R&S International Holding AG
Phone: +41 61 976 34 66
Fax: +41 61 976 34 22
Data Protection Officer:
Group Project Manager Finance
Type of Processed Data:
• Inventory Data (e.g., customer master data, names, addresses).
• Contact details (e.g., e-mail, phone numbers).
• Content Data (e.g., text input, photographs, videos).
• Contract Data (e.g., subject matter of the contract, duration).
• Payment Data (e.g., bank details, payment history).
• Usage Data (e.g., interests, websites visited, access times).
• Meta/communication Data (e.g., device IDs, IP addresses).
Categories of Data Subjects (hereinafter referred to as “users”)
• Customers / prospective customers / business partners.
• Visitors and users of the online service.
Purpose of Processing
• Provision of the online services, its functions and contents.
• Provision of contractual services, service and customer care.
• Response to contact requests and communication with users.
• Security measures.
• Marketing, advertising and market research.
Last updated: January 2020
1. Terms Used
1.1. “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.3. “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
1.4. “Profiling” means any automated processing of personal data consisting in the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people) (e.g. interests in certain contents or products, click behaviour on a website or the location). Cookies and web beacons are often used for profiling purposes.
1.5. “Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person; e.g. if an exact interest profile of the computer user is stored in a cookie (a “marketing avatar”), but not the name of the user, then data is processed pseudonymously. If his name is stored, e.g. as part of his e-mail address or his IP address is stored, then the processing is no longer pseudonymous.
1.6. “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
2. Relevant Legal Basis for the Processing
2.2. In addition, the provisions of Swiss data protection law shall apply, subject to mandatory data protection regulations to which the user may refer, in particular on the basis of the national data protection law protecting the user.
3. Security of Data Processing
3.1. We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
3.2. The measures include the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, integrity and pseudonymity. Furthermore, we have established procedures that guarantee the assertion of data subjects’ rights, the erasure of data and the response to data hazards. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design of technology and by data protection-friendly presettings. The security measures include in particular the encrypted transmission of data between your browser and our server.
4. Disclosure and Transmission of Data
4.1. If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transfer the data to them or otherwise grant them access to the data, this will only be carried out on the basis of a legal permission (e.g. if a transfer of the data to third parties is required for contract fulfilment, if you have consented, if a legal obligation requires this or on the basis of our legitimate interests (e.g. when using agents, web hosting services, etc.).
4.2. If we disclose, transfer or otherwise grant access to data to other companies in our group (undertakings), this is done in particular for administrative purposes as a legitimate interest and in addition on the basis of a Data Processing Agreement.
5. Transfers to Third Countries
5.1. If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA) or Switzerland) or if this occurs in the context of the use of third-party services or disclosure or transmission of data to third parties, this only takes place if it is necessary to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or let the data being processed in a third country only if the legal requirements are met. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised adequate data protection level (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations.
6. Rights of Data Subjects
6.1. You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and a copy of the data in accordance with the law.
6.2. You have correspondingly in accordance with the law, the right to obtain from the controller the rectification of inaccurate personal data concerning you, or the completion of the data concerning you.
6.3. In accordance with the law, you have the right to demand that relevant data be erased without undue delay or, alternatively, to demand a restriction of the processing of the data in accordance with the law.
6.4. You have in accordance with the law the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
6.5. In accordance with the law, you also have the right to file a complaint with a supervisory authority.
6.6. You have the right to withdraw consents granted with effect for the future.
6.7. You can object to the future processing of the data concerning you in accordance with the law at any time. The objection may be lodged in particular against processing for direct marketing purposes.
7. Cookies and Right to Object in Direct Marketing
7.1. „Cookies” are small files that are stored on the user’s computer. Within the cookies different data can be stored. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. Likewise, the interests of users used for web analytics or marketing purposes may be stored in such a cookie. “Third-party cookies” are cookies that are served by providers other than the Controller for operating the online services (otherwise, if they are only the Controller’s cookies, they are referred to as “first-party cookies”).
7.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online services.
8. Erasure of data
8.2. If the data are not erased because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is excluded and not processed for other purposes. This applies, for example, to data that must be retained for commercial or taxation reasons.
9. Contractual services, e-products, events and exhibitions
9.1. We process the data of our contractual partners and prospective customers (uniformly referred to as “contractual partners”) within the scope of our contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.
9.2. The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
9.3. We do not process special categories of personal data, unless these are part of a commissioned or contractual processing.
9.4. We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure, unless this is evident for the contractual partners. Disclosure to external persons or companies is only made if it is required within the framework of a contract. When processing the data provided to us within the scope of an assignment, we act in accordance with the instructions of the contractual partners and the legal requirements.
9.5. When using our online services, we may store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as the users’ interests in the protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary to pursue our claims or there is a legal obligation to do so.
9.6. The data will be deleted if the data is no longer required for the fulfilment of contractual or statutory duties of care or for the handling of any warranty or comparable obligations; in all other respects, the statutory archiving obligations apply.
10. Administration, Financial Accounting, Office Organization, Contact Management
10.1. Based on our legitimate interests we process data in the course of administrative tasks as well as the organisation of our company, financial accounting and compliance with legal obligations, e.g. archiving. We process the same data that we process as part of the performance of our contractual services. Data subjects are affected by the processing: customers, interested parties, business partners and website visitors. The purpose of the processing is the administration, financial accounting, office organization, archiving of data that serve the maintenance of our company and our services.
10.2. We disclose or transmit data to the tax authorities, tax consultants, auditors, other fee offices, legal advisors and payment service providers.
10.3. Furthermore, we store information on business partners, customers and prospects on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.
11. Economic Analyses and Market research
11.1. In order to operate our business economically and to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, inquiries, etc., in order to ensure that we are able to offer our customers the best possible service. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of our legitimate interests, whereby the persons concerned include customers, prospective customers, business partners, visitors and users of our Online Services, exhibition and events.
11.2. The analyses are carried out for the purpose of economic evaluations, marketing and market research. The analyses serve us to increase the user-friendliness, the optimization of our offer and the economic efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.
11.3. If these analyses or profiles are personal, they will be deleted or made anonymous upon cancellation of the contractual relationship. For the rest, macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
12. Contact and Customer Service
12.1. When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details for processing the contact enquiry and its handling within the framework of contractual/pre-contractual relationships with customers or, in the case of non-customers, on the basis of our legitimate interests in responding to the enquiries will be processed. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.
12.2. We delete the requests if they are no longer necessary and the statutory archiving obligations do not require any storage.
13.1. With the following information we inform you about the contents of our newsletter as well as the registration, sending and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to its reception and the described procedures.
13.2. We will only send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “Newsletter”) with the consent of the recipients or a legal permission. If the contents of a Newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information on the latest company news, reference projects, industry trends and our products and services.
13.3. The registration for our Newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. Subscriptions to the Newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.
13.4. To subscribe to the Newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name in the Newsletter in order to address us personally.
13.5. The sending of the Newsletters and the performance measurement associated with it are based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing.
13.6. The registration procedure is logged on the basis of our legitimate interests. We are interested in the use of a user-friendly and secure Newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.
13.7. Users can cancel the receipt of our Newsletter at any time, i.e. revoke their consent. You will find a link to cancel the Newsletter at the end of each Newsletter. We may store the unsubscribed e-mail addresses on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for erasure is possible at any time, provided that at the same time the former existence of a consent is confirmed.
14. Newsletter – Mailing Service Provider
14.2. The Mailing Service Provider can use the recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the sending and presentation of the Newsletter or for statistical purposes. However, the Mailing Service Provider service does not use the data of our Newsletter recipients to contact them itself or to pass the data on to third parties.
15. Newsletter – Performance Measurement
15.1. The Newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is downloaded from our server when the Newsletter is opened or, if we use a Mailing Service Provider, from its server. Within the scope of this request, technical information, such as information about the browser and your system, as well as your IP address and time of request are initially collected.
15.2. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their access location (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the Newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual Newsletter recipients. However, it is neither our endeavour, nor, if used, that of the Mailing Service Provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
15.3. A separate revocation of the performance measurement is unfortunately not possible, in this case the entire Newsletter subscription must be cancelled.
16. Hosting and E-mail Service
16.1. The hosting services we use are provided for the following purposes: infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating our Online Services.
16.2. We and our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, prospective customers and visitors of our Online Services on the basis of our legitimate interests in an efficient and secure provision of our Online Services.
17. Collection of Access Data and Log Files
17.1. We, or our hosting provider, collect data about each access to the server on which our Online Services are located (so-called “server log files”) on the basis of our legitimate interests. Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
17.2. Log file information is stored for a maximum of 14 days for security reasons (e.g. to investigate misuse or fraud) and then deleted or made anonymous. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
18. Google Analytics
18.2. Google is certified under the Privacy Shield framework which offers a guarantee of compliance with European and Swiss data protection legislation.
18.3. Google will use this information on our behalf for the purpose of evaluating use of our Websites by the User, compiling reports on activity on the Websites, and providing us with other services relating to the use of the Websites and use of the Internet. This process may involve creating pseudonymized usage profiles of Users from the processed data.
18.4. We only use Google Analytics with IP anonymization enabled. That means Google truncates the User’s IP address within Member States of the European Union and in other countries that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.
18.5. The IP address transmitted by the User’s browser is not associated with any other data held by Google. Users can prevent cookies from being installed on their computer by adjusting their browser settings accordingly. Users can also prevent Google from collecting data generated by cookies concerning their use of the Websites and can prevent Google from processing this data by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
18.6. Further information on Google’s use of data, your settings options and your opt-out options can be found on Google’s websites: https://policies.google.com/technologies/partner-sites (“How Google uses information from sites or apps that use our services”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”),Opt-out: https://adssettings.google.com/authenticated (“Manage the information used by Google to display advertising to you”).
18.7. Personal data will be made anonymous or deleted after a period of 14 months.
19. Social Media Presences
19.1. We maintain online presences within social networks and platforms in order to communicate with the customers, prospective customers and users active there and to be able to inform them about our services there.
19.2. We would like to point out that data of users outside the European Union and the Switzerland may be processed. This can pose risks for users because, for example, the enforcement of users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they undertake to comply with the data protection standards of the EU and Switzerland.
19.3. Furthermore, user data is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created from the user behaviour and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these).
19.4. The processing of users’ personal data is based on our legitimate interests in effective user information and communication with users. If the users are asked by the respective providers for a consent to the data processing (i.e. declare their consent e.g. by ticking a checkbox or confirming a button), the legal basis of the processing is a consent.
19.5. For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the information provided by the providers linked below. Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, then please contact us.
20. Integration of Third-Party Services and Content
20.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our Online Services), we use content or other services from third parties within our Online Services in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “Content”).
20.2. This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the Content to their browser. The IP address is therefore required for the display of this Content. We make every effort to use only Content whose respective providers use the IP address only for the delivery of the Content. Third-party providers may also use so-called “pixel tags” (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Web beacons can be used to evaluate information such as visitor traffic on the pages of our Online Services. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our Online Services, as well as be linked to such information from other sources.
22.1. Within our online services, functions and contents of the Twitter platform, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter as well as tracking and analytics functions.
23.1. Within our Online Services, functions and contents of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, can be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this Online Services within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the usage of contents and functions mentioned above to the profiles of the users there.