Privacy policy

In this privacy policy, we provide information about which personal data we process in connection with our activities and operations, including our fortdechillon.ch website. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

Further data protection declarations and other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation may apply to individual or additional activities and operations.

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 General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. contact addresses

Responsibility for the processing of personal data:

Fort de Chillon SA
Avenue de Chillon 22
1820 Veytaux

info@fortdechillon.ch

In individual cases, there may be other controllers for the processing of personal data or joint controllership with at least one other controller.

1.1 Data protection officer or data protection advisor

We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities with queries relating to data protection:

Christophe de Rham
Avenue de Chillon 22
1820 Veytaux

Switzerland

christophe.derham@fortdechillon.ch

1.2 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation pursuant to Art. 27 GDPR:

VGS Datenschutz­partner GmbH
Am Kaiserkai 69
20457 Hamburg

Hamburg, Germany

info@datenschutzpartner.eu

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 inquiries in connection with the GDPR.

2 Terms and legal basis

2.1 Definitions

Personal data is 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, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, procuring, collecting, recording, deleting, disclosing, arranging, organizing, storing, 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 General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of personal data.

2.2 Legal basis

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).

If and insofar as the 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. b GD PR 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. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill 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. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
  • 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. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.

3. nature, scope and purpose

We process the personal data required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner.Such personal data may 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 as well as contract and payment data.

We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized 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 data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.

4. communication

We process personal data in order to be able 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.

Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. Among other things, the accuracy of the personal data transmitted must be ensured.

5. applications

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract.The required personal data results in particular from the information requested, for example in the context of a job advertisement.We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms.

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 para. 2 lit. b GDPR.

6. Data security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk.With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication - like all digital communication in general - 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 secret services, police forces and other security authorities. We also cannot rule out the possibility that individual data subjects may be subject to targeted surveillance.

7. personal data abroad

We generally 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 countries and territories on earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as 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 suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract.Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.

8 Rights of data subjects

8.1 Claims under data protection law

We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:

  • Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure 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 can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
  • Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data disclosure and data transfer: Data subjects can request the surrender of personal data or the transfer of their data to another controller.

We may defer, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law.We may inform data subjects of 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.

For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

8.2 Legal protection

Data subjects have the right to enforce their data protection­legal claims through the courts or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for complaints by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC ).

European data protection supervisory authorities for complaints from data subjects - if and insofar as the General Data Protection Regulation (GDPR) is applicable - are organized as members of the European Data Protection Board (EDPB ). In some Member States in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany.

9 Use of the website

9.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can 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. In particular, cookies make it possible to recognize 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.

Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies - at least if and to the extent necessary.

For cookies that are used to measure success and reach or for advertising, a general objection ("opt-out") is possible for numerous 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).

9.2 Logging

We may log at least the following information for each access to our website and our other online presence, insofar as this information is transmitted to our digital infrastructure during such accesses:Date and time including time zone, IP address, access status (HTTP status code), operating­system including user­interface and version, browser including language and version, individual sub-page of our website accessed including amount of data­transferred, last website accessed in the same browser window (referer or referrer).

We log such information, which may also constitute personal data, in log files. The information is required to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.

9.3 Tracking pixels

We can integrate tracking pixels into 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 scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as log files.

10 Notifications and messages

We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.

10.1 Measuring success 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 can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

10.2 Consent and objection

You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation.We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.

You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.

10.3 Service providers for notifications and messages

We send notifications and messages with the help of specialized service providers.

We use in particular:

Mailchimp: Communication platform; Provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Data protection information: Privacy Policy (Intuit ) including "Country and Region-Specific Terms", "Frequently Asked Questions about Mailchimp Privacy", "Mailchimp and European Data Transfers", "Security", Cookie Policy, "Privacy Rights Requests", "Legal Notice"

11. social media

We are present on social media platforms and other online platforms in order to communicate with interested parties 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).

The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and insofar as the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly way.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook and have thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".

12. services of third parties

We use the services of specialized third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the IP addresses of users at least temporarily for technically compelling reasons.

For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

12.1 Digital infrastructure

We use the services of specialized third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

In particular, we use:

12.2 Audio and video conferencing

We use specialized audio and video conferencing services to communicate online.For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on your life situation, we recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences.

We use in particular:

12.3 Map material

We use third-party services to embed maps in our website.

We use in particular:

12.4 Digital audio and video content

We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:

12.5 E-Commerce

We operate e-commerce and use third-party services in order to successfully offer services, content or goods.

12.6 Payments

We use specialized service providers to process our customers' payments securely and reliably. For the processing of payments, the legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, also apply.

We use in particular:

 

12.7 Advertising

We use the option of displaying targeted advertising on third parties such as social media platforms and search engines for our activities and operations.

In particular, we would like to use such advertising 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 relevant - possibly also personal - data 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 whom we advertise and with whom you are registered as a user may be able to assign the use of our website to your profile there.

We use the following in particular:

13. extensions for the website

We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own server infrastructure.

We use in particular:

  • TinyPNG: Image optimization; Provider: Tinify BV (Netherlands); Data protection information: "Terms of Use".

 

14. Success and reach measurement

We try to determine how our online offering is used.In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the IP addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are generally shortened ("IP masking") in order to comply with the principle of data minimization through the corresponding pseudonymization.

Cookies may be used to measure success 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.In principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users.Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.

We use in particular:

15. Video surveillance

We use video surveillance to prevent criminal offenses and to preserve evidence in the event of criminal offenses as well as to exercise our domiciliary rights.If and insofar as the General Data Protection Regulation (GDPR) is applicable, these are overriding legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR.

We store recordings from our video surveillance for as long as they are required to preserve evidence.

We may save recordings due to legal obligations, to enforce our own legal claims and in the event of suspected criminal offenses and transmit them to competent authorities, in particular judicial or law enforcement authorities.

16. final provisions

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.

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