Privacy policy

1. Principle

We take the protection of your personal data very seriously and treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

Depending on the personal data processing, in addition to the applicable Swiss law (Federal Act on Data Protection (FADP) of September 25, 2020, SR 235.1 and the associated Data Protection Ordinance (DPO) of August 31, 2022, SR 235.11), European data protection law (Regulation (EU) 2016/679 (General Data Protection Regulation)) also applies, in particular with regard to the monitoring of the behavior of data subjects residing in the EU (Art. 3 para. 2 lit. b GDPR) and the delivery of products to the EU (Art. 3 para. 2 lit. a GDPR).

2. Scope of the privacy policy

This privacy policy at www.changefactory.swiss applies exclusively to the use of our website, our contact forms and our newsletters.

3. Contact details of the person responsible for data protection

Responsible person:

Change Factory by Mike Portworsnick
Dorfstrasse 50
6390 Engelberg
Mail: contact[at]changefactory.swiss
Telefon: +41 44 586 88 22

Supervisory authority:

Data Protection Officer Schwyz Obwalden Nidwalden
Gotthardstrasse 21
6414 Oberarth
Tel. +41 41 859 16 20
Fax +41 41 859 16 26
info@kdsb.ch

https://www.kdsb.ch/

 

4. Processing of personal data; nature, purpose and use thereof

4a. When visiting the website

When you visit our website www.changefactory.swiss, information is stored. This is information that is automatically sent by your device’s browser. Namely:

• Anonymized IP address of the contacting device
• Date and time of the server request
• Country of origin
• URL of the requested page
• Referrer URL
• Operating system used
• Browser type/browser version
• Screen resolution

We process the aforementioned data for the following purposes:

• Connection establishment of the website,
• Usage analysis and optimization of our website,
• Operation and further development of our website,
• System security and stability
• We do not evaluate personal data about the use of our website (usage data). This data is not merged with other data sources.

The legal basis for data processing is overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR/Art. 31 para. 1 DSG). Our legitimate interest follows from optimizing and ensuring the security of the use of our website.

4b. Newsletter

If you would like to receive the newsletter offered on the website, we require the following data from you:

• Email address
• First name, last name, title (optional)
• When the form is sent, the IP address used is saved to protect against misuse. The IP address is stored together with your subscription confirmation.
• You can unsubscribe from the newsletter at any time free of charge via the link provided in the newsletter.

The legal basis for data processing is overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR/Art. 31 para. 1 FADP). Our legitimate interest is to inform customers and interested parties about the latest Change Factory services.

4c. Contact form

If you use the contact form provided on the website, we require the following personal data from you:

• First name, last name
• Company/Organization
• e-mail
• Message

When the form is sent, the IP address used is saved to protect against misuse. After processing the request, the data, including the IP address, will be deleted.

The purpose of processing:

• Contacting us at your request
• Protection against misuse

Data processing is based on our overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR/Art. 31 para. 1 FADP). Our legitimate interest follows from being able to communicate with customers and interested parties and to get in touch with them.

4d. Registration forms

If you use the registration form offered on the website (webinars, training courses, etc.), we require the following personal data from you:

• First name/Last name
• Company/Organization
• e-mail
• Phone number
• Further event-specific data

When the form is sent, the IP address used is saved to protect against misuse. After the event has been processed, the data, including the IP address, will be deleted.

The purpose of processing:

• The administration of participants for an event or training course.
• Contacting and corresponding with you for marketing purposes
• Protection against misuse

Data processing is based on overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR/ Art. 31 para. 1 FADP). Our legitimate interest arises from the need to administer and conduct webinars and training courses. Our legitimate interest also arises from being able to communicate with customers and interested parties and to get in touch with them.

4e. E-mail and other correspondence

We process your e-mail communication according to your instructions. This includes

• Email address
• IP address and other traffic edge data
• First name/Last name
• Company/Organization

The purpose of processing:

• Contacting and corresponding with you

Data processing is based on overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR/ Art. 31 para. 1 FADP). Our legitimate interest arises from our business activities.

4f. Download forms

If you use a download form offered on the website (e.g. for white papers, quick guides, etc.), we require the following personal data from you:

• Salutation
• First name/Last name
• Company/Organization
• Phone number
• e-mail

When the form is sent, the IP address used is saved to protect against misuse. Your data, including the IP address, will be deleted if it is no longer required for marketing purposes or if you have withdrawn your consent.

The purpose of processing:

• Contacting and corresponding with you for marketing purposes
• Protection against misuse

Data processing is based on overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR / Art. 31 para. 1 FADP) and your consent (Art. 4 para. 11 GDPR / Art. 6 para. 6 FADP). Our legitimate interest arises from our business activities and from being able to communicate and get in touch with customers and interested parties.

4g. Software distribution

As a software sales, consulting and implementation partner of INTRASOFT AG, Rothusstrasse 15, 6331 Hünenberg, Switzerland, we receive the following data from you for order processing and marketing purposes:

• Salutation
• First name/Last name
• Company/Organization
• Function
• Phone number
• e-mail

The purpose of processing:

• Contacting and corresponding with you
• Protection against misuse

Data processing is based on overriding private interest (Art. 6 para. 1 sentence 1 lit. f GDPR / Art. 31 para. 1 FADP) and your consent (Art. 4 para. 11 GDPR / Art. 6 para. 6 FADP). Our legitimate interest arises from our business activities and from being able to communicate with customers and interested parties.

4h. E-Recruiting

We handle applications with a common applicant management tool. On the “Vacancies” page and on other career pages, the job market is directly linked to such a tool. The use of such an applicant tool is subject to a separate privacy policy.

5. Cookies

We use cookies, session cookies and permanent cookies on our website. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. A cookie does not always mean that we can identify you.

Cookies are used on the one hand to record the frequency of use, number of users and behavior on our website, to increase the security of website use and to make our information offering more user-friendly. As soon as you leave the website, these cookies are automatically deleted.

In addition, we also use session cookies to optimize user-friendliness; these are stored on your end device for a specified period of time. If you visit our site again to use our services, it is automatically recognized that you have already visited us and which entries and settings you have made so that you do not have to enter them again.

You can deactivate optional cookies for analysis and marketing purposes at any time via the cookie settings. You will also find a list of the cookies that are used in the cookie settings.

The legal basis for data processing is overriding legitimate interest in accordance with Art. 31 para. 1 FADP and Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest arises from optimizing and ensuring the security of the use of our website.

You can configure your browser settings so that no cookies are stored on your computer. The complete deactivation of cookies may mean that you cannot use all the functions of our website.

By continuing to use our website and/or agreeing to this privacy policy, you consent to cookies being set by us and thus to personal usage data being collected, stored and used, even beyond the end of the browser session. You can revoke this consent at any time by activating the browser setting to refuse third-party cookies.

We use the “Real Cookie Banner” consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. Details on how “Real Cookie Banner” works can be found at <a href=”https://devowl.io/de/rcb/datenverarbeitung/” rel=”noreferrer” target=”_blank”>https://devowl.io/rcb/data-processing/</a>.

The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

6. Tools used

6a. Analysis

On this website, we use a web analysis service software on the basis of our legitimate interest (Art. 6 para. 1 lit. F GDPR) in the statistical analysis of user behavior for optimization and marketing purposes data collected, stored in a database and evaluated. The data linked to the corresponding cookie in the pseudonymous user profile is not used to personally identify you as a visitor to this website. The data collected in this way is also not merged with personal data about the bearer of the pseudonym.

By accessing pages of this website, you consent to the storage and analysis of this data from your visit. Although we record your usage behavior, the anonymization of the data means that no conclusions can be drawn about your person.

6b. Newsletter and e-mail marketing

We use the following tools:

• apollo.io
• hubspot.com
• linkedin.com

The applicable data protection provisions can be accessed here:

https://www.apollo.io/privacy-policy

https://legal.hubspot.com/privacy-policy?hubs_content=www.hubspot.com/&hubs_content-cta=Privacy%20Policy

https://privacy.linkedin.com/de-de

7. Social media plug-ins

We use the social plug-ins listed below on our website to make our company better known. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of Art. 31 para. 1 FADP and Art. 6 para. 1 lit. f GDPR. Responsibility for data protection-compliant operation must be guaranteed by the respective provider. Data processing in connection with these plug-ins is carried out with your consent when you use these plug-ins.

If you use the services of these social networks independently of or in connection with our website, the social networks will evaluate your use of the plug-in. In this case, information about the plug-in is forwarded to the social networks.

8. Disclosure of data to third parties

Your personal data will not be transferred to third parties for purposes other than those listed. Your personal data will be passed on to the following categories of third parties:

• Social media platforms
• Operators of tools used for analysis
• Newsletter and e-mail marketing
• Event management
• Manufacturer or supplier (website developer/operator for support and optimization)
• As implementation and consulting partner of INTRASOFT AG, Rothusstrasse 15, 6331 Hünenberg, Switzerland

The data is passed on for the purposes mentioned in this data protection declaration and for the justification reasons stated therein.

9. Cross-border disclosure to third countries without an adequate level of data protection

No data will be transferred to third countries without an adequate level of data protection without your consent. If you agree to the use of optional cookies from Linkedin Inc., your data may be transferred to the USA and processed there.

10. Your rights

The rights of the data subjects are governed by the applicable national and international law.

Depending on the applicable law, data subjects may be able to assert the following rights:

• To request information about your personal data processed by us. In particular, information pursuant to Art. 15 GDPR or Art. 25 FADP may contain information:
• about the purposes of processing,
• the category of personal data,
• the categories of recipients to whom your data has been or will be disclosed,
• the planned storage period,
• the existence of a right to rectification, erasure, restriction of processing or objection,
• the existence of a right of appeal,
• the origin of your data if it was not collected by us,
• the existence of automated decision-making, including profiling and, where applicable, meaningful information about its details.

In the event of disproportionately high costs, we reserve the right to request proof of identity and payment of the actual costs in advance.

• to immediately request the correction of incorrect or incomplete personal data stored by us (Art. 16 GDPR, Art. 32 FADP).
• to request the deletion of your personal data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims (Art. 17 GDPR, Art. 32 FADP)
• to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR (Art. 18 GDPR, Art. 32 FADP).
• to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request the transfer to another controller (Art. 20 GDPR, Art. 28 FADP)
• to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing that was based on this consent in the future (Art. 7 para. 3 GDPR)
• to lodge a complaint with a supervisory authority (see above) (Art. 77 GDPR)
• The parents (or legal representative) of persons under the age of 16 can request deletion or deregistration at any time.

11. Right of objection

If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.

12. Data security

We have technical and organizational security procedures in place to protect the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access.

However, you should always be aware that the transmission of information via the Internet and other electronic means involves certain security risks and that we cannot guarantee the security of information transmitted in this way. Your personal data is transmitted from this website to us using SSL encryption.

If you notice any incidents in connection with our website that seem unusual to you, we would be very grateful if you would report them to us immediately.

13. Storage period

We store your data for the following period:

We retain data that we process in accordance with the law for the statutory retention period, for example if required by labor, social security or tax law or the Ordinance on Business Records.

Data that we process to protect our overriding legitimate interests is regularly deleted after the end of the contractual relationship, unless we need the data to assert our rights.

Data that we no longer need will be deleted if the purpose of the processing and the basis for processing become invalid, unless there is a legal obligation to retain it.

14. Up-to-dateness and amendment of this privacy policy

We reserve the right to change this privacy policy at any time or to adapt it to new processing methods. The current privacy policy can be viewed at any time on our website.

15. Contact us

If you have any questions about this that are not answered by this privacy policy, you can contact us at any time (for contact details, see section 3 above).