Privacy Policy

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 www.felchlin.com. In particular, we provide information about why, how and where we process personal data. We also provide information about the rights of individuals whose data we process.

We may publish additional privacy policies or other information on data protection 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).

In its decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures adequate data protection. In its report of 15 January 2024, the European Commission confirmed this adequacy decision.

Table of contents

1.   Contact addresses

2.  Terms and legal basis

2.1  Terms

2.2  Legal bases

3.   Nature, scope and purpose of personal data processing

4.   Disclosure of personal data

5.   Communication

6.   Applications

7.   Data security

8.   Personal data abroad

9.   Rights of data subjects

9.1  Data protection claims

9.2  Legal protection

10.    Use of the website

10.1   Cookies

10.2   Logging

10.3   Tracking pixels

11.    Notifications and communications

11.1   Success and reach measurement

11.2   Consent and objection

11.3   Service providers for notifications and messages

12.    Social media

13.    Third-party services

13.1   Digital infrastructure

13.2   Automation and integration of apps and services

13.3   Audio and video conferencing

13.4   Online collaboration

13.5   Mapping

13.6   Digital content

13.7   E-commerce

13.8   Payments

13.9   Advertising

14.    Extensions for the website

15.    Success and reach measurement

16.    Video surveillance

17.    Final notes on the privacy policy

1. Contact addresses

The responsible party in terms of data protection law is:

Max Felchlin AG
Gotthardstrasse 11
6438 Ibach
Switzerland

compliance@felchlin.com

In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide information about the respective responsibility to affected persons upon request.

Data protection representative in the European Economic Area (EEA)

We have the following data protection representative 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 enquiries relating to the GDPR.

 2. Terms and legal basis

2.1 Terms

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

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

 Specially protected personal data: Data on trade union, political, religious or ideological views and activities, data on health, privacy or membership of an ethnic group or race, 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, for example, querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, organising, 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.

2.2 Legal basis

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

Where and to the extent that the European General Data Protection Regulation (GDPR) applies, 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 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 include, in particular, the long-term, people-friendly, secure and reliable exercise of our activities and operations, ensuring information security, protection against misuse, enforcing our own legal claims and complying with Swiss law.

▪     Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under any applicable law of Member States of the European Economic Area (EEA).

▪     Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.

▪     Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.

▪     Art. 6(1)(d) GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.

▪     Art. 9(2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

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).

3. Nature, scope and purpose of the processing of personal data

We process the personal data that is necessary to enable us 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 sensitive 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, insofar as such processing is permissible.

We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to protect overriding interests. We may also seek the consent of data subjects where their consent is not required.

We process personal data for the period of time necessary for the respective purpose. We anonymise or delete personal data in particular in accordance with statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to Drine, have it processed by third parties or process it jointly with third parties. Such third parties may, for example, be specialised providers whose services we use.

Within the scope of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and economic information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent companies, sister companies and subsidiaries, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, authorities, organisations and companies. In particular, we process data that a data subject provides us with when contacting us, for example by post or email. We may store such data in an address book or similar tool.

Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must ensure that such data is accurate and may be transmitted.

6. Job applications

We process personal data about applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent execution of an employment contract. The necessary personal data is derived 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 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 personal data about applicants in particular in accordance with Art. 9 (2) (b) GDPR, insofar as the General Data Protection Regulation (GDPR) is applicable.

We may allow applicants to store their details in our talent pool so that we can consider them for future vacancies. We may also use this information to maintain contact and provide updates. If we believe that an applicant is 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 positions via e-recruitment and to enable and manage applications.

In particular, we use:

▪     Ostendis: e-recruitment; provider: Ostendis AG (Switzerland); information on data protection: privacy policy.

7. Data security

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

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

Like all digital communication, our 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 have no direct influence on the 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.

8. Personal data abroad

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 for processing or to have it processed there.

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with a decision by the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) applies – also in accordance with a decision by the European Commission.

We may transfer personal data to countries whose laws do not provide adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements 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 gladly provide data subjects with information about any guarantees or provide a copy of any guarantees.

9. Rights of data subjects

9.1 Data protection claims

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

▪     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 necessary to assert their data protection claims and 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.

▪  Rectification and restriction: Data subjects may rectify inaccurate personal data, complete incomplete data and have the processing of their data restricted.

▪     Opportunity to express one's own point of view and human review: Data subjects may express their own point of view and request a review by a human being in the case of decisions that are based exclusively on automated processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions).

▪     Deletion and objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.

▪     Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of confidentiality obligations, overriding interests or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular on the grounds of statutory retention obligations.

In exceptional cases, we may charge a fee for exercising these rights. We will inform data subjects in advance of any costs.

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

9.2 Legal protection

Data subjects have the right to enforce their data protection claims through legal action or to file a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some Member States of the European Economic Area (EEA), data protection supervisory authorities have a federal structure, particularly in Germany.

10. Use of the website

10.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data are not necessarily limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as "session cookies" or for a specific 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. Cookies enable us to recognise a browser when it next visits our website and thus measure the reach of our website, for example. 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 for the automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively seek your express consent to the use of cookies, at least to the extent required by applicable law.

For cookies used to measure success and reach or for advertising, a general 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).

10.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: 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 subpages of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).

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

10.3 Tracking pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is logged in log files.

11. Notifications and messages

11.1 Success and reach measurement

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 may also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of the recipients.

11.2 Consent and objection

You must always consent to the use of your email address and other contact details, unless such use is permissible for other legal reasons. We may use the "double opt-in" procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consents obtained, including IP address and timestamp, for evidence and security reasons.

You can object to receiving notifications and communications such as newsletters at any time. By objecting, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.

11.3 Service providers for notifications and communications

We send notifications and communications with the help of specialised service providers. In particular, we use:

▪     SendGrid: platform for transactional emails ("email delivery made easy"); providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); information on data protection: privacy policy.

12. Social media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities. 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 privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, 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 Insights, insofar as the General Data Protection Regulation (GDPR) applies. 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 make our social media presence on Facebook effective and user-friendly.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Addendum for Controllers" with Facebook and have thus in particular that Facebook is responsible for ensuring the rights of data subjects. For Page Insights, the relevant information can be found on the "Page Insights Information" page, including "Page Insights Data Information".

13. Third-party services

We use services from specialised third parties to enable us to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect 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 an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

▪     Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in some cases for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Handling of data protection & protective measures", Data protection declaration, "More information on how Google uses personal data", "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 which our services are used", Cookie policy, "Advertising you can control" (settings for personalised advertising).

▪     Microsoft services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: "Data protection at Microsoft", "Data protection and privacy", Privacy statement, "Data and privacy settings".

13.1 Digital infrastructure

We use services from specialised third parties to access 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:

▪     Cyon: Hosting; provider: cyon GmbH (Switzerland); information on data protection: "Data protection", privacy policy.

▪     Microsoft Azure: storage space and other infrastructure; provider: Microsoft; Microsoft Azure-specific information: "Data protection in Azure".

13.2 Automation and integration of apps and services

We use specialised platforms to integrate and connect existing third-party apps and services. We can also use such "no-code" platforms to automate processes and activities with third-party apps and services.

In particular, we use:

▪     Microsoft Power Automate including Microsoft Power Platform: Integrated application platform; Provider: Microsoft; Microsoft Power Platform-specific information on data protection: "Compatibility and data protection", "Data storage and governance",

"Security".

13.3 Audio and video conferencing

We use specialised services for audio and video conferencing to enable online communication. This allows us to hold virtual meetings or conduct online lessons and webinars, for example. Participation in audio and video conferences is also subject to the legal texts of the individual services, such as privacy policies and terms of use.

Depending on your circumstances, we recommend that you mute your microphone by default when participating in audio or video conferences and blur your background or display a virtual background.