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Privacy Policy

With this Privacy Policy, we inform you about the personal data we process in connection with our activities and operations, including our website. We provide information about the purposes, methods, and locations of the processing of personal data. We also inform about the rights of individuals whose data we process.

For specific or additional activities and operations, additional privacy policies, as well as other legal documents such as Terms and Conditions (T&C), Usage Terms, or Participation Terms, may apply.

We are subject to Swiss data protection law as well as potentially applicable foreign data protection law, especially 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

Responsible for the processing of personal data:

Conda SA
Plaz 2
7524 Zuoz

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

1.1 Data Protection Officers or Advisors

We have the following data protection officer or advisor as a point of contact for affected individuals and authorities regarding inquiries related to data protection:

Davide Piccioli
Conda SA
Plaz 2
7524 Zuoz

1.2 Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation according to Article 27 GDPR:

VGS Datenschutz­partner GmbH
Am Kaiserkai 69
20457 Hamburg

The data protection representation serves as an additional point of contact for inquiries related to GDPR for individuals and authorities in the European Union (EU) and the rest of the European Economic Area (EEA).

2. Definitions and Legal Basis

2.1 Definitions

Personal data refers to any information relating to an identified or identifiable natural person. An affected person is an individual about whom we process personal data.

Processing encompasses any handling of personal data, regardless of the means and methods used, including querying, comparing, adapting, archiving, storing, extracting, disclosing, obtaining, capturing, collecting, deleting, revealing, organizing, storing, altering, distributing, linking, destroying, and using 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, including the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We process – to the extent the General Data Protection Regulation (GDPR) is applicable – personal data based on at least one of the following legal bases:

  • Article 6(1)(b) GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for pre-contractual measures.
  • Article 6(1)(f) GDPR for the necessary processing of personal data to safeguard the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject. Legitimate interests include, in particular, our interest in conducting our activities and operations permanently, user-friendly, safely, and reliably, as well as being able to communicate about them; ensuring information security, protection against abuse, enforcement of our legal claims, and compliance with Swiss law.
  • Article 6(1)(c) GDPR for the necessary processing of personal data for compliance with a legal obligation to which we are subject under potentially applicable laws of Member States in the European Economic Area (EEA).
  • Article 6(1)(e) GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Article 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
  • Article 6(1)(d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or of another natural person.

3. Type, Scope and Purpose

We process those personal data that are necessary to carry out our activities and operations permanently, user-friendly, safely, and reliably. Such personal data may fall into categories including inventory and contact data, browser and device data, content data, meta or marginal data, usage data, location data, sales data, as well as contract and payment data.

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

We may have personal data processed by third parties. We may process or transmit personal data jointly with third parties. Such third parties are typically specialized providers whose services we use. We ensure data protection even with these third parties.

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

In this context, we particularly process information that an affected person voluntarily submits to us when contacting us—such as through postal mail, email, instant messaging, contact forms, social media, or telephone—or when registering for a user account. We may store such information, for example, in an address book or using similar tools. When we receive data about other individuals, the transmitting individuals are obligated to ensure data protection for these individuals and to ensure the accuracy of this personal data.

Furthermore, we process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, provided such processing is legally permissible.

4. Personal Data Abroad

We process personal data primarily in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process or have them processed there.

We may export personal data to all countries and territories on Earth as well as elsewhere in the Universe, provided that the local law, according to the decision of the Swiss Federal Council, ensures adequate data protection, and, to the extent that the General Data Protection Regulation (GDPR) is applicable, according to the decision of the European Commission ensures adequate data protection.

We may transmit personal data to states where the law does not guarantee adequate data protection, provided that data protection is ensured for other reasons, particularly based on standard data protection clauses or other appropriate guarantees. In exceptional cases, we may export personal data to states without adequate or suitable data protection if the special data protection requirements are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.

5. Rights of Data Subjects

5.1 Data Protection Claims

We grant data subjects all claims under applicable data protection law. Data subjects have the following rights, in particular:

  • Information: Data subjects can request information about whether we process personal data about them and, if so, what personal data it is. Data subjects also receive information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data itself, but also information about the purpose of processing, the duration of storage, any disclosure or transfer of data to other countries, and the origin of the personal data, among other things.
  • Rectification and Restriction: Data subjects can correct incorrect personal data, complete incomplete data, and restrict the processing of their data.
  • Erasure and Objection: Data subjects can request the erasure of personal data (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data Disclosure and Data Transfer: Data subjects can request the disclosure of personal data or the transfer of their data to another responsible party.

We may defer, restrict, or refuse the exercise of data subjects’ rights within the legally permissible framework. We may inform data subjects of any conditions that must be fulfilled to exercise their data protection claims. For example, we may fully or partially refuse information on the basis of trade secrets or the protection of other individuals. We may also fully or partially refuse the erasure of personal data based on legal retention obligations, for example.

We may exceptionally charge for the exercise of rights. We will inform data subjects in advance of any potential costs.

We are obligated to identify data subjects who request information or exercise other rights with appropriate measures within the legally permissible framework. Data subjects are obliged to cooperate.

5.2 Right to Lodge a Complaint

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

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).

Data subjects have the right to lodge a complaint with a competent European data protection supervisory authority, to the extent that the General Data Protection Regulation (GDPR) is applicable.

6. Data Security

We implement appropriate technical and organizational measures to ensure data security that is appropriate to the respective risk. However, we cannot guarantee absolute data security.

Access to our website is via transport encryption (SSL / TLS, especially with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock icon in the address bar.

Our digital communication is subject to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries, as is generally the case with all digital communication. We have no direct influence on the processing of personal data by intelligence agencies, police authorities, and other security authorities.

7. Use of the Website

7.1 Cookies

We may use cookies. Cookies – both first-party cookies as well as third-party cookies from services we use – are data that is stored in the browser. Such stored data need not be limited to traditional text-based cookies.

Cookies can be stored in the browser temporarily as “session cookies” or for a specific period as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies allow, in particular, the recognition of a browser during the next visit to our website, thus measuring the reach of our website, for example. However, permanent cookies can also be used for online marketing.

Cookies can be disabled or deleted entirely or partially in the browser settings at any time. Our website may not be fully available without cookies. We kindly request, at least if and to the extent necessary, active consent for the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection (“opt-out”) for numerous services is possible through 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 Log Files

We may record the following information for each access to our website, provided that it is transmitted from your browser to our server infrastructure 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 the amount of data transmitted, and the last website 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, in a user-friendly and reliable manner, and to ensure data security and, in particular, the protection of personal data—also by third parties or with the help of third parties.

7.3 Tracking Pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. With tracking pixels – including those from third parties whose services we use – small, usually invisible images that are automatically retrieved when visiting our website. Tracking pixels can capture the same information as in server log files.

8. Notifications and Communications

We send notifications and communications via email and other communication channels such as instant messaging or SMS.

8.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual notification was opened and which web links were clicked. Such web links and tracking pixels can also capture the usage of notifications and communications on a personal level. We require this statistical tracking of usage for success and reach measurement, in order to effectively and user-friendly deliver notifications and communications based on the needs and reading habits of the recipients, while ensuring their long-term, secure, and reliable transmission.

8.2 Consent and Objection

You must generally provide explicit consent for the use of your email address and other contact addresses, unless the use is permissible for other legal reasons. We use the “Double Opt-in” procedure whenever possible for obtaining consent, meaning you receive an email with a link that you need to click to confirm, in order to prevent misuse by unauthorized third parties. We may log such consents, including Internet Protocol (IP) addresses as well as the date and time, for evidential and security reasons.

You can generally object to receiving notifications and communications, such as newsletters, at any time. By objecting, you can also object to the statistical tracking of usage for success and reach measurement. Necessary notifications and communications related to our activities and operations remain unaffected.

9. Social Media

We have a presence on social media platforms and other online platforms in order to communicate with interested individuals and provide information about our activities and operations. In connection with such platforms, personal data may be processed outside of Switzerland and the European Economic Area (EEA).

The terms and conditions (T&Cs) and usage conditions as well as privacy policies and other provisions of each operator of such platforms also apply. These provisions particularly inform data subjects directly about their rights vis-à-vis the respective platform, including the right to information.

For our Social Media presence on Facebook, including so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland) to the extent that the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly provide our Social Media presence on Facebook.

Further information about the nature, scope, and purpose of data processing, information about the rights of data subjects, as well as contact details for Facebook and Facebook’s Data Protection Officer can be found in the Facebook Privacy Policy. We have concluded the so-called “Controller Addendum” with Facebook, and thereby agreed that Facebook is responsible for ensuring the rights of data subjects. The corresponding information for Page Insights can be found on the “Information about Page Insights” page, including “Information about Page Insights Data”.

10. Third-Party Services

We use services from specialized third parties to conduct our activities and operations permanently, in a user-friendly, secure, and reliable manner. With such services, we can embed functions and content into our website. For such embedding, the used services, for technical reasons, temporarily collect at least the Internet Protocol (IP) addresses of users.

For necessary security, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. These may include performance or usage data in order to provide the respective service.

We particularly use:

10.1 Digital Infrastructure

We utilize services from specialized third parties to access the necessary digital infrastructure in connection with our activities and operations. This includes services such as hosting and storage services from selected providers.

We specifically use:

10.2 Social Media Functions and Content

We use services and plugins from third parties to embed features and content from social media platforms and to enable content sharing on social media platforms and other channels.

We specifically use:

10.3 Map Material

We use services from third parties to embed maps into our website.

We specifically use:

10.4 Fonts

We use services from third parties to embed selected fonts, as well as icons, logos, and symbols into our website.

We specifically use:

10.5 Advertising

We use the option to display targeted advertising for our activities and operations on third-party platforms, such as social media platforms and search engines.

With such advertising, we aim to reach individuals who are already interested in or could potentially be interested in our activities and operations (remarketing and targeting). For this purpose, we may provide relevant – potentially also personally identifiable – information to third parties that enable such advertising. Additionally, we may assess whether our advertising is successful, particularly if it leads to visits to our website (conversion tracking).

Third parties on which we advertise and where you, as a user, are signed in, may associate the use of our online offering with your profile on those platforms.

We specifically use:

11. Website Extensions

We utilize extensions for our website to incorporate additional features.

We specifically use:

  • Google reCAPTCHA: Spam protection (distinguishing between desired comments from humans and undesired comments from bots and spam); Provider: Google; Google reCAPTCHA-specific information: «What is reCAPTCHA?».

12. Success and Reach Measurement

We aim to determine how our online offering is being utilized. In this context, we may measure the success and reach of our activities and operations, as well as the impact of third-party links on our website. We may also experiment and compare how different parts or versions of our online offering are used («A/B test» method). Based on the results of success and reach measurement, we can rectify errors, reinforce popular content, or make improvements to our online offering.

In most cases, internet protocol (IP) addresses of individual users are stored during success and reach measurement. IP addresses are generally truncated («IP masking») to comply with the principle of data minimization through pseudonymization.

Cookies may be used during success and reach measurement, and user profiles may be created. Potentially created user profiles may include visited individual pages or viewed content on our website, details about screen size or browser window, and the – at least approximate – location. Generally, any created user profiles are exclusively pseudonymized and not used to identify individual users. Certain services from third parties, where users are logged in, may associate the use of our online offering with the user account or profile on the respective service.

We specifically use:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement across various browsers and devices (Cross-Device Tracking), as well as with pseudonymized internet protocol (IP) addresses, which are only exceptionally fully transmitted to Google in the USA, «Privacy», «Browser add-on for disabling Google Analytics».
  • Google Tag Manager: Integration and management of other services for success and reach measurement, as well as additional services from Google and third parties; Provider: Google; Google Tag Manager-specific information: «Data collected with Google Tag Manager»; further privacy information can be found with the individual integrated and managed services.

13. Final Provisions

We have created this privacy policy using the Privacy Policy Generator by Datenschutzpartner.

We reserve the right to modify and supplement this privacy policy at any time. We will inform about such modifications and supplements in an appropriate manner, particularly by publishing the current privacy policy on our website.