Privacy policy

Privacy Policy

With this privacy policy, we inform which personal data we process in connection with our activities and operations, including our heks.ch website. We provide information on what personal data we process, for what purpose, how and where. We also inform about the rights of persons whose data we process.
For individual or additional activities and activities, further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
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.

1. contact addresses

Responsibility for the processing of personal data:

HEKS
Seminarstrasse 28
P.O. Box
8042 Zurich

dataprotection@heks.ch

We would like to point out if there are other persons responsible for processing personal data in individual cases.

Data protection officer or data protection advisor

We have the following data protection advisor as a point of contact for data subjects and authorities for inquiries relating to data protection:

Ms. Evelyn Stokar
HEKS
Seminarstrasse 28
P.O. Box
8042 Zurich

dataprotection@heks.ch

 

2. Terms and legal bases

2.1 Terms

Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using 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 Swiss Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

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 fulfillment 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 that 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.

As a matter of principle, we only process personal data with the consent of the persons concerned. If and to the extent that the processing is permitted for other legal reasons, we may waive the requirement to obtain consent. For example, we may process personal data without consent in order to fulfill a contract, to meet legal obligations or to protect overriding interests.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example, by letter, e-mail, instant messaging, contact form, social media or telephone. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection vis-à-vis 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 accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.

 

4. Applications

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.

We may allow applicants to store their details in our talent pool in order to consider them for future vacancies. We may also use such information to maintain contact and provide news. If we believe that an applicant is eligible for a job opening based on the information provided, we may notify the applicant accordingly.

We use third-party services to advertise jobs via e-recruitment and to enable and manage applications.

 

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 countries and territories on earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - adequate data protection in accordance with 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 special data protection requirements 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 a copy of any guarantees upon request.

 

6. Rights of data subjects

6.1 Data protection law claims

We grant data subjects all claims in accordance with applicable data protection law. In particular, data subjects have the following rights:

- Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.

- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.

- Deletion and objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.

- Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

 

We may suspend, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements they must meet in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.

We may exceptionally provide for costs for the exercise of rights. We will inform data subjects in advance of any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

 

6.2 Right of Complaint

Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC). In the case of projects financed by cantons or municipalities in Switzerland, the cantonal data protection commissioners are responsible in some cases.

Data subjects have - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - the right to lodge a complaint with a competent European data protection supervisory authority.

 

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.

Access to our website is via 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 communications - like all digital communications in principle - are subject 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. Use of the website

8.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as "session cookies" or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed.

Permanent cookies have a specific storage period. In particular, cookies allow 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.

Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request - at least if and to the extent necessary - the express consent to the use of cookies.

For 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 collect 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.

 

8.3 Tracking pixel

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

 

9. Notifications and messages

We send notifications and messages via email and other communication channels such as instant messaging or SMS.

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 use 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 based on the needs and reading habits of the recipients in an effective and user-friendly manner 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 the 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.

 

9.3 Service providers for notifications and communications

We send notifications and communications using specialized service providers.

We use in particular:

- ActiveCampaign: email marketing platform; provider: ActiveCampaign LLC (USA); data protection information: privacy policy.

 

10. Social media

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).

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. These provisions inform in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right to information.

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.

 

Further information about the nature, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Responsible Party Addendum" with Facebook and thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Page Insights Information" including "Page Insights Data Information".

 

11. Services of third parties

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. With such services, we can, among other things, embed functions and content into 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:

- Services of Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and Security Principles", Privacy Policy, "Google is committed to complying with applicable data protection laws", "Guideline

- on privacy in Google products", "How we use data from websites or apps on or in which our services are used" (information provided by Google), "Cookie types and other technologies used by Google", "Personalized advertising" (activation / deactivation / settings).

- Microsoft services: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: "Data protection at Microsoft", "Data protection and privacy (Trust Center)", data protection declaration, data protection dashboard (data and privacy settings).

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. This includes, for example, hosting and storage services from selected providers.

In particular, we use:

- Microsoft Azure: storage and other infrastructure; Provider: Microsoft; Microsoft Azure-specific disclosures: "Privacy in Azure".

11.2 Automation and integration of apps and services

We use specialized platforms to integrate and connect existing third-party apps and services. We may also use such "no-code" platforms to automate processes and activities with third-party apps and services.

In particular, we use:

- Zapier: automation and integration of apps and services; provider: Zapier Inc. (USA); privacy information: privacy policy, "Data Privacy at Zapier", "Data Privacy & Security FAQ", "Security and Compliance".

11.3 Contact options

We use services from selected providers to better communicate with third parties such as potential as well as existing customers.

Among others, we use:

- Microsoft Dynamics 365: Customer relationship management (CRM); Provider: Microsoft; Microsoft Dynamics-specific information: "Data protection and personal data in Microsoft Dynamics 365".

- Tocco: Customer Relationship Management (CRM); Provider: Tocco AG (Switzerland); Data protection information: Privacy policy.

11.4 Audio and Video Conferencing

We use specialized audio and video conferencing services to communicate online. We can use them, for example, to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy statements and terms of use apply in addition.

Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or fading in a virtual background.

We use in particular:

- Microsoft Teams: platform for audio and video conferencing, among other things; provider: Microsoft; Teams-specific information: "Privacy and Microsoft Teams".

- Skype: audio and video conferencing; Skype-specific providers: Skype Communications SARL (Luxembourg) / Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom, and Switzerland; privacy information: "Legal information about Skype", "Privacy and security".

- Zoom: Video conferencing; provider: Zoom Video Communications Inc. (USA); privacy information: privacy statement, "Privacy at Zoom," "Legal Compliance Center.

11.5 Online collaboration

We use services of third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.

We use, among others:

- Miro: whiteboard platform; provider: RealtimeBoard Inc. (USA); data protection information: privacy policy, "Trust in Miro" ("Miro Trust Center").

- Padlet: Platform for productive collaboration; Provider: Wallwisher Inc. DBA Padlet; Data protection information: Privacy policy.

11.6 Social media functions and social media content

We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.

We use in particular:

11.7 Map material

We use third party services to embed maps on our website.

We use in particular:

11.8 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:

11.9 Fonts

We use third-party services to embed selected fonts as well as icons, logos and symbols on our website.

We use in particular:

11.10 Payments

We use specialised service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers, such as the General Terms and Conditions (GTC) or data protection declarations, also apply to the processing of payments.

We use in particular:

11.11 Advertising

We use the option of displaying targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.

We would like to use such advertising in particular to reach people 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 who enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our online services to your profile there.

We use in particular:

12. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

 

13. Success and reach measurement

We try to determine how our online offer 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. But we can also, for example, try out and compare how different parts or versions of our online offer are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offer.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are always shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation.

Cookies may be used for performance and reach measurement and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual services of third parties with which users are registered may be able to assign the use of our online services to the user account or user profile of the respective service.

We use in particular:

  • Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, "Data protection", "Browser add-on to deactivate Google Analytics".
  • 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

We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.