Data protection policy

1 Introduction

Wascosa AG offers various contact methods on its website www.wascosa.ch hereinafter ‘website’ through which personal data is collected. In the following, we will provide you with information about the collection of personal data when using our website.

Protection of your data is very important to us. We have therefore created this policy to explain how we handle your personal information.

We use transport encryption (SSL/TLS) when sending data from our website.
 

2 Applicable law

Our website is subject to the Swiss Federal Act on Data Protection (FADP) and applicable foreign data protection law. This includes the European Union’s (EU) General Data Protection Regulation (GDPR). The EU recognises that Switzerland guarantees adequate data protection.
 

3 Which data we use and why

3.1 Hosting

The hosting services we use provide the following services: infrastructure and platform services, computing capacity, storage and database services, security services and technical maintenance services, which we use in order to operate the website.

In the course of this, we or our hosting provider process existing data, contact data, content data, contract data, usage data, meta and communication data of customers, prospective customers and visitors to this website on the basis of our justified interest in an efficient and secure provision of our website according to the Swiss Federal Act on Data Protection (FADP) and, where applicable, Art. 6 para. 1(f) GDPR.

3.2 Access data

We collect information about you when you use this website. We automatically collect information about your usage and interaction with us, and register data about your computer or mobile device. We collect, store and use data about every access to our website (server log files). Access data includes:
 

1. Name and URL of the file retrieved
2. Date and time of retrieval
3. Quantity of data transferred
4. Report of successful retrieval (HTTP response code)
5. Browser type and version
6. Operating system
7. Referrer URL (the page you visited before our website)
8. Websites opened by a user’s system via our website
9. User’s internet service provider
10. IP address and the requesting provider

We use this log data, without linking it to your person or other profiling, for statistical analysis in order to operate, secure and optimise our website, and also to record anonymously the number of visitors to our website (traffic), the scope and type of use of our website and services, for billing purposes and to measure the number of clicks received by our cooperation partners. Based on this information, we can provide personalised, location-specific content and analyse data traffic, search for and correct errors and improve our services.

Therein lies our legitimate interest according to the Swiss Federal Act on Data Protection (FADP) and, where applicable, Art 6 para. 1(f) GDPR.

We reserve the right to subsequently review log data when there are specific indications to legitimately suspect illegal use. We store IP addresses in log files for a limited period of time when this is required for security purposes, such as when one of our offers is used. We also store IP addresses when we have a specific suspicion of an offence in connection with the use of our website. In addition, we store the date of your last visit as part of your account (such as when you register, log in, click links, etc.).

3.3 Cookies

We use session cookies to optimise our website. A session cookie is a small text file sent by a server when you visit a website and stored temporarily on your hard drive. This file contains a session ID, which can assign the various requests of your browser to the joint session. This allows the server to recognise your computer the next time you visit our website. This cookies are deleted after you close your browser.

We also use persistent cookies (small text files stored on your device) to a limited extent; they remain on your device and enable us to recognise your browser the next time you visit. These cookies are stored on your hard drive and delete themselves after a set period of time. Their lifespan is between one month and 10 years. This enables us to present our offer in a more user-friendly, effective and secure way, and to display information tailored to your interests.

Our legitimate interest in the use of cookies according to the Swiss Federal Act on Data Protection (FADP) and, where applicable, Art 6 para. 1(f) GDPR lies in making our website more user-friendly, effective and secure.

The following data and information is stored in the cookies, for example:

• Login information
• Language settings
• Search terms entered
• Information about the number of visits to our website and the use of individual functions on our website.

When a cookie is activated, it is assigned an identification number, but your personal data is not assigned to this identification number. Your name, IP address and similar data that would allow the cookie to be associated with you is not included in the cookie. On the basis of cookie technology, we receive only pseudonymised information, such as information about which pages were visited, which products were viewed, etc.

You can set your browser to inform you of cookies in advance and allow you to decide on a case-by-case basis whether you want to accept cookies in specific cases or generally reject them or block them completely. This may restrict website functionality.

3.4 Data for fulfilment of our contractual obligations

We process personal data that we require to fulfil our contractual obligations, such as names, addresses, email addresses, phone and mobile phone numbers. Collection of this data is required for conclusion of contracts.

This data is deleted after warranty periods and statutory record retention periods expire. Data connected to a user account (see below) is retained for the life of the account in all cases.

The legal basis for processing this data is the Swiss Federal Act on Data Protection (FADP) and, where applicable, Art. 6 para. 1(b) GDPR, since we need this data to fulfil our contractual obligations to you.

3.5 User account

You can use our website to log in to various user accounts. When you log in, we require your company name, your email address or username, and the password you have chosen.

A user account created by you can be deleted by us at any time and at no charge other than the transmission costs in the basic tariffs. A written notification sent to the contact points given in section one (via email, fax or letter) will suffice. We will then delete your stored personal data insofar as we do not need to store it to process an order or due to statutory record retention periods.

The legal basis for processing this data is your consent according to the Swiss Federal Act on Data Protection (FADP) and, where applicable, Art. 6 para. 1(a) GDPR.

3.6 Newsletter (infoletter)

Our website offers you the option to subscribe to our company newsletter. Which personal data is transmitted to be processed by those responsible for the newsletter when you subscribe depends on the subscription form you fill out.

The newsletter is a means by which we regularly inform our customers and business partners of company offers. Our company newsletter can generally be received by a person only if (1) they have a valid email address and (2) they register to receive the newsletter.
Subscribing to our newsletter involves the ‘double opt-in’ process. This means that we send you an email to the address you specified when you subscribed, in which we ask you to confirm that you wish to receive the newsletter. This confirmation email serves to verify whether the owner of the email address, as the data subject, is authorised to receive the newsletter.

In addition, we store the IP address assigned by the internet service provider (ISP) to the computer system used by the person concerned when they subscribe to the newsletter and the date and time of their subscription. This data must be collected in order to enable us to trace (possible) misuse of a data subject’s email address at a later point in time, and so it serves to provide legal protection to those responsible for the data processing.

The personal data collected when a person subscribes to the newsletter is used for the sole purpose of delivery of the newsletter. In addition, subscribers may be notified by email if this is necessary to operate the newsletter service or if registration is required, as may be the case in the event of changes to the newsletter offer or changes in technical circumstances. Personal data collected in the context of the newsletter service will not be passed on to third parties. A subscriber can cancel their subscription to our newsletter at any time. A subscriber can also withdraw their consent to our storage of their personal data for delivery of the newsletter, at any time. Each newsletter contains a link that can be used to withdraw that consent. In addition, the subscriber has the option to unsubscribe from the newsletter on the data processor’s website or notify the data processor of this decision by other means.

Our website uses MailChimp to deliver newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, US. MailChimp is a service that enables us to organise and analyse newsletter delivery. The data you enter to receive the newsletter (such as your email address) is stored on MailChimp’s servers in the US.

MailChimp is certified under the Swiss-US Privacy Shield and the EU-US Privacy Shield. The Privacy Shield is an agreement between Switzerland/European Union (EU) and the US that is intended to ensure compliance with Swiss and European data protection standards in the US.

MailChimp helps us analyse our newsletter campaigns. When you open an email sent with MailChimp, a file (called a web beacon) in that email connects to MailChimp’s servers in the US. This enables the service to determine that a newsletter message was opened and which links in the message were clicked (if any). Technical information is also collected (such as time opened, IP address, browser type and operating system). This information cannot be associated with individual newsletter recipients. Its sole purpose is for statistical analyses of newsletter campaigns. The results of these analyses can be used to better align future newsletters with subscribers’ interests.

Data processing takes place based on your consent (FADP) and, where applicable, Art. 6 para. 1(a) GDPR. You can withdraw your consent at any time with future effect by unsubscribing from the newsletter. The legality of data processing that has already taken place will not be affected when you withdraw your consent.
The data about you that we store in order to send you the newsletter will be stored until you remove yourself from the newsletter mailing list; it will be deleted from our servers and MailChimp’s servers after you unsubscribe from the newsletter. Data that we store for other purposes will not be affected.

For more information, see MailChimp’s data protection terms: https://mailchimp.com/legal/terms/.

We have entered into a Data Processing Agreement with MailChimp in which we require MailChimp to protect our customers’ data and not pass it on to third parties. You can view this agreement here:
https://mailchimp.com/legal/data-processing-addendum/.
 

3.7 Product recommendations and offers

Independently of the newsletter, we will send you other offers via email at irregular intervals. We send you information about products and services in our offer in which you might be interested based on your recent purchases of our services. We always do this in strict compliance with statutory requirements. You may object to this at any time, and at no charge other than the transmission costs in the basic tariffs. A written notification sent to the contact points given in section one (via email, fax or letter) will suffice. Of course every email will have an unsubscribe link too.

The legal basis for this is the statutory allowance according to the Swiss Federal Act on Data Protection (FADP) and, where applicable, as per Art. 6 para. 1(f) GDPR in conjunction with Art. 7 para. 3 UWG.

3.8 E-Mail contact

If you contact us (using a contact form or via email, for example), we process your details in order to handle your request and in the event that you have subsequent questions.

If we process this data to take precontractual measures at your request or, if you are already our customer, to fulfil a contract, the legal basis for this data processing is Art. 6 para. 1(b) GDPR.

We process additional personal data only if you give your consent (Art. 6 para. 1(a) GDPR) or if we have a legitimate interest in processing your data (Art. 6 para. 1(f) GDPR). A legitimate interest exists, for example, in replying to your email.
 

4 Google Analytics

We use Google Analytics, a web analytics service from Google Inc. (‘Google’). Google Analytics uses cookies; these are text files stored on your computer and which enable an analysis of your use of the website. The information that the cookie generates about the use of this website by site visitors is usually transferred to a Google server in the US, where it is stored.

Google has made itself subject to the Privacy Shield agreed between the European Union and the US, and received certification. This means Google agrees to comply with the standards and requirements of European data protection law. You can find more information at the following link:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

We have enabled IP anonymisation on this website (anonymizeIp). This means Google first shortens your IP address within member states of the European Union and in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will your full IP address be transferred to a Google server in the US and shortened there. Google will use this information on our behalf to analyse your use of the website, to compile reports on website activities and to provide us with other services associated with website and internet use.

Google does not link the IP address transferred by your browser within the scope of Google Analytics to other data held by Google. You can prevent storage of cookies by changing the corresponding setting in your browser. However, please note that in such an event you may not be able to use all the functions on this website to their full extent.

In addition, you can prevent transfer of data created by the cookie and related to your use of the website (including your IP address) to Google by downloading and installing the browser plug-in available at the link below:
http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plug-in or for browsers on mobile devices, click the following link to set an opt-out cookie that will prevent Google Analytics from collecting your data on this website in future. (This opt-out cookie works only in this browser and only for this domain. If you delete the cookies in your browser, you must click this link again.)
[Disable Google Analytics]
 

5 Google Maps

Our website employs an API (programming interface) that uses Google Maps. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use the functions of Google Maps, it is necessary to save your IP address. The information is usually transferred to a Google server in the US, where it is stored. The operator of this website has no further control over this data transmission.

Google Maps is used in the interest of providing an appealing presentation of our online offerings and making it easy to find the locations presented on our website. This constitutes a legitimate interest under Art. 6 (1f) GDPR.

More information about Google’s privacy policy can be found at the following link: https://policies.google.com/privacy?hl=policies
 

6 Storage period

Unless specified otherwise, we store personal data only for as long as we need it to fulfil our intended purposes.

In some cases, the law requires that we retain personal data; for example, for the purpose of tax or commercial law. In such cases we continue to store data only for these legal purposes; we do not process it in any other way, and we delete it after the statutory retention period expires.
 

7 Your rights as a subject of data processing

You can find an overview of your rights below, which you can exercise as a subscriber if the relevant legal conditions are met.

7.1 Right to access (Art. 15 GDPR)

You have the right to request a copy of the personal data concerning you that we have stored. There are exceptions to this right, which means that access can be refused, if, for example, the provision of data concerning you would reveal information about another person, or if we are legally prohibited from disclosing this information. You are entitled to view the stored personal data .

7.2 Right to rectification of inaccurate personal data (Art. 16 GDPR)

We strive to keep your personal data accurate, up to date and complete. We recommend that you inform us if your personal data is incorrect or has changed, so we can keep your personal data up to date.

7.3 Deleting stored personal data concerning you (Art. 17 GDPR)

We strive to keep your personal data accurate, up to date and complete. We recommend that you inform us if your personal data is incorrect or has changed, so we can keep your personal data up to date.

7.4 Right to access (Art. 18 GDPR)

Under certain conditions, you can also request that your data cease to be processed. For example, this applies to cases where there is a dispute about the accuracy of the data.

7.5 Right to data portability (Art. 20 GDPR)

You have the right to request that your personal data be made available to you or another data processor in a commonly used, machine-readable format.

7.6 Right to object to processing (Art. 21 GDPR)

Under certain circumstances, you also have the right to object to the processing of your personal data and to ask us to block, delete and restrict your personal data.
 

8 Data security

We make every effort to ensure the security of your data within the scope of applicable data protection laws and technical capabilities.

We encrypt your personal data when transmitting it. This applies to your orders and your customer login. We use the SSL (secure socket layer) coding system, but note that data transmissions on the internet (such as communication via email) may have security holes. It is impossible to protect data completely against third party access.

We take technical and organisational security measures to protect your data according to the Swiss Federal Act on Data Protection (FADP) and, where applicable  Art. 32 GDPR, and we always adapt to current technology.

In addition, we do not guarantee that our offer will be available at certain times; errors, interruptions and outages cannot be ruled out. The servers we use are backed up carefully at regular intervals.
 

9 Transfer of data to third parties, no transfer of data to countries outside the EU

As a rule, we use your personal data only within our company.

If and when we use third parties to fulfil contracts (such as logistics providers), they receive personal data only to the extent needed for the service they provide.

In the event that we outsource certain parts of data processing, we contractually obligate processors to ensure that they use personal data in compliance with the requirements of data processing laws and guarantee protection of the rights of the person concerned.

No transfer of data to locations or persons outside the EU takes place or is planned, apart from the case.
 

10 Controller

The controller within the meaning of the law is:

Wascosa AG
Werftestrasse 4
6005 Lucerne
Phone  +41 41 727 65 95
datenschutz@wascosa.com