Privacy Policy

In this privacy policy, we, 28 Vectors GmbH (hereinafter referred to as we or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; other terms and conditions and similar documents may govern specific matters. Personal data means any information relating to an identified or identifiable person.

If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please make sure that these persons are aware of this privacy policy and only provide us with their personal data if you are allowed to do so and if this personal data is correct.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (GDPR), the Swiss Data Protection Act (DPA) and the revised Swiss Data Protection Act (revDPA). However, whether and to what extent these laws are applicable depends on the individual case.

1. Controller / Data Protection Officer / Representative

Responsible for the data processing we describe here and representative in the EEA according to Art. 27 GDPR is:

Mark Neuhauser
Sumpfstrasse 18
CH-6312 Steinhausen

gruezi@28vectors.com
+41 41 501442 0

If you have any data protection concerns, you can send them to us at the above contact address.

2. Collection and Processing of Personal Data

We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect from their users when operating our websites, apps and other applications.

Where permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from other companies within the group of companies (ITG AG, P4i Partners AG and pending companies), from authorities and other third parties (such as credit agencies, address dealers). In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we conduct business with you personally), information about you in correspondence and meetings with third parties, and information about you in correspondence and meetings with third parties. information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we conduct business with you personally), information about you provided to us by people close to you (family, advisors, legal representatives, etc.) so that we can conclude and process contracts with you. ) so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the use or provision of services by you (e.g. payments made, purchases made). e.g. payments made, purchases made), personal data from the media and the internet (where appropriate in a specific case, e.g. as part of an application, press review, marketing/sales, etc.), your addresses and, where applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

3. Purposes of Data Processing and Legal Bases

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of the implementation and distribution of web applications with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, you and your personal data may of course also be affected in this function.

In addition, we also process personal data of you and other persons, to the extent permitted and deemed appropriate by us, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

1. Offering and further development of our offers, services and websites, apps and other platforms on which we are present;
2. Communication with third parties and processing their inquiries (e.g. applications, media enquiries) applications, media inquiries);
3. testing and optimizing needs analysis procedures for the purpose of direct customer contact and collecting personal data from publicly accessible sources for the purpose of customer acquisition;
4. advertising and marketing (including holding events), provided you have not objected to the use of your data (if we send you advertising from us as an existing customer, you can object to this at any time and we will then put you on a blacklist against further advertising mailings);
5. Market and opinion research, media monitoring;
6. Enforcement of legal claims and defense in connection with legal disputes and official proceedings;
7. Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data collection, data protection);
8. Prevention and investigation of criminal offenses and other misconduct. conducting internal investigations, data analysis to combat fraud);
9. ensuring our operations, in particular IT, our websites, apps and other platforms;

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Cookies / Tracking and Other Technologies in Connection with the Use of Our Website

We typically use "cookies" and similar technologies on our websites and applications to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website or use our applications. This enables us to recognize you when you return to this website or use our applications, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser so that it rejects cookies, only stores them for one session or otherwise deletes them prematurely. Most browsers are pre-set to accept cookies. We use permanent cookies so that you can save user settings (e.g. language, autologin), so that we can better understand how you use our offers and content, and so that we can show you offers and advertising tailored to you (which can also happen on websites of other companies; however, we will not tell them who you are, if we know this at all, because they will only see that the same user is on their website who was also on a certain page on our website). Some of the cookies are set by us, some are also set by contractual partners with whom we work. If you block cookies, certain functions (e.g. language selection, shopping cart, ordering processes) may no longer work.

In some of our newsletters and other marketing emails, we also include visible and invisible image elements, where permitted, which we can retrieve from our servers to determine whether and when you have opened the email so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are pre-set to allow you to do this. By using our websites, applications and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, you must set your browser or email program accordingly.

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as a processor (both "Google"), www.google.com), with which we can measure and evaluate the use of the website (not personalized). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are truncated before being forwarded to the USA and therefore cannot be traced. We have switched off the settings "Data transfer" and "Signals". Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

We also use so-called plug-ins from social networks such as Facebook, X (formerly Twitter), YouTube, Pinterest or Instagram on our websites. This is visible to you in each case (typically via corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

5. Data Transfer and Data Transmission Abroad

As part of our business activities and for the purposes set out in Section 3, we also disclose data to third parties to the extent permitted and deemed appropriate, either because they process it for us or because they wish to use it for their own purposes. This relates in particular to the following bodies:

1. service providers of ours within the group of companies and externally, such as banks, insurance companies, including contract processors (e.g. IT providers);
2. dealers, suppliers, subcontractors and other business partners;
3. customers;
4. domestic and foreign authorities, official bodies or courts;
5. media;
6. public, including visitors to websites and social media;
7. competitors, industry organizations, associations, organizations and other bodies;
8. acquirers or parties interested in acquiring business units, companies or other parts of the group of companies;
9. other parties in potential or actual legal proceedings;
10. other companies in the group of companies;

all collectively referred to below as recipients.

These recipients are partly in Germany, but can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which the group of companies is represented by group companies, branches or other offices, as well as to other countries in Europe and the USA where the service providers we use are located (such as Microsoft, Amazon, HubSpot, ...).

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 law (we use the revised standard contractual clauses of the European Commission, which can be found here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless it is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exemption 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 given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

6. Duration of Storage of Personal Data

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. Shorter retention periods of twelve months or less generally apply to operational data (e.g. system logs, logs).

7. Data Security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization and controls.

8. Obligation to Provide Personal Data

In the context of our business relationship, you must provide the personal data that is necessary for the establishment and execution of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

9. Profiling and Automated Decision-Making

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research.

In principle, we do not use fully automated decision-making (as regulated in Art. 22 GDPR, for example) to establish and conduct the business relationship or otherwise. Should we use such procedures in individual cases, we will inform you of this separately if this is required by law and inform you of the associated rights.

10. Rights of the Data Subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to objection to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing as well as to the disclosure of certain personal data for the purpose of transfer to another body (so-called data portability) within the framework of the data protection law applicable to you and insofar as provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your ID where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.

Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).

11. Changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by email or other suitable means in the event of an update.