Welcome to Alex Grabher! The following Privacy Policy gives you a simple overview of what happens to your Personal Data when you visit our website at www.alexgrabher.com. This policy is intended to inform users of our website about the type, scope and purpose of the collection and use of Personal Data by us in accordance with the Swiss Federal Data Protection Act (“nDSG”) and the EU General Data Protection Regulation (“GDPR”).
WHO IS RESPONSIBLE FOR DATA PROCESSING?
A “data controller” is a person or organization who alone or jointly with others decides on the purposes and manner of processing Personal Data. In this sense, AG Performance of Widmerstrasse 66, 8038, Zurich, Switzerland (“Alex Grabher”, “we”, “us”, “our”) the data controller. If you have any questions about data protection at Alex Grabher in general, you can contact us at letsgo@alexgrabher.com.
WHAT IS PERSONAL DATA?
Personal Data means any information relating to an identified or identifiable living person. Various pieces of information that, taken together, may lead to the identification of a specific individual also constitute personal information.
WHAT IS SPECIAL CATEGORY DATA?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing
WHAT IS PROCESSING?
„Processing“ means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
WHAT LEGAL BASIS ARE THERE FOR PROCESSING YOUR DATA?
All Personal Data that we obtain from you via our website will only be processed for the purposes described in more detail below. This is done within the framework of the nDSG and the GDPR and only if at least one of the following applies: a) you have given your consent; b) the data is necessary for the fulfilment of a contract / pre-contractual measures; c) the data is necessary for the fulfilment of a legal obligation; or d) the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We may collect and process the following Personal Data about you:
- a) Personal information you give us:
This is information about you that you provide to us. This includes, for example, your name, email address and telephone number when you contact us or when you request services. The legal basis is the initiation of a contract with you and your consent.
The protection of your Personal Data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfill our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
You have choices about the Personal Data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our Services. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available. The legal basis for the processing of your Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent. You may withdraw your consent and request us to stop using and/or disclosing your personal and Special Category Data by submitting your request to us.
We also use online meeting tools to conduct online meetings and provide support. When using online meeting tools, different types of data are processed. The scope of the data depends on the information you provide before or during the online meeting. The processing bases are your consent and our legitimate interest.
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
- b) Personal information our website collects about you:
When you visit our website, some information about you and your visit is automatically collected, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages you visit our website. This information is used to monitor website performance and improve the experience of website visitors. The legal basis is the initiation of a contract with you and our legitimate interest.
- c) Cookies:
We use cookies on our website. As set out in Switzerland’s Unfair Competition Act (as amended) (“UCA”), the Telecommunications Act (as amended) (“TA”) and the EU’s Privacy and Electronic Communications Directive (“PECD”), we must obtain your consent to use non-essential cookies. The legal basis for using cookies is our legitimate interest and your consent. For more information about the cookies we use, please see our Cookie Policy.
- d) Processing by third party services:
We use the hosting services of ALL-INKL.COM, for hosting and displaying our website. ALL-INKL.COM does this on the basis of processing on our behalf, which also means that all data collected on our website is processed on ALL-INKL.COM’s servers. The basis for processing is our legitimate interest and the initiation and/or fulfillment of a contract.
We use the open source Content Management System (CMS) of WordPress.Org and the eCommerce system of WooCommerce by Automattic to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us are transferred to ALL-INKL.COM and that your contact and contract data and your usage data are stored on ALL-INKL.COM’s servers. The legal basis for this processing is our legitimate interest.
For booking a Meeting in an easy and convenient way, we use Calendly. Your data from the form will be transferred to our appointment account at Calendly after you press the „Book appointment“ button.
You will then receive a confirmation email with a link to the event. Your data will be kept at Calendly until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Calendly undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.
If you make a purchase, your payment data will be processed via our payment service provider, Stripe. Payment data will solely be processed through Stripe, and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
We have integrated components from Vimeo. The integration requires that Vimeo can perceive the IP address of the user. The IP address is required in order to send the video content to the user’s browser. If you click on a Vimeo component (video) on my website, your internet browser will be prompted by the component to download a corresponding representation of the component. In this way, Vimeo knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.
When you go ahead and download our Publications and Resources, your IP address is requested and logged for documentation purposes by WordPress.Org. This is a mere technical process and required to make our Publications and Resources available for download to your device or depending on your browser available for viewing. The basis for this storage is the provision of a contract and our legitimate interest.
We have integrated Google Fonts by Google, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Font Awesome’s and Google’s server is established when our website is accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.
We also use Google Tag Manager. Google Tag Manager is a solution enabling us to administer website tags via an interface. Google Tag Manager itself, which implements the tags, is a cookie-free domain and does not record any personal data. However, the tool triggers other tags that may record your Personal Data. Google Tag Manager itself does not access this data. If you refuse Analytical/Performance and/ or Marketing & Social Media Cookies, Google Tag Manager remains in place. The legal basis for the processing is our legitimate interest.
HOW WILL WE USE YOUR PERSONAL INFORMATION?
We may collect, store and use your personal information for the following purposes:
- to operate, manage, develop and promote our business, in particular our relationship with you and related transactions, such as:
- Marketing purposes (where we have either obtained prior consent and/or have a legitimate interest in sending you communications that we consider relevant and useful to you);
- accounting and billing/payment purposes;
- to operate, manage and improve our website and other aspects of our business operations;
- to provide you with our website and services;
- to provide you with services or information that you have requested; and
- to inform and keep you updated about relevant topics or services that may interest you.
- to protect our company from fraud, money laundering, breach of trust, theft of proprietary material and other financial or business crimes;
- to comply with our legal and regulatory obligations, to establish and defend legal claims and to enforce legal claims; and
- if the purpose is directly related to an assigned purpose previously communicated to you.
We will only process your Personal Data where necessary to enable us to pursue the purposes described above and where we have a legal basis for such processing. If our legal basis for processing is that such processing is necessary for the purposes of pursuing our legitimate interests, we will only process your Personal Data if we have concluded that our processing does not adversely affect you or your privacy in any way, which would outweigh our legitimate interest. In exceptional cases, we may also be legally obliged to disclose or otherwise process your Personal Data.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it as described above, unless we consider that we need to use it for another purpose and that reason is compatible with the original purpose. If we need to use your personal information for another purpose, we will inform you and explain the legal basis which allows us to do so.
MARKETING
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
We use the services of ActiveCampaign to organise our marketing campaigns and direct marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
STORAGE AND RETENTION
Your Personal Data will remain with us until the purpose for processing the data no longer applies. If you make a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your Personal Data (e.g. tax or commercial law retention periods); in the latter case, the data will be deleted as soon as these reasons no longer exist.
WHEN DO WE SHARE YOUR PERSONAL DATA?
We may share your data with organizations that help us provide the services described in this Policy and who may process that data on our behalf and in accordance with this Policy to support our website and services. If you would like to find out more about how each provider processes your Personal Data, please follow the links embedded in the names of the providers mentioned above.
As a rule, and unless otherwise stated in this policy, data may be shared based on our contractual and pre-contractual obligations. Likewise, if you have consented or if we are legally obliged to do so or on the basis of our legitimate interests (e.g. when using representatives, hosting providers, tax, business and legal advisors, accountants and similar services that it enable us to carry out our contractual obligations, administrative tasks and duties efficiently and effectively). If we allow third parties to process data on the basis of a so-called “Processing Agreements“ give an order.
We may also share information in other circumstances, such as: if you agree to this or if the law, a court order, a legal obligation or a supervisory authority requires us to do so. When the purpose is to prevent fraud or crime or when it is necessary to protect and defend our rights, property or the personal safety of our employees, the website and its users.
HOW WE PROTECT YOUR PERSONAL INFORMATION
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the browser’s address line changing from „http://“ to „https://“ and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
LINKED SITES
For your convenience, our website may contain hyperlinks to other websites. We are not responsible for the privacy practices of linked websites or companies that are not owned or controlled by us, and this Privacy Policy does not apply to them. The links on the Site may collect additional information in addition to the information we collect.
We do not endorse any of these linked websites, their products, services or any content on their websites. We encourage you to read the privacy policies of each linked website you visit to understand how the information collected about you is used and protected.
SOCIAL MEDIA
We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request and the basis for this is both your consent and our legitimate interest.
DATA BREACHES AND NOTIFICATION
Databases or records containing personal information may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose personal information may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.
YOUR RIGHTS AND PRIVILEGES
- Privacy rights
You can exercise the following rights under the nDSG and the GDPR:
- The right of access;
- The right to rectification;
- The right to erasure;
- The right to restrict processing;
- The right to object to processing;
- The right to data portability;
- Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate, or if you would like to have it corrected or deleted, or object to processing based on legitimate interests, please contact us.
- Request for access
If you would like to make a request to access your data, please contact us. We will respond to access and correction requests as quickly as possible. If we are unable to respond to your request within thirty (30) days, we will let you know why and when we will be able to respond to your request. If we are unable to provide you with personal information or make a correction you requested, we will tell you why.
- Complaint to a supervisory authority
The supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC) (www.edoeb.admin.ch). However, we would appreciate it if we could address your concerns before you contact the FDPIC or another supervisory authority.
- What we don’t do
- We do not request personal information from minors and children;
- We do not process special category data without obtaining express consent; and
- We do not use automated decision-making, including profiling.
HELP AND COMPLAINTS
If you have any questions about this policy or the information we hold about you, please contact us using letsgo@alexgrabher.com.
CHANGES
The first version of this policy was issued on Tuesday, 15th of October, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.
