Privacy Policy

Version: v2.0.0

With this Privacy Policy we inform which personal data we process in connection with our activities and activities including our 2media.ch website. In particular, we provide information on what personal data we process, for what purpose, how and where. We also provide information about the rights of persons whose data we process.

Individual or additional activities and operations may be subject to further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation.

We are subject to Swiss data protection law as well as any exceptionally applicable foreign data protection law, such as 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:

2media GmbH
Hagenholzstrasse 81a
8050 Zürich
Switzerland

datenschutz@2media.ch

We point out if there are other responsible parties for the processing of personal data in individual cases.

Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 DSGVO. The data protection representation serves supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries relating to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

2. Terms and Legal Bases

2.1 Terms

Personal data is all information that relates to an identified or identifiable individual. A data subject is a person about whom personal data is processed.

Processing includes any handling of personal data, regardless of the means and procedures used, in particular the retention, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.

The European Economic Area (EEA) includes the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to 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, such as in particular the Federal Data Protection Act (DSG) and the Ordinance to the Federal Data Protection Act (DSV).

We process - if and to the extent that the General Data Protection Regulation (GDPR) is exceptionally applicable - personal data in accordance with at least one of the following legal bases:

  • Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in being able to carry out and communicate about our activities and operations in a sustainable, user-friendly, secure and reliable manner, ensuring information security, protecting against misuse, enforcing our own legal claims and complying with Swiss law.
  • Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with 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. c DSGVO. Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.

3. Nature, scope and purpose

We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. In particular, 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 period that is required for the respective purpose(s) or by law. Personal data whose processing is no longer required will be anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also ensure data protection with such third parties.

We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the fulfillment of a contract with the data subject and for corresponding pre-contractual measures, in order to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example, by letter, e-mail, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obligated to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of this personal data.

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, insofar as and to the extent that such processing is permitted for legal reasons.

4. Applications

We process personal data about applicants to the extent that it is required for assessing 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 also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, resumes and other application documents as well as online profiles.

We process - if and to the extent that the General Data Protection Regulation (GDPR) is applicable by way of exception - personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b GDPR.

5. Personal data abroad

We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer Personal Data to other countries, in particular to process it or have it processed there.

We may export Personal Data to all states and territories on Earth as well as elsewhere in the universe, provided that the law there is compliant according to the assessment of the Federal Data Protection and Information Commissioner (FDPIC) or in accordance with Decision of the Swiss Federal Council, and - if and to the extent that the General Data Protection Regulation (GDPR) is exceptionally applicable - in accordance with Decision of the European Commission.

We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements for this are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance 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.

6. Rights of data subjects

Data subjects about whom we process personal data have rights under Swiss data protection law. These include the right to information as well as the right to rectification, deletion or blocking of the personal data processed.

Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is exceptionally applicable - request confirmation free of charge as to whether we are processing personal data relating to them. In this case, data subjects may request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.

Data subjects whose personal data we process may - if and insofar as the GDPR applies by way of exception - revoke consent given at any time with effect for the future and object to the processing of their personal data at any time.

Data subjects about whom we process personal data have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Swiss Federal Data Protection and Information Commissioner (FDPIC).

7. Data security

We take appropriate technical and organizational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.

Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

Our digital communication is subject - like basically any digital communication - to mass surveillance without cause or suspicion and other monitoring 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 agencies and other security authorities.

8. Use of the website

8.1 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 enable us 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 - at least if and to the extent necessary - explicit consent to the use of cookies.

For cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via the 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).

8.2 Server log files

We may record the following information for each access to our website, provided that this information is transmitted to our server infrastructure by your browser or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

9. Notifications and messages

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

9.1 Performance and reach measurement

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 may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.

9.2 Consent and objection

You must basically expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure where possible, i.e. you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.

You may in principle 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 performance and reach measurement. This is subject to necessary notifications and communications in connection with our activities and operations.

9.3 Service providers for notifications and communications

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

We use in particular:

10. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested persons as well as to inform them 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).

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. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

For our Social Media presence on Facebook including the so-called Page Insights, we are - if and insofar as the General Data Protection Regulation (GDPR) is exceptionally applicable - jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (among others in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to be able to provide our social media presence on Facebook in an effective and user-friendly manner.

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

11. Third Party Services

We use services of specialized third parties in order to be able to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed features and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of users at least temporarily for technically compelling reasons.

For necessary security-related, 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:

11.1 Digital infrastructure

We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

11.2 Contact options

We use services from selected providers to better communicate with third parties such as potential as well as existing customers.

In particular, we use:

11.3 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:

11.4 Fonts

We use third-party services to embed selected fonts as well as icons, logos and symbols on our website.

We use in particular:

11.5 E-Commerce

We engage in e-commerce and use third party services to successfully provide services, content or merchandise.

In particular, we use:

11.6 Advertising

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

We would like to use such advertising in particular 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 corresponding - possibly also personal - information 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 where you are logged in as a user may be able to associate the use of our online offer with your profile there.

We use in particular:

12. Participation in Affiliate Programs

We participate in affiliate programs. On the one hand, we may be compensated for referring or linking to third party offers. On the other hand, we may compensate third parties for referring to our activities and operations or linking to our online offer (affiliate marketing). In this context, it may be recorded - also on a personal basis - in each case which offers are taken up and which web links are followed.

We participate in particular in:

13. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

In particular, we use:

  • Google reCAPTCHA: spam protection (distinguishing between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA specific details: "What is reCAPTCHA?".

14. Performance and Reach Measurement

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

When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymization and thus to improve user data protection.

When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. As a matter of principle, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.

We use in particular:

  • Google Analytics: Performance and reach measurement; provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (Cross-Device Tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy Policy", "Browser Add-on to disable Google Analytics".
  • Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: "Data collected with Google Tag Manager"; further information on data protection can be found at the individual integrated and managed services.

15. Final Provisions

We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.