Data protection declaration

This privacy policy tells you how we, Flyerline Schweiz AG (hereinafter also referred to as “we”, “us” and “our”), process personal data for our business activities and through our website (https://www.flyerline.ch; hereinafter also referred to as “website”). In particular, this is personal data concerning our customers, suppliers, business partners, the authorities, users of our website, visitors, event attendees, newsletter recipients, job applicants and other bodies or their respective contact persons or employees (hereinafter also referred to as “you”). Where appropriate, we may also inform you separately about the processing of your personal data (e.g. in a separate privacy policy or form).

If you are giving us data concerning other people (e.g. coworkers, family members), please ensure that the people concerned have been informed about this privacy policy and that you only provide us with data if you have the right to do so.

1. Controller for processing your personal data

The data controller for the processing described in this privacy policy is Flyerline Schweiz AG, Landstrasse 30, 8595 Altnau, Switzerland.

2. Sources through which we collect personal data

First of all, we process personal data that you provide to us (e.g. for your business relationship or communications with us) or that is recorded from your device when you access our digital content (e.g. our website).

We may also collect personal data from third parties where it is relevant to the purposes described in Section 3, to the extent legally permitted. In particular, these may include:

• Publicly available sources such as trade registers and debt collection registers, media sources, publications or the internet (including social media);
• Your client or employer if we have a business relationship or other connection with them (e.g. if you are named to us as a contact person);
• People acting on your behalf, such as family, representatives, advisers, legal representatives;
• The authorities (including tax authorities and social security, courts, etc.);
• Other third parties, such as employment agencies, credit agencies, database marketers, associations, contractual partners, internet analytics services, people involved in processes that have we initiated (e.g. counterparties, legal representatives, witnesses, expert witnesses), etc.

In particular, this includes the personal data that we process in the context of initiating, concluding and executing contracts, as well as data from correspondence and discussions with third parties, plus all other categories of data as per Section 3 below.

3. Purposes for which we process your personal data; legal basis

We collect and process your personal data primarily for the following purposes:

• Initiation and conclusion of contracts with you or your client or employer, whereby we may process personal data such as your name, address and contact details, financial data, authorised representatives, declarations of consent, information about third parties (e.g. contact persons), contractual content, creditworthiness, and any other data that you might provide to us or that we collect from the sources listed under Section 2. If and to the extent that we provide preliminary work or services, e.g. offer a purchase on account, we reserve the right to protect our interests by e.g. obtaining a credit check from one of the credit agencies named below if it seems appropriate to do so. For such checks, we will disclose the relevant personal data to the credit agency for lawful use, and use the information received concerning the statistical probability of a payment default to make a decision about whether to proceed with or terminate a contractual relationship. You can find more information at: https://mycrifdata.ch/home/en/;
• Recruitment of employees, for reviewing applications, subsequent stages of the application process, and in the case of successful application, for preparation and conclusion of a contract. This includes your name, address and contact details, your bank details, date of birth, marital status, tax data, social security data, information about your wages, working hours and data from the ongoing communication; it also includes in particular data that you provide to us in the context of an application process (e.g. your career path, higher education and further training, information about your moral character) and that we obtain from third parties (e.g. references, data from public sources such as social media);
• Administration and execution of contracts with our customers and other contractual partners (e.g. suppliers, service providers, project partners), in order to provide or request the contractually agreed services. This includes data processing for customer management, executing contracts and defending against claims (debt collection, legal processes, etc.), and accounting. For this purpose, we process the data that we are submitted or collect when initiating and concluding contracts (e.g. data about contractual services and service provision, financial and payment information and the other data mentioned above), and data that we compile as part of our contractual services or that we collect from public sources or other third parties as per Section 2 (e.g. minutes of discussions and advisory reports, memos, internal and external correspondence, contractual documents, order history, documents that we draw up or obtain as part of processes for the authorities, other information associated with the contract, and invoices);
• Compliance with regulatory processes such as legislation, industry standards, directives, recommendations from authorities, internal regulations, etc.;
• Communications with you and in particular with the third parties mentioned in Section 2, via email, the contact form on our website, telephone, letter or other means (e.g. for answering questions, during consulting or as part of initiating and/or executing contracts). For this purpose, we process in particular the contents of communications, your contact data, the metadata associated with your communication, and image and audio recordings from video or telephone calls. We may collect additional personal data if we need to confirm your identity (for example, a copy of your identity card);
• Marketing, advertising, and customer relations management, e.g. to offer personalised advertising (in the form of printed material, by email, or other electronic channels) to our business partners and other interested parties – concerning products, services and other new offers, or in relation to marketing campaigns such as events or competitions. For these purposes, we process in particular the names, addresses (including email addresses), telephone numbers and other contact details that we collect in the course of initiating or executing a contract or for newsletter signups or other registrations. If we collect your email address in relation to sale of a good or service and you have not refused consent, we reserve the right to send you offers relating to our portfolio, invitations to customer events or general company information. You can withdraw your consent to this kind of communication at any time (e.g. by writing to us (see Section 10) or clicking on the unsubscribe link in an email), in particular if you object or withdraw your consent to being contacted for marketing purposes (see Section 9);
• Quality assurance, market research and managing quotes (including compiling statistics, improvements to our products, services and other offers, including online content): for these purposes, we may collect data concerning your behaviour and preferences and data about your satisfaction with our products and services. For example, we may analyse how you navigate through our website, or which products and services are searched for which groups of people and how they are sought;
• Operation of infrastructure (including our IT and our digital content such as our website); in particular, we collect data as per Section 11 and make use of cookies, for the purpose of maintaining a secure, stable website service;
• Registration where this is necessary to use certain offers and services (e.g. a customer account on our website, newsletter), whereby we collect and process the personal data provided during registration, including your username and password. We manage registrations directly;
• Maintaining security, i.e. to ensure an adequate level of security for our infrastructure (e.g. buildings), IT and digital content (e.g. website) – such as prevention or investigation of potential crimes and maintaining security of our premises – and to continually improve our security. This includes monitoring and control measures concerning access to our IT systems and physical access to our premises, analyses and tests of our IT systems, system checks and troubleshooting. We may also keep logs and access records (e.g. visitor records) for the purposes of documentation and security (preventative measures and for investigating incidents);
• Diligent corporate management, in particular development of the company (e.g. acquisition and sale of business units or companies);
• Other purposes – in particular, these include training and professional development, administrative purposes (e.g. accounting), and organising events. For example, we may listen into or record telephone or video conferences for training purposes, as evidence, or for quality assurance purposes; in such cases we will inform you of this on a case-by-case bases and you will be free to inform us if you do not wish to be recorded or would like to terminate the communication, or turn off your camera if you object only to your picture being recorded. We may also process personal data for the purposes of organising, holding and following up on events. Such data may include in particular lists of participants, the contents of presentations and discussions, and images, video and audio recordings from these events. Protection of other legitimate interests must also be included among the other purposes; it is not possible to include an exhaustive list of these.

If and to the extent that we do not request your consent for some processing, we base such processing of your personal data on the fact that it is essential for initiating or executing a contract with you (or the body or entity you are representing) or the fact that we or a third party have a legitimate interest in doing so, in particular in pursuit of the purposes listed above and for taking suitable actions. Compliance with legal requirements also falls under our legitimate interests, assuming that it is not already recognised as a legal basis under the applicable data protection legislation. Other legitimate interests include marketing of our products and services, understanding our markets better, and a legitimate interest in managing and developing our business (including day-to-day operations) securely and efficiently.

4. Obligation to provide personal data

As part of our business relationship, you must provide the personal data necessary for establishing and conducting a business relationship and fulfilment of any related contractual obligations. This is justified as without this data, we are not able to conclude a contract with you (or the body or entity represented by you) or execute such contract. Similarly, our website cannot be used if certain data necessary to data transmission (such as your IP address) is not available. We will always specify if the personal data we ask for is mandatory.

5. Disclosure of your personal data

For the purposes listed in Section 3, we may transmit your personal data to other parties, in particular to the following categories of recipient:

• Service providers: We work together with service providers who process your personal data on our behalf or as joint controllers with us, or receive your data from us and become controllers for it (e.g. IT support, hosting and cloud providers, banks, payment services, insurance companies, trust companies, credit agencies, debt collection agencies, address check agencies, consultancies (including legal services), freight forwarders, shipping companies and the third parties listed under Section 11 who collect your data via our website);
• Business partners and collaborators: for example, customers and contractual partners (in particular, if you work for these entities or provide services to them), suppliers and subcontractors. This relates primarily to situations in which disclosure of your data is a consequence of the contract. The business partners and collaborators take full responsibility for their processing of this personal data;
• Authorities: We may disclose personal data to tax authorities, social security and other authorities, federal offices and the courts, if this is required for executing a contract or if we are legally required to do so or lawfully entitled to do so, or if it seems necessary for protection of our legitimate interests. The authorities will then be considered controllers for the purposes of processing your personal data received from us.

The specified categories of recipients may themselves bring in third parties, to whom your personal data may also be made available. We can restrict the processing by some third parties (e.g., IT support), but not by others (e.g. authorities, banks, insurance companies).

Furthermore, we allow certain third parties to collect and control your personal data through our website (e.g. providers of services that we have integrated into our website). These third parties have sole responsibility for the relevant data processing, unless and to the extent that we are materially involved. If you have any concerns about this processing, or wish to exercise your data protection rights (see Section 9), please contact these third parties directly. For more information about the activities on our website, see Section 11.

6. Data transmission outside Switzerland

We generally process and store any personal data in Switzerland and the EEA. However, recipients to whom we transmit your personal data per Section 5 (e.g. our service providers and their subcontractors) may also be located outside Switzerland or the EEA. In particular, this may apply in relation to services we use (see Section 11). You must therefore assume that your data may be transmitted to any of the countries domiciling our third party contractors.

If a recipient is located in a country without adequate data protection laws, we contractually require that the recipient complies with adequate data protection standards, e.g. by including the EU standard contractual clauses (see https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) with the additions necessary for Switzerland, providing the third party is not already subject to a legally recognised framework for data protection and we are not able to take an exceptional clause as a basis. Examples of exceptions in this sense include legal processes abroad, or cases of predominating public interest, or when the execution of a contract in your interest requires such disclosure, when you have consented or when the data in question has been made publicly available by you and you have not objected to its processing.

7. Data security

We take appropriate security measures to ensure the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing, and to minimise the risks of loss, unintended modification, unwanted exposure or unauthorised access.

When you make orders using our website, your personal data is transmitted via the internet. Data relevant to payment such as credit card details, passwords, etc., is not saved, it is processed directly by our payment provider Datatrans. Your online customer account can only be accessed by entering your individual password. You should always treat your payment information as confidential and close your browser window when you have completed your transaction with us, especially if you are not the only person who uses your computer.

For security reasons and to help protect against fraud by third parties, our website uses SSL encryption (Secure Socket Layer). You can recognise an encrypted connection as the URL for an encrypted connection begins with https:// rather than http:// and you will see a padlock symbol in your browser address bar. As long as the SSL encryption remains active, the data that you send to us cannot be read by third parties.

Please be aware that the communication methods and technologies that we use (email, videoconferencing, etc.) do not guarantee perfect data security for the messages or content being transmitted. In particular, we cannot guarantee that third parties may not be able to access data transmitted over these channels and store and use it for their own purposes. When you communicate with us directly and without further conditions via these channels, or do not explicitly refuse communications of this kind, we will assume that you agree to communication over such channels.

8. Retention period for personal data

We process your data for as long as necessary for our processing purposes, the legal retention periods and our legitimate interests in processing for documentation and verification purposes, or while necessary for technical reasons (e.g. for backups or document management systems). In particular, certain categories of data such as business communications or concluded contracts must be stored for up to 10 years.

Data from job applicants whose application was not taken further is deleted at the end of the application round, unless you have consented to your personal data being stored for longer.

9. Your rights

The data protection legislation applicable to you grants you certain rights in relation to the processing of your personal data. These include the right of access to information about the processing of your personal data, the right to rectification of incorrect personal data or erasure of personal data, the right to restriction of processing, the right to object to data processing (in particular, to processing for direct marketing and other legitimate interests) and the right to receive certain personal data for transmission to another location (data portability). There are various requirements, restrictions and exceptions that apply to these rights (e.g. the protection of third parties or business secrets). We reserve the right to exercise these, for example if we are required to store or process certain data on the basis of our predominant interest (if we are entitled to invoke this) or if the data is needed to assert a claim. We also reserve the right to black out copies or transmit data in excerpt form, on the basis of data protection law. We will inform you in advance if there will be any costs to you.

If and to the extent that we request your consent for certain processing, we will inform you separately about the purposes of that processing. You can withdraw your consent at any time with immediate effect, either in writing (by post) or, unless otherwise specified or agreed, by email. See Section 10 for our contact details. If we have received withdrawal of your consent, we will no longer process your data for purposes that you had originally consented to, unless we have another legal basis for doing so (e.g. a legal obligation or predominant interest). The withdrawal of your consent does not affect the lawfulness of the processing carried out on the basis of your consent until it was withdrawn.

If and to the extent that you do not agree to the way we handle your rights, please contact us (see Section 10). You also have the right to complain to the data protection supervisory authority in your country. The data protection supervisory authority for Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).

If you have questions about your rights or the exercise of these rights, please contact us in writing, or, unless otherwise specified or agreed, by email; our contact details are given in Section 10 below. Please note that we will need to confirm your identity, in order to rule out fraud (e.g., with a copy of your identity card).

10. Contact

If you have any concerns relating to data protection, please contact:

Flyerline Schweiz AG
Mr Stefano Biasella
Landstrasse 30
8595 Altnau, Switzerland

Email: qualitaet@flyerline.ch

11. Data that we process in relation to our website and other digital content

In connection with our digital content, in particular our website, we use technologies that log and store data in server log files, in particular technical data, such as:

• Your browser and browser version
• Your operating system
• Website that linked you to our website (referrer URL)
• The pages that you visit
• Volume of data transferred
• Hostname of the computer used to access the website
• Date and time of the server request

This data is not combined with data from other sources. We reserve the right to review this data if we have concrete reason to believe there may have been unlawful use.

We also use technologies such as cookies that enable us and our third party partners to recognise you and record your behaviour and preferences. Cookies are small pieces of data that are transmitted between your system and the server and used to recognise a particular device or browser. The primary reason for the use of cookies is to distinguish between you (or rather, your system) and other users accessing our content, so that we can guarantee the functionality of the website and undertake analysis and customisation. Cookies help us to make your visit to our website easier, more pleasant and more meaningful.

Most of the cookies that we use are “session cookies”. These are automatically deleted at the end of your browsing session. We also use some cookies that remain stored on your device until you delete them. We use these cookies to recognise your browser when you return to our website.

We only use optional cookies with your prior consent (for more information about the data processing involved, see Section 11.10 below). The first time you visit our website, you will see a banner that you can use to consent to the use of non-essential cookies, by selecting “Accept tracking”. Alternatively, you can select “Manage tracking settings” to enable specific categories of cookies, and then save your settings. If you consent to the use of cookies, a cookie will be saved to your computer and then the banner will no longer appear until that cookie is deleted. If the cookie is deleted, the banner will pop up again. If you simply “Close” the banner, only necessary cookies will be used. You can also configure your browser to notify you when cookies are set and only allow cookies in individual cases, deny cookies for specific cases, or to disable all cookies; you can also set the browser to delete cookies automatically each time you close it. If you disable cookies, this website may not function as intended.

We do not draw any conclusions about your identity based on either the technical data we log or the cookies. However, personal data saved by us, or by third party services we use, may be linked to the technical data or data in the stored cookies, particularly if you have a user account with us or one of the third party services. In this way, it is possible that this data will be linked to you personally.

The legal basis for processing your personal data by using necessary cookies (i.e. cookies that make our website usable or enable basic functions) is our legitimate interest in operating our website, including its security, and optimisation of our digital content. The legal basis for processing your personal data by using cookies for marketing and analysis purposes is your consent, given to us through the cookie banner.

We use our own tools and also third party services (which may place cookies on your device) on our website, for example to improve the functionality or content of our website (e.g. embedded maps and videos) and to compile statistics.

Some of the third party services that we work with are located outside Switzerland. You can find information about data transmission outside of Switzerland in Section 6.

We currently use services from the following third party providers:

11.1 Google Analytics

We use Google Analytics (hereinafter “Google Analytics”), a web analytics service from Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, or Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA (hereinafter “Google”). Google Analytics uses methods that facilitate analysis of how our website is used, such as cookies. This includes the service “Google Analytics 4”. This service makes it possible to associate data, sessions and interactions from different devices with a pseudonymous user ID and thereby to analyse the activity of one user across different devices. The methods used provide information about how you use the website, such as

• Navigation trails through our website
• Time spent on our website (including subpages)
• The last subpage visited before leaving the website
• The country, region, or town where you are when you access the website
• Your device (type, version, colour depth, resolution, width and height of the browser window)
• Web browser (including version) and operating system
• Whether the visitor is a new or repeat visitor
• The website visited before browsing to our website (referrer URL)
• Hostname of the device used to access the website (IP address)
• Time of the server request

This information is transmitted to Google servers in the USA and saved there. IP anonymisation software (“anonymizeIP”) activated on our website is used to truncate IP addresses before transmitting them to Member States of the European Union or other signatory states to the European Economic Area Agreement, including Switzerland. The anonymised IP addresses transmitted from your browser for Google Analytics are not linked with other data from Google. In exceptional cases, the full IP address is transmitted to a Google server in the USA and truncated there. In these cases, we have contractual guarantees in place, in particular the EU standard contractual clauses, to ensure that Google maintains an adequate level of data protection.

We use the information listed above to evaluate how our website is used, to compile reports about activity on our website and to provide additional services associated with use of our website and online services, for the purposes of market research and ensuring our website meets our users’ needs. Google may transmit this information to third parties, if this is legally required or if these third parties process the data on Google’s behalf.

On our website, we use the Google Analytics function “Demographics and Interests”. This tool is used to compile reports that can provide insights about the age, gender and interests of visitors to our website. The data is based on interest-related advertising provided by Google, and visitor data from third party providers. This data cannot be linked to any specific individual. You can disable this function any time in the ad settings in your Google account or by using the following tool to opt out of Google Analytics: Opt out of Google Analytics.

By default, the Google Analytics service is disabled. You can enable it through our cookie banner (see Section 11 above for more details). You can also prevent Google from recording and processing the data saved in the cookies or concerning your use of the website (including your IP address by downloading and installing the following browser add-on: https://tools.google.com/dlpage/gaoptout?hl=en. Once installed, the add-on will stop Google Analytics operating on this website. An opt-out cookie will be saved on your device. If you delete cookies from your device, you will need to click the link again.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information).

For more information about terms of use and data protection, see:

• https://www.google.com/analytics/terms/de.html
• https://policies.google.com/

11.2 Google Maps

We use the Google Maps API (Application Programming Interface, “Google Maps”) by Google on our website for visual presentation of geographic information (maps). Through the use of Google Maps, information about the use of our website, including IP addresses of visitors to our website, will be transmitted to a Google server in the USA and stored there.

By default, the Google Maps service is disabled. You can enable it through our cookie banner (see Section 11 above for more details). You can also use the cookie banner to disable Google Maps to prevent data from being transferred to Google by disabling JavaScript in your browser. However, if you do so you will not be able to use the map displays.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information).

For more information about the collection, processing and use of your data by Google, and your associated rights, see the Google privacy policy at https://policies.google.com/privacy and the additional terms of use for Google Maps and Google Earth at https://www.google.com/help/terms_maps.

11.3 YouTube

Our website uses plugins from YouTube, which is a video portal from YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a subsidiary of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “YouTube”), which operates the services in the European Economic Area and Switzerland. We use this plugin to improve your user experience by providing videos.

Each time you load a page that integrates one or more YouTube video clips, a direct connection will be established between your browser and a YouTube server in the USA. Information about your visit and your IP address will be recorded. When you interact with the YouTube plugins (e.g. by clicking the start button), this information will also be transmitted to YouTube and saved by YouTube. If you have a YouTube account and do not want YouTube to collect data about you from this website and link it to your YouTube account, you must log out of YouTube before you visit this website.

YouTube also uses the Google Analytics tool in the iFrame in which the video is requested (see Section 11.1 for more information about Google Analytics). This tracking is done directly by YouTube and we do not have any access to it. By default, YouTube and the Google Analytics tracking are disabled. However, you can enable these (see Section 11 and the end of Section point 11.1).

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information). See Section 11.1 for information about the data processing by Google Analytics.

For more information about how your data is collected and used by YouTube, see the YouTube/Google privacy policy: https://policies.google.com/privacy.

11.4 Google Tag Manager

We use Google Tag Manager, a Google service, on our website to manage the tracking cookies and pixels for tracking and other tools. Tag Manager is a cookie-free domain and does not record any personal data. However, it does trigger other tags that might collect personal data. If you have disabled tracking or cookies, this setting will apply for all tracking tags implemented with Google Tag Manager.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information). See Section 11.1 for information about the data processing by Google Analytics. Although we only use Google Tag Manager with your consent, we do also have a legitimate interest in analysing the behaviour of users of our website, in order to improve our online content and in particular our commercial viability.

For more information about how your personal data is collected and used by Tag Manager, see the Tag Manager privacy policy: https://marketingplatform.google.com/intl/en_uk/about/.

11.5 Google Ads

We use the Google Ads software program from Google, which includes conversion tracking. A conversion tracking cookie is set when you click on an ad placed by Google. These cookies expire after 90 days and are not used for personal identification.

If you visit certain of our websites and the cookie has not expired, Google can identify that you clicked on the ad and were directed to one of our websites. The information generated using conversion cookies is used to compile conversion statistics for us. We learn the total number of users who clicked on the adverts and were redirected to a webpage with a conversion tracking tag. We do not receive any information that can be used to identify individual users.

Conversion tracking is disabled by default. You can enable it through our cookie banner (see Section 11 above for more details).

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information). See Section 11.1 for information about the data processing by Google Analytics.

For more information about data protection in relation to Google Ads, see https://policies.google.com/technologies/ads.

11.6 Microsoft Bing Ads

On our website, we use conversion tracking by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). If you arrive at our website from a Microsoft Bing ad, Microsoft sets a cookie which enables Microsoft and us to identify that someone clicked on an ad and was directed to a predefined target page on our website. We do not receive any information about the identity of individual users. We only learn the total number of users who clicked on a Bing ad and were directed to the target page.

Your personal data is only processed by Microsoft if you have consented to the use of non-essential cookies through our banner (see Section 11 above). You can also prevent Microsoft from recording and processing the data saved in the cookies or concerning your use of the website (including your IP address) from the following link: https://account.microsoft.com/privacy/ad-settings/signedout.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information). See Section 11.1 for information about the data processing by Google Analytics.

For more information about data protection in relation to Microsoft and Bing Ads and the cookies they use, see: https://privacy.microsoft.com/en-GB/privacystatement.

11.7 Meta pixel

We use the Meta pixel (from Facebook) on our website. Facebook is a social network by Meta Platforms Ireland Ltd., Block J, Serpentine Avenue, Dublin, Ireland (hereinafter “Facebook”).

The Meta pixel is used by Facebook to define a target group for displaying ads based on identifying users of our website. We can use this pixel to limit display of our Facebook ads to those Facebook users who have shown an interest in our website or who exhibit certain characteristics that we tell Facebook about (e.g. an interest in certain topics or products, determined based on the websites visited – this is called “Custom Audiences”). This applies only to users who have enabled personalised ads. In this way, we want to ensure that our Facebook ads correspond to the potential interests of the users and are not seen as an annoyance. Since the Meta pixel provides information about whether users reach our website by clicking on a Facebook ad, it also enables us to review the effectiveness of our Facebook ads. This is useful for statistical and market research purposes and for optimising future ad campaigns.

Your personal data is only processed by Facebook if you have consented to the use of non-essential cookies through our banner (see Section 11 above). If you have done so, the Meta pixel will be loaded whenever you visit our website, and may save a cookie to your device. If you then log into Facebook or visit Facebook while logged in, the visit to our website will be recorded in your Facebook profile. The data recorded about you in this way is anonymous to us and we cannot use it to draw any conclusions about your identity. However, the data is also saved and processed by Facebook and may be associated with your Facebook user profile. This data may be used by Facebook for its own market research and advertising purposes.

You can disable the remarketing function “Custom Audiences” in your Facebook ad settings https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You will need to be logged into Facebook.

If you do not have a Facebook account, you can disable Facebook ads from the website of the European Interactive Digital Advertising Alliance: https://www.youronlinechoices.com/uk/your-ad-choices.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information).

For more information about how your data is collected and used by Facebook, see the Facebook privacy policy: https://www.facebook.com/privacy/explanation

11.8 X pixel (formerly Twitter)

On our website, we use the X pixel from Twitter International Company, Attn: Data Protection Officer, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland (hereinafter “X”). We use the X pixel to capture statistics about the use of our website so that we can optimise it.

Your personal data is only processed by X if you have consented to the use of non-essential cookies through our banner (see Section 11 above). If you have given your consent, then when you reach our website by clicking on an X ad, X will set a cookie on your device (“conversion tracking”). Conversion tracking is used for compiling statistics, not for identifying individuals. We want to know which X ads or interactions bring users to our website. This helps us to manage and target our ad campaigns, for example by enabling banner ads on specific websites.

You can prevent the X cookie from being set by disabling cookies in your browser settings (see Section 11 above). You can also configure your ad settings in your X account: https://x.com/settings/account/personalization. For more information, see https://help.twitter.com/

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information).

For more information about how your data is collected and used by Twitter, see the Twitter privacy policy: https://x.com/en/privacy

11.9 LinkedIn pixel

On our website, we use the LinkedIn pixel from LinkedIn Ireland Unlimited Company, Attn: Legal Dept., Privacy Policy and User Agreement, Wilton Plaza, Wilton Place, Dublin 2, Ireland (hereinafter “LinkedIn”). We use the LinkedIn pixel to capture statistics about the use of our website so that we can optimise it.

Your personal data is only processed by LinkedIn if you have consented to the use of non-essential cookies through our banner (see Section 11 above). If you have given your consent, then when you reach our website by clicking on a LinkedIn ad, LinkedIn will set a cookie on your device (“conversion tracking”). Conversion tracking is used for compiling statistics, not for identifying individuals. We want to know which LinkedIn ads or interactions bring users to our website. This helps us to manage and target our ad campaigns, for example by enabling banner ads on specific websites.

You can disable cookies in your browser settings. For more details on how to do this, see Section 11 above, or www.linkedin.com/help/linkedin.

The legal basis for processing your data for the purposes described above is your consent, which you give us from the cookie banner (see Section 11 above). You can withdraw your consent at any time (see Section 9 for more information).

For more information about how your data is collected and used by LinkedIn, see: https://www.linkedin.com/help/linkedin

11.10 Consent Manager (cookie banner)

Our website uses a consent manager to obtain your consent for the use of particular cookies or other technologies through your browser, and to document your consent in line with data protection guidelines. The consent manager enables you to choose which cookies and technologies you want to enable and which (non-essential) cookies and technologies you prefer to disable.

For the use of the consent manager, the following data is saved and processed:

• IP address (anonymised)
• Date and time of your consent
• Your browser user agent
• URL of our website
• Technical data about your browser
• Encrypted, anonymous key
• Cookies that you have accepted (as verification of your consent)

A cookie is set in your browser when you use our website, enabling us to associate your consent or refusal of cookies with your device. This cookie records which technologies you have consented to and which you have refused. The consent manager is stored locally on our servers and does not transmit any data to third parties.

The legal basis for processing your personal data for the above purposes is our legitimate interest in making our website user-friendly and in meeting our legal obligations (data protection).

12. Links to third party websites from our website

The footer of our website includes links to our corporate profiles on various social media networks. You can identify these by the logos of the respective social media networks. If you click on one of these links, you will be taken to our profile page on that social media network, and the data protection terms of that provider will apply (for more information, see Section 13). To use the functionality of the respective social media network, you may need to be logged into your user account there.

When you click the link to a social media network, a connection will be established directly between your browser and the social media network’s servers. Accordingly, the social media network will receive the information that you visited our website from your IP address and accessed the social media link from there. Furthermore, if you are logged into the social media network, the contents of our website may be linked to your profile on that network and your visit to our website may thus be linked directly to your social media account. If you do not want this to happen, you will need to log out of the social media site before clicking on the link from our page. However, if you log into the social media network after clicking on our link, your account will still be associated with the click.

In addition to our corporate profile on the various social media networks, our website also includes links to the websites of other third parties – in particular, institutions with whom we partner, which are linked from the “Partnerships” page.

The operators of the respective social media networks and websites have full responsibility for the contents and accuracy of the information on the social media sites and websites in the links. For more information about data protection on these pages, please see the privacy policies of those websites. At the time we added the links, we were not aware of any legal infringements. We do not have any influence on the current or future contents of the websites we link to.

13. Data that we process through our social media profiles

We have profiles on social media networks operated by third parties and we may process data about you through these profiles. For example, we can collect information about you if you communicate with us or comment on our content on these networks, or through the platform in the form of statistics. The platform operators may analyse your usage and process this data together with other data that they have about you. They also process this data for their own purposes (e.g. marketing and market research, management of the platform). In this context, they are the controller for that data. You can find more information about the processing by the platform operators in the privacy statements of the specific platforms.

We currently use the following platforms (the identity and contact details of each platform operator can be found in their privacy policy):

• Facebook
  www.facebook.com
  Privacy policy: www.facebook.com/privacy/policy
• LinkedIn
  www.linkedin.com
  Privacy policy: https://linkedin.com/legal/privacy-policy
• Instagram
  www.instagram.com
  Privacy policy: https://privacycenter.instagram.com/policy
• YouTube
  www.youtube.com
  Privacy policy: https://policies.google.com/privacy

We are entitled, but not obliged, to review third party content before or after its publication in our online content, delete content without notification and, if necessary, to report it to the provider of the relevant platform.

14. Changes to our privacy policy

We may review and update this privacy policy at any time. This applies even if the policy is referred to in contracts with you (including our general T&Cs), since the privacy policy does not comprise part of the contract. The version published on this website is always the current version.

Version: 16 december 2024