Additional privacy policies and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply to individual or additional activities and tasks.
We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.
1. Contact us
Responsibility for processing personal data:
Foundation Klangwelt Toggenburg
Sonnenhalbstrasse 22
9656 Alt St. Johann
Switzerland
We will indicate if there are other controllers responsible for processing personal data in individual cases.
Data protection representative in the European Economic Area (EEA)
We have the following data protection representative in accordance with art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.
2. Terms and legal principles
2.1 Terms
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organising, storing, modifying, distributing, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the handling of personal data as the processing of personal data.
2.2 Legal principles
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).
Where and to the extent that the General Data Protection Regulation (GDPR) applies, we process personal data in accordance with at least one of the following legal bases:
Art. 6(1)(b) GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
Art. 6(1)(f) GDPR for the necessary processing of personal data to safeguard our legitimate interests or those of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, ensuring information security, protecting against misuse, enforcing our own legal claims and complying with Swiss law.
Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject in accordance with any applicable law of member states in the European Economic Area (EEA).
Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process the personal data that is required in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the period of time required for the respective purpose or purposes or as required by law. Personal data that is no longer required for processing is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
We only ever process personal data with the consent of the persons concerned. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example, by post, e-mail, instant messaging, contact form, social media or telephone – or when registering for a user account. For example, we may store such information in an address book, a customer relationship management system (CRM system) or similar tools. If we receive data about other persons, the persons transmitting the data are obliged to guarantee data protection for these persons and to ensure the accuracy of this 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 activities and operations, provided that such processing is permitted for legal reasons..
4. Applications
We process personal data about applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent execution of an employment contract. The personal data required is derived in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents, as well as online profiles.
We process personal data about applicants in particular in accordance with Art. 9 (2) (b) GDPR, insofar as the General Data Protection Regulation (GDPR) is applicable.
5. Personal data abroad
We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for processing or to have it processed there.
We may export personal data to all states and territories on Earth, provided that the law there complies with decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - in accordance with decision of the European Commission guarantees an adequate level of data protection.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed 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 data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all rights in accordance with applicable data protection law. Data subjects have the following rights in particular:
Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to assert their data protection rights and ensure transparency. This includes the personal data processed 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 may correct inaccurate personal data, complete incomplete data and restrict the processing of their data.
Deletion and objection: Data subjects may have personal data deleted (‘right to be forgotten’) and object to the processing of their data with future effect.
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 data subjects' rights within the legally permissible framework. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of business secrets or the protection of other persons. We may also refuse to delete personal data in whole or in part on the grounds of statutory retention obligations.
We may charge a fee for exercising these rights in exceptional cases. We will inform data subjects in advance of any costs.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
6.2 Right to appeal
Data subjects have the right to enforce their data protection rights through legal action or to lodge a complaint with a competent 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).
Data subjects have the right to lodge a complaint with a competent European data protection supervisory authority, provided that the General Data Protection Regulation (GDPR) is applicable.
7. Data security
We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk. However, we cannot guarantee absolute data security.
Access to our website is secured by transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the processing of personal data by secret services, police forces and other security authorities.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies – both 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 cookies in text form.
Cookies can be stored in the browser temporarily 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 period. Cookies enable, in particular, a browser to be recognised the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be deactivated and deleted in whole or in part at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request – at least where and to the extent necessary – your express consent to the use of cookies.
For cookies that are used to measure success and reach or for advertising, a general objection (‘opt-out’) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Server log files
We may collect the following information for each visit to our website, provided that it is transmitted by your browser to our server infrastructure or can be determined by our web server: 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-pages of our website accessed including the amount of data transferred, last website accessed in the same browser window (referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to ensure that our website is permanently available, user-friendly and reliable, and to ensure data security and, in particular, the protection of personal data – including by third parties or with the help of third parties.
8.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.
9. Notifications and messages
We send notifications and messages by email and via other communication channels such as instant messaging or text message.
9.1 Measuring success and reach
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 may also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and communications effectively and in a user-friendly manner, as well as permanently, securely and reliably, based on the needs and reading habits of the recipients.
9.2 Consent and objection
In principle, you must explicitly consent to the use of your email address and other contact details, unless such use is permitted for other legal reasons. Where possible, we use the ‘double opt-in’ procedure for any consent, which means that you will receive an email with a web link that you must click on to confirm, so that no misuse by unauthorised third parties can occur. We may log such consents, including IP address and date and time, for evidence and security reasons.
In principle, you can object to receiving notifications and communications such as newsletters at any time. By doing so, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.
9.3 Service provider for notifications and communications
We send notifications and messages with the help of specialised service providers.
In particular, we use:
SendGrid: platform for transactional emails (‘Email delivery made easy’); providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); information on data protection: Privacy Policy.
10. Social Media
We are present on social media platforms and other online platforms in order 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 Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called page insights, insofar as the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook effective and user-friendly.
Further information about the type, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called ‘Addendum for Controllers’ with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page ‘Information about Page Insights’, including ‘Information about Page Insights data’.
11. Third party services
We use the services of specialised third parties to ensure that our activities and operations are sustainable, user-friendly, secure and reliable. These services enable us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons.
For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service.
In particular, we use:
Services of Google: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles", 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 where our services are used" (information provided by Google), "Types of cookies and other technologies used by Google", "Personalised advertising" (activation / deactivation / settings).
Services from Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: "Data protection at Microsoft", "Data protection and privacy (Trust Centre)", Privacy Statement, Privacy Dashboard (data and privacy settings).
11.1 Digital infrastructure
Cyon: Hosting; provider: cyon GmbH (Switzerland); information on data protection: ‘Data protection’, data protection declaration.
Google Cloud including Google Cloud Platform (GCP): Storage space and other infrastructure; Google Cloud-specific providers: Google/ LLC (USA) for users in the USA, among other places / Google Ireland Limited or Google Commerce Limited (both Ireland) for users in the European Economic Area (EEA) and Switzerland, among other places (see ‘Google Contracting Entity’ for providers in other countries); Google Cloud-specific information: ‘Privacy Resource Centre’, “Privacy”, ‘Compliance Resource Centre’, ‘Trust and Safety’.
METANET: Hosting; provider: METANET AG (Switzerland); information on data protection: Privacy Policy, ‘Technical and Organisational Measures’.
e-guma voucher system and ticket system: Hosting, provider: Idea Creation GmbH (Switzerland); data protection information: Data protection – e-guma | Voucher system and ticket system
Kontor, modular business application: Hosting, provider: Manuel Märklin Programming – Home (Switzerland); data protection information: Manuel Märklin Programming – Privacy policy
11.2 Contact options
We use services from selected providers to improve communication with third parties, such as potential and existing customers.
In particular, we use:
Wilken EMS: E-Marketing Suite (EMS); provider: Wilken Software Group; information on data protection: Privacy Policy.
11.3 Audio and video conferences
We use specialised audio and video conferencing services to communicate online. This allows us to hold virtual meetings or conduct online lessons and webinars, for example. Participation in audio and video conferences is also subject to the legal texts of the individual services, such as privacy policies and terms of use.
Depending on your life situation, we recommend muting your microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.
In particular, we use:
Microsoft Teams: Platform for audio and video conferencing, among other things; provider: Microsoft; Teams-specific information: ‘Data protection and Microsoft Teams’.
Zoom: Video conferences; provider: Zoom Video Communications Inc. (USA); information on data protection: Privacy Policy, ‘Data Protection at Zoom’, ‘Compliance Centre’.
11.4 Maps
We use third-party services to embed maps in our website.
In particular, we use:
Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific information: ‘How Google uses location information’.
OpenStreetMap (OSM): map service; provider: OpenStreetMap Foundation (United Kingdom); information on data protection: Privacy Policy.
11.5 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.
In particular, we use:
SoundCloud: Music and podcast platform; provider: SoundCloud Global Limited & Co. KG (Germany); data protection information: Privacy Policy, Cookie Policy.
Vimeo: video platform; provider: Vimeo Inc. (USA); data protection information: Privacy Policy, ‘Privacy’.
YouTube: video platform; provider: Google; YouTube-specific information: ‘Privacy and Security Centre’, ‘My data on YouTube’.
11.6 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols in our website.
In particular, we use:
Adobe Fonts: Fonts; Providers: Adobe Inc. (USA) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Information on data protection: ‘Adobe Privacy Centre’, Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), ‘Questions about privacy?’, ‘Adobe privacy settings’.
Font Awesome: icons and logos; provider: Fonticons Inc. (USA); privacy information: Privacy Policy.
Google Fonts: Fonts; provider: Google; Google Fonts-specific information: ‘Privacy and Google Fonts’, ‘Privacy and data collection’.
IcoMoon: Icons; provider: Roonas (USA); data protection information: Privacy Policy.
MyFonts (by Monotype): Fonts; providers: Monotype Imaging Holdings Inc. (USA) / MyFonts Inc. (USA); information on data protection: ‘Your Privacy’, Privacy Policy, ‘Web Font Tracking Privacy Policy’.
11.7 E-Commerce
We operate an e-commerce business and use third-party services to successfully offer services, content or goods.
In particular, we use:
e-guma: booking platform; provider: Idea Creation GmbH (Switzerland); information on data protection: Privacy Policy.
11.8 Payments
We use specialised service providers to process our customers' payments securely and reliably. The legal texts of the individual service providers, such as general terms and conditions (GTC) or data protection declarations, also apply to the processing of payments.
In particular, we use:
Datatrans: Payment processing; provider: Datatrans AG (Switzerland); data protection information: Data protection provisions, ‘Security & Compliance’.
PostFinance: E-payment solutions; provider: PostFinance AG (Switzerland); data protection information: ‘Legal information and accessibility’, ‘Data protection’ (including data protection declarations).
TWINT: Processing of payments in Switzerland; provider: TWINT AG (Switzerland); Information on data protection: Data protection declaration, ‘Security according to Swiss standards’.
Worldline: Payment processing, in particular with mobile payment solutions; Providers: Worldline Financial Services (Europe) SA (France) and other Worldline companies; Information on data protection: General data protection declaration, Data protection declaration of Worldline Financial Services (Europe) SA, ‘Security in cashless payments’.
11.9 Advertising
We use the option of displaying targeted advertising for our activities and services on third-party platforms such as social media platforms and search engines.
With this type of advertising, we aim to reach people who are already interested in our activities and services or who may be interested in them (remarketing and targeting). To this end, we may transfer relevant information, including personal data, to third parties who enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are registered as a user may assign your use of our website to your profile there.
In particular, we use:
Facebook advertising (Facebook Ads): social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: remarketing and targeting, in particular with the Facebook pixel and custom audiences, including lookalike audiences, privacy policy, ‘advertising preferences’ (registration as a user required).
Google Ads: search engine advertising; provider: Google; Google Ads-specific information: advertising based on search queries, among other things, whereby various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, ‘Advertising’ (Google), ‘Why am I seeing a particular ad?’.
Instagram Ads: social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Information on data protection: Remarketing and targeting, in particular with Facebook Pixel and Custom Audiences, including Lookalike Audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), ‘Advertising Preferences’ (Instagram) (registration as a user required), ‘Advertising preferences’ (Facebook) (registration as a user required).
LinkedIn Ads: Social media advertising; Providers: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Information on data protection: Remarketing and targeting, in particular with the LinkedIn Insight Tag, ‘Data protection’, Privacy policy, Cookie policy, Objection to personalised advertising.
12. Website extensions
We use extensions for our website to enable additional functions.
In particular, we use:
Google reCAPTCHA: spam protection (distinguishing between desired comments from humans and unwanted comments from bots and spam); provider: Google; Google reCAPTCHA-specific information: ‘What is reCAPTCHA?’.
13. Measuring success and reach
We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and the impact of third-party links on our website. However, we can also test and compare how different parts or versions of our online offering are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the IP addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are always shortened (‘IP masking’) in order to comply with the principle of data minimisation through appropriate pseudonymisation.
Cookies may be used to measure success 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 website, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.
In particular, we use:
AWStats: Success and reach measurement; developer: AWStats (free open source software); data protection information: evaluation of server log files on our own server infrastructure, ‘What is AWStats / Features Overview’.
Google Analytics: Success and reach measurement; provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (cross-device tracking) and with pseudonymised IP addresses, which are only transferred in full to Google in the USA in exceptional cases, ‘Data protection’, ‘Browser add-on to deactivate Google Analytics’.
Google Tag Manager: Integration and management of other services for measuring success and reach, as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: ‘Data collected with Google Tag Manager’; further information on data protection can be found in the individual integrated and managed services.
14. Final provisions
We have created this privacy policy using the privacy policy generator from Datenschutzpartner.
We may amend and supplement this privacy policy at any time. We will provide information about such amendments and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.