Privacy Policy

This Privacy Policy is governed by and must be interpreted in accordance with Swiss law. The new regulations within the framework of the EU General Data Protection Regulation of 2018 (GDPR 2016/679) will be taken into account. We may change our privacy policy from time to time, in particular to reflect changes in law or jurisdiction or business requirements. Please check this page from time to time to ensure that you are aware of any changes.

General information

The following notes provide a simple overview of what to do with your  personal data happens when you visit this website.Personal information is any information that personally identifies you. Detailed information on data protection can be found in our Privacy Policy, which is included below this text.

Data collection on this website

Who is responsible for capturing data on this website?

Data processing on this website is carried out by the website operator. Their contact details can be found in the legal notice of this website.

How do we collect your data?

On the one hand, your data is collected by you communicating it to us. This can be, for example, data you enter in a contact form. Other data will be automatically collected when you visit the website via our IT systems. These are mainly technical data (e.g. Internet browser, operating system or time of the access). This data is collected automatically as soon as you enter this website.

What do we use your data for?
Some of the data is collected to ensure a faultless operation of our website. Other data may be used to analyse your user behaviour. Your data will be transmitted to the following recipients:

• Service providers and partners used by Silenccio AG insofar as they need your data to fulfil their respective tasks. These service providers are contractually obliged to treat your data confidentially and to process it only to the extent necessary for the performance of their services.
• Within Silenccio AG, those employees and departments that require your data for the fulfilment of their respective contractual and legal obligations will receive it.
• Silenccio AG will also pass on your data to public bodies and authorities if there is a legal obligation to do so.

In all cases mentioned above, Silenccio AG will ensure that third parties only have access to personal data necessary for the performance of individual tasks.

What rights do you have regarding your data?

You have the right at any time and free of charge to obtain information about origin, recipient and purpose of your stored personal data. You also have the right to demand the correction, blocking or deletion of this data, the right to limit the processing and to data transferability and the right to object to the processing. If you have further questions concerning data protection, you can contact us at any time at the address provided in the legal notice. You also have the right to lodge a complaint with the competent supervisory authority. The supervisory authority under Swiss data protection law is the Federal Data Protection and Information Commissioner (info@edoeb.admin.ch).

Analysis tools and tools of third-party providers

When you visit our website, your surfing habits can be statistically analysed. This is done primarily with cookies and analysis programmes. The analysis of your surfing habits is usually anonymous; the surfing habits cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. Detailed information about these tools and your options for objection can be found in the following privacy policy.

Data protection

The operators of these pages are committed to protecting your personal data. We treat your personal data confidentially and in line with the legal data protection regulations as well as this privacy statement. If you use this website, different types of personal data will be collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and how we use it and what we use it for. It also explains how and for what purpose this is done and how long personal data is stored. Please note that data transmission via the internet (e.g. communication by e-mail) may be subject to security gaps. It is not possible to fully protect data against access by third parties.

Reference to the data controller

The data controller is the natural or legal person, who alone or together with others decides on the purposes and means of processing of personal data (e.g. names, e-mail addresses, etc.).

The data controller for data processing on this website is:
Silenccio AG
Florastrasse 56
8008 Zürich
Schweiz

Telefon: +41 44 552 23 32
E-Mail: datenschutz@silenccio.com

Basis for data processing

With your declaration of consent you agree to this data protection declaration. However, we reserve the right to refer to the following bases for lawful data processing in addition to this declaration of consent:

• If the data processing is necessary for the performance of the contract (e.g. newsletter service). This also applies to data processing operations which are necessary for the implementation of pre-contractual measures which take place at your request (cf. Art. 6 (1) (b) GDPR).
• Insofar as data processing is necessary to fulfil a legal obligation (e.g. storage obligation) to which we are subject (cf. Art. 6 (1) (c) GDPR).
• If data processing is necessary to safeguard a legitimate interest of ours or a third party (e.g. for the assertion of claims) and your interests, fundamental rights and fundamental freedoms do not prevail over the former (cf. Art. 6 (1) (f) GDPR).
• In exceptional cases, when vital interests of yours or another natural person make data processing necessary (cf. Art. 6 (1) (d) GDPR).

Withdrawal of Your Consent to Data Processing

Many data processing procedures are only possible with your explicit consent. You are entitled to withdraw your consent at any time. To do this, an informal notice via e-mail to us is sufficient. The withdrawal does not affect the lawfulness of the data processing carried out up to the withdrawal.

Right of objection to data collection in special cases as well as against direct advertising (Art. 21 GDPR)

If the data processing is carried out on the basis of Art. 6 (1) (e) (i.e. the 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) or f (i.e. the processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, are overridden, in particular where the data subject is a child) GDPR, you have the right at all times to object to the processing of your personal data for reasons connected with your particular situation, including profiling based on these provisions. The respective legal basis for the processing is stated in this Privacy Policy. If you file an objection, we will no longer process your personal data concerned unless we can prove compelling reasons for the processing worthy of protection which outweigh your interests, rights and freedoms or the processing serves the assertion, exercise or defence of legal claims (objection pursuant to Art. 21 (1) GDPR). If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of personal data relating to you where the data is processed for the purpose of such advertising; this also applies to profiling, insofar as it is connected to such direct advertising. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21 (2) GDPR).

Right to lodge a complaint with the responsible supervisory authority

In the event of infringements of the DSGVO, the persons concerned have the right to appeal to a supervisory authority, in particular in the Member State of their habitual residence, workplace or place of presumed infringement (Art. 77 GDPR). The right of appeal exists without prejudice to other administrative or judicial remedies. The supervisory authority under Swiss data protection law is the Federal Data Protection and Information Commissioner (info@edoeb.admin.ch).

Right of data portability

You have the right to have the personal data concerning you, which we have automatically processed on the basis of your consent or in order to implement a contract, to be passed to you or to a third party, in a commonly used and machine-readable format. If you request the direct transfer of this data to another controller, this will only be done where technically feasible.

Information, deletion and correction

Within the scope of the statutory provisions, you have the right to obtain free information about your stored personal data, its origin and recipients and the purpose of data processing, and if appropriate, the right to rectification or erasure of such data at any time. If you have any further questions concerning this or personal data, you can contact us at any time at the address provided in the legal notice.

You have the right to require us to limit the processing of your personal data. To do so, you can contact us at any time at the address given in the legal notice. The right to restrict the processing exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the check, you have the right to require us to limit the processing of your personal data.
• If the processing of your personal data has taken place unlawfully, you can demand the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21 (1) GDPR, your interests must be weighed against ours. As long as it is not yet clear whose interests predominate, you have the right to require us to limit the processing of your personal data.

If processing of your personal data has been restricted, then this data may only be processed, apart from its storage, with your permission or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of a significant public interest of the European Union or a member state.

External hosting

This website is hosted by an external service provider (Google).

Personal data collected on this website is stored on the host’s servers. This may include IP addresses, contact requests, meta and communication information, contract information, contact information, names, web page views, and other information generated by a website. The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1) (b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6 (1) (f) GDPR.). Our hoster will only process your data to the extent that this is necessary to fulfil its performance obligations and to follow our instructions with regard to this data.

SSL or TLS Encryption

This site uses, for security reasons and to protect the transmission of confidential content, such as requests that you send to us as a site operator, an SSL or. TLS encryption. You can recognise an encrypted connection by the address line of your browser, which changes from “http://” to “https://” and the padlock symbol in your browser line. If the SSL or TLS encryption is activated, third parties will not be able to read the data you are transmitting to us.

Cookies

Our website makes partial use of what are referred to as cookies. Cookies do not cause any damage to your computer and they do not contain viruses. Cookies do help in making our site more user-friendly, effective and safer. Cookies are small text files that are stored on your computer and saved by your browser. Most of the cookies we use are so-called “session cookies”. They are automatically deleted at the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to identify your browser during your next visit. You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, the acceptance of cookies for certain cases or generally exclude and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted. Cookies that are required to carry out the electronic communication process or to provide certain functions you desire, are stored based on Art. 6 (1) (f) of the GDPR. The website operator has a legitimate interest in storing cookies in order to be able to provide technically error-free and optimised services. If a corresponding consent has been requested (e.g. a consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR; the consent can be revoked at any time. To the extent that other cookies (e.g. cookies for the analysis of your surfing behaviour) are stored, they will be addressed separately in this data protection declaration.

Server log files

The provider of the web pages collects and saves information automatically in so-called server log files, which are automatically transferred to us by your browser. These are:

• Type and version of browsers
• Operating system in use
• Referrer URL
• Host name of the accessing computer
• Time of server enquiry
• IP address

This data will not be merged with other data sources. The collection of the data is based on Article 6 (1) (f) GDPR. The website operator has a justified interest in the technically error-free presentation and optimisation of its website – for this purpose the server log files must be recorded.

Contact form

If you are using the contact form to submit your enquiry to us, your details you have provide in the form will be saved at our end along with the contact data specified in the form, for the purpose of processing the enquiry and for follow-up questions. We will not share such data with third parties without your consent. The processing of this data is based on Article 6 (1) (f) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art.6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) if this has been requested. The data you provide with the contact form will remain with us until you request us to delete it, you withdraw your consent to its storage or when the purpose of the data storage no longer exists (e.g. after your request has been processed). Mandatory statutory provisions – especially those related to retention periods – shall remain unaffected.

Inquiry by e-mail or telephone

If you contact us by e-mail or telephone, your request including all personal data (name, request) will be stored and processed by us for the purpose of processing your request. We will not share such data with third parties without your consent. The processing of this data is based on Article 6 (1) (f) GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases the processing is based on your consent (Art. 6 (1) (a) GDPR) and/or on our legitimate interests (Art. 6 (1) (f) GDPR), as we have a legitimate interest in the effective processing of the enquiries addressed to us. The data you send to us by e-mail will remain with us until you request us to delete it, you withdraw your consent to its storage or when the purpose of the data storage no longer exists (e.g. after your request has been processed). Mandatory statutory provisions – especially those related to statutory retention periods – shall remain unaffected.

Newsletter data

If you wish to receive the newsletter offered on the website, we require your e-mail address as well as information, which enables us to verify that the e-mail address provided to us is registered to you, and that you agree to receive the newsletter. Further data is not necessary for the functioning of the newsletter, but can be provided by you. We use this data solely to send the requested information to you and we do not share the data with third parties. Thus the data entered in the newsletter registration form is processed exclusively on the basis of your consent (Article 6 (1) (a) GDPR). You can, at any time, revoke the consent you have provided for the storage of the data, the e-mail address as well as their use for sending the newsletter, for example via the “deregister” link in the newsletter. The withdrawal does not affect the lawfulness of the data processing already carried out up to the withdrawal. The data you provide to us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored by us for other purposes remain unaffected by this. After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest in the sense of Art. 6 (1) (f) GDPR). The storage in the blacklist is not time-limited. You can object to the storage if your interests outweigh our legitimate interest.

Google Analytics

This website uses Google Analytics. This allows cookies to be used to evaluate your use of the website, to report on website activity and to provide other services relating to website activity and internet usage. In particular, Google Analytics collects the following data in anonymous form: Indicators of your device (brand, type, screen, memory), operating system, type and version of your browser, abbreviated IP address (so that it is impossible to assign it to a specific user). Google does not combine this data with any other data held by Google. The information generated by cookies about your usage of this website is normally sent to one of Google’s servers in the USA and stored there. The terms of use for Google Analytics can be found here: https://www.google.com/analytics/terms/de.html

We have a legitimate interest in the storage of Google Analytics cookies, in particular in order to optimise our website and advertising by analysing user behaviour (cf. Art. 6 (1) (f) GDPR). The provider of these services is Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. You can find Google’s privacy policy here:

https://policies.google.com/privacy?hl=de

Hotjar

This website uses Hotjar. This is a tool used to evaluate your user habits on our website (e.g. mouse and scroll movements, clicks, length of time spent on a particular location or page, cancellation of entries in a contact form (so-called conversion funnels), obtaining feedback from website visitors) using permanent cookies. Based on this, Hotjar creates a so-called heat map, which shows which website areas are preferred. We have a legitimate interest in the storage of Hotjar cookies, in particular in order to optimise our website and advertising by analysing user behaviour (cf. Art. 6 (1) (f) GDPR). The provider of this service is Hotjar Ltd., Level 2, St. Julians Business Centre 3, Elia Zammit Street, St. Julians STJ 3155, Malta, Europe. You can find Hotjar’s privacy policy here: https://www.hotjar.com/legal/policies/privacy

Tracking pixels

This website uses tracking pixels (also known as pixel tags, web beacons or clear GIFs). A tracking pixel is a 1×1 pixel-sized, invisible graphic related to your user ID. Tracking pixels measure, for example, the number of visitors to a page, the number of clicks on important parts of a site or which files are opened. This helps us to analyse the effectiveness of the website. Tracking pixels do not collect any personal data about you.

Facebook pixel

This website uses a Facebook pixel. We use cookies to see when you click on a Facebook ad to access our website. For us, the data collected is anonymous and we cannot deduce the identity of the user. Facebook, on the other hand, stores and processes the data and can create a connection to the respective user profile in order to use the data for its own advertising purposes. We cannot control how Facebook uses the information. Facebook Pixel allows us to measure the effectiveness of our Facebook advertisements for statistical purposes, market research and to improve our advertising, which gives us a legitimate interest in the use of Facebook pixels (Art. 6 (1) (f) GDPR). The provider of this service is Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. You can find Facebook’s privacy policy here: https://www.facebook.com/privacy/explanation

YouTube

This website incorporates videos from the YouTube website. The website is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Irland. When you visit one of our websites where YouTube is hosted, a connection is established to YouTube’s servers. This informs the YouTube server as to which of our pages you have visited. YouTube may also store various cookies on your device. YouTube may use these cookies to obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve usability and prevent fraud. The Cookies remain on your device until you delete them. When you are signed into your YouTube account, you enable YouTube to associate your Internet usage directly with your personal profile. You can prevent this by logging out of your YouTube account. The use of YouTube takes place in the interest of an attractive presentation of our websites (cf. Art. 6 (1) (f) GDPR). If a corresponding consent has been requested (e.g. a consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR; the consent can be revoked at any time. Additional information on the handling of user data can be found in YouTube’s Privacy Policy at: https://policies.google.com/privacy?hl=de.

Insofar as it is legally permissible and indicated and it justifies one of the aforementioned data processing purposes, we disclose data to third parties so that they can process it for us or for their own purposes. Third parties can be:

• Business partners, including group companies, contractors (e.g. IT providers) and auxiliary persons
• Domestic and foreign authorities and courts
• Media, public
• Branch organisations, associations, competitors
• Counterparties in any transactions under company law
• Other parties in any legal proceedings

These third parties may be here or abroad. Among others, data is exchanged with the following third parties: AXA, Facebook, Twitter, Microsoft, Google, SendGrid, HaveIbeenpwned and Salesforce.

Websites and services of other providers to which our website links are designed and provided by third parties. We have no control over the content and function of these third party services. Please note that the linked third-party services may install their own cookies or collect personal data. We have no control over this.