Privacy Policy Karin Berger Strategie Atelier
This privacy policy informs you about the processing of personal data in connection with our activities and operations, including our websites (strategieatelier.ch and joulendar.com).
This English translation is provided automatically as a courtesy. For accuracy, please consult the original German version.
1. Swiss Data Protection Law, Contact, Amendments
(a) We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
(b) The European Commission recognized with its decision of July 26, 2000, that Swiss data protection law ensures an adequate level of data protection. With its report of January 15, 2024, the European Commission confirmed this adequacy decision.
(c) Responsible for the processing of personal data: Karin Berger Strategie Atelier Florastrasse 10 8610 Uster/Switzerland Karin Berger, E-Mail: mail@strategieatelier.ch
(d) We may amend or supplement this privacy policy at any time. We will provide appropriate information about such amendments and supplements, in particular by publishing the current privacy policy on our websites.
2. Legal Bases
(a) We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
(b) If and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data for the fulfillment of 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. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.
Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests include, in particular, the permanent, secure, and reliable exercise of our activities and operations, ensuring information security, protection against misuse, enforcement of our own legal claims, and compliance with Swiss law.
Art. 9 para. 2 et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Type, Scope, and Purpose of Processing Personal Data
(a) We process the personal data that is necessary to carry out our activities and operations permanently, securely, and reliably. The processed personal data may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data.
(b) We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during the exercise of our activities and operations, provided that such processing is legally permissible.
(c) We process personal data as necessary with the consent of the data subjects. In many cases, we can process personal data without consent, for example, to fulfill legal obligations or to safeguard overriding interests. We may also ask data subjects for their consent even if their consent is not required.
(d) We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data, in particular depending on legal retention and limitation periods.
(e) We process personal data to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, for example, by post or e-mail. We may store such data in an address book or with comparable tools.
(f) Third parties who transmit data about other persons are obliged to ensure data protection towards such data subjects. Among other things, the accuracy of the transmitted personal data must be ensured.
6. Data Security
(a) We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the processed personal data, without being able to guarantee absolute data security.
(b) Access to our websites and our other online presence is via transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS).
(c) Our digital communication – like any digital communication – is subject to mass surveillance without cause or suspicion 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 intelligence services, policeauthorities, and other security authorities. We also cannot exclude that a data subject is specifically monitored.
(d) If you are redirected to third-party websites via links on our websites, please inform yourself there about the respective handling of your data.
7. Disclosure of Personal Data, Personal Data Abroad
(a) We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties are, in particular, specialized providers whose services we use.
(b) We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular to process it or have it processed there.
(c) We may export personal data to all countries and territories on earth, provided that the law there ensures an adequate level of data protection in accordance with a decision by the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance with a decision by the European Commission.
(d) We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with othersuitable guarantees. Exceptionally, we may export personal data to countries without adequate or suitable 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 execution of a contract.
8. Rights of Data Subjects
(a) We grant data subjects all claims in accordance with applicable data protection law. Data subjects have, in particular, the following rights:
Information: Data subjects may request information on whether we process personal data about them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims andensure transparency. This includes the processed personal data as such, but also 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 correct incorrect personal data, complete incomplete data, and have 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 release of personal data or the transfer of their data to another controller.
(b) We may postpone, restrict, or refuse the exercise of the rights of data subjects within the legally permissible scope. We may inform data subjects of any conditions to be met for the exercise of their data protection claims.
(c) For example, we may refuse information in whole or in part with reference to confidentiality obligations or the protection of other persons. For example, we may also refuse the deletion of personal data in whole or in part with reference to legal retention obligations.
(d) We may provide for costs for the exercise of rights. We inform data subjects in advance about any costs.
(e) We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are obliged to cooperate.
(f) Data subjects have the right to enforce their data protection claims in court or to file a report or complaint with a data protection supervisory authority. The data protection supervisory authority for private controllers and federal authorities in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured.
9. Use of Websites
(a) We may use cookies. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data is not limited to traditional text-based cookies.
(b) Cookies can be stored temporarily in the browser as "session cookies" or for a specific period as so-called persistent cookies. "Session cookies" are automatically deleted when the browser is closed. Persistent cookies have a specific storage period. Cookies enable, in particular, the recognition of a browser on the next visit to our websites and thereby, for example, the measurement of the reach of our websites. However, persistent cookies can also be used for online marketing, for example.
(c) Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our websites may no longer be fully available. We actively request—at least where and to the extent necessary—explicit consent to the use of cookies.
(d) We may log at least the following information for each access to our websites and our other online presence, provided that this information is transmitted to our digital infrastructure during such access: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual pages of our websites accessed including data volume transmitted, last website accessed in the same browser window (referrer).
(e) We log such information, which may also constitute personal data, in log files. The information is necessary to provide our online presence permanently, securely, and reliably. The information is also necessary to ensure data security—including by third parties or with the help of third parties.
(f) We may embed tracking pixels in our online presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or JavaScript-formatted scripts that are automatically retrieved when accessing our online presence. Tracking pixels can collect at least the same information as in log files.
10. Notifications and Communications
(a) Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. 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 success and reach measurement to send notifications and communications effectively, permanently, securely, and reliably based on the needs and reading habits of the recipients.
(b) You must generally consent to the use of your email address and other contact addresses unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain any double-confirmed consent. In this case, you will receive a communication with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidentiary and security reasons.
(c) You can generally 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 success and reach measurement. Necessary notifications and communications related to our activities and operations remain reserved.
11. Social Media
(a) We are present on social media platforms and other online platforms to communicate with interested parties and 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).
(b) The general terms and conditions (GTC), terms of use, privacy policies, and other provisions of the individual operators of such platforms apply.
12. Third-Party Services
(a) We use services from specialized third parties to embed functions and content into our websites. For such embedding, the used services collect the IP addresses of users at least temporarily for technically mandatory reasons.
(b) For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. This includes, for example, performance or usage data to provide the respective service.
(c) We use in particular:
Systems.io: E-Academy/Shop/Marketing Platform; Provider: ITACWT Limited (Ireland).
Hostpoint: Hosting; Provider: Hostpoint AG (Switzerland).
Usercentrics: Cookie Service; Provider: Usercentrics A/S (Denmark).
Canva: Platform for collaborative work; Provider: Canva Pty Ltd. (Australia).
Zoom: Platform for collaborative work; Provider: Zoom Video Communications Inc. (USA).
Mollie: Payment platform; Provider: Mollie B.V. (Netherlands).
Google: Google Fonts (embedded in Systeme.io), Google reCaptcha as spam protection, Google Drive for collaborative work and providing digital content. Provider: Google LLC (USA), Google Ireland Limited (Ireland).