DATA PROTECTION POLICY WEVALUE
wevalue AG, with its registered office in Rheinfelden, Switzerland (hereinafter also referred to as “we”, “us”), obtains and processes personal data relating to you or also to other persons (so-called “third parties”). We use the term “data” here synonymously with “personal data” or “personal data”.
2. INFORMATION ABOUT THE RESPONSIBLE PERSON
For questions in connection with the processing of personal data as well as for the exercise of claims, we are at the disposal of the persons concerned as follows:
Privet path 12
3. PROCESSING OF PERSONAL DATA
We process different categories of data about you. The main categories are the following:
- Technical Data: When you use our websites or other electronic offerings, we collect the IP address of your terminal device and other technical data to ensure the functionality and security of those offerings. This data also includes logs in which the use of our systems is recorded. The technical data in itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they may be linked to other categories of data (and thus possibly to your person).
- Registration Data: Certain offers and services (e.g. login areas of our websites) can only be used with a user account or registration, which can be done directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data about the use of the offer or service.
- Communication Data: If you are in contact with us via the contact form, by e-mail, telephone or chat, by letter or via other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we want or need to establish your identity, e.g. in the case of a request for information made by you, we collect data to identify you (e.g. a copy of an identification document).
- Master Data: We refer to Master Data as the basic data that we need, in addition to Contractual Data (see below), to process our contractual and other business relationships or for marketing and promotional purposes, such as name, contact details and information about, for example, your role and function, customer history and consent forms. We process your master data if you are a customer or other business contact or are working for one (e.g. as a contact person of the business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. in the context of marketing and advertising). We receive master data from you yourself (e.g. as part of a registration), from bodies for which you work, or from third parties such as our contractual partners, associations and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.).
- Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g., information about contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information about reactions. We generally collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third-party sources (e.g. providers of creditworthiness data) and from publicly available sources.
Many of the items listed in this sec. 3 you disclose to us yourself. As a rule, you are not obliged to do so. If you wish to conclude contracts with us or claim services, you must also provide us with data as part of your contractual obligation under the relevant contract, in particular master data, contract data and registration data. When using our websites, the processing of technical data is unavoidable.
Unless this is inadmissible, we also take data from publicly accessible sources (e.g. land registers, commercial registers, the Internet incl. social media) or receive data from other companies within our Group, from public authorities and from other third parties.
4. PURPOSES OF DATA PROCESSING
We process your data for the purposes we explain below. Further information for the online area can be found in para. 11. These purposes or the underlying objectives represent legitimate interests of us and, if applicable, of third parties. You will find further information on the legal basis for our processing in para. 5.
We process your data for purposes related to communication with you, in particular to respond to inquiries and assert your rights (para. 10), and to contact you in the event of queries. For this purpose, we use in particular communication data and master data and, in connection with offers and services used by you, also registration data. We retain this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
We process data for the establishment, administration and processing of contractual relationships.
We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalized advertising about products and services from us. This may take the form of e-mails or newsletters, for example. You can refuse such contacts at any time or refuse or revoke consent to be contacted for advertising purposes (see para. 5).
We further process your data for market research, to improve our services and operations, and for product development.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (compliance).
We also process data for the purposes of our risk management and as part of prudent corporate governance, including operational organization and corporate development.
We may process your data for other purposes, e.g. as part of our internal processes and administration.
5. BASICS OF DATA PROCESSING
Insofar as we ask for your consent for certain processing, we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with effect for the future by written notification (by post) or, where not otherwise stated, by e-mail to us; our contact details can be found in para. 2. If you have a user account, a revocation or contact with us may also be carried out via the relevant website or other service, if applicable. Once we have received notification of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The revocation of your consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Where we do not ask for your consent for processing, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, such as, in particular, in order to fulfill the obligations set out above under section 4. 4 and related objectives described above and to be able to implement appropriate measures.
In individual cases, other legal grounds may come into play, which we will communicate to you separately where necessary.
6. DISCLOSURE OF PERSONAL DATA
In connection with our contracts, the websites, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other interests described in para. 4 we also transfer your personal data to third parties, in particular to the following categories of recipients:
- Service providers: We work with service providers in Germany and abroad who process data about you on our behalf or in joint responsibility with us or receive data about you from us in their own responsibility (e.g. IT provider, chat provider, newsletter provider, etc.).
- Contractual partners including customers: This initially refers to customers (e.g. service recipients) and other contractual partners of ours, because this data transfer arises from these contracts. If you work for such a contractual partner yourself, we may also transfer data about you to them in this context. The recipients also include contractual partners with whom we cooperate.
- Authorities: We may disclose personal data to offices, courts and other authorities in Germany and abroad if we are legally obliged or entitled to do so, or if this appears necessary to protect our interests.
- Other persons: This refers to other cases where the inclusion of third parties arises from the purposes set forth in para. 4.
All these categories of recipients may in turn involve third parties, so that your data may also be made accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities).
7. PLACE OF DATA PROCESSING
Your personal data will generally be processed in Switzerland, the data relating to the Websites will be stored in a data center in Zurich. As described in para. 6 we also disclose data to other bodies. These are not only located in Switzerland. Your data may therefore be processed both in Europe and in the USA; in exceptional cases, however, in any country in the world.
If a recipient is located in a country without adequate legal data protection, we contractually oblige the recipient to comply with the applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? ), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have consented or if it is a matter of data made generally available by you, the processing of which you have not objected to.
8. DURATION OF STORAGE
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary. If there are no legal or contractual obligations to the contrary, we delete or anonymize your data after the storage or processing period has expired as part of our normal processes.
9. DATA SECURITY
We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal information, to protect it against unauthorized or unlawful processing, and to protect against the risks of loss, accidental alteration, unauthorized disclosure or access.
10. YOUR RIGHTS
To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:
- The right to request information from us as to whether and what data we process from you;
- the right to have us correct data if it is inaccurate;
- the right to request the deletion of data;
- the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
- the right to withdraw consent, insofar as our processing is based on your consent;
- the right to object to the processing of your data;
- the right to receive, upon request, further information necessary for the exercise of these rights;
If you do not agree with our handling of your rights or data protection, please let us know. You also have the right to complain to the data protection supervisory authority. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/adresse.html.
We use various technologies on our websites that allow us and third parties we engage to recognize you when you use them and, under certain circumstances, to track you across multiple visits. In this section we inform you about this.
In essence, this is so that we can distinguish access by you (via your system) from access by other users, so that we can ensure the functionality of the websites and carry out evaluations and personalizations. We do not want to infer your identity, even if we can, as far as we or third parties engaged by us can identify you by combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognized as an individual visitor each time you access the site, for example by our server (or the servers of third parties) assigning you or your browser a specific identification number (so-called “cookie”).
We use such techniques on our websites and allow certain third parties to do so as well. You can program your browser to block, deceive, or delete existing cookies from certain cookies or alternative techniques. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword “Privacy”) or on the websites of the third parties that we list below.
The following cookies are distinguished (techniques with comparable functionalities such as fingerprinting are included here):
- Necessary cookies: Some cookies are necessary for the functioning of the websites as such or certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies only exist temporarily (“session cookies”). If you block them, the websites may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you request this function (e.g. language selected, consent given, the function for automatic login, etc.). These cookies have an expiration date of up to 24 months.
Currently we use offers of the following service providers:
- Google Analytics: Google Ireland (based in Ireland) is the provider of the “Google Analytics” service and acts as our order processor. Google Ireland relies on Google LLC (based in the USA) as its order processor (both “Google”). Google thereby tracks the behavior of visitors to our websites (duration, frequency of pages viewed, geographical origin of access, etc.) through performance cookies (see above) and creates reports for us on the use of our websites on this basis. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and thus cannot be traced. We have turned off the “data sharing” and “signals” settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. Information on the data protection of Google Analytics can be found here: https://support.google.com/analytics/answer/6004245. If you have a Google account, you can find more information on processing by Google here: https://policies.google.com/technologies/partner-sites?hl=de.
- Google Ads Conversion and Remarketing: We use the Google Ads Conversion offer of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Ads). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the interest of showing you advertising that is of interest to you, making our websites more interesting for you and achieving a fair calculation of advertising costs. These advertisements are delivered by Google via so-called “ad servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as display of the ads or clicks by users, can be measured. If you access our websites via a Google ad, Google Ads will store a cookie on your end device. These cookies usually lose their validity after 30 days and are not intended to identify you personally. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of the advertising measures used are particularly effective.
Furthermore, we use Google Ads remarketing. With the remarketing function, we can present users of our websites with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called “Google Ads” or on other websites). For this purpose, the interaction of the users on our websites is analyzed, e.g. which offers the user was interested in, in order to be able to display targeted advertising to the users on other sites even after they have visited our websites.
You can find more information about Google’s data protection here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html.