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Privacy Policy

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Terms & Conditions

Terms & Conditions

What is this privacy notice about? / Who is the controller for your data? / How do we process data in relation with our products and services? / How do we process data in relating with marketing?

    We also process personal data in order to advertise us and our services:
  • Newsletters: We send electronic information and newsletters, which include advertising for our offers. We will ask for you for consent beforehand, except where we advertise certain offers to existing customers.
  • For newsletters with performance measurement: In addition to your name and e-mail address, we also process information about the services you have used before, whether you open newsletters and which links you click. For this purpose, our e-mail provider offers a function that essentially works with invisible images that are loaded from a server through a coded link and thus transmits this data to the server. This is a common method that helps us to assess the effect of newsletters and optimize our newsletters. You can object to this measurement through the settings of your e-mail client (for example by turning off automatic image loading).
  • Online advertising: It is possible that you come across content that has been personalized for you based on your preferences recorded, for example the most suitable course or the ideal tutor for you.
  • Advertising messages: You could receive communication regarding our latest offers suited to you via various communication channels like email, WhatsApp, Instagram direct messages.
  • Market research: We also process data to improve performance and develop new products, such as information about your purchases, your response to newsletters, information from customer surveys or from social media, as well as from media monitoring services and public sources.

How do we work with service providers?

    We use various services provided by third parties, in particular IT services (examples are hosting and data analysis providers), logistics services, banks, the post office, consultants, etc. For service providers for our website, see sec. 8 below. These service providers may also process personal data to the extent necessary.

Can we disclose data abroad?

    The recipients of personal data are not all located in Switzerland. This applies in particular to certain service providers (especially IT service providers). These have locations both within the EU or the EEA (for example Star World Web in India, but also in other countries worldwide, for example Stripe Inc in USA. We may also transfer data to authorities and other recipients abroad if we are under a legal obligation to do so or, for example, in the context of a company or asset sale or legal proceedings (see sec. 9). Not all of these countries provide an adequate level of data protection. We therefore use particular agreements in order to provide additional protection, in particular the standard contractual clauses of the European Commission, which8https://eur-lex.europa.eu/legalcontent/DE/TXT/HTML/?uri=CELEX:32021D0914&from=EN are available here3. In certain cases, we may transfer personal data in accordance with applicable data protection regulation without such agreements, for example if you have consented to the transfer or if the transfer is necessary for the execution of the agreement, for the establishment, exercise or enforcement of legal claims or for overriding public interests.

How do we process data in relation with our website?

    Each time our website is used, certain data is generated, for technical reasons, which is temporarily stored in log files. Key examples are the IP address of the device used, information about the internet service provider and the operating system of your device, information about the referring URL, information about the browser, the date and time of access, and the content accessed. We use this data so that our website can be used, to ensure security and stability, to optimize our website and for statistical purposes.
  • Our website also uses cookies, i.e. small text files that your browser stores on your device. This allows us to distinguish individual visitors, but usually without identifying them. Cookies may also contain information about pages accessed and the duration of the visit. Certain cookies («session cookies») are deleted when the browser is closed. Other cookies («essential cookies») remain stored for a certain period of time so that we can recognize visitors when they visit us again.
  • You can configure your browser in the settings to block certain cookies or similar technologies or to delete cookies and other stored data. You can find out more in the help pages of your browser (usually when you look for «data protection»).
  • Third party cookies : These cookies and other technologies may be set by third-party companies that provide certain features to us. These may be located outside Switzerland and the EEA (see sec. 7 for more information). For example, we use analytics services to help us optimize [6and personalize] our website. Cookies and similar technologies from third parties also help them to target you with individualized advertising on our or other websites and on social networks that work with the same third party, and to measure how the effectiveness of ads (for example whether you came to our website through an ad and what actions you then take on our website). These third parties may record the use of the website and combine these records with other information they have from other websites. This allows them to collect data about user behavior across multiple websites and devices, in order to provide statistical evaluations on this basis. The providers can also use this information for their own purposes, for example for personalized advertising on their own or other websites. If a user is registered with the provider, the provider can also link the usage data to that user.
  • Two key providers are Google and Meta. More information on these can be found below. Other third parties usually process personal and other data in a similar way. — Our website uses Google Analytics, an analytics service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA, USA) and Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland). Google collects information about the behavior of users on the website and about the device used. The IP addresses of visitors are truncated in Europe before being sent onwards to the USA. Google provides us with statistical information based on the data recorded, but also uses some data for its own purposes. Information on Google Analytics privacy can be found here https://support.google.com/analytics/answer/6004245, and if you have a Google Account, you can find more information here .
  • We may transmit user information such as e-mail addresses to Meta Inc (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in order to advertise on Meta Platforms. Meta matches these with information they have about their members in order to be able to display targeted ads to our users («Custom Audiences»). You can object to that at any time (see sec. 14). Our websites may [also] use the «Meta pixel» and similar technologies provided by Meta. We use these technologies to display the Meta ads we place only to users of Meta Platforms and of partners that cooperate with Meta who have shown an interest in us. We can also use these technologies to understand the effectiveness of Meta ads for statistical purposes and market research, by collecting information if users were redirected to our website after clicking on a Meta ad («conversion measurement»). More information can be found here . We are joint controllers with Meta for displaying personalized ads, improving ad delivery, and personalizing other features and content (but not for further processing). We have therefore concluded an agreement with Meta . Users can send requests for access and other requests in relation with the joint controllership directly to Meta.

How do we process data through social media?

    We operate fan pages and other pages on social networks and other platforms ([Facebook fan pages, instagram page and a YouTube channel]). If you communicate with us there or comment on or redistribute content, we collect information that we use primarily for communication with you, for marketing purposes and for statistical evaluations (see sec. 4 and 10). Please note that the platform provider will also collect and use some data (for example about user behavior), possibly together with other data they have about a user, for example for marketing purposes or to personalize platform content. Where we are joint controllers with the provider, we enter into a agreement about which you can obtain information directly from the provider.

Are there other types of processing?

    Yes, as many of the necessary things that we do involve processing personal data as well as common and unavoidable internal processes. It is not always possible to know in advance if this will occur nor the specific extent of the data processed, but below you will find information on typical (not necessarily frequent) cases:
  • Communication: When we are in contact with you (for example [when you call customer service] [or when you communicate with us on a social media platform]), we process information about the content and type, time and place of the communication. We may also process information to identify you. [Calls with us may be recorded [and overheard]. We will let you know of this at the beginning of each call. If you do not want us to record such conversations, you have the option at any time to end the conversation and contact us through other means, for example by e-mail].
  • Compliance with the law: We may process personal data and disclose data to authorities as required for our obligations or rights arising under applicable law, and to comply with internal regulations.
  • Prevention: We process data to prevent criminal acts and other violations, for example in the context of fraud prevention or internal investigations.
  • Legal proceedings: Where we are involved in legal proceedings (for example judicial or administrative proceedings), we process data for example about other parties to the proceedings and other persons involved, such as witnesses or respondents, and disclose data to such parties and to courts and authorities, possibly also abroad.
  • IT security: We process data for monitoring, controlling, analyzing, testing, securing and assessing our IT infrastructure, but also for backups and data archiving.
  • Competition: We process data about our competitors and the market in general (for example the political situation, relevant business associations, etc.). In doing so, we may process data about key persons, in particular name, contact details, role or function and public statements.
  • Transactions: If we sell or acquire receivables, other assets, business units or companies, we process data to the extent necessary to prepare and carry out such transactions, for example information about customers or their contact persons or employees, and we may also disclose such data to buyers or sellers.
  • Other purposes: We process data to the extent necessary for other purposes such as training and education, administration (for example contract management, accounting, enforcement and defense of claims, evaluation and improvement of internal processes, anonymous statistics and evaluations, and protection of other legitimate interests.

How long do we process personal data?

    We process personal data as long as it is necessary for the processing purpose (in the case of agreements, usually for the duration of the agreement), as long as we have a legitimate interest in the storage (for example to enforce legal claims, for archiving and or to ensure IT security) and as long as data is subject to retention obligations (for example, a ten-year retention period applies for certain data). After expiry of these periods, we delete or anonymize your personal data.

Anything else to consider?

    To be used if the GDPR may apply:11 Depending on the applicable law, personal data may only be processed if applicable law specifically permits it. This does not apply under to the Swiss Data Protection Act, but it does, for example, under the EU General Data Protection Regulation (GDPR), should it apply. In this case, our processing is based on the fact that it is necessary for the preparation and execution of agreements (sec. 3), that it is necessary for legitimate interests of us or third parties, for example statistical evaluations (sec. 3) or marketing purposes (sec. 4), that it is required or permitted by law or that you have separately given consent to the processing. The relevant provisions are articles 6 and 9 of the GDPR.334
    You are under no obligation to share data to us, except in specific cases (for example if you have to fulfil an agreed obligation, which may require disclosing data to us). However, for legal and other reasons, we have to process personal data when we conclude and execute agreements. Using our website is also not possible without data processing (see sec. 8).

What are your rights?

    Subject to the conditions and restrictions of applicable data protection law, you have certain rights in order to receive a copy of your personal data or have a say about our processing of your data:
  • You can request a copy of your personal data and more information about our data processing;
  • You can object to our data processing, in particular in connection with direct marketing;
  • You can correct or complete incorrect or incomplete personal data or have us register a note of dispute;
  • You may have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format, where data processing is based on your consent or is necessary for the performance of an agreement;
  • If we process data on the basis of your consent, you can withdraw your consent at any time. Withdrawing consent only affects our processing going forward, and we reserve the right to continue processing data on another basis, as permitted by applicable law.
    • If you wish to exercise your rights, please contact us (sec. 2). As a rule, we will have to verify your identity (for example by means of a copy of an ID document). You are also free to lodge a complaint against our processing with the competent supervisory authority, in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC).
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