. e-mail address and telephone numbers)
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Applicant data (e.g. information about the person, postal and contact addresses, the documentation belong-ing to the application and the information contained therein, e.g. cover letter, CV, certificates and other in-formation regarding themselves or qualifications, which is provided by applicants for a specific job opening or voluntarily)
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Content data (e.g. inputs in online forms)
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Usage data (e.g. websites visited, interest in content, access times)
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Meta/communication data (e.g. device information, IP addresses)
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Contractual data (e.g. subject of the contract, term, customer category)
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Payment data (e.g. bank details, invoices, payment history)
2.2 Purpose of processing
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Providing the website, its functions and contents
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Responding to contact requests and communication with users
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Application processes (reason for and any later implementation, as well as potential later termination of the employment relationship).
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Security measures
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Range measurement/marketing
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Tracking (e.g. interest- or content-related profiling, use of cookies)
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Providing contractual services and customer service
3. What is the legal basis for processing your personal data?
Unless the legal basis is specified in the data privacy statement, the following applies: Processing can be based on consent. Processing can then be used to provide our services and to implement contractual measures, as well as to answer queries. Furthermore, processing can be based on our legitimate interest or be due to legal obligations.
4. Which rights do you have?
You have the following rights based on the data protection legislation applicable to you if provided for therein:
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Right of access, rectification, erasure and restriction: You have the right to request access at any time to whether we are processing your personal data and which personal data we are processing. If we process or use your personal data, we will endeavour to take reasonable measures to ensure that your personal data is correct and current for the purpose for which it was collected. In the event that your personal data is incorrect or incomplete, you can request rectification of this. Furthermore, you have the right to request erasure or restriction to processing your personal data, e.g. if there is no longer a legitimate business purpose for pro-cessing your personal data according to this data privacy statement or the applicable legislation, and it legal re-tention periods do not require your data to be saved.
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Right to data portability: If necessary, you have the right to obtain the applicable personal data that you have provided to us in a structured, common and machine-readable format or to request transmission of this data to a third party.
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Right to revoke your consent: If you have consented to your personal data being collected, processed and used, you can revoke your consent at any time with future effect without affecting the legitimacy of the pro-cessing that was performed due to the consent until the time of revocation. Notification is sufficient by e-mail to privacy@kummlermatter.ch.
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Right to object: If your personal data is processed on the basis of our legitimate interest, you can object to future processing of your data. Furthermore, you can object to processing of your data for the purposes of direct advertisement.
You can contact us using the details specified in the “Controller” section at any time to exert your data protection rights.
You also have the right to lodge a complaint to the data protection supervisory authority regarding our processing of your personal data.
Please note that exceptions apply to these rights. In particular, we may have to process your personal data further and save it in order to fulfil a contract with you, to protect our own legitimate interests such as establishment, exercise or defence of legal claims, or to comply with legal obligations. If legally permissible, we can therefore reject your data protection requests, e.g. access and erasure requests, or only grant them to a limited extent.
5. How long will your personal data be saved?
We process and save your personal data only in the scope and for the duration for which it is required to fulfil our contractual and legal obligations or for other purposes relating to processing, as well as in accordance with the legal retention periods. As soon as your personal data is no longer required for the aforementioned purposes or a specified retention period elapses, your personal data will be deleted or anonymised as a matter of course and insofar as possible.
6. How do we protect your personal data?
The security of your personal data is important to us. We have taken comprehensive technical and organisational security precautions to safeguard the security of your personal data and to protect this against unauthorised or unlawful processing and/or against inadvertent loss, modification, dissemination or access. We check our security measures on a regular basis and adapt them to ensure that they are state of the art.
Despite reasonable and suitable organisational and technical measured being taken, processing personal data on the internet can always be subject to security vulnerabilities. We can therefore not guarantee absolute data security.
7. To whom do we transmit your personal data?
We will not transmit your personal data to third parties or disseminate it in any other way unless this is required to provide our services, you have consented to transmission or transmission of data is permissible due to applicable legal provisions.
In order to provide our services, to comply with contractual or legal regulations or for the purposes specified in this data privacy statement, it may be necessary to impart your personal data to the following categories of recipient:
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Group companies
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Service providers such as IT service providers, logistics companies, banks, consultants, sales and marketing
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Dealers, suppliers, subcontractors or other business partners
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Customers
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Domestic and foreign authorities, agencies or courts
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The public including website and social media visitors
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Media, press offices
The recipients can be domestic or foreign (anywhere in the world). You must expect your personal data to be transmitted to European countries and the USA, where the service providers used by us (such as Google LLC) are located. Depending on the type of service, personal data may have to be transmitted to recipients in states where there is no adequate data protection level. If the recipient is in a country without adequate legal data protection, we will oblige the recipient contractually to comply with the applicable data protection (we use the standard contractual clauses provided by the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en? for this) unless they are already subject to legally recognised regulations to ensure data protection and we cannot rely on an exceptional clause. An exception may be due to legal proceedings abroad, but also in the event over overwhelming public interest or if processing a contract requires such dissemination, if you have consented or if the data is data that you have made accessible in general and you have not objected to its processing.
8. Which personal data to we collect and for what purpose?
8.1 Use of our website, access data
You can use our website for purely informative purposes without disclosing your identity. When you load the individual pages on our website, only access data is transmitted to our providers so that you can view the website. This includes the following data:
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IP address
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Date and time of the query
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Name and URL of the data loaded
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Operating system of your computer and the browser used by you
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Country from which our website was accessed
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Name of your internet service provider
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Time zone difference to Greenwich Mean Time (GMT)
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Request contents (concrete page)
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Access status/HTTP status code
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Data volume transmitted
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Last websites visited
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Browser settings
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Language and version of the browser software
This data is only processed for the purpose of enabling use of our website (establishing a connection), guarantee-ing system security and stability continuously, optimising our offering and for internal statistical purposes, and therefore on the basis of our legitimate interest. This data will not be transferred to third parties or evaluated in any other way. Personal user profiles are not created.
8.2 Contact
If you contact us (e.g. via the contact form, e-mail, telephone or social media), the personal data provided by you will be processed by us to respond to your query and to communicate with you. The data collected by a contact form is shown on the relevant form. Required inputs for processing the query are highlighted. Other inputs are voluntary.
This personal data is only processed for the purpose of contact. The other personal data processed during the sending procedure is used to prevent misuse of the contact form and to safeguard the security of our IT systems.
The legal basis for processing is our legitimate interest in handling your query or fulfilling our contractual obligations if you contact us in relation to concluding a contract.
The personal data that you provided to us in contact requests will be deleted if you request that we do so, withdraw your consent to saving or the purpose of saving the data no longer exists (e.g. after your query has been processed completely). Legal retention periods remain unaffected by this.
8.3 Newsletter
You can subscribe to our newsletter on our website. We will use this to inform you about us, our offers and services.
Sending the newsletter is therefore based on your consent or, if consent is not required, on the basis of our legitimate interest in direct marketing as long as and insofar as this is legally permitted, e.g. in the event of existing customer marketing.
You have the option to cancel your subscription to the newsletter at any time and to withdraw the consent that you granted. To do this, click the relevant button (link) in the newsletter. This link to cancel your subscription to the newsletter is provided at the end of every newsletter. We will delete the personal data that we store for the purpose of sending the newsletter after you cancel the subscription.
8.4 Applications
If you apply for a job with us, we will process the personal data that we received from you as part of the application process. In addition to your personal information, education, work experience and abilities, this will also in-clude the usual correspondence data such as postal address, e-mail address and telephone number. Furthermore, all documents that you submit as part of your applications, such as the cover letter, CV and certificates will be processed. Applicants can provide us with further information on a voluntary basis. This data will only be saved, evalu-ated, processed or forwarded internally as part of your application. It can also be processed for statistical purposed (e.g. reporting). In this case, no conclusions can be drawn about individual people.
The legal basis for processing the application data is our legitimate interest in performing the application process or fulfilling our contractual obligations if processing is required to conclude a contract of employment. If the application is successful, the data that you submitted for the purpose of implementing an employment relationship will be saved.
If we conclude a contract of employment with you, the data submitted will be saved for the purpose of executing the employment relationship in accordance with the legal regulations. If the application process ends without employment, your data will be deleted unless you have given us consent to use your data for further application pro-cesses with us and to contact you again if necessary.
8.5 Careers
We offer you the option to register on our website. Registration requires you to enter the personal data that we request in the input form required for this. In addition, the IP address that you use and the date and time of submitting the registration form will be collected. We collect and save this personal data for internal use, for the pur-pose of communication with you, to execute existing or future contractual relationships (e.g. orders), to protect our technical system and to prevent misuse, as well as for transmission to one or several order processors (e.g. postal, package and payment service providers).
The legal basis for processing is your consent or fulfilling our contractual obligations if you register with us to conclude a contract.
As a registered person, you can change the personal data that you provided during registration at any time or have it deleted unless there are any other legal regulations such as retention periods that prevent this.
We will save the data collected during registration as long as you remain registered on the website and then delete it. Legal retention periods remain unaffected by this.
8.6 Use of our online shop
When you use our online shop, this requires the following processing of your personal data:
If you wish to order from our online shop, you must specify your personal data that we require to process your or-der in order to conclude the contract. Required inputs for processing the contracts are highlighted. Other inputs are voluntary. We will process the data you provide to complete your order. The legal basis for this is the requirement for order processing.
If the online shop offers this, you can create a voluntary customer account that we can use to save your data for later purchases. When you create a customer account, the data you provide is saved revocably. You can always de-lete all other data including your user account in the customer area.
If we save your personal data due to a contractual relationship, this data will remain saved at least for the duration of the contractual relationship and not longer than the limitation periods for possible claims from us run or legal and contractual retention periods exist.
9. What are cookies and how are they used?
Our website and various online services such as Google use cookies. Cookies are small files that are stored on your end device (laptop, tablet, smartphone, etc.) and saved by your browser. They are used to make our website more user friendly and effective and to make your visit to our website as convenient as possible. Cookies do not cause any damage.
The majority of cookies used by us are session cookies. They are deleted automatically when you log out or close your browser. Other cookies remain saved on your computer beyond the relevant usage process and enable us or our partner companies (third-party cookies) to remember your browser the next time you visit. If other cookies (such as cookies to analyse your browsing behaviour) are saved, these will be discussed separately in this data privacy statement.
The basis on which we process your personal data using cookies depends on whether we request your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your consent. Otherwise, the personal data processed using cookies is processed on the basis of our legitimate interest (e.g. in analysing and optimising our services and offers) or if the use of cookies is required in order to comply with our contractual obligations.
Regardless of whether processing takes place on the basis of consent or legal permission, you have the right to withdraw consent at any time or to object to processing of your personal data using cookie technology. You can set your browser up to inform you in advance of any cookies to be set and to decide in individual cases whether you wish to reject cookies for certain situations or in general, or to prevent cookies entirely. For more information, see your browser’s help menu.
10. How are analysis and marketing tools used?
We use various website analysis and tracking tools on our website, which we will explain in detail below. If we request your consent to use third parties, the legal basis for this form of data processing is your consent. If we do not obtain consent, your personal data is processed on the basis of our legitimate interests, i.e. our interest in providing efficient, economical and user-friendly services. In this regard, we would like to refer you to the information regarding the use of cookies in this data privacy statement.
10.1 Google Analytics
This website uses the Google Analytics analysis tracking tool, which is a web analysis software provided by Google LLC (USA). Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services within Europe.
Google Analytics uses cookies and similar technologies that are saved on your computer and enable analysis of your use of our website. We have added the “anonymizeIP” code to Google Analytics on our website. This guarantees that your IP address is masked so that all data is always transmitted anonymously to Google. The full IP address is only transferred to a Google server and shortened there in exceptional cases. Google will use this information to evaluate your use of our website for us, to compile reports regarding website activities for us and to provide further services associated with the website and use of the internet. Google will also transmit this data to third parties of necessary, as long as this is legally prescribed or if third parties process this data on behalf of Google. As per their own information, Google will never associate your IP address with other Google data.
You can use corresponding settings in your browser software to prevent cookies being saved but we would like to advise you that this may prevent you using some functions of our website completely. Furthermore, you can pre-vent Google collecting and processing the data by downloading the browser add-on that is available at the follow-ing link and installing it: https://tools.google.com/dlpage/gaoptout. You can deactivate Google Analytics for display advertising and adjust the advertisements in the Google display network by calling the advertisement settings: https://adssettings.google.co.uk.
For more information about the usage conditions and data privacy of Google Analytics, see: https://marketingplatform.google.com/about/analytics/terms/gb/ and https://policies.google.com/privacy.
11. How is social media used?
In addition to this website, we also maintain a presence on various social media. If you visit this online presence, personal data may be transmitted to the provider of the social network. We would like to advise you that user data may also be transmitted to a server in the third country and could therefore be processed outside Switzerland.
Furthermore, the user data is normally processed within social networks for market research and advertising pur-poses. For this purpose, cookies are normally placed on the users’ computers and save the usage behaviour and interests of the user. Furthermore, the usage profiles may also save data regardless of the devices used by the users (particularly if users are members of the relevant platforms and are logged in there).
Refer to the data privacy regulations and statements of the operators of the relevant networks for detailed infor-mation about the relevant forms of processing and objection options (opt-out). There, you can also find out the countries in which the data will be processed, which access, erasure and other data subject rights you have and how you can exert these or obtain further information.
12. Links to other websites
Our website may contain links to other websites. We do not have any control over the data protection practices or content on these other websites. We therefore recommend that you carefully read the data privacy statements of these other websites that you visit.