Privacy Policy

ThisPrivacy Policyprovides information about the processing of personal data in connection with ouractivities and operations, including ourwebsiteat the domain name atrete.ch. In particular, we explain what personal data we process, for what purpose, how, and where. We also provide information about the rights of individuals whose data we process.

We have drafted this privacy policy in German. In the event that it is published in another language, the German version of the privacy policy shall prevail.

We may publish additional privacy policies or other information regarding data protection for specific or additional activities and operations.

1. Contact Information

The data controller is:

at rete ag, Zurich
Dufourstrasse 90
8008 Zurich

info@atrete.ch

In certain cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. Upon request, we are happy to provide data subjects with information regarding the respective responsibility.

2. Definitions and Legal Basis

2.1 Terms and definitions

Data subject:A natural person whose personal data we process.

Personal data:Anyinformation relating to an identified or identifiable natural person.

Sensitive personal data:data regarding trade union, political, religious, or ideological views and activities; data regarding health, privacy, or ethnicity or race; genetic data; biometric data that uniquely identifies a natural person; data regarding criminal or administrative sanctions or proceedings, and data regarding social assistance measures.

Processing:Anyhandling of personal data,regardlessof the means and methods used, such as retrieving, comparing, modifying, archiving, storing, reading, disclosing, obtaining, collecting, collecting, deleting, disclosing, classifying, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.

2.2 Legal Basis

We process personal data in accordance with Swiss law, in particular theFederal Act on Data Protection(Data Protection Act, DPA) and theOrdinance on Data Protection(Data Protection Ordinance, DPO).

3. Nature, Scope, and Purpose of the Processing of Personal Data

We process the personal datanecessaryto carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may include, in particular, browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact data), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our business activities, to the extent that such processing is permitted.

We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to protect legitimate interests. We may also ask data subjects for their consent even when it is not required.

We process personal data foras long as is necessary for the respective purpose. We anonymize or delete personal data, in particular, in accordance with statutory retention and statute of limitations periods.

4. Disclosure of Personal Data

We maydisclose personal datato third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized service providers whose services we use. These third parties may, in turn, disclose personal data to other third parties.

We may disclose personal data in the course of our activities and operations, in particular to banks and other financial service providers, government agencies, educational and research institutions, consultants and attorneys, accounting and fiduciary service providers, debt collection agencies, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, as well as with government agencies, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by mail or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data about other individuals are legally obligated to ensure the privacy of those individuals on their own. In particular, they must ensure that they are authorized to disclose such data and must also guarantee the accuracy of the data provided.

We use selected services from appropriate providers to facilitate and improve communication with individuals and other communication partners. We may also use such services to manage and otherwise process the data of data subjects beyond the scope of direct communication, for example in connection with orders, services, projects, and resource planning.

6. Applications

We process personal data about applicants to the extent necessary to assess their suitability for employment or for the subsequent performance of an employment contract. The personal data required is derived in particular from the information requested, for example in connection with a job posting. We may publish job postings with the assistance of appropriate third parties, for example in electronic and print media or on job portals and recruitment platforms.

We also process personal data that applicantsvoluntarilyprovide or make public, particularly as part of cover letters, resumes, and other application materials, as well as through online profiles.

We allow applicants to submit their information to ourtalent poolso that we can consider them for future job openings. We may also use this information to stay in touch and provide updates. If we believe an applicant is a good fit for an open position based on the information provided, we may contact the applicant to let them know.

7. Data Security

We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. Through these measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the personal data we process; however, we cannot guarantee absolute data security.

Access to our website and other digital platforms is secured using transport encryption (SSL/TLS, specifically theHypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers issue a warning before visiting a website that does not use transport encryption.

Our digital communications—likealldigital communications—are subject to mass surveillance without cause or suspicion by security agencies in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence over the processing of personal data by intelligence agencies, police departments, and other security authorities. Nor can we rule out the possibility that a data subject is being specifically monitored.

8. Personal Data Abroad

Wegenerallyprocess personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it there or have it processed there.

We may disclose personal data to anycountry on Earthor elsewhere inthe universe, provided that the laws of that jurisdiction ensure an adequate level of data protection, asdetermined by the Swiss Federal Council.

We may disclose personal data to countries whose laws do not provide adequate data protection, provided that appropriate data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific legal requirements for data protection 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 safeguards or supply a copy of such safeguards.

9. Rights of Data Subjects

9.1 Claims under data protection law

We grant data subjects all rights provided for under applicable law. In particular, data subjects have the following rights:

We may defer, restrict, or deny the exercise of data subjects’ rights to the extent permitted by law. We may inform data subjects of any prerequisites that must be met for them to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other individuals. We may also, for example, refuse to delete personal data in whole or in part, particularly citing legal retention obligations.

In exceptional cases, we may charge a fee for the exercise of these rights. We will inform the individuals concerned in advance of any such fees.

We are required to take reasonable steps to identify data subjects who request information or exercise other rights. Data subjects are required to cooperate.

9.2 Legal Protection

Data subjects have the right to enforce their data protection rights through legal action or to file a complaint with a data protection supervisory authority.

The supervisory authority for data protection for private data controllers and federal agencies in Switzerland is theFederal Data Protection and Information Commissioner (FDPIC).

10. Use of the Website

10.1 Cookies

We may use cookies. Cookies—including our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.

Cookies can be stored temporarily in the browser as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies make it possible, in particular, to recognize a browser on the next visit to our website and thereby, for example, measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be disabled, restricted, or deleted in whole or in part at any time via your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request—at least to the extent required by applicable law—your explicit consent to the use of cookies.

For cookies used to measure performance and reach or for advertising purposes, many services offer a general opt-out option throughAdChoices(Digital Advertising Alliance of Canada), theNetwork Advertising Initiative(NAI),YourAdChoices(Digital Advertising Alliance), orYour Online Choices(European Interactive Digital Advertising Alliance, EDAA).

10.2 Logging

For every visit to our website and our other digital platforms, we may log at least the following information, provided that this information is automatically collected or transmitted to our digital infrastructure during such visits: 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, specific subpage of our website accessed including the amount of data transferred,and the last webpage accessed in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence remains available on a long-term basis, in a user-friendly and reliable manner. It is also necessary to ensure data security—including through third parties or with the assistance of third parties.

10.3 Pixel Count

We may incorporate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are typically small, invisible images or JavaScript scripts that are automatically loaded when you access our digital presence. Tracking pixels can collect at least the same information as is recorded in log files.

11. Notices and Announcements

11.1 Measuring Performance and Reach

Notifications and messages may contain web links or tracking pixels that track whether a specific message has been opened and which web links were clicked within it. Such web links and tracking pixels may also track the use of notifications and messages on an individual basis. We require this statistical tracking of usage to measure effectiveness and reach so that we can send notifications and messages in a way that is effective, user-friendly, sustainable, secure, and reliable, based on the needs and reading habits of the recipients.

11.2 Consent and Objection

You mustgenerallyconsent to the use of your email address and other contact information, unless such use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log obtained consents, includingIP addressesandtimestamps, for evidentiary and security purposes.

You may,in principle, opt out of receiving notifications and communications—such as newsletters—at any time. By opting out, you are also objecting to the collection of usage data for the purpose of measuring performance and reach. This does not apply to necessary notifications and communications related to our activities and operations.

11.3 Service Provider for Notifications and Announcements

We send out notifications and announcements through specialized service providers.

In particular, we use:

12. Social Media

We maintain a presence on social media and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with these platforms, personal data may also be processed outside of Switzerland.

The General Terms and Conditions (GTC), Terms of Use, privacy policies, and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information, in particular, about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

13. Third-Party Services

We use services provided by specialized third parties to ensure that our operations and activities are sustainable, user-friendly, secure, and reliable. These services allow us, among other things, to embed features and content on our website. When such content is embedded, the services used collect users’IP addresses—at least temporarily—for technical reasons.

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 form. This includes, for example, performance or usage data, which is necessary to provide the respective service.

In particular, we use:

13.1 Digital Infrastructure

We use services provided by specialized third parties to access the digital infrastructure required for our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

13.2 Scheduling

We use services provided by specialized third parties to enable online scheduling, such as for meetings. In addition to this Privacy Policy, any terms and conditions directly associated with the services we use—such as terms of use or privacy policies—also apply.

In particular, we use:

13.3 Audio and Video Conferences

We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is also subject to the legal terms and conditions of the individual services, such as privacy policies and terms of use.

Depending on your situation, we recommend that you mute your microphone by default when participating in audio or video conferences, and either blur the background or use a virtual background.

In particular, we use:

13.4 Online Collaboration

We use third-party services to facilitate online collaboration. In addition to this Privacy Policy, any terms and conditions directly associated with the services we use—such as terms of service or privacy policies—also apply.

In particular, we use:

13.5 Maps

We use third-party services to embed maps on our website.

In particular, we use:

13.6 Digital Content

We use services provided by specialized third parties to embed digital content on our website. Digital content includes, in particular, images, videos, music, and podcasts.

In particular, we use:

13.7 Fonts

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

In particular, we use:

13.8 Advertising

We take advantage of the opportunity to display targetedadvertisementsfor our activities and serviceson third-party platforms, such as social media platforms and search engines.

We use this type of advertising specifically to reach people who are already interested in our activities and services, or who might be interested in them (remarketingandtargeting). To this end, we may share relevant information—including, where applicable, personal data—with third parties that facilitate such advertising. We can also determine whether our advertising is successful, specifically whether it leads to visits to our website(conversion tracking).

Third parties with whom we advertise and with whom you, as a user, have an account may, in some cases, associate your use of our website with your profile on their platform.

In particular, we use:

14. Website Extensions

We use extensions on our website to provide additional functionality. We may use selected services from appropriate providers or implement such extensions on our own digital infrastructure.

In particular, we use:

15. Measuring Success and Reach

We strive to measure the success and reach of our activities and initiatives. In this context, we can also measure the impact of third-party content or test how different parts or versions of our digital presence are used (using the “A/B testing” method). Based on the results of our success and reach measurements, we can, in particular, fix errors, enhance popular content, or make improvements.

In most cases, theIP addressesof individual users are collected for the purpose of measuring success and reach. In such cases, IP addresses arealwaystruncated (“IP masking”) in order to comply with the principle of data minimization through pseudonymization.

Cookies may be used to measure performance and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital platform, information about the size of the screen or browser window, and the user’s location (at least approximately). In principle, any user profiles created are exclusively pseudonymized and are not used to identify individual users. Certain third-party services with which users are registered may, in some cases, associate the use of our online offering with the user’s account or profile on the respective service.

In particular, we use:

16. Final Notes on the Privacy Policy

We created this privacy policy using theprivacy policy generatorfromDatenschutzpartner.

We may update this Privacy Policy at any time. We will notify you of any updates by posting the most current version of the Privacy Policy on our website.

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