Privacy Policy

With this privacy policy we inform you about which personal data we process in connection with our activities and operations , including our website . In particular, we inform you about what, how and where we process which personal data. We also inform you about the rights of people whose data we process.

For individual or additional activities and operations, additional data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact addresses

Responsibility for the processing of personal data:

Andreas Freimüller
nowtec solutions AG
Hermetschloostrasse 70
8048 Zurich

[email protected]

We will point out if there are other persons responsible for the processing of personal data in individual cases.

Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR :

VGS Data Protection Partner GmbH
Am Kaiserkai 69
20457 Hamburg

[email protected]

The data protection representation serves as an additional contact point for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the GDPR.

2. Terms and legal bases

2.1 Terms

Personal data is all information that relates to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, retrieving, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, changing, disseminating, linking, destroying and using personal data.

The European Economic Area (EEA) comprises the member states of the European Union  (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.

2.2 Legal basis

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

We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

  • Art. 6 (1) (b) GDPR for the necessary processing of personal data to fulfill a contract with the data subject and to carry out pre-contractual measures.
  • Art. 6 Para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and fundamental rights and interests of the data subject prevail. Legitimate interests are in particular our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, ensuring information security, protecting against misuse, enforcing our own legal claims and complying with Swiss law.
  • Art. 6 (1) (c) GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 (1) (e) GDPR for the necessary processing of personal data to perform a task carried out in the public interest.
  • Art. 6 (1) (a) GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 (1) (d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or of another natural person.

3. Nature, scope and purpose

We process the personal data that is necessary to carry out our activities in a long-term, user-friendly, secure and reliable manner. Such personal data can fall into the categories of inventory and contact data, browser and device data, content data, meta or peripheral data and usage data, location data, sales data and contract and payment data.

We process personal data for the period required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymized or deleted.

We may have personal data processed by third parties . We may process personal data jointly with third parties or transmit it to third parties. Such third parties are in particular specialized providers whose services we use. We also guarantee data protection for such third parties.

As a general rule, we only process personal data with the consent of the data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to protect overriding interests.

In this context, we process in particular information that a data subject voluntarily sends to us when contacting us – for example by letter, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We can store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other people, the people transmitting the data are obliged to guarantee data protection for these people and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities, provided and to the extent that such processing is permitted for legal reasons.

4. Data security

We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the personal data processed.

Access to our online presence, in particular our website, is carried out using transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries – like all digital communication in principle . We have no direct influence on the corresponding processing of personal data by secret services, police departments and other security authorities.

5. Personal data abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it there or to have it processed there.

We may export personal data to all countries and territories on Earth and elsewhere in the universe , provided that the laws there ensure adequate data protection as decided by the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – as decided by the European Commission .

We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.

6. Rights of data subjects

6.1 Data protection claims

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

  • Information: Data subjects can request information as to whether we process personal data about them and, if so, which personal data is involved. Data subjects also receive the information required to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
  • Correction and restriction: Data subjects can correct inaccurate personal data, complete incomplete data and have the processing of their data restricted.
  • Deletion and objection: Affected persons can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data disclosure and data transfer: Data subjects can request the disclosure of personal data or the transfer of their data to another responsible party.

We can postpone, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We can inform data subjects of any conditions that must be met in order to exercise their data protection claims. For example, we can refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. For example, we can also refuse to delete personal data in whole or in part with reference to statutory retention periods.

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

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

6.2 Legal protection

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

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

Possible data protection supervisory authorities for complaints from data subjects – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – are organized as members of the European Data Protection Board (  EDPB). In some Member States in the European Economic Area (EEA), the data protection supervisory authorities are structured on a federal basis, in particular in Germany .

7. Use of the website

7.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that is stored in the browser. Such stored data does not have to be limited to traditional text cookies.

Cookies can be stored temporarily in the browser as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies are stored for a certain period of time. Cookies make it possible in particular to recognize a browser the next time you visit our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be deactivated or deleted in whole or in part at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies – at least if and to the extent necessary.

For cookies used for success and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices ( Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

7.2 Server log files

We may record the following information for each access to our website, provided that it is transmitted from your browser to our server infrastructure or can be determined by our web server: date and time including time zone, IP address , access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. The information is required in order to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.

7.3 Web beacons

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those of third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can record the same information as in server log files.

8. Notifications and communications

We send notifications and communications via email and other communication channels such as instant messaging or SMS.

8.1 Measuring success and reach

Notifications and messages can contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.

8.2 Consent and objection

You must always give your express consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure wherever possible, which means that you will receive an email with a web link that you must click to confirm so that no misuse can occur by unauthorized third parties. We can log such consents, including the IP address and the date and time, for evidential and security reasons.

In principle, you can object to receiving notifications and messages such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for success and reach measurement. Necessary notifications and messages in connection with our activities and operations remain reserved.

8.3 Service providers for notifications and communications

We send notifications and communications with the help of specialized service providers.

In particular, we use:

9. Social-Media

We are present on social media platforms and other online platforms in order to communicate with interested parties and to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights, if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to be able to provide our social media presence on Facebook in an effective and user-friendly manner.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook’s data protection officer can be found in Facebook’s privacy policy . We have concluded the so-called “Addendum for Responsible Parties” with Facebook and have thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. The corresponding information for the so-called Page Insights can be found on the “Information on Page Insights” page , including “Information on Page Insights data” .

10. Third Party Services

We use services from specialized third parties to be able to carry out our activities in a permanent, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into our website. With such embedding, the services used record the IP addresses of the users at least temporarily for technically compelling reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities in an aggregated, anonymized or pseudonymized manner. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

10.1 Digital infrastructure

We use services from specialized third parties to provide the digital infrastructure required in connection with our activities. This includes, for example, hosting and storage services from selected providers.

In particular, we use:

10.2 Automation and integration of apps and services

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

10.3 Contact options

We use services from selected providers to better communicate with third parties such as potential and existing customers.

10.4 Scheduling

We use services from specialized third parties to arrange appointments online, for example for meetings. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply.

10.5 Audio and video conferences

We use specialized services for audio and video conferences to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.

In particular, we use:

10.6 Online collaboration

We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible terms and conditions of the services used, such as terms of use or privacy policies, also apply.

10.7 Social media functions and social media content

We use third-party services and plug-ins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.

In particular, we use:

10.8 Digital audio and video content

We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.

In particular, we use:

10.9 Documents

We use third-party services to embed documents into our website. Such documents can include forms, PDF files, presentations, tables and text documents. This allows us to not only view, but also edit or comment on such documents.

In particular, we use:

10.10 Advertising

We use the option to display targeted advertising for our activities and operations on third parties such as social media platforms and search engines.

With such advertising, we would particularly like to reach people who are already interested in our activities and operations or who could be interested in them ( remarketing and targeting ). To do this, we can transmit relevant information – possibly also personal information – to third parties who enable such advertising. We can also determine whether our advertising is successful, in particular whether it leads to visits to our website (conversion tracking) .

Third parties with whom we advertise and where you are registered as a user may associate your use of our website with your profile there.

In particular, we use:

11. Website extensions

We use extensions for our website to provide additional functionality.

In particular, we use:

  • Google reCAPTCHA: Spam protection (differentiation between desired comments from people and unwanted comments from bots and spam); Provider: Google; Google reCAPTCHA-specific information: «What is reCAPTCHA?» .

12. Measuring success and reach

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. But we can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the IP addresses of individual users are stored to measure success and reach. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.

Cookies can be used to measure success and reach and user profiles can be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymous form and are not used to identify individual users. Individual third-party services with which users are registered can at most assign the use of our online offering to the user account or user profile on the respective service.

In particular, we use:

13. Final provisions

We have created this privacy policy with the data protection generator from Datenschutzpartner .

We may adapt and supplement this privacy policy at any time. We will inform you about such adaptations and additions in an appropriate manner, in particular by publishing the current privacy policy on our website.