AVIS DE CONFIDENTIALITÉ
This privacy notice describes how we at CURADEN AG gather, save, and use information relating to individual users of this website. When you visit this website, you acknowledge and agree that information will be gathered and used as described in this privacy statement.
TABLE DES MATIÈRES
1 GENERAL INFORMATION AND CONTACT PERSONS
2 PROTECTION OF PERSONAL DATA
3 TYPE OF PERSONAL DATA COLLECTED
4 PURPOSE OF DATA PROCESSING BY CURADEN
5 TRANSFER OF PERSONAL DATA TO THIRD PARTIES
6 USE OF PERSONAL DATA FOR DIRECT MARKETING
7 ONLINE MARKETING AND WEB ANALYTICS SERVICES
8 USE OF SOCIAL MEDIA: SOCIAL MEDIA PLUGINS
9 CHILDREN AS WEBSITE USERS
10 STORAGE PERIOD
11 PLACE OF STORAGE AND INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
12 RIGHT TO INSPECTION, MODIFICATION AND DELETION OF YOUR PERSONAL DATA
13 CONTACT
Version of: May 29, 2018
1) INFORMATIONS GÉNÉRALES ET CONTACTS
It is very important to us to protect your privacy, so that CURADEN handles your personal data in a careful, trustworthy and respectful manner. We collect personal data in order to offer our esteemed customers better service and to constantly improve their experience on CURADEN’s websites, Online Shops and Apps. CURADEN always handles your personal data in compliance with the applicable data protection laws. This Privacy Notice will give you a clear overview of when and why CURADEN collects data about you when you use CURADEN’s websites, stores or Apps, and how CURADEN uses the data that you provide. We shall also describe the recipients to whom we transmit your data and what options and statutory rights you have for the processing of your personal data.
The data controller for this website is
Curaden AG, Mathias Riechsteiner, Amlehnstrasse 22, CH-6010 Kriens, Tel. +41 (0) 319 45 00, e-mail: gdpr@curaden.ch
If you have any questions about the processing of your data, you can contact our data protection officer directly, who is also available for requests for information, requests or complaints:
Curaden AG, Mathias Riechsteiner, Amlehnstrasse 22, CH-6010 Kriens, Tel. +41 (0) 319 45 00, e-mail: gdpr@curaden.ch
Due to the continued development of our website and new technologies, it may be necessary to adjust, supplement and/or change the Terms of Use of the website, the present Privacy Notice or the GTB of the Online Shop. Whenever you access or visit the website, the version of the website accessible at that time shall be the authoritative version. Please visit this page regularly to view the latest rules. We shall keep you informed of any substantial changes in this Privacy Notice by displaying a notice on our websites and/or mobile Apps as well as an updated version of the Privacy Notice. If you do not agree with the modified rules, please inform us of your objection by sending an e-mail to info@curaden.ch and delete your user profile, if you have created one, by the effective date of the changes. Without your cancellation, you user profile will continue to be displayed under the new rules even after the effective date of the changes.
In the event of any contradictions between this Privacy Notice and other applicable terms of business or contract clauses of CURADEN, the provisions of this Privacy Notice shall take priority.
By visiting the CURADEN website, you express your consent to information being collected and used in the manner described in this Privacy Notice.
2) LA PROTECTION DES DONNÉES PERSONNELLES
CURADEN uses data networks protected by the standard firewalls and password systems, among other things, to ensure the security and confidentiality of any personal data recorded. When handling your personal data, we take appropriate technical and organizational measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration or destruction.
For our CURADEN websites, we use encryption techniques (SSL or TLS encryption) for security reasons to protect your personal data and other confidential content. The lock icon and “https://” in the browser address box show you that the website is encrypted.
3) LE TYPE DE DONNÉES PERSONNELLES COLLECTÉES
The term “personal data” for the purposes of this Privacy Notice means information that can be used to identify you personally.
“Personal data processing” means any form of handling of your personal data, such as recording, using, storing, disclosing, transmitting or deleting such data.
CURADEN automatically records personal data, when you use and interact with our websites, Online Shops or Apps. Moreover, the personal data that you supply is recorded automatically or manually (e.g., during sign-up and creation of your user profile or customer account). The data entry forms show you what data items are collected.
3.1 LES DONNÉES QUI SONT ENREGISTRÉES AUTOMATIQUEMENT
When you use our websites, Online Shops or Apps, CURADEN records certain personal data even if you do not sign in or actively provide information.
Websites:
When you open a CURADEN website, your browser communicates data to us. The data is also stored in the log files of our system. Those data are not stored together with other personal data. The following data are recorded:
- which CURADEN websites are visited;
- the number of visits, as well as the date, time and duration of the visit;
- the source or reference of the site from which the user reached the website;
- Hardware and browser information (operating system, browser type and version, etc.);
- IP-address used;
The data are stored in log files for functional purposes of the website. In addition, we use the data to optimize the website and protect the security of our IT systems. No data are analyzed for marketing purposes in this context.
Such data are deleted as soon as they are no longer needed for the purpose for which they were collected. Data recorded for presentation of the website are deleted at the end of each session. Data stored in log files are generally deleted within one month, at the latest. Storage for a longer period is possible only if the users’ IP addresses are deleted or coded so that the requesting client can no longer be identified.
Recording the data for broadcasting of the website and storage of the data in log files are absolutely necessary in order to operate the website. The user therefore has no right to object.
Cookies:
To enable the use of various features, CURADEN and CURADEN partners use cookies. Cookies are small text files that are stored by your browser on your computer’s hard disk. Most of the cookies used by CURADEN are deleted from your hard disk at the end of each browser session (i.e., “sessions cookies”). Other cookies remain on your computer and enable CURADEN to recognize your computer the next time you visit (i.e., “persistent cookies”). Certain user information such as browser and location data are collected and processed. Persistent cookies are automatically deleted, too, after the period specified for the relevant cookie. Cookies facilitate your use of the CURADEN website and are used to make the CURADEN website attractive and easier to use. For example, cookies make it possible to welcome you with your user name, facilitate the completion of forms with your contact details, remember your language preferences or products in the shopping cart. The cookies of our partner companies, especially our advertising and social-media partners, can be used to collect product and shopping preferences for the purposes of various marketing activities (i.e., “targeting cookies”). Such cookies also provide information about the shopping behaviour of our visitors, so that we can provide you with an optimal shopping experience. Finally, cookies are used when you “like” or recommend CURADEN or CURADEN products in the context of social media networks.
Most browsers accept such cookies automatically. You can also configure your browser to block cookies. For further details, see the user instructions or help system of your browser.
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- Safari: https://support.apple.com/kb/PH21411?locale=de_DE&viewlocale=en_US
If you disable cookies, you may not be able to make full use of all the features of this website.
Location information:
In certain features of CURADEN websites, Online Shops or Apps, you can use location-specific services (e.g., tooth-brushing app/ preventionOne). In such cases, you will be informed in advance that your actual location will be tracked and processed. You can disable location determination in the hardware settings.
3.2 DONNÉES LORS DE L’INTERACTION AVEC CURADEN, LORS DE L’OUVERTURE D’UN COMPTE CLIENT ET POUR LE TRAITEMENT DES CONTRATS
CURADEN processes the personal data that you give us when you sign up with CURADEN, for example by registering or actively providing information. Registration is required in order to store certain content and services on our website and for the performance of a contract with you or for the performance of precontractual measures.
Information sources:
Most of the information that CURADEN records about you is personal data that you shared with us voluntarily, for example on our websites, in our Online Shops, on mobile Apps, at local businesses, etc. Other sources from which we obtain your personal data include:
- our POS systems (i.e., certain information about you may be recorded when you shop at our POS);
- other companies of the CURADEN Group; and
- third parties (e.g., credit agencies, law enforcement/supervisory authorities and companies providing commercially available databases etc.).
Contact:
For example, you give us personal data when you contact us by means of the CURADEN contact form or by e-mail. The data entry forms show you what data items are collected. Your personal data are processed by CURADEN for the sole purpose of answering your query or for any other purpose for which you sent the form and then stored for technical administration. After completion of the processing, your query or other contract form will be deleted, unless we are required by law to retain the data.
Customer account:
You have the option of setting up a customer account (e.g., for the Online Shop or preventionOne). For your convenience, CURADEN lets you use a “single sign-on” method for our websites (see item 4.1 below). If you have registered for a CURADEN account, you sign into all our platforms with the same sign-on data (Single-Sign-on).
The data entry forms show you what data items are collected. CURADEN’s forms ask for basic personal data, indicating which input fields are required and which are optional. The data that you enter when creating a customer account will be stored and used for the sole purpose of contract processing unless you expressly consent to more extensive use.
For example, the following information may be requested and processed:
Personal data
- First and last names
- Date of birth and age;
- Gender;
- Home address;
- Shopping habits;
- Information about purchasing power;
- Customer and shopping preferences;
- Delivery address;
- Billing address;
- Credit card and account information;
- Language preferences;
- Telephone number(s);
- E-mail address(es);
- Customer or member numbers;
- Information on subscription newsletters or other advertising;
- Consent to receive advertising;
- Online customer account information (e.g., account-opening date, user name or profile picture).
Data on customer’s activities
- Contract data (including the date of signature, type, contents; parties, effective period and value of the contract, and any claims asserted thereunder);
- Purchasing information (including the date, place and time of purchase; the nature, quantity and value of the purchased goods and services; shopping cart; discontinued purchase in shopping cart; payment method used; paying agent; shopping history);
- Customer service information (including product returns, complaints, warranty claims, delivery information);
- Session data concerning visits of our websites, mobile apps or offers on our Internet platforms, multimedia portals or social networks (including the duration and frequency of the visits, language and country settings, information and browsers and the computer operating system, Internet Protocol addresses, search words, and search results, evaluations given);
- Location-specific data when using mobile devices.
You can delete your customer account at any time using the delete feature or button in the customer account or by sending a message to the data controller (see item 1 above). Upon complete performance of the agreement or upon deletion of your customer account, the data are blocked and stored for the retention period required under commercial and tax law and then deleted at the end of the retention period, unless you have expressly authorized further use of your data or we reserved a legally permitted use of the data after informing you of such use.
Participation in raffles, prize drawings, or surveys, etc.:
If you would like to participate in raffles, prize drawings, or surveys, etc., CURADEN may ask you in some cases for further personal data, such as your postal address, in order to be able to send you the prize. The data entry forms show you what data items are collected and to what purpose. Personal data collected for raffles, prize drawings, or surveys are generally deleted as soon as the purpose of the action has been fulfilled.
4) FINALITÉ DU TRAITEMENT DES DONNÉES PAR CURADEN
Your personal data are used by CURADEN for the purposes described below.
4.1 “SINGLE SIGN-ON” DE CURADEN
The personal data that you give CURADEN when you first register are used for identification and authentication purposes for all our services. You can therefore use the same sign-on data no matter where you are or which device you are using. Thanks to the overall single sign-on, our systems are able to identify you regardless of your location. This means that you do not have to re-register when you want to use a new CURADEN web service or are travelling in another country.
4.2 FOURNITURE DE BIENS ET DE SERVICES PAR CURADEN
CURADEN uses your personal data to perform orders and contracts, including to send confirmations of orders and forwarding, delivery confirmations, and to make deliveries and invoicing.
In addition, your information is used to check your age to confirm that you have the minimum legal age, to ensure compliance with the minimum legal age requirements for online purchasing or other purposes related to the applicable data protection and/or distribution laws.
Moreover, your personal data may be used for organizing and carrying out customer service tasks, e.g., after you use the contact form to get in touch with CURADEN.
4.3 AMÉLIORATION DES PRODUITS ET SERVICES CURADEN
CURADEN uses your personal data to create a profile that helps us understand how CURADEN products and services are used so that we can develop more interesting and relevant products and services and tailor them to your needs.
4.4 SERVICES DE COMMUNICATION ET AUTRES PRODUITS OU SERVICES DEMANDÉS
CURADEN uses your personal data to prepare, manage and carry out customer communications by post or by electronic communications media.
Moreover, we use your information to prepare the requested products or services (e.g., e-mail newsletter, advertising campaigns, raffles, contests, participation in events (e.g., iTOP Events), etc.
4.5 FONCTION DE COMMENTAIRE
If you use the comment feature that may be available on certain CURADEN websites, your selected user name and the date and time of posting will be stored and displayed next to your comment on the website. We also log and store your IP address. The IP address is saved for tracking purposes in the event that third-party rights are infringed by a comment made or illegal content is posted. If a third party complains of content you have published and our examination confirms that it is unlawful, you will be contacted at the e-mail address you have specified. CURADEN deletes comments that are complained of as unlawful by third parties.
You can opt into following the replies to your comment or follow-up comments. To opt in, you will receive a confirmation e-mail to validate your e-mail address (Double Opt-In process). Your option to participate in ongoing comments can be revoked at any time with effect for the future. Further information about how to opt out will be provide in the confirmation e-mail or CURADEN website.
4.6 APPLICATIONS CURADEN
CURADEN provides several apps that let you upload and/or save certain information. Depending on the app, you may be asked for various personal details (e.g., your name, age, dental care information (frequency, duration, Bleeding Index data, etc.), location, etc.); the entry form will indicate which information is required to provide the service and which information is optional.
4.7 ACTIVITÉS ET ÉVÉNEMENTS MARKETING
In addition, in line with applicable law and where appropriate, CURADEN may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:
- sending of advertising, newsletters or advertising mailings as well as organizing and holding contests and prize drawings, including for the notification and publication of the winners on CURADEN websites, multimedia portals or social networks;
- Organizing and holding special occasions such as events and advertising events;
- To prevent unnecessary advertising thanks to the findings from the analysis of customer behaviour, for customized and individualized direct marketing;
- individualized and personal and/or anonymous and group-related identification, classification and analysis of current and potential customer needs and interests;
- individualized and personal and/or anonymous and group-related classification and analysis of customer behaviour and potential;
- statistical analysis of customer behaviour based on anonymized customer data.
5) LE TRANSFERT DE DONNÉES PERSONNELLES À DES TIERS
For data processing and storage, CURADEN works together with other companies and individuals or enters into subcontracting agreements with companies or individuals. When companies perform services for CURADEN, we enter into written agreements with those companies to ensure that they cannot use your personal information for any purposes other than those that have been clearly specified or are required by law. CURADEN will transfer your data to third parties in the cases defined below.
5.1 CONDITIONS D’UTILISATION ET DE SÉCURITÉ
CURADEN will transfer your data to third parties:
- to ensure the protection and security of all CURADEN customers and of third parties (e.g., technical support service related to the CURADEN website);
- to protect the rights and property of CURADEN’s and of CURADEN’s customers and of third parties;
- to enforce the CURADEN Terms of Use that you have accepted or other applicable rules;
- to comply with legal obligations of disclosure imposed on CURADEN by law or in legal proceedings (orders issued by a court or by a law enforcement authority, etc.).
5.2 TRAITEMENT DES COMMANDES ET VÉRIFICATION DU CRÉDIT
Your data may be transferred by CURADEN:
- when companies perform services for CURADEN, e.g., parcel delivery, payment processing or customer service jobs, to the extent that the data transfer is necessary for the delivery of goods or services.
- Parcel shipment and delivery may be handled by forwarding agents such as the Swiss Post, DHL (Deutsche Post AG), DPD (DPD Deutschland GmbH), UPS (United Parcel Service Deutschland Inc. & Co), etc.
- If you give your express consent in the ordering process, your e-mail address may be communicated [to the forwarding agent] prior to product delivery so that you can agree on a delivery date or receive an announcement of delivery. Otherwise, the recipient’s name and delivery address will be given to the forwarding agent for delivery purposes but only to the extent necessary for product delivery. In that case, you will not be able to agree on the delivery date in advance with the forwarding agent or request delivery status information. You may revoke your authorization with effect for the future by addressing the data controller (see item 1 above).
- To the extent necessary for payment processing, your payment data may be forwarded to the credit institution engaged for payment processing. Such data shall be forwarded only to the extent necessary for payment processing.
- In the case of credit card payments, your payment data may be forwarded to the following payment solutions in the course of payment processing:
- Saferpay from SIX Payment Services Ltd, Hardturmstrasse 201, 8005 Zurich;
- Datatrans Ltd, Kreuzbühlstrasse 26, CH-8008 Zurich.
- In case of payment by PayPal, we give your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”) in the course of payment processing. For further information about the treatment of your personal data, see the PayPal Privacy Notice: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
- In the case of credit card payments, your payment data may be forwarded to the following payment solutions in the course of payment processing:
- In order to protect our legitimate interest in determining the solvency of our clients, and to prevent fraud and other abusive payment practices. In such cases, CURADEN and the credit institutions involved reserve the right to perform verifications or check credit ratings before payment transactions, particularly if CURADEN tenders performance in advance of payment (e.g., delivery with an invoice). To that purpose, internal and external sources of information may be used or forwarded to credit reporting agencies.
You may object to the processing of your data at any time by sending a message to the data controller or the credit institution, but CURADEN or the credit institution, where applicable, shall retain the right to process your personal data, to the extent necessary to process your payment according to the contract.
5.3 ANALYSE ET ACTIVITÉS DE MARKETING
CURADEN will transfer your data to third parties:
- in order to be able to send direct marketing with your consent or in our legitimate interests (see item 6 below);
- if you have not limited the use of cookies when opening the CURADEN website, CURADEN will use analytical tools and services of third parties to perform online marketing or web analytics (see item 7 below);
- if you ask CURADEN to forward your personal data to third-party websites or platforms, such as social networking websites. Please note that after the transmission of your personal data for marketing purposes to another company, the data received by the other company is subject to the data protection practices of that other company (see item 8 below).
6) L’UTILISATION DES DONNÉES PERSONNELLES POUR LE MARKETING DIRECT
6.1 INSCRIPTION À LA LETTRE D’INFORMATION ÉLECTRONIQUE
When entering your e-mail-address, you have the option of signing up for various e-mail newsletters (e.g., about products, product news, job vacancies, etc.) of CURADEN, in order to receive regular information about our offers or job vacancies. Providing further information, e.g., your first and last names, is optional and will be used so that we can address you personally.
The newsletters will not be sent to you until you have entered your e-mail address and clicked on the link in the confirmation e-mail that will be sent to you (Double Opt-in process). By clicking on the confirmation link, you inform CURADEN of your authorization to use your personal data. To keep a record of your consent, CURADEN stores your IP address and the date time of your consent.
Each e-mail Newsletter contains a link that lets you unsubscribe from the mailing list. Alternatively, you may contact the data protection officer (see item 1). Your personal data will then be deleted, unless further use of the data is permitted by law.
6.2 ENVOI DE LA LETTRE D’INFORMATION ÉLECTRONIQUE AUX CLIENTS EXISTANTS
CURADEN processes personal data of you and other persons, which may also come from publicly accessible sources, to the extent permitted and deemed appropriate to us, also for advertising and marketing purposes or for the purpose of customer acquisition in which we (and sometimes also third parties) have a justified interest corresponding to the purpose.
Hence, CURADEN is permitted by law to send you by post or e-mail regular offers for products or services from our range similar to the items you purchased, even without your explicit consent, if you provided your e-mail address to CURADEN when purchasing goods or services.
You are entitled, at any time with effect for the future, to prohibit your postal or e-mail address being used for the above-described marketing purpose by clicking on the link in the e-mail to remove yourself from the mailing list, or by sending a message to the data protection officer. Upon receipt of your objection, the use of your e-mail address for marketing purposes will be discontinued without delay.
6.3 ENVOI DE LA NEWSLETTER VIA MAILCHIMP
For the mailing of e-mail newsletter, CURADEN works with the technical service “MailChimp” of the company The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (http://www.mailchimp.com/), to which CURADEN forwards that data that you supplied to us when signing up for the newsletter. Please note that your data will generally be transmitted to a MailChimp server in the USA and stored there.
MailChimp uses that information for mailing and statistical analysis of newsletter by order of CURADEN. For analysis, the e-mails sent contain so-called “web-beacons” or “tracking pixels” (single-pixel image files), which are stored on our website. They let us know, for example, whether you opened a newsletter message and which links you clicked on. Technical information is recorded, too (e.g., time of opening, IP address, browser type and operating system). Such data are collected exclusively in pseudonymized format and not linked with your other personal data, so that it is impossible to determine your identity on that basis. Such data are used exclusively for statistical analysis of newsletter campaigns. The findings from those analyses can be used to better adapt future newsletters to the interests of the recipients.
Moreover, MailChimp itself may use such data for its own legitimate interests in need-based design and optimization of the service for market research purposes, in order to determine the home countries of the recipients, for example. MailChimp does not use the data of our newsletter recipients, however, to write to them directly or to forward the data to third parties.
If you object to the data analysis for statistical purposes, you have to unsubscribe from the newsletter.
To protect your data in the USA, CURADEN and MailChimp have entered into a data-processing agreement based on the standard contract clauses of the European Commission in order to enable the transmission of your personal data to MailChimp. Interested parties can view that data-processing agreement at the following address: http://mailchimp.com/legal/forms/data-processing-agreement/.
Moreover, MailChimp is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which require MailChimp to comply with the applicable data protection provisions. MailChimp’s privacy policy is posted at: https://mailchimp.com/legal/privacy/
7) SERVICES DE MARKETING EN LIGNE ET D’ANALYSE DU WEB
The anonymized data recorded in cookies when you open our website may be used for analytical purposes and to optimize our website in relation to third-party services. Such third parties themselves maybe thereby collect personal data about CURADEN users to a limited extent insofar as they can recognize them based on their own cookies or logins, for example.
CURADEN uses the following third-party services for Online Marketing and web analytics services:
- DoubleClick by Google;
- Google Analytics: https://support.google.com/analytics/answer/6004245?hl=de
- Matomo (formerly PIWIK): https://matomo.org/docs/privacy/
- Facebook Custom Audience (“Facebook-Pixel”): https://www.facebook.com/about/privacy/
Web Analytics tools provide statistics and graphics that give insights into use of our websites and our users’ browsing behaviour. In the process, the data about the use of a website is transmitted to the server used to that purpose. Such servers may be located abroad, depending on the provider of the online-marketing or web analytics Tools.
7.1 OUTILS GOOGLE
In the case of the tool Google Analytics used for web analytics, the recorded data are transferred, including truncated IP addresses, which prevents the identification of individual devices.
The online-marketing tool DoubleClick uses cookies in order to insert advertisements that are relevant to the user, to improve the reports on campaign performance or to prevent a given user from seeing the same advertisements several times. Google uses a cookie ID to record which advertisements are inserted in which browser in order to prevent displaying them several times. Moreover, DoubleClick can use cookie IDs to record “conversions”, which are related to ad requests. Such is the case, for example, when a user sees a DoubleClick advertisement and subsequently opens the advertiser’s website with the same browser and buys something there. According to Google, DoubleClick Cookies do not contain any personal information.
Because of the Google tools used, your browser automatically sets up a direct connection with the Google server. CURADEN has no control over the scope and further use of the data collected by Google using that tool.
Google complies with Swiss and EU data protection provisions and has registered with the US Department of Commerce for the “Swiss-U.S. Privacy Shield” and “EU-U.S. Privacy Shield” (for information about Privacy Shield, see https://www.privacyshield.gov). Any transfer of such data by Google to third parties will be made only to the extent permitted by statutory provisions or for the purposes of order processing.
If you wish to be excluded from the tracking actions of analytical services, you must adjust your browser settings to block the relevant cookies (see item 3.1: Adjusting the cookie settings on your browser). You can permanently disable advertising cookies by selecting the appropriate setting in your browser software or by downloading and installing the Browser-Plug-in available at the following link: http://www.google.com/settings/ads/plugin?hl=de
For further information about Google’s data protection, see the provider’s privacy policy at: https://www.google.de/intl/de/policies/privacy
7.2 ANALYSE WEB PAR MATOMO (ANCIENNEMENT PIWIK)
The Matomo software records the following information you when open individual pages of our website:
- two bytes of the IP address of the calling system of the user
- the called website
- the website from which the user reached the called website (Referrer)
- the subsites that were called from the called website
- the length of the visit to the website
- the frequency of calling the website.
In the process, the Matomo software is run exclusively on our website servers, so that user personal data is only stored there and not shared with third parties. The software is set up to mask two bytes of each IP address instead of storing the full address (e.g., 192.168.xxx.xxx). The truncated IP address can no longer be identified with the calling computer.
Any data no longer needed for the purposes of our record-keeping are deleted within one month, at the latest.
Cookies are stored on the user’s computer and sent to our website from it. Therefore, as a user, you have full control over the use of cookies since you can set your browser to block or limit their transmission (see item 3.1: Adjusting the cookie settings on your browser). You can manually delete the cookies stored on your computer at any time or set your browser to delete them automatically. If you disable cookies for our website, however, you might not be able to make full use of our website’s features.
7.3 OUTILS FACEBOOK (FACEBOOK AUDIENCE, FACEBOOK PIXEL)
Facebook Pixel is an analytics tool that measures the effectiveness of advertising on Facebook. It helps advertisers understand who is performing which actions on the website. If users grant their express consent, the tool can be used to track the user’s behaviour after viewing or clicking on a Facebook advertisement. This process is used to analyse the effectiveness of Facebook advertisements for statistical and market research purposes and thus help optimize future advertising campaigns.
The data collected are anonymous for CURADEN and therefore cannot be used to identify the user. The data are stored and processed by Facebook, however, so that the data may be linked with the relevant user profile and be used by Facebook for its own advertising purposes in accordance with Facebook’s data policy (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to insert advertisement on and outside of Facebook. A cookie may also be stored on your computer to that purpose. Such processing is not performed unless you grant your express consent.
Facebook Inc., which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
To disable the use of Cookies on your computer, you can adjust your browser’s settings to prevent future storage of cookies on your computer and/or to delete any cookies already stored. If you block all cookies, however, you may no longer be able to use certain features of our websites. You can also disable the use of cookies by third party providers such as Facebook on the following website of Digital Advertising Alliance: http://www.aboutads.info/choices/
8) L’UTILISATION DES MÉDIAS SOCIAUX : PLUGINS DE MÉDIAS SOCIAUX
8.1 PROCESSUS D'”AUTHENTIFICATION UNIQUE” AU MOYEN D’UN COMPTE DE MÉDIA SOCIAL
CURADEN lets you use your sign-in data of your user account on a social network (e.g., Facebook or Google+) to sign in and/or create a customer account. When social media plugins are used, the user’s personal data are shared with social network providers.
When you open a CURADEN website that contains such a plugin, your browser sets up a direct connection with the relevant social network’s servers. The content of the plugin will then be transmitted directly from the social network to your browser and integrated into the page you are viewing. Through integration of plugins, the social network will be informed that your browser has opened the corresponding page of our website, even if you do not have a profile with the social network in question or are not currently logged into it. Such information (including your IP address) is transmitted directly from your browser to one of the social network’s servers, where it is stored.
8.1.1 Facebook Connect
If you want to use your Facebook profile to log into the CURADEN website, the social plugin “Facebook Connect” lets you use the single sign-on process. The social plugin “Facebook Connect” is operated by the social network Facebook, of the company Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). You can recognize “Facebook Connect” social plugins by the blue button with the Facebook logo and the label “Log in with Facebook” or “Connect with Facebook” or “Sign in with Facebook”.
You can also click the “Facebook Connect” button on our website to log in or register with our website using your Facebook Connect user data.
When you click the “Facebook Connect” button on our website, in order for us to receive the general information in your Facebook profile and the data that you have made generally available by selecting “Public” in your Facebook privacy settings, you must first expressly consent to data sharing with Facebook by selecting the appropriate option before the log-in process. Such information includes your User ID, name, profile picture, age and gender.
Please note that according to amendments to the Facebook Privacy Notice and Terms of Use, if you grant your consent, your profile pictures, your friends’ user IDs and friend list may also be shared with us, if you have set those items to “public” in your Facebook privacy settings. The data shared by Facebook will be used by us to create a user account with the necessary data (title, first names, last name, address, country, e-mail address, date of birth), and then stored and processed, in case you have consented to the release of such information on Facebook. And, vice-versa, with your consent, we may share data (e.g., information about your browsing or shopping behaviour) with your Facebook profile.
You may revoke your consent at any time by sending a message to our data protection officer (see item 1).
Facebook Inc., which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
For more information about the purpose and scope of the data collected and the further processing and use of the data by Facebook, as well as your related rights and optional privacy settings, please see Facebook’s data policy at: http://www.facebook.com/policy.php
If you do not want Facebook to assign the data collected on our website directly to your Facebook profile, you need to log out from Facebook before visiting our website. You can also completely block the downloading of Facebook plugins with add-ons for your browser, e.g., by using “Adblock Plus” (https://adblockplus.org/de/).
8.1.2 Google+ Sign-In
If you want to log into the CURADEN website using your Google+ profile, the social plugin “Google+ Sign-in” lets you use the single sign-on process. The social plugin “Google+ Sign-In” is operated by the social network Google+, of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google+”). You can recognize the social plugins of “Google+ Sign-In” on our website by the red button with the Google+ logo and the label “Google Sign-In” or “Log in with Google”.
You can also click the “Google+” button on our website to log in or register with our website using your Google+ user data. When you click the “Google+” button on our website, in order for us to receive the information in your Google+ profile that you have made generally available in your Google+ privacy settings, you must first expressly consent to data sharing with Google+ by selecting the appropriate option before the log-in process. Such information includes your User ID, name, profile picture, age and gender.
Please note that according to amendments to the Google+ Privacy Notice and Terms of Use, if you grant your consent, your profile pictures, your friends’ user IDs and friend list may also be shared with us, if you have set those items to “public” in your Facebook privacy settings. The data shared by Google+ will be used by us to create a user account with the necessary data (title, first names, last name, address, country, e-mail address, date of birth), and then stored and processed, in case you have consented to the release of such information on Google+. And, vice-versa, with your consent, we may share data (e.g., information about your browsing or shopping behaviour) with your Google+ profile.
You may revoke your consent at any time by sending a message to our data protection officer (see item 1 above).
Google LLC, which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
For more information about the purpose and scope of the data collected and the further processing and use of the data by Google+, as well as your related rights and optional privacy settings, please see the Google+ privacy policy at: https://www.google.de/intl/de/policies/privacy/
You can view the Terms of Use for “Google+ Sign-In” here: https://www.google.de/intl/de/policies/terms/regional.html
8.2 UTILISER LES MÉDIAS SOCIAUX AU MOYEN DE “PLUGINS DE MÉDIAS SOCIAUX”.
CURADEN may use social media plugins on the website, e.g., from social networks such as Facebook, Google+, Twitter or Instagram. Those platforms have their own privacy policies, which are beyond CURADEN’s control.
To increase the protection of your data when you visit the CURADEN website, we have integrated two different mechanisms:
- DoubleClick solution (Facebook, Google+, Twitter)
The social network plugins are initially disabled and can be integrated into the site by means of a “2-Klick” solution. Disabled plugins, which are greyed out, are not able to set up a connection with the social network’s servers until you express your consent to data sharing by double-clicking them. At that point your browser will connect directly to the social platform’s servers. The content of the relevant plugin will then be transmitted directly from the social network to your browser and integrated into the site. The plugin will then share data (including your IP address) with the social network. CURADEN has no control over the scope of the data collected by the social network by means of the plugin. Through integration of plugins, the social network will be informed that your browser has opened the corresponding page of our website, even if you do not have a profile with the social network in question or are not currently logged into it. The collected information (including your IP address) is transmitted directly from your browser to one of the social network’s servers, where it is stored. When you interact with the plugins, the corresponding information will also be transmitted directly to one of the social network’s servers and stored there. That information will also be published on your social network profile and your contacts will be displayed there. - Shariff solution (LinkedIn, Instagram)
The buttons of the social networks LinkedIn and Instagram are integrated into the site using an HTML link. Such integration ensures that, when you open a page of our website that contains such buttons, no connection will be set up with the social network’s servers yet. When you click the button, a new browser window will be displayed and the page of the social network will be called where you can interact with its plugins (you may have to enter into your login data first).
You can revoke your consent at any time by clicking the enabled plugin again to disable it, or by logging out of the social network and closing the website. Such revocation will not affect the data already transmitted to the social network, however.
The social networks listed below have signed the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, certifying compliance with the data protection standards applicable in Switzerland and in the EU.
- Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA: http://www.facebook.com/policy.php
- Google+, Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA: https://www.google.com/intl/de/policies/privacy/
- Twitter, Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA: https://twitter.com/privacy
- Instagram, Instagram LLC., 1601 Willow Rd, Menlo Park, CA 94025, USA: https://help.instagram.com/155833707900388/
- LinkedIn, LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA: https://www.linkedin.com/legal/privacy-policy
8.3 UTILISER DES VIDÉOS YOUTUBE
CURADEN uses the YouTube embed function for display and playback of the videos from “YouTube”, which is owned by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
The extended data protection mode is used which, according to YouTube, does not begin storage of user information until playback of the video(s). Once the playback of an embedded YouTube video has been launched, YouTube uses cookies to collect information about the user’s behaviour. According to “YouTube”, such information is used to record video statistics, improve user-friendliness and prevent abusive practices If you are logged into Google, your data will be assigned directly to your account if you click on a video. If you do not want your data to be assigned to your YouTube profile, you need to log out before clicking the button. Google stores and analyses your data in the form of user profiles (even in the case of users who are not logged in). Such analysis is performed, in particular, based on Google’s legitimate interests in displaying personalized advertising, market research and/or need-based design of its website. You are entitled to object to the formation of this user profile, in which case you must exercise that right on YouTube.
Regardless of playback of the embedded videos, every time you open the website a connection is established with the Google network “DoubleClick”, which may trigger further data processing that is beyond our control.
Google LLC, which is based in the USA, is certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, which ensures compliance with the data protection standards applicable in Switzerland and in the EU.
For further information about YouTube’s data protection, see the provider’s privacy policy at:
https://www.google.de/intl/de/policies/privacy
9) LES ENFANTS EN TANT QU’UTILISATEURS DE SITES WEB
In general, we do not intentionally collect any personal data of children and teens under 16 years of age. If we learn that we unintentionally recorded private data of children and teens under the age of 16, we take steps to delete such information as soon as possible, unless we are required by the applicable laws to retain that information.
If we know that a child is over 16 years of age but is considered underage according to the applicable laws, then we seek to obtain the consent of the child’s parent or guardian before using the child’s personal data.
10) PÉRIODE DE STOCKAGE
CURADEN retains personal data only so long as necessary in order to comply with the applicable laws and to safeguard our rights (statutory retention period, e.g., retention periods under commercial or tax law) or so long as necessary for the purposes for which the data were collected.
In particular, CURADEN retains the personal data collected from customers in compliance with the periods indicated below and deletes such data thereafter, unless there are statutory retention duties or reasons not to delete the data related to operational record-keeping, or we have informed you in advance of different storage periods.
- Data collected at the time of purchase in the online shop will generally be stored for a 10-year period after the last process operation for bookkeeping reasons;
- Data for marketing measures and advertising purposes are to be derived from the principle of whether the storage is necessary for the advertising address. Normally, data is deleted at the latest two years after no longer being used for advertising purposes.
- Data from correspondence, for example using the contact form, will be retained for six weeks after the last processing operation and then deleted;
- Data from applicants will be deleted after six months in case of a rejection. If the applicant consents to further storage of his or her personal data, the data will be stored on our systems and deleted within two years at the latest. If the applicant is hired, the data are transferred to an employee information system.
- Personal data collected by CURADEN for web analytics are deleted as soon as they are no longer needed or in any case by the end of the statutory maximal retention period, at the latest. In general, such data are deleted one month after entry.
- Data recorded for preparation of the website are deleted at the end of the relevant session. Data stored in log files are deleted within one month, at the latest.
11) LIEU DE STOCKAGE ET TRANSFERTS INTERNATIONAUX DE VOS DONNÉES PERSONNELLES
CURADEN stores and processes your personal data in Switzerland.
There may also be cases, however, in which CURADEN must transfer your personal data within the European Union (EU), where there is an appropriate standard of data protection, or outside the European Economic Area (“EEA”) to a country that does not ensure the same standard of data protection as the country in which our products and/or services are generally used. If the personal data that you provide during registration of a CURADEN account or when interacting with the CURADEN website is processed outside the European Union or EEA, we shall take reasonable steps to ensure adequate protection for your personal data.
If the standard of data protection in a country is not guaranteed by an adequacy resolution, we shall enter into a contract ensuring that the protection of your personal data will be equivalent to that in Switzerland at all times. To do so, we shall take one or more of the following measures:
- by entering into EU Model Clauses with the service providers engaged, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
- by ensuring that the service providers engaged are certified under the Swiss-US or EU-US Privacy Shield Frameworks (if the data recipient is based in the USA or stores the data there), cf. https://www.privacyshield.gov/
- by ensuring that the service providers engaged have Binding Corporate Rules (BCR) acknowledged by European data protection authorities, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en.
12) DROIT D’INSPECTION, DE MODIFICATION ET DE SUPPRESSION DE VOS DONNÉES PERSONNELLES
CURADEN has implemented mechanisms to ensure that you can exercise your legal rights concerning your personal data.
Once the data controller (see item 1 above) has received your request and sufficient information to confirm your identity, we shall provide you with a copy of your personal data available to us for which you have a legal right of access. Moreover, we shall inform you of the purposes for which your personal data are used, of the recipient of your personal data and the source of the information.
You may contact CURADEN in writing at any time to request changes in certain personal data that you consider erroneous or insignificant, or ask us to block, delete or otherwise remove your personal data to the extent permitted by the applicable law. We shall update, block, delete or remove your personal data as required by law.
Moreover, you have the option of revoking your consent that you previously granted to CURADEN for marketing activities and marketing communications. Marketing communications contain a simple mechanism of unsubscribing from future communications, such as a hyperlink that you can click to unsubscribe. You can unsubscribe by following the instructions in the relevant communication that you have received on a certain channel or by using the settings of your CURADEN customer account. Alternatively, you can contact us directly using the contact information stated below.
Please note, that even after receiving your request to block or delete your personal data, we may be required to retain some of your personal data for the purposes of our statutory or contractual recordkeeping obligations (e.g., for invoicing purposes) in which case we shall only block your personal data to the extent necessary to that purpose. Moreover, deletion of your personal data may have the effect that you can no longer receive or use the services for which you have signed up. Under certain conditions, you may be entitled to require us to transfer your personal data in a commonly used format to you or to a designated third party.
13) CONTACT
If you have questions about this policy, please send a letter to Curaden AG, Amlehnstrasse 22, CH-6010 Kriens, Tel. +41 (0) 319 45 00 or an e-mail to info@curaden.ch.
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