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Data Policy

Data protection declaration

With this data protection declaration we inform you about what personal data we collect in connection with our activities including our www.luckey-technology.ch website. In particular, we provide information about why, how and where we process which personal data. We also provide information about the rights of people whose data we process.

For individual or additional activities and activities, additional data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

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 recognizes that Swiss data protection law guarantees adequate data protection.

  1. Contact addresses

Responsibility for processing personal data:

Urszula Luckey

Avenue des Acacias 7

CH-1006 Lausanne

data@luckey-technology.ch

In individual cases, there may be other persons responsible for the processing of personal data or a joint responsibility with at least one other person responsible.

1.1 Data protection officer or data protection consultant

We have the following data protection officer or data protection advisor as a contact point for data subjects and authorities for inquiries relating to data protection:

Urszula Luckey

Chemin de Beau Rivage 6

CH-1006 Lausanne

data@luckey-technology.ch

1.2 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art.27 GDPR:

VGS Datenschutzpartner GmbH

Am Kaiserkai 69

20457 Hamburg

Germany

info@datenschutzpartner.eu

The Data Protection Representation serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional contact point for inquiries relating to the GDPR.

  1. Terms and legal bases

2.1 Terms

Personal data is all  information that relates to a specific 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, for example querying, comparing, adapting, archiving and storing , reading, disclosing, obtaining, recording, collecting, deleting, disclosing, sorting, organizing, storing, changing, disseminating, linking, destroying and using personal data.

The European Economic Area (EEA) includes the Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) describes the processing of personal data as processing of personal data.

2.2 Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (Data Protection Act, DSG) and the Data Protection Ordinance (Data Protection Ordinance, DSV).

We process personal data – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with at least one of the following legal bases:

  • 6 Para. 1 lit. b GDPR for the necessary processing of personal data to fulfill a contract with the data subject and to carry out pre-contractual measures.
  • 6 Para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or third parties, unless the fundamental freedoms and fundamental rights as well as the interests of the data subject outweigh this. Legitimate interests include, in particular, our interest in being able to carry out our activities and activities in a permanent, user-friendly, secure and reliable manner and to be able to communicate about them, ensuring information security, protecting against misuse, enforcing our own legal claims and complying with Swiss law.
  • 6 Para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
  • 6 Para. 1 lit. e GDPR for the necessary processing of personal data to carry out a task that is in the public interest.
  • 6 Para. 1 lit. a GDPR for the processing of personal data with the consent of the person concerned.
  • 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.
  1. Type, scope and purpose

We process the personal data that is necessary in order to be able to carry out our activities in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or edge data and usage data, location data, sales data as well as contract and payment data.

We process personal data for the duration that is necessary for the respective purpose(s) or by law. Personal data that no longer needs to be processed will be anonymized or deleted.

We can have personal data processed by third parties. We may process personal data together with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.

We process personal data as a general rule only with the consent of the person concerned. If and to the extent that processing is permitted for other legal reasons, we may waive the need to obtain consent. For example, we may process personal data without consent to fulfill a contract, to comply with legal obligations or to protect overriding interests.

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the exercise of our activities and activities, if and to the extent that such processing is permitted for legal reasons.

  1. Communication

We process personal data in order to be able to communicate with third parties. In this context, we process in particular data that a data subject transmits when contacting us, for example by post or email. We may store such data in an address book or similar means.

Third parties who transmit data about other people are obliged to ensure data protection for such data subjects. To do this, among other things, the accuracy of the transmitted personal data must be ensured.

  1. Data security

We take appropriate technical and organizational measures to ensure data security that is appropriate to the respective risk. With our measures we ensure in particular the confidentiality, availability, traceability and integrity of the processed personal data, but cannot guarantee absolute data security.

Access to our website and our other online presence is carried out using transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a small padlock in the address bar.

Our digital communication is subject – like fundamentally all digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and in other countries. We cannot have any direct influence on the appropriate processing of personal data by secret services, police departments and other security authorities. We also cannot rule out the possibility that individual affected persons will be specifically monitored.

  1. Personal data abroad

We process personal data basically in Switzerland and the European Economic Area (EEA). We can also export or transfer personal data to other countries, in particular in order to process it or have it processed there.

We can transfer personal data to all states and territories on earth as well as elsewhere in the Universe,  provided that the local law is in accordance with Decision of the Swiss Federal Council to ensure adequate data protection and– if and to the extent that the General Data Protection Regulation(GDPR) is applicable– in accordance with Decision of the European Commission ensures adequate 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 with other appropriate guarantees. As an exception, we can export personal data to countries without adequate or suitable data protection if the special 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 affected persons with information about any guarantees or provide a copy of any guarantees.

  1. Rights of data subjects

7.1 Data protection claims

We grant affected persons all claims in accordance with applicable data protection law. Data subjects have the following rights in particular:

  • Information: Affected persons can request information as to whether we process personal data about them and, if so, what personal data is involved. Affected persons also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also, among other things, 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: Affected persons can correct incorrect personal data, complete incomplete data and have the processing of their data restricted.
  • Deletion and objection: Affected persons can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data release and data transfer: Affected persons can request the release of personal data or the transfer of their data to another person responsible.

We may suspend, restrict or refuse to exercise the rights of data subjects to the extent permitted by law. We can inform affected persons of any requirements that need to be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part with reference to trade secrets or the protection of other persons. For example, we can also refuse to delete personal data in whole or in part with reference to legal retention obligations.

We can exceptionally provide for costs for the exercise of the rights. We will inform those affected in advance about any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Those affected are obliged to cooperate.

7.2 Legal protection

Affected persons have the right to enforce their data protection claims through legal action or to file a report or complaint with a responsible data protection supervisory authority.

The data protection supervisory authority for complaints from data subjects against private parties and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner(EDÖB).

European data protection supervisory authorities for complaints from data subjects – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – are as Members of the European Data Protection Board (EDSA). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are structured federally, especially in Germany.

  1. Use of the website

8.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) and 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 text-based cookies.

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 you visit our website and thereby, for example, measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be completely 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 – at least if and to the extent necessary – your express consent to the use of cookies.

8.2 Logging

We can log at least the following information for every access to our website and our other online presence, provided that it is transmitted to our digital infrastructure during such access: 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, website last accessed in the same browser window (referrer).

We log such information, which can also represent personal data, in log files. The information is required in order to be able to provide our online presence in a permanent, user-friendly and reliable manner. The information is also required in order to ensure data security – also by third parties or with the help of third parties.

8.3 Tracking pixels

We may incorporate tracking pixels into our online presence. Web beacons are also known as web beacons. Web beacons – including those from third parties whose services we use – are usually small, invisible images or scripts formulated in JavaScript that are automatically retrieved when you access our online presence. With tracking pixels, at least the same information can be recorded as in log files.

  1. Third Party Services

We use services from specialized third parties in order to be able to carry out our activities in a permanent, user-friendly, safe and reliable manner. Such services allow us, among other things, to embed functions and content into our website. In the case of such embedding, the services used record the IP address of users at least temporarily for technically compelling reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data related to our activities and activities in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

9.1 Digital infrastructure

We use services from specialized third parties in order 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:

9.2 Fonts

We use third-party services to be able to embed selected fonts as well as icons, logos and symbols into our website.

We use in particular:

  1. Final provisions

We have created this data protection declaration with the Data protection Generator  created by Datenschutzpartner.

We can adapt and supplement this data protection declaration at any time. We will inform you about such adjustments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.