Privacy Policy

Introduction

With the following data protection declaration, we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender specific.

As of November 14, 2022

Table of Contents

• Introduction
• Responsible
• Overview of processing
• Relevant legal bases
• Security Measures
• Transmission of personal data
• Data processing in third countries
• Deletion of data
• Use of cookies
• Provision of the online offer and web hosting
• Contact and request management
• Web analysis, monitoring and optimization
• Change and update of the privacy policy
• Rights of data subjects
• Definitions of terms

Responsible person

Megura AG

Email address:

patrick.ulrich(at)megura.ch

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Contact details.
• Content data.
• Usage data.
• Meta/Communication Data.

Categories of data subjects

• Communication partner.
• Users.

Purposes of processing

• Contact requests and communication.
• Security measures.
• Reach measurement.
• Tracking.
• Managing and responding to requests.
• Feedback.
• Profiles with user-related information.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

In the following you will find an overview of the legal basis of the GDPR, on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of them in the data protection declaration.

• Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR) - The person concerned has given their consent to the processing of their personal data for a specific purpose or several specific purposes given.
• Performance of a contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation pre-contractual measures are required, which are carried out at the request of the data subject.
• Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR) - Processing is necessary to protect the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and fundamental freedoms of the data subject, which require the protection of personal data, prevail.

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Switzerland. This includes in particular the Federal Data Protection Act (DSG). The DSG applies in particular if no EU/EEC citizens are affected and, for example, only data from Swiss citizens is processed.

Security Measures

We take appropriate technical measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data can include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if there are certifications or binding internal data protection regulations (Art. 44 bis 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as your consent to processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other, legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Our data protection information may also contain further information on the storage and deletion of data, which apply primarily to the respective processing.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the content of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Furthermore, cookies can be used for different purposes, eg for purposes of functionality, security and comfort of online offers as well as the creation of analyzes of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except where not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide the users with a telemedia service (i.e. our online offer) that they have expressly requested. The revocable consent is clearly communicated to the users and contains information on the respective use of cookies.

Notes on legal bases under data protection law: On which legal basis under data protection law we process the personal data of users with the help of cookies depends on whether we ask users for their consent. If the users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to enable our to fulfill contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

• Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application). has.
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 DSGVO.  Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (which can also limit the functionality of our online services). You can also object to the use of cookies for online marketing purposes via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing, procedures and services:

• Processing of cookie data on the basis of consent: We use a cookie consent management process, in the context of which the consent of the user to the use of cookies, or the The processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by the users. The declaration of consent is stored here so that the query does not have to be repeated and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or his device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and saved with the time of the consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

Provision of the online offer and web hosting

We process user data in order to be able to provide our online services to them. For this purpose we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the browser or the end device of the user.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Persons affected: users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security Measures.
• Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Further information on processing, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web hoster") or obtain otherwise; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The address and name of the retrieved websites and files, date and time of retrieval, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilization and stability; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or made anonymous. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

Contact and request management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) and in the context of existing user and business relationships, the details of the requesting person are processed to the extent necessary to answer the contact request and any requested measures .

• Types of data processed: Contact details (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Persons affected: Communication partners.
• Purposes of processing: contact requests and communication; managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) DSGVO).

Further information on processing, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).< /li>

Web analysis, monitoring and optimization

The web analysis (also referred to as "reach measurement") serves to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, identify at what time our online offer or its functions or content are used most frequently or invite people to use them again. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, ie data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read out from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have given their consent to us or the providers of the services we use to collect their location data, location data can also be processed.

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective process.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Persons affected: users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles); Tracking (e.g. interest/behavioural profiling, use of cookies); Provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).

Further information on processing, procedures and services:

• Google Analytics: Web analysis, range measurement and measurement of user flows; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website:https://marketingplatform.google.com/intl /en/about/analytics/; Privacy Policy:https://policies.google.com/privacy; Order processing agreement:https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring the level of data protection when processing in third countries):https://business.safety.google/ adsprocessorterms; Opt-out option: Opt-out plugin: https ://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated; More information:https://privacy.google.com/businesses/adsservices (types of processing and the data processed).

Change and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

Rights of data subjects

As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

• Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR to file an objection; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
• Right to withdraw consent: You have the right to withdraw consent at any time.
• Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
• Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, a restriction of the to request the processing of the data.
• Right to data portability: You have the right to receive data that you have provided to us in accordance with legal requirements in a structured, common and machine-readable format or to have it transmitted to someone else to demand those responsible.
• Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you are of the opinion that the processing of your personal data violates the provisions of the GDPR.

Definitions of Terms

This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.

• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, expressing the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or evaluate certain personal aspects relating to a natural person (depending on the type of profiling, different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.). to predict them (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
• Range measurement: The range measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for range analysis purposes in order to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.
• Tracking: One speaks of "tracking" when the behavior of users can be traced across several online offers. As a rule, behavior and interest information with regard to the online offers used is stored in cookies or on servers stored by the provider of the tracking technologies (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
• Responsible: The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
• Processing: "Processing" is any operation or series of operations carried out with or without the aid of automated procedures in connection with personal data. The term goes far and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.

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