PRIVACY POLICY OF 19DOT GMBH
Version dated February 23, 2024
In this privacy policy, we, 19dot GmbH (hereinafter referred to as 19dot GmbH, we, or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; specific matters may be regulated by other privacy policies (or general terms and conditions, participation conditions, and similar documents). Personal data refers to all information relating to an identified or identifiable individual.
If you provide us with personal data of other individuals (e.g., family members, data of colleagues), please ensure that these individuals are aware of this privacy policy, and only provide us with their personal data if you are authorized to do so and if this personal data is correct.
1/RESPONSIBLE PARTY / DATA PROTECTION OFFICER / REPRESENTATIVE
Responsible for the data processing described here is 19dot GmbH (Dornacherstrasse 7, 4600 Olten, Switzerland), unless otherwise specified in individual cases. If you have data protection concerns, you can contact us at the following address:
19dot GmbH
Dornacherstrasse 7
4600 Olten
Switzerland
info@19dot.com
Our representative in the EEA according to Art. 27 GDPR (if required) is: Simon Leutenegger, info@19dot.com.
Collection and Processing of Personal Data
We primarily process the personal data that we receive from our customers and other business partners, as well as from other persons involved, in the context of our business relationship or that we collect when operating our websites, apps, and other applications from their users.
To the extent permitted, we also obtain certain data from publicly available sources (e.g., debt collection registers, land registers, commercial registers, press, internet) or receive such data from other companies, authorities, and other third parties. In addition to the data you directly provide to us, the categories of personal data we receive from third parties about you include information from public registers, information we learn in connection with official and judicial proceedings, information related to your professional functions and activities (so that, for example, we can conclude and process transactions with your employer with your assistance), information about you in correspondence and meetings with third parties, credit reports (if we conduct business with you personally), information about you provided by individuals in your environment (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or involving you (e.g., references, your delivery address, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, distribution and other contractual partners of ours for the provision or performance of services by you (e.g., payments made, purchases made), information from media and the internet about your person (to the extent necessary in specific cases, e.g., in the context of an application, press review, marketing/sales, etc.), your addresses and possibly interests and other socio-demographic data (for marketing), data related to 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 visit, accessed pages and content, functions used, referring website, location information).
2/PURPOSES OF DATA PROCESSING AND LEGAL BASES
We use the personal data collected by us primarily to conclude and execute contracts with our customers and business partners, especially in the context of service provision with our customers and the procurement of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you are acting on behalf of such a customer or business partner, you may also be affected by the processing of your personal data in this capacity.
In addition, we process personal data from you and other persons, to the extent permitted and as deemed appropriate, also for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
Offer and further development of our offers, services, and websites, apps, and other platforms on which we are present;
Communication with third parties and processing of their inquiries (e.g., applications, media inquiries);
Examination and optimization of procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for customer acquisition;
Advertising and marketing (including conducting events), unless you have objected to the use of your data (if we send you advertising as an existing customer of ours, you can object to this at any time, and we will then add you to a blocklist against further advertising mailings);
Market and opinion research, media monitoring;
Assertion of legal claims and defense in connection with legal disputes and official proceedings;
Prevention and investigation of crimes and other misconduct (e.g., conducting internal investigations, data analysis to combat fraud);
Ensuring the operation of our business, in particular IT, our websites, apps, and other platforms;
Video surveillance to protect the rights of the property owner and other measures for IT, building and plant security, and protection of our employees and other persons and assets belonging to us or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone recordings);
Purchase and sale of business areas, companies or parts of companies and other corporate transactions, and related transfer of personal data as well as measures for business management and to comply with legal and regulatory obligations.
If you have given us consent to process your personal data for specific purposes (e.g., when registering to receive newsletters or conducting a background check), we will process your personal data within the scope and based on this consent, provided we do not have another legal basis and we require such. A consent given can be revoked at any time, but this does not affect data processing that has already taken place.
3/COOKIES / TRACKING AND OTHER TECHNOLOGIES IN CONNECTION WITH THE USE OF OUR WEBSITE
We typically use “cookies” and similar techniques on our websites, with which your browser or device can be identified. 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 are using when you visit our website. When you revisit this website, we can recognize you, even if we do not know who you are. In addition to cookies that are used only during a session and deleted after your website visit (“session cookies”), cookies can also be used to store user settings and other information for a certain period (e.g., two years) (“permanent cookies”). However, you can configure your browser to reject cookies, store them only for one session, or delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies to save user settings (e.g., language, auto-login), to better understand how you use our offers and content, and to show you offers and advertising tailored to you (which may also occur on websites of other companies; however, they do not receive any information from us about who you are if we know this at all because they only see that the same user is on their website who was also on a specific page with us). Some of the cookies are set by us, some also by contractual partners with whom we work together. If you block cookies, certain functionalities (such as language selection, shopping cart, order processes) may no longer function.
We sometimes include visible and invisible image elements in our newsletters and other marketing emails, which, if retrieved from our servers, allow us to determine whether and when you have opened the email, so that we can also measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are preset to do so.
By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not wish to do so, you must adjust your browser or email program accordingly.
We sometimes use Google Analytics or similar services on our websites. This is a third-party service that may be located anywhere 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 data processor (both “Google”), www.google.com), with which we can measure and evaluate the use of the website (not personally). For this purpose, permanent cookies are also used, which the service provider sets. 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 then takes place under the responsibility of the service provider in accordance with its data protection regulations. The service provider only informs us about how our respective website is used (no information about you personally).
We also use so-called plug-ins from social networks such as Facebook, Whatsapp, Twitter, Youtube, Vimeo, Pinterest, or Instagram on our websites. This is visible to you in each case (typically via corresponding symbols). We have configured these elements so that they are deactivated by default. If you activate them (by clicking), 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 then takes place under the responsibility of this operator in accordance with its data protection regulations. We do not receive any information from him about you.
4/DATA TRANSFER AND TRANSFER OF DATA ABROAD
As part of our business activities and the purposes set out in clause 3, we also disclose to third parties, to the extent permitted and as appropriate, whether because they process them for us or because they wish to use them for their own purposes. This concerns in particular the following bodies:
Service providers of ours (such as banks, insurance companies), including data processors (such as IT providers);
Merchants, suppliers, subcontractors, and other business partners;
Customers;
Domestic and foreign authorities, public authorities, or courts;
Media;
Public, including visitors to websites and social media;
Competitors, industry organizations, associations, organizations, and other bodies;
Acquirers or interested parties in the acquisition of business areas, companies, or other parts of 19dot GmbH;
other parties in actual or potential legal proceedings;
Other companies of 19dot GmbH;
all together recipients.
These recipients are partly domestic but can be anywhere in the world. In particular, you must consent to the transfer of your data to other countries in Europe and the USA, where the service providers we use are located (such as Microsoft, Apple, Squarespace).
If a recipient is in a country without adequate legal data protection, we contractually obligate the recipient to comply with applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless it is already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exemption provision. An exception may apply, in particular, in foreign legal proceedings, but also in cases of overriding public interests or if contract processing requires such disclosure, if you have consented, or if it concerns data made generally accessible by you, the processing of which you have not objected to.
5/RETENTION PERIOD FOR PERSONAL DATA
We process and store your personal data for as long as necessary to fulfill our contractual and legal obligations or the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from initiation, processing to termination of a contract) and beyond in accordance with legal retention and documentation obligations. It is possible that personal data will be retained for the time during which claims can be asserted against our company and to the extent that we are otherwise legally obligated or have legitimate business interests (e.g., for evidence and documentation purposes). Once your personal data is no longer required for the aforementioned purposes, it will generally be deleted or anonymized to the extent possible. For operational data (e.g., system logs, logs), generally shorter retention periods of twelve months or less apply.
6/DATA SECURITY
We take appropriate technical and organizational security measures to protect your personal data against unauthorized access and misuse, such as IT and network security solutions, encryption of data carriers and transmissions, pseudonymization, controls.
7/OBLIGATION TO PROVIDE PERSONAL DATA
In the context of our business relationship, you must provide the personal data necessary to establish and conduct a business relationship and fulfill 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 cannot be used if certain information to ensure data traffic (such as IP address) is not disclosed.
8/PROFILING AND AUTOMATED DECISION-MAKING
We process your personal data partially automated with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to inform and advise you about products in a targeted manner. For this purpose, we use evaluation instruments that enable us to tailor communication and advertising, including market and opinion research, to your needs.
9/RIGHTS OF THE DATA SUBJECT
Under the applicable data protection law and to the extent provided therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and to object to our data processing, in particular that for purposes of direct marketing, profiling for direct advertising purposes, and other legitimate interests in processing, as well as to provide certain personal data for transfer to another entity (so-called data portability). Please note, however, that we reserve the right to invoke the statutory limitations ourselves, for example, if we are required to retain or process certain data, have a predominant interest (to the extent we may invoke this), or need them to assert claims. If costs are incurred for you, we will inform you in advance. We have already informed you about the possibility of revoking 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 in such cases where this is not already contractually regulated.
The exercise of such rights generally requires that you provide clear proof of your identity (e.g., by means of a copy of an identity document where your identity is otherwise not clear or can be verified). To exercise your rights, you can contact us at the address provided in section 1.
Any 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 (http://www.edoeb.admin.ch).
10/CHANGES
We may amend this privacy policy at any time without prior notice. The current version published on our website applies. If the privacy policy is part of an agreement with you, we will inform you of the change by email or by other appropriate means in the event of an update.