Introduction
This Privacy Policy provides information about the processing of personal data in connection with the use of our website. The abbreviation GDPR stands for the EU General Data Protection Regulation and applies to individuals in the EU who visit our site (hereinafter “Individuals from the EU”). The abbreviation DSG stands for the Swiss Data Protection Act and applies to individuals in Switzerland who visit our website (hereinafter “individuals from Switzerland”). In particular, we also inform you about the processing of contractual data (subject matter, term, and customer categories) as well as payment data (bank account information, payment history), which we require to provide contractual services to you. We also inform you about our services, customer care, marketing, advertising, and market research, which are made possible by this data. The data controller within the meaning of data protection legislation and other provisions of a data protection nature is:

Soldati AG
Hasliring 1
6023 Emmen
Switzerland

Phone: +41 41 269 50 90
info@soldati.ch


Your Rights
Right of Access
Under Art. 8 of the DSG / Art. 15 of the GDPR, you have the right to request confirmation from us as to whether we are processing personal data concerning you. If this is the case, you have the right to access this personal data and to receive further information as specified in Art. 8 of the DSG / Art. 15 of the GDPR.

Right to Rectification
Under Art. 5 of the DSG / Art. 16 of the GDPR, you have the right to request that we rectify any inaccurate personal data concerning you without delay. Taking into account the purposes of the processing, you also have the right to request that incomplete personal data be completed — including by means of a supplementary statement.

Right to Erasure
Individuals from the EU have the right to request that we erase personal data concerning them without delay. We are obligated to erase personal data without delay provided that the relevant conditions set forth in Article 17 of the GDPR are met. For details, please refer to Article 17 of the GDPR. Individuals from Switzerland also have the option, in the cases provided for by law, to request the erasure of data, for example, if the data is no longer required or necessary, or if consent to processing has been withdrawn.

Pursuant to Article 18 of the GDPR, individuals from the EU have the right, under certain conditions, to request that we restrict the processing of their personal data.

Right to Data Portability
Under Article 20 of the GDPR, individuals from the EU have the right to receive the personal data concerning them that they have provided to us in a structured, commonly used, and machine-readable format, and they have the right to transmit this data to another controller without hindrance from us, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means.

Right to Object
Under Article 21 of the GDPR, individuals from the EU have the right to object to the processing of their personal data that is based on Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If we process your personal data for the purpose of direct marketing, you have the right at any time to object to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing.

Right to Lodge a Complaint with a Supervisory Authority
Under Article 77 of the GDPR, individuals from the EU have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy. This right applies in particular in the Member State of your residence, your workplace, or the location of the alleged infringement if you believe that the processing of your personal data violates the GDPR.

Individuals from Switzerland may avail themselves of the remedies provided under Articles 15, 25, 27, and 29 of the DSG.

Exercising Your Rights
If you wish to exercise any of your rights, please contact us, the data controller, using the contact information provided above, or use one of the other methods we offer to submit this request. If you have any questions, please contact us.

Server Log Files
When you visit our website, the company we have commissioned to operate the website processes and stores, in addition to technical information about the device you are using (operating system, screen resolution, and other non-personal characteristics) and your browser (version, language settings), in particular the public IP address of the computer you are using to visit our website, along with the date and time of access. An IP address is a unique numerical address through which your device sends or retrieves data on the Internet. As a rule, neither we nor our service provider knows who is behind an IP address, unless you provide us with information while using our website that enables us to identify you. Furthermore, a user may be identified if legal action is taken against them (e.g., in the event of attacks on our website) and we learn of their identity as part of the investigation. Therefore, you generally do not need to worry that we will be able to link your IP address to you.

Our service provider uses the processed data in a non-personalized manner for statistical purposes, so that we can track which devices with which settings are used to visit our website, in order to optimize it for those users if necessary. These statistics do not contain any personal data. The basis for compiling these statistics is our interest in improving and ensuring the efficient operation of our business (legal basis under the GDPR: Art. 6(1)(f)). The IP address is also used to enable you to access and use our website technically, as well as to detect and defend against attacks on our service provider or our website. Unfortunately, there are frequent attacks aimed at causing harm to website operators or their users (e.g., preventing access, spying on data, spreading malware (e.g., viruses), or other unlawful purposes). Such attacks would impair the proper functioning of the data center operated by the company we have commissioned, the use of our website and its functionality, as well as the security of our website visitors.

The IP address and the time of access are processed to defend against such attacks. Through our service provider, we pursue the legitimate interest in ensuring the functionality of our website and defending against unlawful attacks against us and our website visitors. The basis for this processing is the improvement and efficient operation of our business (legal basis under the GDPR: Art. 6(1)(f)). The stored IP data is deleted (through anonymization) when it is no longer needed to detect or defend against an attack.

Cookies
We use cookies and similar technologies (local storage) to operate our website, to ensure its technical functionality, to understand how visitors use our website, and to save the preferences a user has set in their browser. A cookie is a small text file that your browser stores on your device when you visit our website. When you visit our website again later, we can read these cookies. Cookies are stored for varying lengths of time. You can configure your browser at any time to specify which cookies it should accept; however, this may result in our website no longer functioning properly. You can also delete cookies yourself at any time.

If you do not do so, we can specify when saving a cookie how long it should remain stored on your computer. Here, a distinction must be made between so-called session cookies and persistent cookies. Session cookies are deleted by your browser when you leave our website or close your browser. Persistent cookies are stored for the duration we specify when saving them.

We use cookies for the following purposes:

• Technically necessary cookies, which are essential for using the features of our website (e.g., to determine whether you are logged in). Without these cookies, certain features could not be provided.
• Functional cookies, which are used to technically enable specific features that you wish to use.
• Analytics cookies, which are used to analyze your user behavior.
• Third-party cookies. Third-party cookies are stored by third parties whose features we integrate into our website to enable certain functions. They may also be used to analyze user behavior.

Most browsers used by our users allow you to control which cookies are stored and enable you to delete (certain) cookies. If you restrict the storage of cookies on certain websites or do not allow cookies from third-party websites, this may, under certain circumstances, prevent you from using our website to its full extent. Here you’ll find information on how to adjust cookie settings for the most common browsers:

Google Chrome

Internet Explorer

Firefox

Safari


Contact Form
If you send us a message using one of the contact options provided, we will use the data you provide to process your inquiry. The basis for this is our legitimate interest in responding to your inquiry (legal basis under the GDPR: Art. 6(1)(f)). If your inquiry is intended to lead to the conclusion of a contract with us, an additional legal basis for processing is the performance of that contract (Legal basis under the GDPR: Art. 6(1)(b)). The data will be deleted once your inquiry has been resolved. If we are legally required to retain the data for a longer period, it will be deleted upon expiration of the applicable retention period.

Job Applications
We are pleased that you are interested in our company and have applied—or are applying—for a position with us. Below, we would like to provide you with information regarding the processing of your personal data in connection with your application.

We process the data you have provided to us in connection with your application to assess your suitability for the position (or, if applicable, other open positions within our company) and to conduct the application process.

The basis for processing your personal data is our legitimate interest (legal basis under the GDPR: Art. 6(1)(f)) in conducting the application process and, if necessary, in asserting or defending against claims.

Data from applicants will be deleted within 6 months in the event of a rejection.

If you are offered a position as part of the application process, the data from the applicant management system will be transferred to our human resources information system.

Within the company, access to your data is generally limited to those individuals who need it to ensure the proper conduct of our application process.

Data Transfer Upon Contract Conclusion
When you purchase a product from us, we process the data you provide to conclude and fulfill the contract. To the extent necessary, data is transferred to service providers for the shipping and billing of your purchase. The legal basis for this processing is Article 6(1)(b) of the GDPR.

We also process this data to detect and prevent fraud attempts based on Article 6(1)(f) of the GDPR. Our goal in doing so is to protect ourselves against fraudulent transactions.

Data stored in connection with the conclusion of a contract for the purchase of a product is deleted once the statutory retention period has expired. To the extent that legal record-keeping and retention obligations exist due to the fulfillment of a sales contract (e.g., retention of invoices under tax law), the legal basis for the processing is Article 6(1)(c) of the GDPR.

We delete or anonymize the data when it is no longer needed for the performance of the respective contract and no statutory retention obligations remain.

Disclosure of Data to Third Parties
As a general rule, we do not disclose the personal data provided to us to third parties—in particular, not for advertising purposes.

However, we collaborate with third parties to operate this website or to provide products and services. In doing so, such third parties may gain access to personal data. We carefully select our service providers—particularly with regard to data protection and data security — and take all measures required under data protection law to ensure lawful data processing.

Data Processing in Switzerland / in the EU
We generally process data in Switzerland (data transmission upon conclusion of a contract, server log files, contact form, registration, cookies). The EU has determined that Switzerland maintains an adequate level of data protection under Decision 2000/518/EC. However, some of our service providers, whose plugins and tools we use, process data outside the EU. This is disclosed in this Privacy Policy whenever we provide information about the plugins and tools used.

An adequate level of data protection is ensured through participation in the «EU-U.S. Data Privacy» framework and the measures taken by the service provider regarding data protection and data security. Furthermore, we ensure that the provider is located in a country with an adequate level of data protection under Swiss law (Art. 7 VDSG) and is listed by the EDÖB.

«Google Analytics» Analysis Tool
We use Google Analytics, a service provided by Google LLC (“Google”), Amphitheatre Parkway, Mountain View, CA 94043, USA, as part of a data processing arrangement, potentially via Google Tag Manager. Google, acting as a data processor, uses a so-called «cookie» for this purpose. This is a small text file that is stored on your computer by your browser. Through this cookie, Google receives information about which website you have visited, as well as, in particular, the following information: browser type and version, operating system used, technical information about the operating system and browser, and the public IP address of the computer you are using.

We use Google Analytics in such a way that your IP address is used only in anonymized form. According to Google, this anonymization takes place within the European Union or a member state of the EEA. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and truncated there. According to Google, anonymization takes place before the IP address is first stored on a permanent data storage medium. For further details, please refer to Google’s Privacy Policy, available at https://support.google.com/analytics/answer/6004245?hl=en.

Google Analytics allows us to compile usage statistics for our website in a non-personally identifiable form, as well as demographic data about visitors and their user behavior. In addition, statistics are compiled that help us better understand how our website is found, so that we can improve our search engine optimization and our advertising efforts. Our legitimate interest in this processing is to improve our website and our advertising efforts. The legal basis for the processing is Article 6(1)(f) of the GDPR. You can find information on how to opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout?hl=en.

Google is a member of the Privacy Shield Framework and has entered into a data processing agreement with us for Google Analytics. The pseudonymized data is deleted after 14 months.

Social Media
We provide links to the following social media platforms: LinkedIn, Facebook, Instagram, and YouTube. You can find the corresponding privacy policies at
https://linkedin.com/legal/privacy-policy
https://www.facebook.com/privacy/explanation
https://www.instagram.com/legal/privacy
https://policies.google.com/privacy?hl=de

Updates to the Privacy Policy
We keep this Privacy Policy up to date. Therefore, we reserve the right to amend it from time to time and to reflect any changes in the collection, processing, or use of your data. The current version of the Privacy Policy is always available at the following address: https://soldati.ch/en/privacy