We are subject to Swiss data protection law and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
Responsibility for the processing of personal data:
Swiss Property AG
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (FADP) and the Ordinance to the Federal Data Protection Act (DPA).
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner, as well as to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
- Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with 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 DSGVO for the necessary processing of personal data for the performance of a task which is in the public interest.
- Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 (1) (d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. In particular, such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data and contract and payment data.
We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required will be anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
We process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the fulfillment of a contract with the data subject and for corresponding pre-contractual measures, in order to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example, by letter, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information, for example, in an address book or with comparable tools. If we receive data about other persons, the transmitting persons are obligated to ensure data protection with respect to these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
We process personal data about applicants to the extent that it is required for assessing their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, resumes and other application documents as well as online profiles.
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 (2) lit. b GDPR.
5. Personal data abroad
We process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer Personal Data to other countries, in particular to process it or have it processed there.
We may export personal data to all states and territories on earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) or according to the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to the decision of the European Commission.
We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.
6. Rights of data subjects
Data subjects about whom we process personal data have rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.
Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – request confirmation free of charge as to whether we are processing personal data relating to them. In this case, data subjects may request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.
Data subjects whose personal data we process may – if and insofar as the GDPR applies – revoke consent they have given at any time with future effect and object to the processing of their personal data at any time.
Data subjects about whom we process personal data have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
7. Data security
We take appropriate technical and organizational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communication is subject – as is basically all digital communication – to mass surveillance without cause or suspicion and other monitoring 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 agencies and other security authorities.
8. Website usage
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 enable us to recognize 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.
In the case of cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Server log files
We may record the following information for each access to our website, provided that this information 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, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably as well as to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
9. Notifications and messages
9.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked on. Such web links and tracking pixels may also record the usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
9.2 Consent and objection
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure wherever possible, i.e. you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.
9.3 Service providers for notifications and communications
We send notifications and communications with the help of specialized service providers.
In particular, we use:
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are – if and insofar as the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). 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 manner.
11. Third party services
We use services of specialized third parties in order to carry out our activities and operations in a durable, user-friendly, safe and reliable manner. Such services allow us, among other things, to embed functions and content in our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
11.1 Digital infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
11.2 Digital audio and video content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
In particular, we use:
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular persons who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We may also determine whether our advertising is successful, that is, in particular, whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are logged in as a user can, if necessary, assign the use of our online offer to your profile there.
We use in particular:
- Facebook advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting in particular with the Facebook pixel as well as Custom Audiences including Lookalike Audiences, data protection declaration, “advertising preferences” (user registration required).
- Google Ads: search engine advertising; provider: Google; Google Ads-specific data: Advertising based on search queries, among other things, using different domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, “Advertising” (Google), “Why do I see a certain ad?“.
- Instagram Ads: social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting in particular with Facebook Pixel as well as Custom Audiences including Lookalike Audiences, data protection declaration (Instagram), data protection declaration (Facebook), “Advertising preferences” (Instagram) (user registration required), “Advertising preferences” (Facebook) (user registration required).
12. Extensions for the website
We use extensions for our website to provide additional functionality.
In particular, we use:
13. Success and reach measurement
We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offering or parts of our online offering are used (“A/B test” method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization and thus to improve user data protection.
When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. As a matter of principle, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual users. Individual services of third parties to which users are logged in can, if necessary, assign the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager“; further information on data protection can be found with the individual integrated and managed services.
14. Final provisions
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