data privacy

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privacy policy
comTeam AG with its brands cadolino® and Lacoray® and accordingly also on their websites
Foreword

Data protection is important to us and the protection of personal data is a top priority for us. The following general privacy policy provides an overview of the collection and processing of personal data by comTeam AG.

Although an EU regulation, the GDPR is relevant to comTeam AG for various reasons: Among others: Swiss data protection law is historically closely tied to EU regulation, the Swiss Data Protection Act (revDSG) is heavily influenced by the GDPR, and finally, the GDPR imposes high data protection standards with extraterritorial effect. This means that companies outside the EU are bound by these regulations under certain conditions.

Therefore, comTeam AG has decided to apply the stricter data protection requirements for all customers. We therefore ask you to familiarize yourself with the following information on data protection.

The controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is

comTeam AG
Wagistrasse 23
CH-8952 Schlieren

T +41 (0) 44 730 45 10
E info@comteam-ag.ch

Represented by:

The owner, Managing Director and Chairman of the Board of Directors Marcel Spiess

Company data protection advisor:

Do you have any questions about our websites www.comteam-ag.ch, www.cadolino.com, www.lacoray.ch. Our data protection officer is at your disposal:

comTeam AG
Marcel Spiess
CEO, Owner & Chairman of the Board of Directors
Wagistrasse 23
8952 Schlieren

Phone +41 44 730 45 10
E-Mail: info@comteam-ag.ch

1. general information

Based on Article 13 of the Swiss Federal Constitution and the data protection provisions of the Swiss Confederation (Data Protection Act, DSG), every person is entitled to protection of their privacy and protection against misuse of their personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

In cooperation with our hosting providers, we endeavor to protect the databases as well as possible against unauthorized access, loss, misuse or falsification.

We would like to point out that data transmission over the Internet (e.g. when communicating by e-mail) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

By using this website, you consent to the collection, processing and use of data in accordance with the following description. This website can generally be visited without registration. Data such as pages called up or the name of the file called up, date and time are stored on the server for statistical purposes without this data being directly related to your person. Personal data, in particular name, address or e-mail address, are collected on a voluntary basis as far as possible. The data will not be passed on to third parties without your consent.

We collect the data listed in order to ensure a smooth connection to the website and to enable users to use our website conveniently. The log file is also used to evaluate system security and stability as well as for administrative purposes. The legal basis for the temporary storage of the data or log files is Art. 6 para. 1 lit. f) GDPR.

2. processing of personal data

Personal data is any information relating to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, deletion, storage, modification, destruction and use of personal data.

We process personal data in accordance with Swiss data protection law. In addition, we process personal data in accordance with the following legal bases in connection with Art. 6 para. 1 GDPR, insofar as the EU GDPR is applicable:

  • lit. a) Processing of personal data with the consent of the data subject
  • .

  • lit. b) Processing of personal data for the performance of a contract with the data subject and for the implementation of corresponding pre-contractual measures.
  • lit. c) Processing of personal data for compliance with a legal obligation to which we are subject under any applicable EU law or under any applicable law of a country in which the GDPR is applicable in whole or in part.
  • lit. d) processing of personal data in order to protect the vital interests of the data subject or of another natural person
  • lit. f) Processing of personal data in order to protect the legitimate interests of us or of third parties, except where such interests are overridden by the fundamental freedoms and rights and interests of the data subject. Legitimate interests are, in particular, our commercial interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.
  • We process personal data for the duration required for the respective purpose or purposes. In the case of longer-term retention obligations due to legal and other obligations to which we are subject, we restrict processing accordingly.

    We currently also offer the following social media channels

    As part of social media use, we may retrieve statistical usage data from the respective social media company. This may include information about page views and activities, views of individual articles, videos and services, etc. The legal basis for retrieving the data when using social media is Art. 6 para. 1 lit. f) GDPR.

    3. purpose of processing and legal basis

    We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and the Swiss Data Protection Act (revDSG).

    If necessary, we process your data beyond the actual fulfillment of the contract to protect our legitimate interests or those of third parties. We collect the data listed above in order to ensure a smooth connection to the website and to enable users to use our website conveniently. The log file is also used to evaluate system security and stability as well as for administrative purposes. We also store your data for technical security reasons, in particular to defend against attempted attacks on our web server.

    Examples in this context:

  • Responding to contact requests and communicating with users
  • Testing and optimizing processes for needs analysis and direct customer contact;
  • Advertising or market and opinion research, e.g. through the use of cookies, provided you have not objected to the use of your data;
  • Enforcement of legal claims and defense in legal disputes;measures for business management and further development of services and products;

    In particular, the social media companies use your usage behavior to create so-called usage profiles and use them to display advertisements. Cookies are usually stored on your computer for this purpose.

    If you have given us consent pursuant to Art. 6 (1) (a) GDPR to process personal data for specific purposes (e.g. transfer of data to third parties, evaluation of data for marketing purposes), the lawfulness of this processing is based on your consent. You can withdraw your consent at any time.

    Please note that the revocation is only effective for the future. Processing that took place before the withdrawal is not affected.

    If you have given the social media companies your consent to a specific data processing, the processing is carried out on the legal basis of Art. 6 para. 1 lit. a) GDPR.

    We are also subject to various legal obligations, i.e. legal requirements. Insofar as data is processed in this regard, this is done exclusively on the basis of these regulations.

    Applicable legal bases:

  • Consent, Art. 6 para. 1 lit. a and Art. 7 GDPR;
  • for the performance of our services and implementation of contractual measures as well as responding to inquiries, Art. 6 para. 1 lit. b GDPR;
  • to fulfill legal obligations, Art. 6 para. 1 lit. c GDPR;
  • in the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR;
  • for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, Art. 6 para. 1 lit. e GDPR;
  • to safeguard legitimate interests, Art. 6 para. 1 lit. f GDPR.

The processing of data for purposes other than those for which it was collected is governed by the provisions of Art. 6 (4) GDPR.

The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR].

4. Forwarding of the data

Within the company, those departments that need your data to fulfill our contractual and legal obligations will receive it. Processors employed by us (Art. 28 GDPR) may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, advice and consulting as well as sales and marketing.

With regard to the transfer of data to recipients outside the company, please note that we only pass on your data if this is permitted or required by law, if you have given your consent or if we are authorized to provide information. Under these conditions, recipients of personal data may be, for example, public bodies and institutions (e.g. public prosecutor’s office, police, supervisory authorities) if there is a legal or official obligation.

5. Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk. This includes ensuring the confidentiality, integrity and availability of data by controlling physical access to the data as well as access, input, disclosure, availability and separation of the data.

6. Data transfer to third countries

Data is transferred to bodies in countries outside Switzerland (so-called third countries) insofar as

  • it is necessary for the execution of your orders; or
  • you have given us your consent
  • .

We will inform you of the details separately if required by law.

When you visit our social media offerings, we would like to point out that your data may be processed as a user outside the EU. In the absence of standard contractual clauses, Art. 6 para. 1 lit. b) GDPR cannot be used as the legal basis for data transfer to Facebook and Instagram; instead, the exception under Art. 49 para. 1 lit. a) and c) GDPR applies.

In addition, we ensure, if possible, through appropriate contracts that an adequate level of data protection in accordance with European data protection law is maintained.

7. use of cookies

Our website uses cookies, which are stored by the browser on your device and contain certain settings for the use of the website (e.g. for the current session). Cookies are used to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser. Most of the cookies we use are so-called session cookies, which are automatically deleted when you close your browser. Other cookies remain stored on your end device until you delete them or the storage period expires. These cookies enable us to recognize your browser on your next visit.

In some cases, cookies are used to simplify website processes by storing settings (e.g. keeping options already selected). If personal data is also processed by individual cookies implemented by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b) GDPR either for the execution of the contract or in accordance with Art. 6 para. 1 lit. f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

We use the “Real Cookie Banner” consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. You can find details on how “Real Cookie Banner” works at https://devowl.io/de/rcb/datenverarbeitung

The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

8. YouTube video

This website embeds videos from YouTube.

When you visit one of our web pages on which YouTube is integrated, a connection to the YouTube servers is established.

YouTube is integrated via the domain https://www.youtube-nocookie.com in the so-called “extended data protection mode”, whereby no cookies are collected on user activities in order to personalize the video playback. Nevertheless, information on user interaction with the video (e.g. remembering the last playback point) may be stored.

We would like to point out that you use the YouTube service offered here and its functions in your own interest independently and under the responsibility of Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). This applies in particular to the use of interactive functions (e.g. sharing, rating). You can find information about which data is processed by Google and for what purposes it is used in YouTube’s privacy policy: https://policies.google.com/privacy

We have no influence on the type and scope of the data processed by Google, the type of processing and use or the transfer of this data to third parties. We also have no effective control options in this respect. By using YouTube, your personal data will be collected, transferred, stored, disclosed and used by Google and transferred to, stored and used in the United States, Ireland and any other country in which Google does business, regardless of your place of residence.

9. Google Analytics

On our website, we use the web analysis service Google Analytics from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, provided that you have given us your consent in accordance with Art. 6 para. 1 lit. a) GDPR. For this service, a cookie is set on your computer and the usage data stored is forwarded to Google and transferred to a server, which is usually located in the USA, and stored there. Google uses this information to evaluate the use of our online offer and in particular to create user statistics with pseudonymized user profiles. Google Analytics is only used with activated IP anonymization, which means that the IP address of Google users within member states of the European Union or in other contracting states of the Agreement on the European Economic Area is shortened. However, transmission of the full IP address to a Google server in the USA cannot be ruled out. Users can prevent the storage of cookies by refusing to give their consent or by setting their browser software accordingly. Furthermore, you can prevent the transmission of the data stored by the cookie to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de

You can find more information in Google’s privacy policy: https://policies.google.com/technologies/ads

10. Google API

The use of the Google AMP URL API is subject to the terms of use for Google APIs and Google’s privacy policy.

https://www.google.com/policies/privacy/

11. Google Tag Manager

Google Tag Manager is a service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). It is used to create, update and manage tags. These are used to measure traffic and visitor behavior on our website and to measure the impact of online advertising and social channels.

When you visit our website, the current tag configuration is sent to your browser. The tool itself does not collect any personal data. However, it triggers other tags, which in turn may collect data. You can find more information on how Google Tag Manager tags work here:

https://support.google.com/tagmanager/answer/2772432?hl=de&topic=2574304&ctx=topic and in the usage guidelines: https://www.google.de/tagmanager/use-policy.html.

12. Social plugins

We use social plugins (“plugins”) on the basis of our legitimate interests, i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f) GDPR. When you visit our site, a direct connection is established between your browser and the Facebook server via the plugin. Facebook receives the information that you have visited our site with your IP address. If you click on Facebook while you are logged into your respective account, you can link the content of our pages to your Facebook profile. This allows the visit to our site to be assigned to your user profile. If you are not a member of Facebook, it is still possible for Facebook to find out your IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany. If you do not want Facebook to collect data via this online service, you must log out of Facebook and delete your cookies before using our online service.

As the provider of the site, we have no knowledge of the content of the transmitted data or its use by Facebook. Further information can be found in Facebook’s privacy policy at https://de-de.facebook.com/policy.php.

13. User analysis by Permaleads

The internet offers on all our websites use a corresponding web analysis tool for the analysis of user behavior and the identification of the IP address of companies for marketing purposes. The use of this service requires that data on user behavior (e.g. IP address, time of access, user behavior, browser request, etc.) is transmitted directly to the analysis servers and made available for the exclusive use of comTeam AG. The data collected is treated as strictly confidential and is neither sold nor passed on to third parties. If you no longer wish to be identified in the future, please send an email to our data protection officer.

14. Facebook

We operate the Facebook fan page: https://de-de.facebook.com/cadolinoSchweiz

The operation of this fan page constitutes processing under joint responsibility with Facebook in accordance with Art. 26 GDPR. For this purpose, an agreement was concluded with Facebook Ireland Ltd. or Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This agreement can be accessed at the following link

https://www.facebook.com/legal/terms/page_controller_addendum.

According to this agreement, we ourselves have no decisions or influence over the processing of data by Facebook.

The responsibility for the processing of the so-called “Insights data” as well as the fulfillment of the corresponding obligations under the GDPR is assumed by Facebook.

15. Instagram

We also operate an Instagram page, which you can find at the following link

https://www.instagram.com/cadolino_com

Within our online offer, functions and content of the Instagram service are integrated by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA or Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This may include, for example, content such as images, videos or texts and buttons with which users can express their liking of the content, subscribe to the authors of the content or subscribe to our posts. If the users are members of the Instagram platform, Instagram can assign the access to the above-mentioned content and functions to the users’ profiles there.

You can find more information in Instagram’s privacy policy: http://instagram.com/about/legal/privacy/.

16. LinkedIn

We operate the LinkedIn page:

https://www.linkedin.com/company/comteam-ag-cadolino/

LinkedIn Ireland Unlimited Company (“LinkedIn Ireland”), Wilton Place, Dublin, Ireland is the sole controller for the processing of personal data when you visit our LinkedIn profile. The plugin can be used to publish feeds, content or links to our company LinkedIn page and enables us to share content of interest to users directly via our presence there, among other things. Responsible for data processing in the European Economic Area is the.

We have no influence on the type and scope of the data processed by LinkedIn Ireland Unlimited Company, the type of processing and use or the transfer of this data to third parties. We also have no effective control options in this respect. By using LinkedIn, your personal data will be collected, transferred, stored, disclosed and used by LinkedIn Ireland Unlimited Company and transferred to, stored and used in other countries, regardless of your place of residence.

17. contact form

For an inquiry via our contact form, we need your name, a valid e-mail address and a brief description of your request.

Information that you send us via the contact form, including the contact details you provide there, will be stored by us for the purpose of processing the request and in the event of follow-up questions. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

18. E-mail enquiries/communication via CleverReach

If you send us inquiries by email, your details from your email, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. An e-mail address is required for contact purposes, as well as your name. We will never pass on this data without your consent. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f) GDPR and, if applicable, Art. 6 para. 1 lit. b) GDPR if your request is aimed at concluding a contract. Your data will be deleted after final processing of your request, provided that there are no legal retention obligations to the contrary. In the case of Art. 6 para. 1 lit. f) GDPR, you can object to the processing of your personal data at any time.

Further information on CleverReach and CleverReach data protection can be found here:

https://www.cleverreach.com/de-de/datenschutz/

19. job vacancies and online applications

From time to time, we advertise vacancies in our company on our website with the option of applying to us directly online (direct application). If you apply for an advertised position, your data will only be collected and processed by us as part of the application process and deleted by us after the vacancy has been filled, unless legal requirements (for example, the burden of proof under the General Equal Treatment Act) make longer storage necessary, you have expressly consented to longer storage in the event that a position is to be filled again later, or we conclude an employment contract with you, in which case the data will be stored by us in the personnel file and for processing payroll accounting in compliance with the statutory data protection requirements. The legal basis for data processing is Section 26 BDSG and Art. 6 para. 1 sentence 1 lit. f) GDPR. The legitimate interest lies in the fulfillment of the burden of proof under the General Equal Treatment Act. The data will be deleted after 6 months at the latest.

If you consent to longer storage, the legal basis is Art. 6 para. 1 sentence 1 lit. a).

20. duration of the storage of personal data

To the extent permitted by law, we process and store your personal data, in particular as long as this is necessary to fulfill the respective purposes and the deletion does not conflict with any statutory retention requirements. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies in particular to data that must be retained for commercial or tax law reasons. Due to legal requirements, books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB are stored for 10 years. A 6-year retention period applies to commercial letters in accordance with Section 257 para. 1 no. 2 and 3, para. 4 HGB.

The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consent.

21 Your rights

Below you will find information on the data subject rights that the applicable data protection law grants you vis-à-vis the controller with regard to the processing of your personal data:

Right to information:Right to rectification:

The right, pursuant to Art. 16 GDPR, to request the rectification of inaccurate or incomplete personal data stored by us without undue delay.

Right to erasure:

The right, in accordance with Art. 17 GDPR, to request the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.

Right to restriction of processing:Right to data portability in accordance with Art. 20 GDPR:

You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller, provided this is technically feasible

Right to lodge a complaint:

You have the right to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of the federal state of our registered office or, if applicable, that of your usual place of residence or workplace.

Right of withdrawal:

Right to withdraw consent granted in accordance with Art. 7 para. 3 GDPR: You have the right to withdraw your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

22. right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) GDPR (data processing in the public interest) and Article 6(1)(f) GDPR (data processing on the basis of a balancing of interests); this also applies to profiling based on this provision within the meaning of Article 4(4) GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the establishment, exercise or defense of legal claims. The objection can be made informally and should preferably be addressed to one of the addresses given above.

We would like to point out that the easiest way to assert your rights as a data subject in connection with your social media use is to contact the social media company.

With Facebook under: https://www.facebook.com/legal/terms/information_about_page_insights_data

On Instagram under: https://help.instagram.com/155833707900388

On YouTube under: https://support.google.com/youtube/topic/2803240?hl=de&ref_topic=6151248

On Google under: https://policies.google.com/privacy?hl=de

On LinkedIn under: https://de.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy

23. obligation to provide data

When using the internet or social media, you only have to provide the personal data that is required for use or that we are legally obliged to collect. Without this data, meaningful use may be restricted or impossible.

24. external links

Where links are provided to other websites, we have neither influence nor control over the linked content and the data protection provisions there. When accessing linked websites, we recommend checking the privacy policies of these websites to determine whether and to what extent personal data is collected, processed, used or made accessible to third parties.

25. changes

We reserve the right to amend the Privacy Policy and the Terms of Use so that they always comply with current legal requirements or to implement changes to our services in the Terms of Use, e.g. when introducing new services. All changes and additions are at the sole discretion of the company. The current status is March 2023 and the new privacy policy will apply when you visit our website again.

26. copyrights

The copyright and all other rights to content, images, photos or other files on the website belong exclusively to the operator of this website or the specifically named rights holders. The written consent of the copyright holder must be obtained in advance for the reproduction of any files.

Anyone who commits a copyright infringement without the consent of the respective copyright holder may be liable to prosecution and may be liable for damages.

27 General exclusion of liability

All information on our website has been carefully checked. We make every effort to ensure that the information we provide is up-to-date, correct and complete. Nevertheless, the occurrence of errors cannot be completely ruled out, which means that we cannot guarantee the completeness, correctness and topicality of information, even of a journalistic or editorial nature. Liability claims arising from material or immaterial damage caused by the use of the information provided are excluded, unless there is evidence of willful intent or gross negligence.

The publisher may change or delete texts at its own discretion and without notice and is not obliged to update the content of this website. The use of or access to this website is at the visitor’s own risk. The publisher, its clients or partners are not responsible for damages, such as direct, indirect, accidental, pre-determined or consequential damages, which are allegedly caused by visiting this website and therefore assume no liability for this.

The publisher also accepts no responsibility or liability for the content and availability of third-party websites that can be accessed via external links on this website. The operators of the linked pages are solely responsible for their content. The publisher therefore expressly distances itself from all third-party content that may be relevant under criminal or liability law or offend common decency.

Schlieren, August 1, 2023 – comTeam AG (cadolino® and Lacoray®)

www.comteam-ag.ch, www.cadolino.com, www.lacoray.ch