Privacy policy
This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our grow-cluster.ch website. In particular, we provide information on why, how, and where we process which personal data. We also provide information about the rights of persons whose data we process.
Further data protection declarations or other information on data protection may apply to individual or additional activities and operations.
1. contact addresses
Responsibility for the processing of personal data:
Stiftung grow
Einsiedlerstrasse 30
CH-8820 Wädenswil
In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties.
2. terms and legal bases
2.1 Terms
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data concerning trade union, political, religious or philosophical opinions and activities, data concerning health, privacy or ethnic or racial origin, genetic data, biometric data uniquely identifying a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, recording, deletion, disclosure, organization, storage, modification, dissemination, linking, destruction and use of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
3. nature, scope, and purpose of the processing of personal data
We process the personal data required to carry out our activities and operations in a sustainable, humane, secure, and reliable manner. The processed personal data may fall into the categories of browser and device data, content data, communication data, metadata, usage data, and master data including inventory and contact data, location data, transaction data, contract data, and payment data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities and operations, insofar as such processing is permitted for legal reasons.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.
We process personal data for the duration required for the respective purpose. We anonymize or delete personal data in particular depending on statutory retention and limitation periods.
4. disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties are, in particular, specialized providers whose services we use.
For example, we may disclose personal data to banks and other financial service providers, public authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, and insurance companies.
5. communication
We process personal data to be able to communicate with third parties. In this context, we process in particular data that a data subject transmits when making contact, for example by post or e-mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. To this end, the accuracy of the personal data transmitted must be ensured, among other things.
6. data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability, and integrity of the processed personal data, without being able to guarantee absolute data security.
Our website and our other online presence are accessed using transport encryption(SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting websites without transport encryption.
Our digital communication – like all digital communication – is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.
7. personal data abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it or have it processed there.
We may disclose personal data to all countries and territories in the world, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council.
We may disclose personal data to countries whose laws do not guarantee adequate data protection, provided that adequate data protection is guaranteed for other reasons, in particular, based on standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example, the express consent of the data subjects or a direct connection with the conclusion or fulfillment of a contract. On request, we will be happy to provide data subjects with information about any guarantees or provide a copy of the guarantees.
8. rights of data subjects
8.1 Data protection claims
We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:
- Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.
- Erasure and objection: Data subjects can have their personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal protection
Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC ).
9. use of the website
9.1 Cookies
We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
Cookies can be fully or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies – at least if and to the extent necessary.
9.2 Logging
We may log at least the following information for each access to our website and our other online presence, insofar as this information is transmitted to our digital infrastructure during such accesses: 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, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The information is required to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security – also by third parties or with the help of third parties.
9.3 Tracking pixel
We can integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as log files.
10. notifications and messages
10.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a human-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
10.2 Consent and objection
You must always consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
10.3 Service provider for notifications and messages
We send notifications and messages with the help of specialised service providers.
We use in particular:
- Mailchimp: Communication platform; Service provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Data protection information: Privacy policy (Intuit) including “Country and Region-Specific Terms”, “Frequently asked questions about data protection at Mailchimp”, “Mailchimp and European data transfers”, “Security”, “ Cookie policy”, “Privacy Rights Requests”, “Legal provisions”.
11. social media
We are present on social media platforms and other online platforms to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland.
The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
12. services of third parties
We use services from specialized third parties to be able to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the IP addresses of users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data to be able to offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and Security Principles”, “Information on how Google uses personal data”, Privacy Policy, “Google is committed to complying with applicable data protection laws”, “Guide to privacy in Google products”, “How we use data from websites or apps on or in which our services are used”, “Types of cookies and similar technologies Google uses”, “Advertising you can control” (“Personalised advertising”). in which our services are used”, “Types of cookies and similar technologies used by Google”, “Advertising you can control” (“Personalised advertising”).
12.1 Digital infrastructure
We use the services of specialized third parties to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- Cyon: Hosting; Service provider: cyon GmbH (Switzerland); Information on data protection: “Data protection”, Privacy policy .
- WordPress.com: Blog hosting and website builder; Service provider: Automattic Inc (USA) / Aut O’Mattic A8C Ireland Ltd (Ireland) for users in Europe and elsewhere; Privacy Policy: Privacy Policy, Cookie Policy.
12.2 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Service provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts”, “Privacy and data collection” (for Google Fonts).
13. extensions for the website
We use extensions for our website to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure.
We use in particular:
- Google reCAPTCHA: Spam protection (differentiation between wanted content from humans and unwanted content from bots and spam); Service provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”.
14. final provisions
We have created this privacy policy with the data protection generator of Datenschutzpartner.
We may amend and supplement this privacy policy at any time. We will inform you of such amendments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.