Personal data – refers to any information related to a specific or identifiable individual. A data subject is an individual about whom personal data is processed.

Processing – encompasses all activities involving personal data, regardless of the methods or procedures employed. This includes storage, disclosure, acquisition, collection, deletion, alteration, destruction, and utilization of personal data.

The European Economic Area (EEA) – comprises the member states of the European Union (EU), along with the Principality of Liechtenstein, Iceland, and Norway.

The General Data Protection Regulation (GDPR) defines the processing of personal data.

We process personal data in accordance with Swiss data protection laws, specifically the Federal Data Protection Act (DSG) and the Ordinance on the Federal Data Protection Act (VDSG).

For personal data processing falling within the scope of the General Data Protection Regulation (GDPR), we adhere to at least one of the following legal bases:

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We process personal data necessary to conduct our activities consistently, ensuring permanence, user-friendliness, security, and reliability. Such data may include inventory and contact details, browser and device information, content data, metadata, usage data, location information, sales data, and contractual and payment details. Personal data is processed for the duration required by the respective purpose(s) or as mandated by law. Once personal data is no longer needed, it will be anonymized or deleted. We may engage third parties to process personal data on our behalf. This could involve joint processing or data transfer. These third parties, often specialized service providers, are subject to data protection guarantees.

Unless processing is permitted for other legal reasons, we only process personal data with the consent of the individual concerned. Processing without consent may be permissible to fulfill contractual obligations, undertake appropriate pre-contractual measures, protect our legitimate interests, or when processing is evident from the circumstances or preceded by adequate information.

When individuals contact us voluntarily, such as through mail, email, instant messaging, contact forms, social media, or telephone, or when registering for a user account, we process the information provided. This information may be stored in an address book, customer relationship management system (CRM), or similar tools. When we receive data about others, the providers are obligated to ensure data protection and the accuracy of the provided personal data.

Additionally, we process personal data obtained from third parties, publicly available sources, or collected during our activities, provided such processing is legally permissible.

4.1 Cookies

We may utilize cookies, including our own first-party cookies and third-party cookies from services we use, which are data stored in the browser. These stored data may extend beyond traditional text-based cookies.

Cookies can exist in the browser temporarily as "session cookies" or for a specific duration as "permanent cookies." Session cookies are automatically deleted when the browser is closed, while permanent cookies have a designated storage period. Cookies enable browser recognition upon revisiting our website, facilitating functions such as measuring website reach and supporting online marketing efforts.
You have the option to completely or partially deactivate and delete cookies in your browser settings at any time. However, please note that without cookies, certain features of our website may not be fully available.

For cookies that are used to measure success and reach or for advertising, a general objection ("opt-out") is required 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).

4.2 Server Log Files

We may collect the following information for you to access to our website, provided that it is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including time zone, Internet Protocol (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 amount of data transferred, last website accessed in the same browser window (referrer).

We may need to store such information, which may include personal data, in server log files. This information is essential for our website's functionality but is stored in a manner that prioritizes user-friendliness, reliability, and data security, particularly concerning the protection of personal data. This security may be ensured either independently or with the assistance of third parties.

4.3 Web Beacons

We may use web beacons on our website. Web beacons are also known as web beacons. Web beacons - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Web beacons can be used to collect the same information as server log files.

4.4 Opting Out of Cookies, Server Log Files, and Web Beacons

You can configure your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Server log files record details about your device, browser type, referring page, date/time stamp, and other information. These files are used for website administration and to analyze trends, track user movements, and gather demographic information.

Web beacons (also known as clear gifs, pixel tags, or web bugs) are small graphic images embedded in web pages to monitor user behavior and collect data about how you interact with our website.

By opting out of cookies, server log files, and web beacons, certain features of our website may be limited. You can manage your preferences and opt out of these technologies by adjusting your browser settings or using other opt-out mechanisms provided.

We typically process personal data within Switzerland and the European Economic Area (EEA). However, we reserve the right to export or transfer personal data to other countries, particularly for processing purposes.

We may export personal data to any country, state, or territory provided that, in the opinion of the Federal Data Protection and Information Commissioner (FDPIC) or as per a decision by the Swiss Federal Council, the respective laws ensure adequate data protection. If the General Data Protection Regulation (GDPR) is applicable, we ensure appropriate data protection in accordance with decisions made by the European Commission.

In cases where the laws of certain countries do not guarantee adequate data protection, we may still transfer personal data if protection is ensured through alternative means, such as standard data protection clauses or other appropriate safeguards. In exceptional circumstances, personal data may be exported to countries lacking adequate or suitable data protection if specific data protection requirements are met, such as obtaining explicit consent from data subjects or when directly linked to the conclusion or execution of a contract. Upon request, affected individuals can obtain information about these safeguards or receive copies of them.

Individuals whose personal data we process (data subjects) have rights under Swiss data protection law. This includes the right to information and the right to correct, delete, or block processed personal data.

If the General Data Protection Regulation (GDPR) applies, affected individuals whose personal data we process can request confirmation free of charge regarding the processing of their personal data. They may request information about the processing, restrict processing, exercise their right to data portability, and request correction, deletion ("right to be forgotten"), blocking, or completion of their personal data. Additionally, if the GDPR applies, affected individuals whose personal data we process can revoke their consent at any time with future effect and object to the processing of their personal data at any time.

RIGHT TO OBJECT: IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST AS PART OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENSE OF LEGAL CLAIMS. IF YOUR PERSONAL DATA IS PROCESSED BY US TO CARRY OUT DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING. YOU CAN EXERCISE YOUR RIGHT OF OBJECTION AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT OF OBJECTION, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

Individuals about whom we process personal data have the right to lodge a complaint with the responsible supervisory authority. In Switzerland, the supervisory authority for data protection is the Federal Data Protection and Information Commissioner (FDPIC).

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We implement appropriate technical and organizational measures to ensure data security commensurate with the associated risks. However, absolute data security cannot be guaranteed. We take appropriate steps to protect data security. Our website employs transport encryption (SSL/TLS, specifically Hypertext Transfer Protocol Secure, HTTPS) to secure data transmission. Most browsers indicate secure connections with a padlock icon in the address bar.

It's important to note that our digital communications, like most digital communications, are subject to potential mass surveillance and monitoring by security authorities in Switzerland, Europe, the United States of America (USA), and other countries. We do not have direct control over how personal data is handled by secret services, law enforcement agencies, and other security authorities.

We may communicate through various channels such as email, instant messaging, or SMS.

8.1 Outreach
Our notifications and messages may include web links or web beacons to track interactions such as message opens and link clicks. This statistical data helps us gauge the effectiveness and audience reach to tailor future communications to recipients' preferences and habits, ensuring efficiency and reliability.

8.2 Newsletter
We use Mailchimp, a service provided by The Rocket Science Group LLC d/b/a Mailchimp, located in Mountain View, CA, USA, to send our newsletters. Mailchimp assists us in managing subscriber lists and delivering our newsletters to you. By subscribing to our newsletter, you acknowledge that the information you provide will be transferred to Mailchimp for processing in accordance with their Privacy Policy and Terms. Mailchimp is certified under the Swiss-U.S. Privacy Shield Framework, ensuring a level of data protection equivalent to that in Switzerland. Mailchimp has committed not to use your email address for its purposes or to disclose it to third parties. You can review Mailchimp’s Privacy Policy for more information on how they handle your data.

8.3 Consent and Opt-out
We typically require explicit consent for using email and other contact details, unless permitted by law. We employ a "double opt-in" process whenever possible to ensure consent authenticity. Your objections to receiving notifications, including opting out of usage tracking for performance evaluation, are respected. Essential communications related to our operations remain unaffected.

We maintain an active presence on social media platforms and other online forums to engage with interested parties and disseminate information regarding our activities and initiatives. Please note that in association with these platforms, personal data may be processed outside of Switzerland and the European Economic Area (EEA). The terms of service, general terms and conditions (GTC), and privacy policies of the respective platform operators also apply. These documents outline data subjects’ rights, including the right to access information, directly concerning the platform.

9.1 Youtube

This website uses YouTube’s embedding function to display and play videos from YouTube, provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). The extended data protection mode is enabled, which only starts storing user information when the video is played.

When playing embedded YouTube videos, YouTube may use cookies to collect information about user behavior for purposes such as video statistics, improving user-friendliness, and preventing abuse. If logged into Google, your data will be directly linked to your account when you click on a video. To avoid this, log out before playing a video. Google stores data as usage profiles and evaluates them under Art. 6(1)(f) GDPR, based on their legitimate interests in personalized advertising, market research, and website design. You have the right to object to these profiles by contacting YouTube. Personal data may also be transferred to Google LLC servers in the USA.

A connection to the Google network is established whenever this website is accessed, potentially triggering further data processing beyond our control. For more information, refer to YouTube’s privacy policy at: YouTube Privacy Policy. Where legally required, we have obtained your consent under Art. 6 (1)(a) GDPR for processing your data. You can revoke your consent at any time with future effect by following the objection procedure described above.

9.2 Facebook and Meta Platforms

Within our online offering, we utilize the “Facebook Pixel” provided by Facebook Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland (“Facebook”). The Facebook Pixel is used when a user interacts with our advertisements displayed on Facebook.

When a user clicks on one of our ads on Facebook, the Facebook Pixel adds a URL parameter to our linked page. If our website allows data sharing with Facebook via Pixel, this URL parameter is stored in the user’s browser via a cookie set by our website. The Facebook Pixel reads this cookie, allowing data to be transmitted to Facebook.

Through the Facebook Pixel, we can identify visitors to our online offering as a target group for displaying advertisements (“Facebook Ads”). This allows us to show Facebook Ads specifically to users who have shown interest in our online offering or exhibit certain characteristics (e.g., interests in specific topics or products based on websites visited), which we transmit to Facebook (known as “custom audiences”). The Facebook Pixel also helps us analyze the effectiveness of Facebook Ads by tracking whether users were redirected to our website after clicking on a Facebook advertisement (“conversion”).

The data collected is anonymous to us, so we cannot identify individual users. However, Facebook may connect this data to the user’s profile and use it for its own advertising purposes, under Facebook’s data usage policy.

(https://www.facebook.com/about/privacy/). This data may also be used by Facebook and its partners to display advertisements on and off Facebook.

Processing of data associated with the Facebook Pixel is based solely on your explicit consent under Art. 6(1)(a) GDPR. You can withdraw your consent at any time in the future. To revoke your consent, please use the “Cookie Consent Tool” integrated on our website.

9.3 Third Party Services

We rely on specialized third-party services to facilitate the continuous, user-friendly, secure, and reliable execution of our activities. These services enable us, among other functionalities, to integrate features and content into our website. During this embedding process, the utilized services may temporarily record users’ Internet Protocol (IP) addresses for technical necessity.

For essential security, statistical, and technical purposes, third-party service providers we engage with may process data on our activities in aggregated, anonymized, or pseudonymized formats. This includes performance or usage data necessary for delivering the respective services.

9.3.1. Google AdSense:

This website uses Google AdSense, a web advertising service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google AdSense employs cookies, which are stored on your computer and enable an analysis of how users use the site. Additionally, Google AdSense utilizes web beacons (invisible graphics) to gather information, which are used to record, collect, and analyze simple actions such as visitor traffic on the website. The information generated by the cookie and/or web beacon (including your IP address) about your use of the website will be transmitted to and stored by Google on servers, including those in the USA. Google uses this information to evaluate your use of AdSense ads. Your IP address, transmitted by your browser as part of Google AdSense, is not merged with other Google data. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. This processing is conducted in accordance with Art. 6 Paragraph 1(f) of GDPR for targeted advertising by displaying third-party ads based on evaluated user behavior, thereby serving our financial interest in supporting our website through displaying personalized third-party advertising content.

For more information about Google’s privacy practices, please visit: Google Privacy Policy. You can permanently disable cookies for ad preferences by adjusting your browser settings or by installing the browser plug-in available at: Google Ad Settings. Please note that certain functions of this website may be unavailable or limited if you disable cookies.

9.3.2 Google Ads Conversion Tracking:

This website uses Google Ads, an online advertising program provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), which includes Google Ads conversion tracking. Google Ads helps us promote our offerings effectively on external websites using advertising materials (Google Adwords). Conversion tracking cookies are set when a user clicks on a Google Ads advertisement. These cookies, typically expiring after 30 days and not used for personal identification, allow Google and us to recognize if a user visits specific pages after clicking on an ad. Each Google Ads customer receives a unique cookie, preventing cookies from being tracked across the websites of Google Ads customers. The information collected via the conversion cookie generates conversion statistics for Google Ads customers opting for conversion tracking. It provides aggregate data on the total number of users who clicked on their ads and were redirected to pages with conversion tracking tags, without identifying individual users personally. To opt out of tracking, you can disable the Google Conversion Tracking cookie in your internet browser settings under “User Preferences,” excluding you from conversion tracking statistics.

We use Google Ads based on our legitimate interest in targeted advertising under Art. 6(1)(f) of GDPR. When using Google Ads, personal data may be transferred to Google LLC servers in the USA. For more information about Google’s privacy practices, please visit: Google Privacy Policy. You can permanently disable cookies for ad preferences by adjusting your browser settings or by installing the browser plug-in available at: Google Ad Settings. Please note that certain functions of this website may be unavailable or limited if you disable cookies.

For processing your data as described above, we have obtained your consent in accordance with Art. 6(1)(a) of GDPR, where required. You have the right to revoke your consent for further processing of your personal data at any time. To withdraw consent or opt out of specific processing activities, please follow the opt-out instructions provided in our communications or contact us directly using the contact details provided in this Privacy Policy.

9.4 Advertising

We leverage targeted advertising opportunities across third-party platforms such as social media platforms and search engines to promote our activities and initiatives. Through targeted advertising, we aim to reach individuals who are either already interested in our activities or could potentially be interested in them (remarketing and targeting). To achieve this, we may share relevant information, which may include personal data, with third parties who facilitate such advertising. Additionally, we utilize conversion tracking to evaluate the effectiveness of our advertising efforts, particularly in terms of website visits.

It’s important to note that third-party platforms where you are registered as a user may link your use of our online offerings to your profile on their platform.

Our primary channels for targeted advertising include:

1. Facebook advertising (Facebook Ads): Social media advertising facilitated by Meta Platforms Ireland Limited and other Meta companies. For detailed data protection information, including remarketing and targeting with the Facebook pixel, custom audiences, and advertising preferences, please refer to Facebook's documentation.
2. Google Ads: Search engine advertising provided by Google. This includes advertising based on search queries, utilizing various domain names such as doubleclick.net, googleadservices.com, and googlesyndication.com. For more information, including details on advertising and why you see certain advertisements, consult Google’s resources.
3. Instagram Ads: Social media advertising offered by Meta Platforms Ireland Limited and other Meta companies. Data protection information includes details on remarketing and targeting with Facebook pixels, custom audiences, and advertising preferences. Please refer to Instagram’s and Facebook’s data protection declarations for further information.
4. LinkedIn Ads: Social media advertising provided by LinkedIn Corporation and LinkedIn Ireland Unlimited Company. This includes remarketing and targeting, particularly with the LinkedIn Insight Tag. For data protection details, including information on objections to personalized advertising, consult LinkedIn’s resources.

9.5 Analytics and User Behavior Tracking Tools

We employ various services and programs to analyze the usage of our online platform. These tools enable us to measure the success and reach of our activities, assess the impact of third-party links, and conduct A/B tests for continuous improvement. This helps us identify and rectify errors, enhance popular content, and improve our platform based on insights gained.

When utilizing these services, we may store Internet Protocol (IP) addresses to measure success and reach. To protect user data, IP addresses are typically shortened through IP masking, ensuring data pseudonymization. Additionally, cookies may be used, and user profiles generated for success and reach measurement. These profiles include information such as visited pages, viewed content, screen and browser sizes, and approximate location. User profiles are pseudonymous and not used for individual identification, though third-party services linked to user accounts may associate platform usage with user profiles.

We utilize Google services including Google My Business, Google Conversion Tracking, Google Search Console, Google Analytics, and Google Tag Manager. These services use cookies to collect data on your interactions with our site. Data collected may be stored on servers globally, including outside the EU and Switzerland. By using our website, you consent to Google processing your data as described in their Privacy Policies.

You have the right to access, correct, or delete your personal data, as well as to restrict or object to its processing and request data portability. For more information on how Google processes your data and your rights, please review Google Privacy Policy.

9.6 E-Commerce and Payments

Orders in our online shop require the creation of a personal customer account, restricted to individuals aged 18 and above residing within Swiss customs territory. Payments are accepted exclusively in Swiss francs.

Upon opening a personal customer account, you consent to the collection and processing of data provided during registration. Additionally, you agree to the use of your data for marketing purposes within Le Virage GmbH.

For online purchases using debit cards, credit cards, or online payment services, we collaborate with the following payment service providers:

• Twint AG, Zurich (Switzerland)
• Stripe, Inc (Ireland)

We transmit your personal data to the selected payment service provider for identification and payment processing purposes. Your data is not stored by us. By utilizing our services, you have previously agreed to the general terms and conditions, terms of use, and data protection policies of the respective company or payment method.

Our payment service providers are committed to safeguarding your personal data in compliance with applicable laws, refraining from sharing or disclosing it to third parties, except under circumstances specified in their terms and conditions or privacy policies, to which you have consented.

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The duration of personal data storage is determined by the respective legal basis, the purpose of processing, and, if applicable, statutory retention periods (e.g., under commercial and tax law). Personal data is processed based on explicit consent under Art. 6(1)(a) GDPR is retained until the data subject withdraws their consent. Data processed under legal or quasi-legal obligations according to Art. 6(1)(b) GDPR is deleted after statutory retention periods expire, provided it is no longer necessary for contract fulfillment or initiation, and we have no legitimate interest in its retention.

Data processed under Art. 6(1)(f) GDPR is stored until the data subject exercises their right to object under Art. 21(1) GDPR, unless compelling legitimate grounds for processing override the data subject’s interests, rights, and freedoms, or the processing is necessary for legal claims. Personal data processed for direct marketing under Art. 6(1)(f) GDPR is kept until the data subject exercises their right to object under Art. 21(2) GDPR.

Unless indicated otherwise in specific processing situations within this declaration, personal data is deleted when no longer necessary for its original collection or processing purposes.

Le Virage GmbH retains the right to modify this privacy policy as needed. The version of the privacy policy posted on this website is the only valid version.

July 2024