In this privacy policy, we, Daniela Sieber GmbH, Klusenstrasse 41, 6043 Adligenswil, represented by Daniela Sieber, explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation and similar documents may govern specific matters. Personal data refers to all information relating to an identified or identifiable person.
If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only share their personal data with us if you are permitted to do so and if this personal data is correct.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA") and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.

1. Controller / data protection officer / representative
Responsible for the data processing that we describe here is:
Daniela Sieber GmbH
Klusenstrasse 41
6043 Adligenswil
Switzerland

Represented by:
Daniela Sieber

If you have any data protection concerns, you can send them to the following contact address: hallo@danielasieber.com
Data protection officer:
Daniela Sieber
+41 41 521 01 05
hallo@danielasieber.com

2. Collection and processing of personal data
We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect from their users when operating our websites, apps and other applications.
Insofar as this is permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from other companies, authorities and other third parties (such as credit agencies). In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we obtain in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, full addresses, etc.). References, your address for deliveries, powers of attorney, information on compliance with legal requirements such as the fight against money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the use or provision of services by you (e.g. payments made, purchases made), information from the media and Internet about your person (insofar as this is appropriate in the specific case, e.g. in the context of a job application, press releases, etc.). e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

3. Purposes of data processing and legal basis
We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular as part of our core business with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this function. In addition, we also process personal data of you and other persons, where permitted and where we deem it appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offer and further develop our products, services and websites, apps and other platforms on which we are present;
•  Communicate with third parties and process their inquiries (e.g. job applications, media enquiries) advertising and marketing (including the organization of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then place you on a blacklist against further advertising mailings);
• market and opinion research, media monitoring;
• assertion of legal claims and defense in connection with legal disputes and official proceedings;
• prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
• prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud); - ensuring our operations, in particular IT, our websites, apps and other platforms;
• video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to us or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone recordings);
• purchase and sale of business divisions, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations and internal regulations of Daniela Sieber GmbH.

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Cookies / tracking and other technologies in connection with the use of our website
We typically use "cookies" and similar technologies on our websites with which your browser or device can be identified. In addition to cookies that are only used during a session and are deleted after your website visit ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser so that it rejects cookies, only stores them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. If you block cookies, certain functions (e.g. language selection, shopping cart, ordering processes) may no longer work.

5. Data disclosure and data transfer abroad
Within the scope of our business activities and the purposes set out in Section 3, we also disclose data to third parties, insofar as this is permitted and appears appropriate to us, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following bodies:

• service providers of ours (within Daniela Sieber GmbH and externally, such as banks, insurance companies), including contract processors (such as IT providers);
• dealers, suppliers, subcontractors and other business partners;
• domestic and foreign authorities, official bodies or courts;
• media in the context of self-promotion;
• the public, including visitors to websites and social media;
• competitors, industry organizations, associations, organizations and other bodies;
• acquirers or parties interested in acquiring business units, companies or other parts of Daniela Sieber GmbH;
• other parties in potential or actual legal proceedings; all joint recipients.

Some of these recipients are in Germany, but they can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which Daniela Sieber is represented by group companies, branches or other offices, as well as to other countries in Europe and the USA where the service providers we use are located (e.g. [Microsoft], [APPLE] etc.).
If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection (we use the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have given your consent or if the data in question has been made generally accessible by you and you have not objected to its processing.

6 Duration of storage of personal data
We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from the initiation, execution to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

7. Data security
We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, controls.

8. Obligation to provide personal data
As part of our business relationship, you must provide the personal data that is necessary for the establishment and execution of a business relationship and the fulfillment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

9. Profiling and automated decision-making
In principle, we do not use fully automated decision-making (as regulated in Art. 22 GDPR) for the establishment and implementation of the business relationship or otherwise. Should we use such procedures in individual cases, we will inform you of this separately if this is required by law and inform you of the associated rights.

10. Rights of the data subject
You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another body (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.
The exercise of such rights generally requires that you clearly prove your identity (e.g. by means of a copy of your identity card, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.
Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11 Changes
We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.
Source: This privacy policy is based on the template of the DSAT - Data Protection Self Assessment Tool and has been adapted to the actual circumstances of the website www.danielasieber.com.