We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) in the form of the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
CB Multilingual LLC
General Wille-Strasse 201
We will indicate if there are other persons responsible for processing personal data in individual cases.
Data protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
The data protection representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries related to the GDPR.
2. Terms and legal bases
Personal data refers to 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, irrespective of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading out, notifying, procuring, recording, collecting, deleting, disclosing, arranging, organising, saving, 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 use of an individual’s information is referred to in the GDPR as the processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Act on Data Protection (FADP) and the Ordinance on Data Protection (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(1)b GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6(1)f GDPR for the necessary processing of personal data in order 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 include, in particular, our interest in being able to carry out and communicate about our activities and operations in a permanent, user-friendly, secure and reliable manner, ensuring information security, protecting against misuse, enforcing our own legal claims and complying with Swiss law.
- Art. 6(1)c GDPR 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(1)e GDPR for the necessary processing of personal data for the performance of a task that is in the public interest.
- Art. 6(1)a GDPR 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 vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process those personal data that are necessary to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular 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 duration that is required for the respective purpose(s) or by law. Personal data that no longer needs to be processed is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialised 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 fulfil a contract, to comply with 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, 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 obliged to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of these 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 necessary to assess their suitability for an employment relationship or for the subsequent implementation of an employment contract. The necessary personal data result 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, CVs and other application documents as well as online profiles.
We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9(2)b GDPR.
5. Personal data abroad
As a general rule 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 in order 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 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 – in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other appropriate guarantees. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law 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 on any guarantees or a copy of any guarantees on request.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all rights under 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 are involved. Data subjects also receive the information necessary 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 may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects may 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 can draw the attention of data subjects to any requirements that must be met 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 inform affected persons in advance of any costs.
We are obliged to take reasonable steps to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
6.2 Right to complain
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).
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 suitable technical and organisational measures to ensure data security appropriate to the respective risk. 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 indicate transport encryption with a padlock in the address bar.
Our digital communication is subject – like all digital communication in principle – 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
Cookies may 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. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
For cookies used to measure conversions and reach or for advertising, a general objection (“opt-out”) is possible for many 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 required to make our website available in a permanent, user-friendly and reliable manner and 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 pixels
We may use tracking pixels on our website. Tracking pixels are also known 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. Pixel counters can be used to collect the same information as server log files.
9. Notifications and messages
We send notifications and communications by email and through other communication channels such as instant messaging or SMS.
9.1 Measuring conversions and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage to measure conversions and reach in order to be able to send notifications and messages effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of the recipients.
9.2 Consent and objection
As a matter of 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 where possible, i.e. you receive an e-mail with a web link that you must click to confirm, excluding the possibility of misuse by unauthorised third parties. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
As a general principle, you may object to receiving notifications and communications such as newsletters at any time. With such an objection, you may simultaneously object to the statistical recording of use for the purposes of measuring conversions and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
9.3 Service provider for notifications and messages
We send notifications and messages with the help of specialised service providers.
We use in particular:
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 Switzerland and the European Economic Area (EEA).
11. Services from third parties
We use services provided by specialised third parties in order to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, 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, anonymised or pseudonymised form. This relates, for example, to performance or usage data in order to be able to offer the respective service.
We use in particular:
- Services from Microsoft: Providers: 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)”, privacy statement, data protection dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
11.2 Audio and video conference
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 having a virtual background superimposed.
We use in particular:
- Microsoft Teams: platform for, among other things, audio and video conferencing; provider: Microsoft; Teams-specific information: “Data protection and Microsoft Teams”.
- Zoom: video conferencing; provider: Zoom Video Communications Inc. (USA); information on data protection: privacy statement, “Privacy at Zoom”, “Legal Compliance Centre”.
11.3 Map material
We use third party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform: mapping service; provider: Google; Google Maps-specific information: “How Google uses location information”.
11.4 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:
- Vimeo: video platform; provider: Vimeo Inc. (USA); information on data protection: Privacy Notice, “Data protection”.
- YouTube: video platform; provider: Google; YouTube-specific information: “Privacy and Safety Center”, “Your Data in YouTube”.
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 that 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 which 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:
- Google Ads: search engine advertising; provider: Google; Google Ads-specific claims: advertising based on, inter alia, search queries, 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?”.
12. Measuring conversions and reach
We try to determine how our online offer is being used. In this context, we may, for example, measure the conversions and reach of our activities and operations as well as the effect of third-party links to our website. But we may 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 conversions and reach measurement, we may 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 the purposes of measuring conversions and reach. 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 to measure conversions and reach, 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. Any user profiles created are, as a matter of principle, 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: measurement of conversions and reach; 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 conversions 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.
13. Final provisions
Zur Verwaltung der eingesetzten Cookies und ähnlichen Technologien (Tracking-Pixel, Web-Beacons etc.) und diesbezüglicher Einwilligungen setzen wir das Consent Tool “Real Cookie Banner” ein. Details zur Funktionsweise von “Real Cookie Banner” findest du unter https://devowl.io/de/rcb/datenverarbeitung/.
Rechtsgrundlagen für die Verarbeitung von personenbezogenen Daten in diesem Zusammenhang sind Art. 6 Abs. 1 lit. c DS-GVO und Art. 6 Abs. 1 lit. f DS-GVO. Unser berechtigtes Interesse ist die Verwaltung der eingesetzten Cookies und ähnlichen Technologien und der diesbezüglichen Einwilligungen.
Die Bereitstellung der personenbezogenen Daten ist weder vertraglich vorgeschrieben noch für den Abschluss eines Vertrages notwendig. Du bist nicht verpflichtet die personenbezogenen Daten bereitzustellen. Wenn du die personenbezogenen Daten nicht bereitstellst, können wir deine Einwilligungen nicht verwalten.