Privacy Policy
Name and Contact Details of the Controller pursuant to Article 4(7) GDPR
etageeins GmbH
Bundesplatz 16, 6300 Zug, Switzerland
Security and Protection of Your Personal Data
We consider it our primary task to maintain the confidentiality of the personal data you provide and to protect it from unauthorized access. Therefore, we apply the utmost care and state-of-the-art security standards to ensure maximum protection of your personal data.
As a private law company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the regulations of the Federal Data Protection Act (BDSG). We have implemented technical and organizational measures to ensure that data protection regulations are observed by us as well as by our external service providers.
Definitions
The legislator requires that personal data be processed in a lawful manner, in good faith, and in a way that is transparent to the data subject (“lawfulness, processing in good faith, transparency”). To ensure this, we inform you about the individual legal definitions that are also used in this privacy policy:
Personal Data
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Processing
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Restriction of Processing
“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.
Profiling
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Pseudonymization
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Filing System
“Filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized, or dispersed on a functional or geographical basis.
Controller
“Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor
“Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Recipient
“Recipient” means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third Party
“Third party” means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent
“Consent” of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Lawfulness of Processing
The processing of personal data shall be lawful only if and to the extent that there is a legal basis for doing so. Pursuant to Article 6(1)(a) – (f) GDPR, the legal basis for processing may in particular be:
The data subject has given consent to the processing of his or her personal data for one or more specific purposes; Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; Processing is necessary for compliance with a legal obligation to which the controller is subject; Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Information on the Collection of Personal Data
(1) In the following, we inform you about the collection of personal data when using our website. Personal data includes, for example, name, address, email addresses, user behavior.
(2) If you contact us by email or via a contact form, the data you provide (your email address, and if applicable, your name, telephone number, position, and company) will be stored by us to answer your questions. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.
Collection of Personal Data When Visiting Our WebsiteWhen using the website for information purposes only, i.e., if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6(1) sentence 1 lit. f GDPR):
IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.
Use of Cookies
(1) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard disk in association with the browser you are using and through which certain information flows to the place that sets the cookie. Cookies cannot run programs or transmit viruses to your computer. They serve to make the website more user-friendly and effective overall.
(2) This website uses the following types of cookies, the scope and functionality of which are explained below:
– Transient cookies (see a.)
– Persistent cookies (see b.).
a.) Transient cookies are automatically deleted when you close your browser. This includes in particular session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This allows your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.
b.) Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.
c.) You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third-party cookies or all cookies. So-called “third-party cookies” are cookies set by a third party, not by the actual website you are currently visiting. Please note that by disabling cookies, you may not be able to use all functions of this website.
d.) The Flash cookies used are not detected by your browser but by your Flash plug-in. We also use HTML5 storage objects that are stored on your device. These objects store the required data independently of your browser and do not have an automatic expiration date. If you do not wish Flash cookies to be processed, you must install a corresponding add-on, e.g., “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/en-US/firefox/addon/betterprivacy/) or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. We also recommend that you regularly delete your cookies and browser history manually.
Further Functions and Offers of Our Website
(1) In addition to the purely informational use of our website, we offer various services which you can use if interested. As a rule, you must provide further personal data for this, which we use to provide the respective service and to which the aforementioned data processing principles apply.
(2) In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions, and are regularly checked.
(3) Furthermore, we may pass on your personal data to third parties if we offer participation in promotions, events, competitions, contract conclusions, or similar services in conjunction with partners. For more information, please provide your personal data or see the description of the offer below.
(4) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.
Newsletter
(1) With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers and events. The advertised goods, services, and events are named in the declaration of consent.
(2) We use the so-called double-opt-in procedure to subscribe to our newsletter. This means that after your registration, we will send you an email to the specified email address in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data.
(3) The only mandatory information for sending the newsletter is your email address. The provision of further, separately marked data is voluntary and is used to address you personally. After your confirmation, we store your email address for the purpose of sending the newsletter. The legal basis is Art. 6(1) sentence 1 lit. a GDPR.
(4) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare your revocation by clicking on the link provided in every newsletter email, by email to info@etage1.com, or by sending a message to the contact details given in the legal notice.
(5) We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are one-pixel image files stored on our website. For the evaluations, we link the data mentioned in § 3 and the web beacons with your email address and an individual ID. The data is collected exclusively in pseudonymized form, so the IDs are not linked to your other personal data, excluding direct personal identifiability. You can object to this tracking at any time by clicking on the separate link provided in each email or by informing us via another contact method. The information is stored for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously.
Children
Our offer is basically aimed at adults. Persons under 18 years of age should not transmit any personal data to us without the consent of their parents or legal guardians.Rights of the Data Subject
(1) Revocation of ConsentIf the processing of personal data is based on a given consent, you have the right to revoke the consent at any time. The revocation of consent shall not affect the lawfulness of processing based on consent before its withdrawal.You can contact us at any time to exercise your right of revocation.
(2) Right to ConfirmationYou have the right to request confirmation from the controller as to whether we are processing personal data concerning you. You can request this confirmation at any time using the contact details above.
(3) Right of Access
If personal data is processed, you can request information about this personal data and about the following information at any time:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Where personal data are transferred to a third country or to an international organization, you shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer. We shall provide a copy of the personal data undergoing processing. For any further copies requested by you, we may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
(4) Right to Rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
(5) Right to Erasure (“Right to be Forgotten”)
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and we shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing. The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The right to erasure (“right to be forgotten”) does not exist to the extent that processing is necessary:
for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) GDPR;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or for the establishment, exercise or defense of legal claims.
(6) Right to Restriction of Processing
You have the right to obtain from us restriction of processing where one of the following applies:
the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; or the data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. Where processing has been restricted under the aforementioned conditions, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
To exercise the right to restriction of processing, the data subject may contact us at any time using the contact details provided above.
(7) Right to Data Portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1) GDPR; and the processing is carried out by automated means.
In exercising the right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The exercise of the right to data portability shall be without prejudice to the right to erasure (“right to be forgotten”). That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(8) Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
You have the right to object, on grounds relating to your particular situation, to processing of personal data concerning you for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You can exercise the right to object at any time by contacting the respective controller.
(9) Automated Individual Decision-Making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision:
is necessary for entering into, or performance of, a contract between the data subject and a data controller;
is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or is based on the data subject’s explicit consent.
The data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.The data subject can exercise this right at any time by contacting the respective controller.
(10) Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.
(11) Right to an Effective Judicial Remedy
Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, you shall have the right to an effective judicial remedy where you consider that your rights under this Regulation have been infringed as a result of the processing of your personal data in non-compliance with this Regulation.
Use of Social Media Plugins
(1) We currently use the following social media plug-ins: [Facebook, Google+, Twitter, Xing, LinkedIn]. We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the plug-in providers. You can recognize the provider of the plug-in by the marking on the box above its initial letter or the logo. We offer you the opportunity to communicate directly with the provider of the plug-in via the button. Only if you click on the marked field and thereby activate it will the plug-in provider receive the information that you have accessed the corresponding website of our online offer. In addition, the data mentioned in § 3 of this declaration will be transmitted. In the case of Facebook and Xing, according to the respective providers in Germany, the IP address is anonymized immediately after collection. By activating the plug-in, personal data is transmitted from you to the respective plug-in provider and stored there (in the case of US providers, in the USA). Since the plug-in provider collects data particularly via cookies, we recommend that you delete all cookies via your browser’s security settings before clicking on the grayed-out box.
(2) We have no influence on the data collected and data processing operations, nor are we aware of the full extent of data collection, the purposes of processing, or the storage periods. We also have no information on the deletion of the collected data by the plug-in provider.
(3) The plug-in provider stores the data collected about you as user profiles and uses this for the purposes of advertising, market research, and/or demand-oriented design of its website. Such an evaluation takes place in particular (also for users who are not logged in) for the purpose of presenting demand-oriented advertising and to inform other users of the social network about your activities on our website. You have a right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Through the plug-ins, we offer you the opportunity to interact with social networks and other users, so that we can improve our offer and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6(1) sentence 1 lit. f GDPR.
(4) The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected by us will be directly assigned to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.
(5) For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the data protection declarations of these providers as notified below. They will also provide you with further information about your rights in this regard and setting options for the protection of your privacy.
(6) Addresses of the respective plug-in providers and URLs with their data protection notices:Google Inc., 1600 Amphitheater Parkway, Mountain View, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=en. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/en/privacy.
