Privacy policy
This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name www.feratel-sitour.ch. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.
We may publish further data protection declarations or other information on data protection for individual or additional activities and operations.
We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
In its decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures adequate data protection. In its report of 15 January 2024, the European Commission confirmed this adequacy decision.
Table of contents
- 1. contact addresses
- 2 Terms and legal bases
- 3 Type, scope and purpose of the processing of personal data
- 4 Disclosure of personal data
- 5. communication
- 6 Data security
- 7. personal data abroad
- 8 Rights of data subjects
- 9. use of the website
- 10 Notifications and messages
- 11. social media
- 12. third-party services
- 13. extensions for the website
- 14 Success and reach measurement
- 15. final notes on the privacy policy
1. contact addresses
Responsible in terms of data protection law is
Markus Bien
Feratel Schweiz AG
Riedstrasse 1
CH-6343 Rotkreuz
In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties. We are happy to provide data subjects with information about the respective responsibility on request.
Data protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for enquiries in connection with the GDPR.
2 Terms and legal bases
2.1 Definitions
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data about trade union, political, religious or ideological views and activities, data about health, privacy or membership of an ethnic or racial group, genetic data, biometric data that uniquely identifies a natural person, data about criminal and administrative sanctions or prosecutions, and data about social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, recording, erasure, disclosure, organisation, storage, modification, dissemination, linking, destruction and use of personal data.
European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal bases
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
If and insofar as the European General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
- Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subject.
The European General Data Protection Regulation (GDPR) characterises the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3 Type, scope and purpose of the processing of personal data
We process the personal data required to carry out our activities and operations in a sustainable, humane, secure and reliable manner. The processed personal data may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive 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 and operations, insofar as such processing is permitted.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example to fulfil legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymise or delete personal data, in particular in accordance with statutory retention and limitation periods.
4 Disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties are, in particular, specialised providers whose services we use.
For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. communication
We process personal data in order to be able to communicate with individuals and with authorities, organisations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is correct and may be transmitted.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of data subjects beyond direct communication.
6 Data security
We take appropriate technical and organisational 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 processed personal data, without being able to guarantee absolute data security.
Access to our website and our other digital presence takes place using transport encryption(SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport encryption.
Our digital communication - like all digital communication in general - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. We also cannot rule out the possibility that a data subject may be subject to targeted surveillance.
7 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 in order to process it or have it processed there.
We may export personal data to all countries on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does 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. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.
8 Rights of data subjects
8.1 Claims under data protection law
We grant data subjects all rights in accordance with applicable law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data 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 have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Possibility for own point of view and human review: In the case of decisions based exclusively on the automated processing of personal data that have legal consequences for them or significantly affect them (automated individual decisions), data subjects can present their own point of view and request a review by a human being.
- Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to co-operate.
8.2 Legal protection
Data subjects have the right to enforce their data protection claims through the courts or to lodge a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB ). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are organised on a federal level, particularly in Germany.
9 Use of the website
9.1 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 are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily 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 have a specific storage period. In particular, cookies make it possible to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be completely or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request explicit consent to the use of cookies - at least if and to the extent required by applicable law.
For cookies that are used to measure success and reach 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).
9.2 Logging
We may log at least the following information for each access to our website and our other digital presence, insofar as this information is transmitted to our digital infrastructure during such access: 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 subpage of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The information is required to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.
9.3 Tracking pixels
We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Counting pixels can be used to record at least the same information as is recorded in log files.
10 Notifications and messages
10.1 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 on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages effectively and in a human-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
10.2 Consent and objection
You must always consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
11. social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and to provide information 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 in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, 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). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly way.
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 "Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights Data".
12. services of third parties
We use the services of specialised third parties in order to be able to carry out our activities and operations in a sustainable, human-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used collect the IP addresses of 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 and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Privacy and security principles", "More information on how Google uses personal data", Privacy policy, "Google is committed to complying with applicable data protection laws", "Guide to data protection in Google products", "How we use data from websites or apps on or in which our services are used", "How we use data from websites or apps on or in which our services are used" . where our services are used", "Types of cookies and similar technologies Google uses", "Advertising you can control" ("Personalised advertising").
- Services from Microsoft: Provider: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: "Data protection at Microsoft", "Data protection and privacy", Privacy Policy, "Data and privacy settings".
12.1 Digital infrastructure
We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
12.2 Audio and video conferencing
We use specialised audio and video conferencing services 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 and blurring the background or displaying a virtual background when participating in audio or video conferences.
We use in particular:
- TeamViewer Meeting: Video conferencing; Provider: TeamViewer Germany GmbH (Germany); Data protection information: Privacy policy, "First-class data protection".
- Webex: Video conferencing; Provider: Cisco Systems Inc (USA); Data protection information: "Cisco Online Privacy Policy", "Compliance and Certifications for Cisco Webex".
- Zoom: Platform for collaborative work, in particular with video conferencing; Service provider: Zoom Video Communications Inc (USA); Information on data protection: "Data protection at Zoom", Privacy Policy, "Legal compliance".
12.3 Online collaboration
We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply.
We use in particular:
- Asana: Platform for collaboration in companies; Provider: Asana Inc (USA); Data protection information: "Trust in Asana", privacy policy, bug bounty programme.
- Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; Service provider: Microsoft; Teams-specific information: "Security and compliance in Microsoft Teams", in particular "Data protection".
12.4 Map material
We use third-party services to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".
12.5 Digital content
We use services from specialised third parties to integrate digital content into our website. Digital content includes, in particular, image and video material, music and podcasts.
We use in particular:
- Vimeo: Video platform; Provider: Vimeo Inc (USA); Data protection information: Privacy policy, "Private video hosting".
- YouTube: Video platform; provider: Google; YouTube-specific information: "Privacy and security centre", "My data on YouTube".
12.6 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: "Your Privacy and Google Fonts" ("Your Privacy and Google Fonts"), "Privacy and Data Collection" (Google Fonts).
13. extensions for the website
We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.
We use in particular:
- Imagify: Image optimisation; Provider: WP MEDIA (France); Privacy Policy: Terms of Service, Frequently Asked Questions.
- TinyPNG: Image optimisation; Service provider: Tinify BV (Netherlands); Privacy Policy: "Terms of Use".
14. success and reach measurement
We endeavour to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence 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.
In most cases, the IP addresses of individual users are recorded to measure success and reach. In this case, IP addresses are generally shortened ("IP masking") in order to comply with the principle of data minimisation through the corresponding pseudonymisation.
Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are only created in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile with the respective service.
We use in particular:
- Google Marketing Platform: Success and reach measurement, in particular with Google Analytics; Provider: Google; Google Marketing Platform-specific data: Measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only transmitted in full to Google in the USA in exceptional cases, privacy policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
- Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services.
15. final notes on the privacy policy
We have created this privacy policy using the privacy policy generator from Datenschutzpartner.
We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.