This privacy statement provides information on which personal data we process in connection with our Anão website and our other services. In particular, we provide information about what personal data we process, for what purpose, how and where. With this data protection declaration, we also inform you about the rights of persons whose data we process.
Our offer is subject to Swiss data protection law as well as any applicable foreign data protection law, such as 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 addresses
Responsible for processing personal data:
Digital Hub AG
We point out if there are other responsible parties for processing personal data in individual cases.
2. Processing of personal data
Personal data means any information relating to an identified or identifiable individual. A data subject is a person about whom personal data are processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, such as in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (FADP).
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights as well as interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to provide our offer in a permanent, user-friendly, secure and reliable manner and to be able to advertise for it as required, information security as well as protection against misuse and unauthorised use, the enforcement of our own legal claims and compliance with Swiss law.
Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data in order to comply with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
Art. 6 para. 1 lit. e DSGVO 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 DSGVO for the processing of personal data with the consent of the data subject.
2.3 Type, scope and purpose
We process those personal data that are necessary to provide our offer 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 marginal data and usage data, location data, sales, contract and payment data.
We process personal data for the duration that is required for the respective purpose or purposes or by law. Personal data whose processing is no longer necessary is anonymised or deleted. Persons whose data we process have in principle a right to deletion.
We process personal data in principle only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject provides to us voluntarily and ourselves when contacting us - for example, by letter, email, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book or with comparable tools. If you transmit personal data to us via third parties, you are obliged to guarantee data protection vis-à-vis such third parties and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, procure from publicly accessible sources or collect in the course of providing our service, insofar as and to the extent that such processing is permissible for legal reasons.
2.4 Processing of personal data by third parties, including abroad
We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties.
Such third parties are generally located in Switzerland and in the European Economic Area (EEA). Such third parties may also be located in other states and territories on Earth as well as elsewhere in the universe, provided that their data protection laws are in accordance with the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - in accordance with assessment of the European Commission, or if adequate data protection is ensured for other reasons, such as by an appropriate contractual agreement, in particular on the basis of standard contractual clauses, or by an appropriate certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the requirements under data protection law, such as the express consent of the data subject, are met.
3. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.
Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.
Data subjects whose personal data we process may - if and to the extent that the GDPR applies - revoke consent they have given at any time with future effect and may object to the processing of their personal data at any time.
Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
4. Data security
We take appropriate and suitable technical and organisational measures to ensure data protection and in particular data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.
Access to our online offer is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Access to our online offer is subject - as is basically any use of the Internet - to mass surveillance without cause and without suspicion as well as other surveillance by security authorities in Switzerland, in the European Union (EU), in the United States of America (USA) and in other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.
5. Use of the website
Cookies can be stored temporarily in your browser as "session cookies" when you visit us or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when you close your browser. Permanent cookies have a specific storage period. Cookies make it possible in particular to recognise your browser the next time you visit our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
For cookies that are used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via the 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).
5.2 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted to our server infrastructure by your browser or can be determined by our web server: Date and time including time zone, Internet Protocol (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 (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
5.3 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.
6. Notifications and communications
We send notifications and communications such as newsletters via email and other communication channels such as instant messaging.
6.1 Performance and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to offer notifications and communications effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
6.2 Consent and objection
You must basically expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure where possible, i.e. you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorised third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
You can basically unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. Notifications and messages that are absolutely necessary for our offer remain reserved.
6.3 Service providers for notifications and messages
We use in particular:
7. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our offer. In this context, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
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 and to the extent that the GDPR is applicable. 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 be able to provide our social media presence on Facebook in an effective and user-friendly way.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in the Data Protection Statement of Facebook. We have entered into the so-called "Addendum for Responsible Parties" 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 corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights Data".
8. Third-party services
We use third-party services in order to be able to provide our offer in a durable, user-friendly, secure and reliable manner. Such services may also be used to embed content on our website. Such services - for example hosting and storage services, video services and payment services - require your Internet Protocol (IP) address, as such services cannot otherwise transmit the corresponding content.
For their own security-related, statistical and technical purposes, third parties whose services we use may also process data in connection with our offer as well as from other sources - including cookies, log files and counting pixels - in aggregated, anonymised or pseudonymised form.
We use in particular:
8.1 Digital infrastructure
We use third party services to provide necessary digital infrastructure for our services. This includes, for example, hosting and storage services from specialised providers.
8.2 Social media features and social media content
We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and other ways.
We use in particular:
We engage in e-commerce and use third party services to successfully provide services, content or goods.
We use payment service providers to securely and reliably process payments from our customers. The terms and conditions of the respective payment service providers, such as general terms and conditions (GTC) or data protection statements, apply to the processing.
We use in particular:
PayPal (including Braintree): Processing of payments; Provider: PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg) / PayPal Pte. Ltd. (Singapore); privacy disclosures: Privacy Statement, "Statement on Cookies and Tracking Technologies".
Credit card services such as Visa and Mastercard. American Express is not supported.
We use the possibility of displaying targeted advertising for our offer on third parties such as social media platforms and search engines.
We would like to use such advertising in particular to reach people who are interested in our offer or who already use our offer (remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - information 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 can, if necessary, assign the use of our offer to your profile there.
We use in particular:
Google Ads: search engine advertising; Google Ads-specific privacy disclosures: advertising based on search queries, among other things, using various domain names - notably doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why do I see a certain advertisement?".
11. Performance and Reach Measurement
We use services and programmes to determine how our online offering is used. In this context, we may, for example, measure the success and reach of our online offer and the effect of third-party links to our website. We can also, for example, test and compare how different versions of our online offer or parts of our online offer are used ("A/B test" method). Based on the results of the performance and reach measurement, we can, in particular, correct errors, strengthen particularly popular content or make improvements to our online offering.
When using services and programmes for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are basically shortened in order to follow the principle of data economy through the corresponding pseudonymisation and to improve the data protection of visitors to our website ("IP masking").
When using services and programmes for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. In principle, user profiles are only created pseudonymously. We do not use user profiles to identify individual visitors to our website. Individual services with which you are registered as a user can, if necessary, assign the use of our online offer to your profile with the respective service, whereby you usually had to give your consent to this assignment in advance.
We use in particular:
Google Analytics: performance and reach measurement; Google Analytics-specific information on data protection: measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy", "Browser Add-on to disable Google Analytics".
Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; Google Tag Manager-specific information on data protection: "Data collected with Google Tag Manager"; further information on data protection can be found with the individual integrated and managed services..