This Privacy Policy provides information on what personal data we process in connection with our activities and operations, including our www.globalstrategic.ch website. In particular, we provide information about what personal data we process, for what purpose, how and where. We also provide information about the rights of persons whose data we process.
For individual or additional activities and operations, further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
We are subject to Swiss data protection law as well as any 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 recognises that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
Daniel Brühwiler
Seefeldstrasse 287
CH-8008 Zurich
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
2.1 Terms
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, for example, the retrieval, comparison, adaptation, archiving, storage, reading out, disclosure, procurement, recording, collection, deletion, disclosure, ordering, organising, storage, modification, dissemination, linking, destruction and use of personal data.
The processing includes any handling of personal data, regardless of the means and procedures used.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) and 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 (Data Protection Act, DPA) and the Data Protection Ordinance (Data Protection Ordinance, DPA).
We process – if and insofar as the General Data Protection Regulation (GDPR) is 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 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, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance 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. 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. Such personal data may in particular 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 that is necessary for us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner.
We process personal data for the period necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary will be anonymised or deleted.
We may process personal data for the period of time necessary for the purpose(s) in question or required by law.
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, specialised providers whose services we use. We also guarantee data protection for such third parties.
We process personal data jointly with third parties.
We process personal data as a matter of principle only with the consent of the persons concerned. If and to the extent that the processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process personal data only with consent.
In this context, we process in particular information that a data subject provides to us voluntarily when contacting us – for example by letter post, email, 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 obliged to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of this personal data.
We also process data about other persons on a voluntary basis.
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. Personal data abroad
We process personal data in principle in Switzerland and 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 process personal data abroad.
We may export personal data to all states and territories on Earth and elsewhere in the universe, provided that the law there is in accordance with decision of the Swiss Federal Council provides for adequate data protection and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to Decision of the European Commission ensures adequate data protection.
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. Exceptionally, we may export personal data to countries without adequate or appropriate 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 performance of a contract. We will be happy to provide data subjects with information about any guarantees on request or provide a copy of any guarantees.
5. Rights of data subjects
5.1 Data protection rights
We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what that personal data is. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, 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 have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data surrender and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can draw the attention of data subjects to 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. We may also, for example, refuse to delete personal data in whole or in part with reference to legal obligations to retain data.
We may provide for costs for the exercise of rights exceptionally. We inform data subjects in advance of any costs.
We are obligated to provide information to data subjects.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
5.2 Right to complain
Data subjects have the right to enforce their data protection rights through legal channels or to lodge a complaint with a competent data protection supervisory authority
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – the right to lodge a complaint with a competent European data protection supervisory authority.
6. Data security
We take appropriate technical and organisational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject to – as basically any digital communication – mass surveillance without cause and suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot have any direct influence on the corresponding processing of personal data by secret services, police agencies and other security authorities.
7. Use of the website
7.1 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. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, 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 – your express consent to the use of cookies.
For cookies that are not stored on your computer, we ask for your consent.
For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is available for many 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).
7.2 Server logfiles
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: 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 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 for each access to our website.
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website in a permanent, user-friendly and reliable manner 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.
We store such information, which may also represent personal data, in server log files.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.
8. Notifications and communications
We send notifications and communications by email and through other communication channels such as instant messaging or SMS.
8.1 Performance and reach measurement
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 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.
8.2 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 unauthorised third parties can take place. We may log such consents including IP address as well as date and time for evidentiary and security reasons.
You can 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 use for performance and reach measurement. This is without prejudice to necessary notifications and communications in connection with our activities and operations.
8.3 Notifications and communications service providers
We send notifications and communications with the help of specialised service providers.
9. Social media
We have a presence on social media platforms and other online platforms to communicate with interested individuals and to 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).
In each case, the data protection laws also apply.
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.
10. Third-party services
We use the services of specialised third parties in order 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 at least temporarily collect the IP addresses of the users for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Services of Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and Security Principles”, privacy policy, “Google is committed to complying with applicable privacy laws”, “Privacy Guide for Google Products”, “How we use information from websites or apps where our services are used” (provided by Google), “Cookie types and other technologies used by Google”, “Personalised advertising” (enable/disable/settings).
- Services provided by Microsoft: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Privacy at Microsoft”, “Data protection and privacy (Trust Center)”, privacy statement, privacy dashboard (data and privacy settings).
10.1 Digital infrastructure
We use services from specialised third parties to access required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers
We use in particular:
- Cyon: hosting; provider: cyon GmbH (Switzerland); data protection information: “Data protection”, Data protection declaration.
10.2 Contact options
We use services from selected providers to better communicate with third parties such as potential as well as existing customers.
10.3 Social media functions and social media content
We use third party services and plugins to embed features and content from social media platforms, as well as to enable sharing of content on social media platforms and other means.
We use in particular:
- Facebook (social plugins): Embedding Facebook functions and Facebook content, for example “Like” or “Share”; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: Data protection declaration.
- LinkedIn Consumer Solutions Platform: Embedding features and content from LinkedIn, for example with plugins such as the “Share Plugin”; Provider: Microsoft; LinkedIn-specific details: “Privacy”, Privacy Policy, Cookie Policy, cookie management /objection to email and SMS communications from LinkedIn, objection to interest-based advertising.
- Twitter for websites: Integration of features and content from Twitter, for example embedded tweets or “follow” and “tweet” buttons; Twitter International Unlimited Company (Ireland) for users in the European Economic Area (EEA), the UK and Switzerland / X Corp. (USA) in the rest of the world; Privacy information: Privacy Policy, “Additional information on data processing”, “Privacy […] at Twitter for websites”, “Personalisation based on inferred identity”, “Privacy controls for personalised ads”.
10.4 Fonts
We use third party services to embed selected fonts, as well as icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific details: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”.
11. Extensions for the website
We use extensions for our website to enable us to use additional features.
12. Success-and-reach-measurement
We try to determine how our online offer is used. As part of this, we may, for example, measure the success and reach of our activities and operations and the impact of third party links to our website. But we can also, for example, try out and compare how different parts or versions of our online offer 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 basically shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymisation.
The measurement of success and reach may involve the use of cookies and the creation of user profiles. Any user profiles that are 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 pseudonymously and are not used to identify individual users. Individual services of third parties with which users are registered can, if necessary, allocate the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Matomo: performance and reach measurement; provider: Matomo (free open source software); data protection information: use on own server infrastructure and with pseudonymised IP addresses, “List of all Matomo Features”).
13. Final provisions
We have created this privacy policy using the Privacy Policy Generator from Privacy Partners.
We may amend and supplement this Privacy Policy 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.
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.