The security and privacy of your personal data and the protection of your private sphere are important to us. You may expect us to handle your data with due care and to ensure a high level of data privacy. As a conse-quence, it goes without saying that we satisfy the legal requirements of the Swiss Federal Data Privacy Law (Datenschutzgesetz, DSG), the directives of the Federal Data Privacy Law (Verordnung zum Bundesgesetz über den Datenschutz, VDSG), of the Telecommunications Law (Fernmeldegesetz, FMG) and other provisions of Swiss data privacy laws. In processing data related to persons located in the European Union (EU), we will additionally observe in particular the provisions of the EU Data Privacy Basic Directive (EU-Datenschutz-Grundverordnung, DSGVO).
This Data Privacy Statement informs you about the most important aspects of online as well as offline data processing.
1.1 Name and address of the function in charge
The function in charge in the sense of the DSGVO and other national data privacy laws of the EU member states as well as other legal data privacy provisions is:
Trapeze Switzerland GmbH
8212 Neuhausen am Rheinfall
Phone: +41 58 911 11 11
1.2 Name and address of the representative in the EU
The EU representative of the function in charge is:
Trapeze Elgeba GmbH
53604 Bad Honnef / Aegidienberg
Phone: +49 2224 8285 58
1.3 Name and address of the data privacy officer
The data privacy officer of the function in charge is:
Dr. Dominic N. Staiger
Attorney at Law (NY) / Solicitor (England & Wales)
SIDD Institut für Datenschutz und Datensicherheit GmbH
Technoparkstrasse 1, 8005 Zürich
Tel: +41 (0) 445 866 210
2 Scope and purpose of gathering, processing and utilising personal data
The DSGVO defines personal data as “data/information linked to identified or identifiable natural persons.” Online identification features such as IP addresses are considered as personal data if they are not selectively anonymised.
We process your personal data for the following purposes:
- Enquiries received through the contact form
- Newsletter subscription
- Opening of a customer account
- Optimisation of the internet site (adjustment of the website to your needs)
- Defence against and recording of hacker attacks
- Creation of user statistics
- Fulfilment of our contractual obligations towards our customers, suppliers and service providers
2.1 Visits to the website
When you visit our website, our servers will temporarily save the following data in a log file, the so-called server log files.
- IP addresses of the enquiring computer
- Date and time of access/enquiry
- Name and URL of the data enquired
- Operating system of your computer and of the browser that you use
- Country from where our website is accessed
- Name of your internet access provider
- Timezone difference from Greenwich Mean Time (GMT)
- Contents of the enquiry (concrete site)
- Access status/HTTP status code
- Data volume transmitted each time
- Website last visited
- Browser settings
- Language and version of the browser software
- Activated browser plugins
The basis for temporary saving of your personal data and the log files is legitimate interest. Legitimate interest exists in order to
- be able to correctly display the contents of our website and to optimise advertising for it,
- provide the law enforcement authorities with the information required to enforce the law in case of an incidence,
- further improve our offerings and our internet appearance,
- collect statistical data.
2.2 Newsletter / e-mail communications
You may subscribe to our Newsletter through our website. Our Newsletter informs you about our organisation and our offerings.
If you wish to subscribe to our Newsletter, we need the following information (*mandatory). The other information is optional:
- First name
- Last name
- e-mail address*
- Preferred language*
We need the information marked as mandatory in order to send you our Newsletter. The optional statement of additional data enables us to provide you with further information that may be of interest to you.
Your personal data that you have transmitted will not be merged with any other data.
The basis for processing your personal data after you have subscribed to our Newsletter is your consent. For processing your personal data, your consent will therefore be requested during the registration process, and your attention will be drawn to the present Data Privacy Statement.
By stating your e-mail address, you are giving us the permission to use it for transmitting our Newsletter in order to inform you about news from the relevant corporate entity.
For Newsletter registration, we use the so-called double opt-in process. This means that after you have stated your e-mail address, we will send you a confirmation e-mail to the e-mail address specified in which we ask you to confirm that you wish to receive our Newsletter. You will confirm by clicking an activation link contained in the confirmation e-mail.
You may at any time cancel your Newsletter subscription and thus revoke your consent. For this purpose, all you have to do is click the relevant button (link) in the Newsletter sent to you. In addition, you may send your cancellation to the following e-mail address: email@example.com.
2.3 Contacting / downloading
In our website, you may contact us via a contact form and/or by e-mail and request information by electronic means. In this case, the information you provide will be used for processing your contact enquiry. If you wish to contact us, we need the following information (*mandatory). The other information is optional:
- First name*
- Last name*
- E-mail address*
- Phone number
We need the information marked as mandatory in order to process your enquiry. The optional information on other data enables us to provide you with additional information that may be of interest to you.
Your personal data will not be merged with any other data.
The basis for processing your personal data is our legitimate interest in processing your enquiry. If the purpose of contacting us is the fulfilment of a contract to which you are a contracting party or the execution of pre-contractual measures, this shall constitute an additional basis for processing your personal data.
You may challenge this data processing at any time. Please send your challenge to the following e-mail address: firstname.lastname@example.org, and we will review your concern.
2.4 Fulfilment of contractual performance
In order to fulfil our contractual and pre-contractual obligations, we process master data (e.g. names and addresses plus your contact data) and contractual data (e.g. services used, names of contacts, payment information).
The basis for processing your personal data is the fulfilment of a contract to which you are a contracting party or the execution of pre-contractual measures.
If we save your personal data because of a contractual relationship, these data shall be saved for as long as the contractual relationship exists and for no longer than the periods of the statute of limitations for claims that we may make or legal or contractual obligations that we have to preserve business records.
On our website, you may register by specifying your personal data. These data are entered in an input mask and transmitted to us, where they are saved. Your personal data will not be forwarded to any third parties.
For registration, we need the following information (*mandatory):
- First name*
- Last name*
- Phone nummer*
- E-mail address*
- Access authorisation
We need the mandatory information to process your concern.
The basis for processing your personal data is your consent. For processing your personal data, we will therefore request via email your permission when you register and draw your attention to the present Data Privacy Statement. If the purpose of your registration is to fulfil a contract to which you are a contracting party or the execution of pre-contractual measures, this shall be an additional basis for processing your personal data.
In the course of registration and re-registrations, and when you use our online services, we will additionally save the IP address and the point of time of the relevant user action. This saving is done on the basis of our legitimate interests as well as that of users as security against abuse and other unauthorised use. These data will not be forwarded to any third parties unless we must do so to pursue our claims or if we have a legal obligation.
Your personal data will be deleted as soon as they cease to be required for achieving the purpose for which they were gathered. This is the case during the registration process for fulfilment of a contract or execution of pre-contractual measures when the data are no longer needed for performing the contract.
If we save your personal data because of a contractual relationship, these data will be saved for as long as the contractual relationship exists and for no longer than the periods of the statute of limitations for claims that we may make or legal or contractual obligations that we have to preserve business records.
You may at any time cancel your registration. You may at any time modify or delete your personal data. If the data are required for fulfilling a contract or for executing pre-contractual measures, early deletion of the data is only possible if no contractual or legal obligations contradict such deletion.
We process and save your personal data only for the period of time required for achieving the purpose of saving or if this has been provided for in laws or regulations that we are subject to. When the purpose of saving ceases to exist, or when a prescribed period of preserving business records expires, your personal data will be disabled or deleted on a routine basis and in accordance with legal provisions. If your personal data are not deleted because they are required for other and legally allowed purposes, their processing shall be restricted.
In addition, we will delete your personal data if you request us to do so at email@example.com and we are not under any legal or contractual obligations to preserve or otherwise save these data.
4 Forwarding to third parties
We will forward your personal data only after you have given us the explicit permission to do so; if we are under a legal obligation to do so; or if this is required for enforcing our rights, in particular for enforcing claims arising from a contractual relationship.
In addition, we will forward your personal data to third parties if this is required for using our website or possibly for providing the services that you have requested. Utilisation of the forwarded data by such third parties is strictly limited to the purposes stated.
We will make certain data related to your person known to the following categories of recipients:
- Companies of the Trapeze Group
- Partner companies
- Service operators
- Commercial partners such as licensees and distributors
- Credit rating companies and collecting partners
- Supply chain (logistics) partners
- Market research companies (upon ordering them to evaluate products)
- Marketing services
In addition, we will forward data related to your person also to third-party companies (assigned service providers) outside the country if this is appropriate for the data processing described in this Data Privacy Statement.
We will always observe the legal regulations for forwarding your personal data to third parties. Third parties are subject to the same data privacy obligations as we ourselves are. If the data security level in a given country is not the same as that stipulated by Swiss or EU data privacy laws, we will ensure by contractual means that the security and privacy of your personal data will always equal that in Switzerland or the European Economic Area.
When we employ subcontractors in providing our services, we will take appropriate legal as well as technical and organisational action to ensure the security and privacy of your personal data in accordance with the relevant legal provisions.
5.1 What are cookies?
Cookies are small text files that are saved with the aid of the browser on your terminal device. When you call up a website, a cookie may be saved on your operating system. This cookie contains a characteristic sequence of characters allowing the unique identification of your browser the next time your website is called up.
Cookies allow information and offerings on our website to be optimised for your benefit. Cookies enable us to recognize a visitor again. The purpose of this recognition is to make it easier for you to use our website. This constitutes our legitimate interest in data processing.
5.2 What data are saved in the cookies?
In the cookies that we use, only pseudonymous data are saved. When the cookies are activated, they are given an identification number. No allocation of your personal data is made to this identification number. Your name, your IP address or similar data that would enable a direct allocation of the cookies to your person are not saved in the cookie.
5.3 What types of cookies do we use?
We use temporary cookies. They save a so-called session ID with which different enquiries of your browser can be allocated to a common session. This allows your computer to be identified again when you return to our website.
Moreover, we use persistent cookies, which are applied beyond a given utilisation process on your computer. When you revisit our site, the system automatically recognises that you have visited us before and the inputs and settings that you prefer. These cookies (life cycle 1 month to 10 years) are saved on your harddisk and are automatically deleted after the specified time. These files allow you, say, to have information displayed on the site that is specifically tailored to your personal interests.
We use security cookies to identify and avoid security risks. For example, we may use these cookies to save information on your web session.
Your acceptance of cookies is not required for visiting our website.
Most internet browsers accept cookies automatically. If you do not wish this to be so, you may set up your browser so that it will inform you about the setting of cookies so that you may permit this only in individual cases; or that you refuse to accept cookies for certain cases or on a general basis; or that you activate the automatic deletion of the cookies when you close the browser. In addition, you may at any time delete cookies that have already been set by using an internet browser or other software programs.
The procedure of checking and deleting cookies depends on the browser you use. You can find pertinent information on this in the Help menu of your browser. You can find information on this option for the most commonly used browsers through the following links:
• Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: https://support.apple.com/kb/ph21411?locale=en_US
• Opera: http://help.opera.com/Linux/12.10/de/cookies.html
6 Pixels, local saving and similar technologies
We also use other technologies such as counting pixels and local saving. We use these technologies, say, for checking out the most popular functions; in order to create a more personal user experience; or to publish advertising of interest to users.
Counting pixels (also called clear GIFs, web beacons or pixel tags) are small code units that are installed in or on a website, mobile app or advertisement. These pixels may enquire certain information on your browser and your terminal, for example operating system, browser type, terminal type and version, referenced website, visited website, IP address and other similar information.
7 Analysis tools
7.1 Google Analytics
The information generated by the cookie on your utilisation of this website (including your IP address) is transmitted to a server of Google in the United States, where it is saved. Google is certified under the Privacy Shield Framework and is thus committed to ensuring an appropriate level of data privacy in transmitting personal data, which is comparable to that applied in the EU and thus also in Switzerland. For more information, go to https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
Moreover, we have signed a corresponding contract with Google on job data processing.
Google uses this information on our behalf to evaluate your utilisation of our website, to compile reports on website activities and to provide additional services to us that are related to the utilisation of our website and the internet. The IP address transmitted by your browser in connection with Google Analytics is not merged with any other data of Google.
We use Google Analytics exclusively with activated IP anonymisation. This means that the user’s IP address is abbreviated by Google within the member countries of the European Union or other signatories to the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a server of Google in the United States and be abbreviated there.
You may prevent the gathering of and transmission to Google of the data generated by the cookie and related to your utilisation of our website (including your IP address) as well as the processing of these data by Google by downloading and installing the browser plugin available through the following link: (https://tools.google.com/dlpage/gaoptout). An opt-out cookie will be set that prevents any future data collection when you visit this website. However, we draw your attention to the fact that in this case you may be unable to fully use all the functions of this website.
For more information on the terms and conditions of use and data privacy, see https://www.google.com/analytics/terms/gb.html or https://policies.google.com/. We draw your attention to the fact that on this website Google Analytics has been extended by the addition of the code “gat._anonymizeIp();” in order to ensure anonymised gathering of IP addresses (so-called IP masking).
HubSpot is certified as part of the Switzerland-US as well as the EU-US Privacy Shield Framework and is thus committed to ensuring an adequate level of data privacy in transmitting personal data, which is comparable to that in the EU and thus also in Switzerland. For more information in this connection, go to http://www.privacyshield.gov/ or https://www.hubspot.com/data-privacy/privacy-shield.
Moreover, we have signed a contract with HubSpot governing job data processing.
You may prevent the saving of the HubSpot cookies by selecting an appropriate setting of your browsers software. However, we draw your attention to the fact that in this case you may be unable to fully use all the functions of this website. In addition, you may at any time deactivate the HubSpot tracking feature (and thus prevent the gathering of the data generated by the cookie and related to your utilisation of the website – including your IP address – and the transmission of this data to HubSpot as well as processing by HubSpot).
You may at any time refuse data gathering and processing. Possibly, this may restrict individual functions when you use the website. For more information on data processing by Marketo, go to https://legal.hubspot.com/privacy-policy.
As Salesforce is an international company with headquarters in the United States, it may be that your personal data will be transmitted to the United States. Salesforce is certified as part of the Switzerland-US as well as the EU-US Privacy Shield Framework and is thus committed to ensuring an adequate level of data privacy in transmitting personal data, which is comparable to that in the EU and thus also in Switzerland. For more information in this connection, go to https://www.privacyshield.gov/participant?id=a2zt0000000KzLyAAK&status=Active.
In addition, we have signed a corresponding contract with Salesforce for job data processing.
You may at an< time reject the surveying and processing of data. Possibly, this may restrict individual functions when you use our website. For more information, go https://www.salesforce.com/company/privacy/
8 Social Plugins
On our website, we use social plugins. Plugins are small programs or program packages allowing software to be tailored and extended to suit your specific needs. The basic versions of many programs such as graphics programs, media players or internet browsers support the functions that normal users need.
On our website, we have incorporated links with our social media profile with the following social networks:
- Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA,
- Twitter Inc.,1355 Market Street, Suite 900, San Francisco, CA 94103, USA
- Youtube, a service operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
- LinkedIn Inc., 2029 Stierlin Ct, Mountain View, CA 94043, USA
When you visit our website and use one of the social plugins listed in the website, a direct link will be established between your browser and the server of the social network in question. This gives the network the information that you have visited our website and called up the link with your IP address. When you call up a link with a network while being logged into the relevant network in your account, the contents of our site may be linked with your profile at the network. This means that the network can allocate your visit to our website directly to your user account so that we receive your personal data such as name, e-mail address, location, friends list and profile image. These data allow us to offer certain functions in the sites. If you wish to prevent this, you must log out before activating corresponding links. An allocation will be made in any event when you log into the relevant network after activating the link.
If you are logged into a social network via your user account while visiting our website, the relevant provider may in addition allocate your visit to the site to your user account. When you interact with a plug-in, the pertinent information will also be directly transmitted to a server of the provider in question in the United States, where it is saved. The information is also published via your user account in the relevant social network, where it is displayed to your contacts.
Even if you are not logged into the providers of the plugins while visiting our website, the data gathered by the plugins may under certain circumstances still be allocated to your user account. A cookie with an identification character is set by a plugin each time the website is called up. As your browser includes this cookie in the transmission without being requested to do so each time a connection is established with a server of the relevant provider, this might basically enable the social networks to create a profile showing which website the user has called up who belongs to the identification character. It may then be possible to allocate this identification character to a person at a later date, for instance when you log into the provider at some later time.
You may select the function “disable cookies of third-party providers” in your browser settings. Then your browser will not send any cookies to the server of the social network. However, with this setting other functions across different sites of other providers may also cease to work besides the plugins.
For more information on the purpose and scope of data gathering and further processing and utilisation of your personal data, please see the data security information of the various providers. There you will also find more information on your rights and setting options for protecting your privacy as well as your right to reject the creation of user profiles:
We use YouTube as a provider for incorporating videos. YouTube is a service provided by the YouTube LLC (“YouTube”), 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube is an affiliated company of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google is certified under the Privacy Shield Framework and is thus committed to ensuring an adequate level of data privacy in transmitting personal data, which is comparable to that in the EU and thus also in Switzerland. For more information, go to: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
We use embedded YouTube videos in the so-called “extended data security mode”. This means that no data related to your person as a user will be transmitted to YouTube as long as you do not play the videos. Only when you activate the videos will such a data transmission start, over which we have no control. By selecting an appropriate setting in the browser software, you can prevent YouTube from saving cookies. It will then still be possible to use our website. Occasionally, this may entail individual restrictions of functions when you use our website.
For more details on the processing of the data in connection with YouTube and on your rights and setting options for protecting your privacy, please see the terms and conditions of use and the notes on data security: https://www.youtube.com/t/terms, http://www.google.de/intl/de/policies/privacy.
10 Adobe Stock (formerly Fotolia)
The information on your use of this website generated by the cookies may be saved and processed on the servers in the United States and the European Union. Adobe is certified under the Privacy Shield Framework and is thus committed to ensuring an adequate level of data privacy in transmitting personal data, which is comparable to that in the EU and thus also in Switzerland. For more information, go to: https://www.privacyshield.gov/EU-US-Framework.
For more details on the processing of the data in connection with Adobe and on your rights and setting options for protecting your privacy, please see the terms and conditions of use and the notes on data security: https://www.adobe.com/privacy.html.
11 Your rights
You basically have the right to demand information, correction, deletion, restriction, data transmittability, refusal and revocation of your permission with regard to your personal data.
If you believe that the processing of your personal data violates data privacy laws, or if you think your legal entitlement to data privacy has been violated in some other way, you may also lodge a complaint with a supervisory body. In Switzerland, this is the Federal Office for Data Security and Public Affairs (Eidgenössischer Beauftragter für Datenschutz and Öffentlichkeit, EDÖB).
For this purpose, should you have any questions, suggestions or wishes, please contact:
Dr. Dominic N. Staiger
Attorney at Law (NY) / Solicitor (England & Wales)
SIDD Institut für Datenschutz und Datensicherheit GmbH
Technoparkstrasse 1, 8005 Zürich
Tel: +41 (0) 445 866 210
12 Utilisation of the website by minors
The website is addressed to an adult public. Minors, and in particular children under the age of 16, are not allowed without permission from and approval by their parents or guardians to send us any data related to their persons or to register for a service. If we find that such data have been transmitted to us, they will be deleted. The parents (or the legal guardians) of the child may contact us and demand deletion or cancellation. For this, we need the duplicate of an official document proving that you are the parent or legal guardian.
13 Data privacy
We take all the technical and organisational security measures to safeguard your personal data against manipulation, loss, destruction or access by unauthorised persons and to ensure protection of your rights and compliance with the applicable data privacy provisions.
The actions taken are designed to permanently ensure the confidentiality and integrity of your personal data as well as the availability and load handling capacity of our systems and services in processing your personal data. In addition, they shall ensure fast restoring of the availability of your personal data and access to them in the event of a physical or technical incidence.
Our data processing and our privacy and security provisions are continuously improved in line with technological developments.
When your register with us as a user, access to your user account will only be possible upon entering your personal password.
Please always treat payment and access information confidentially and close your browser window when you have finished communicating with us, in particular if you share a computer with others.
We also take our own inhouse data security seriously. Our employees and the service providers that we assign have been committed to maintaining secrecy and to complying with data privacy laws. Moreover, they are only allowed to access your personal data as far as this is actually required.
14 Links with websites of other providers
Our website may contain links with websites of other providers not covered by this Data Privacy Statement. After you have clicked such links, we cease to have any control over the processing of data possibly transmitted to third parties by the clicking of the links (e.g. the IP address or the URL on which the link is located), as the conduct of third parties is beyond our control. We therefore decline any responsibility for the processing of your personal data by third parties. To know the extent to which the utilisation of other providers’ websites is associated with the gathering, processing or utilisation of your personal data, please see the notes on data privacy of the relevant providers.
15 Modifications to the Data Privacy Statement
The company may supplement or modify this Data Privacy Statement at any time. Any changes and additions will be made at our own discretion.
The original Data Privacy Statement is in German. The translated versions serve only for better understanding. In case of discrepancies, the German version shall have priority.