1. Preface

    

2.  

3. SwissSalary Ltd. (28, Bernstasse, Urtenen-Schönbühl 3322, phone: 031 950 07 07, email: info@swisssalary.ch) is committed to protecting personal data and takes this subject very seriously. Your personal data will be treated confidentially and in compliance with due respect for data protection provisions and this Privacy Policy.

    

   The following information is to show you how SwissSalary Ltd. collects and uses personal data, what information is collected during your visit and how it is used. Below (Section 4.0), you will receive information about your rights pursuant to the Federal Law on Data Protection of June 19, 1992 (SR 235.1, “DSG”) and the Ordinance to the Federal Act on Data Protection of June 14, 1993 (SR 235.11, “VDSG”) and Regulation 2016/679 (EU) of the European Parlament and of the Council on protection of individuals with regard to personal data processing and on the free movement of such data [...] of April 27, 2016 (“EU-GDPR”) and how you can exercise them.

    

   Your personal data will generally not be handed over to third parties without your consent or a legal obligation and will only be used by us for technical administration of the websites. If you are one of our customers or partners, we use your data for customer and partner administration and for marketing purposes, and only within the respectively required and legally permitted framework. As a SwissSalary Ltd. customer or partner, you have the right to object to the use of data for advertising purposes at any time.

    

   Swiss Salary Ltd. only provides support for the collection or transfer of personal data to government institutions and authorities, provided that there is mandatory national legislation for this purpose.

    

 

1. General Information

2.  

   The subject of this Privacy Policy is the processing of personal data by SwissSalary Ltd. as a service provider as well as via the website at www.swisssalary.ch.

    

 

1. Processing of Personal Data

2.  

   In general, the website of SwissSalary Ltd. can be used without providing personal data. Personal data like name, address, telephone number or email is only collected if this information is voluntarily provided by the user.

    

   Swiss Salary Ltd. uses your personal data for the following purposes:

    

1. Fulfillment of Contract
   

   To fulfill contracts, SwissSalary Ltd. processes personal data of its customers, their employees and our partners. This also applies to information provided to us by customers and partners in the context of pre-contractual correspondence. The specific purpose of data processing depends on the respective product and the customer or partner application, and can also be used to create needs analyzes. This will allow us to better understand which products and services are suitable for you. To fulfill the contract, we need your name, address, telephone number or email for SwissSalary Ltd. employees to be able to contact you. Details of the respective data processing purposes can be found in the contract documents and our general terms and conditions.

   This processing is based on cl. 4 and 13 of the DSG, as well as cl. 6 of the GDPR.

    

2. Strengthening and Optimization of Customer and Partner Relationship
   

   Swiss Salary Ltd. strives to continually improve customer and partner relationship. Therefore, we kindly ask you to participate in our surveys. The survey results support us in the needs-oriented adaptation of SwissSalary Ltd.'s products and services. This processing is based on cl. 4 and 13 of the DSG, as well as cl. 6 of the GDPR.

    

3. Data Processing and Analysis for Marketing Purposes
   

   Your requests are important to us. Therefore, we endeavor to give you information about products and services that meet your needs. The findings from our business relationship and from market research help SwissSalary Ltd. in this endeavor. Swiss Salary Ltd. assures you that the data used in this context will always be processed in accordance with applicable data protection legislation.

   Important: You may object to the use of your personal data for this purpose at any time.

   What exactly do we analyze and process?

    

• the results of our marketing efforts to measure our campaigns’ efficiency and impact;
• information from your visits of our website and Customer Portal;
• We analyze the possible needs for our products and services.



This processing is based on cl. 4 and 13 of the DSG, as well as cl. 6 of the GDPR.

 

4. Email Marketing and Newsletters
   

   After registration through our Customer Portal, you can receive newsletters and emails with information about interesting topics, news about our company, invitations to customer events, etc. We need your email address for the mailout, all other information is voluntary. You may reject these personalized notifications or the newsletter at any time.

    

   The processing of your data for this purpose is carried out by SwissSalary Ltd. on the basis of your consent under cl. 4 of the DSG and cl. 6 of the GDPR. The legislator has certain requirements for the effectiveness of electronic consent used to sign up for the newsletter. This also includes the logging of your consent form. We therefore log the date, time and the text of the informed consent, the fact of checkbox selection, your email and all other optional information. We also log the date and time the confirmation link and the link in the confirmation email are clicked. We only collect this information to comply with legal obligations.

    

    

   You have the right to revoke your consent at any time. However, the revocation of consent does not affect the lawfulness of the processing carried out by the point of the revocation.

    

5. Actions to Ensure Your Safety
   

   Among other things, SwissSalary Ltd. uses your personal data in the following cases:

    

• We analyze your data to protect you or your company against fraudulent activities. This can occur, for example, if you have been the victim of identity theft or if unauthorized persons have otherwise gained access to your user account;
• To improve the reliability of our web applications, our IT support works closely with you in case of technical issues. In this context, we also evaluate the logging of page views, actions taken, etc.;
• To ensure IT security;
• To be able to record and prove facts in case of possible legal disputes.

  This processing is carried out based on cl. 4 of the DSG as well as cl. 6 of the GDPR.

   

6. Subject to Your Consent
   

   If you have given your consent to the processing of your personal data for one or more specific purposes, we shall be permitted to process your data. With the future in mind, this consent can be revoked at any time without incurring additional costs on your part. However, the revocation of consent does not affect the lawfulness of the processing carried out by the point of the revocation.

   This processing is carried out based on cl. 4 of the DSG as well as cl. 6 of the GDPR.

    

7. Subject to Legal Requirements or in the Public Interest
   

   Swiss Salary Ltd. is subject to a wide variety of legal requirements. To meet these legal obligations, we only process the necessary personal data.

    

   According to the applicable data protection regulations, your personal data will not be stored longer than we need for the purposes of respective processing. If the data is no longer required for the fulfillment of contractual or legal obligations (e.g. retention obligation), we carry out regular deletion.

    

   The personal data processed by SwissSalary Ltd. on behalf of the customer or the partner is deleted exclusively upon written request from the respective data owner.

    

    

1. Cookies

2.  

   Our website partly uses so called cookies. They are small text files that make it possible to store specific device-related information about users' access devices (PCs, smartphones, etc.). They are used, on the one hand, for user-friendliness of web pages thus serving the users (for example, recording of login data) and, on the other hand, for the collection of website usage statistical data to analyze it for service offer improvement. 

    

3.  

4. We recommend that you set the Internet browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate automatic deletion of cookies when the Internet browser is closed. If cookies are deactivated, the functionality of the SwissSalary Ltd. website may be limited.

    

1. Google AdWords and Conversion Tracking

    

2.  

   To draw attention to SwissSalary Ltd. products and services, we use Google Adwords ads and in this context we use Google's conversion tracking. 

    

   Google Adwords ads appear on Google Network sites after search queries and can be controlled via the ad settings. When an ad is clicked, Google places a cookie on the user's computer. It is valid for about 30 days. For more information about the applicable cookie technology, please refer to Site Stats and Privacy Policy by Google.

    

   The cookie technology lets Google and us know when a user clicks an ad and gets redirected to our website. This information is used only for ad optimization and for statistical analysis. We do not receive any information that might allow personal identification of visitors. The statistics provided to us by Google only include the total number of users that have clicked one of our ads and, if applicable, whether they have been redirected to a conversion-tagged page of our website.

3.  

   If you do not want this, you can prevent the storage of the cookie required for this technology, for example, in your Internet browser settings. In this case, your visit will not be recorded in the user statistics

    

1. Google Analytics

    

2.  

   This website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses so-called “cookies”, i.e. text files placed on your computer, to help analyze how users use the website. The information generated by the cookie about your use of the website (including your IP address that is however anonymized using the _anonymizeIp() method to prevent it from being assigned to a connection) is transmitted to and stored by Google on a server in the United States.

    

   Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

    

   You may object to the collection of data by Google Analytics with effect for the future by installing a deactivation add-on (http://tools.google.com/dlpage/gaoptout?hl=de) for your browser. As an alternative to the browser add-on or Internet browsers of mobile devices, please click this link to prevent the collection by Google Analytics on this website in the future (the opt-out only works in this Internet browser and only for this domain). In doing so, an opt-out cookie is stored on your device. If you clear the cookies in this Internet browser, you must click this link again.

    

1. Using XING Button

2.  

   The SwissSalary Ltd. website uses XING network functionality. The provider is XING AG: 29-32, Dammtorstrasse, Hamburg, Germany 20354. Each time you visit our page that contains XING features, it will connect to XING servers. To our knowledge, no personal data is stored. In particular, no IP addresses are stored nor usage behavior is evaluated.

3.  

   For more information on privacy and the XING Share button, please refer to XING's privacy policy at www.xing.com/app/share.

    

1. Using Facebook Social Plug-Ins

2.  

3. Our website uses social plugins (“plugins”) from social network facebook.com run by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA (“Facebook”). All users outside the United States and Canada are under jurisdiction of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. Facebook social plugins are identified by one of the Facebook logos (white “f” on a blue tile, term “Like” or a “Thumbs up” sign) or with the additional clause “Facebook Social Plugin". The list and appearance of Facebook social plugins can be found here: developers.facebook.com/docs/plugins/.

    

   If you go to a website containing such a plugin, your Internet browser establishes a direct connection to Facebook servers. The content of the plugin is transmitted by Facebook directly to your Internet browser and integrated by it in the website. As a website provider, SwissSalary Ltd. has no influence on the scope of data collected by Facebook with the help of this plugin and therefore informs you based on our current information as follows:

4.  

   By integrating Facebook social plugins, Facebook receives the information that a user has accessed the corresponding website. If the user is logged in to Facebook at the time, Facebook can assign the visit to his/her Facebook account. If there is an interaction between the user and the plugin, for example if the user clicks the “Like” button or makes a comment, the corresponding information is transmitted from the Internet browser directly to Facebook and stored there. Even if a user is not registered with Facebook, there is a possibility that Facebook will find and save his/her IP address. According to Facebook, an anonymized IP address is only stored in Germany.

5.  

   For the purpose and scope of data collection as well as further processing and use of the data by Facebook and your related rights and configuration options for the protection of your privacy, please refer to Facebook’s Privacy Policy:

    www.facebook.com/about/privacy/.

    

   If you have a Facebook user account and do not want Facebook to collect data about you via our website and link it to your member data stored on Facebook, you must log out of Facebook before visiting our website. Other settings and disagreement as to the use of data for promotional purposes are possible in Facebook profile settings: www.facebook.com/settings.

    

1. Using Twitter Plug-Ins (e.g. “Twit” button)

2.  

   Swiss Salary Ltd. has installed on its website so-called social plugins (“plugins”) of microblogging service Twitter run by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (“Twitter”). The plugins can be recognized by the Twitter logo, for example in the form of a blue “Twitter bird”. An overview of Twitter plugins and their appearance can be found here: twitter.com/about/resources/Buttons.

    

3.  

   When you visit a page of our website containing such a plugin, your Internet browser establishes a direct connection to Twitter servers. The content of the plugin is transmitted by Twitter directly to your Internet browser and integrated in the page. The integration allows Twitter to receive the information that your Internet browser has accessed the corresponding page of our website, even if you do not have a profile on Twitter or are currently not logged in to Twitter. This information (including the IP address) is sent directly to a Twitter server in the USA from your Internet browser and stored there.

4.  

   If you are logged in to Twitter, Twitter can assign the visit to our website to your Twitter account. If you interact with the plugins, for example by clicking the “Tweet” button, the information is also transmitted directly to a Twitter server and stored there. The information will also be published on your Twitter account and displayed there in your contacts.

    

   For the purpose and scope of data collection as well as further processing and use of the data by Twitter and your related rights and configuration options for the protection of your privacy, please refer to Twitter’s Privacy Policy: twitter.com/privacy.

    

   Your privacy settings can be changed under your Twitter Account Settings at twitter.com/account/settings.

    

   If you do not want Twitter to assign the data collected via our website directly to your Twitter account, you must log out of Twitter before visiting our website. You can also completely prevent Twitter plugins from being loaded with add-ons for your Internet browser, e.g. with the “NoScript” script blocker (http://noscript.net/).

    

1. Using LinkedIn Plug-Ins

2.  

   Our website uses social plugins (“plugins”) from social network LinkedIn run by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). LinkedIn plugins on this website are identified by the LinkedIn logo or the “Recommend” button.

3.  

   When you visit a page of our website containing such a plugin, your Internet browser establishes a direct connection to LinkedIn servers. The content of the plugin is transmitted by LinkedIn directly to your Internet browser and integrated in the page. The integration allows LinkedIn to receive the information that your Internet browser has accessed the corresponding page of our website, even if you do not have a profile on LinkedIn or are currently not logged in to LinkedIn. This information (including IP address) is transmitted directly to a LinkedIn server in the USA from your Internet browser and stored there.

4.  

   If you are logged in to LinkedIn, LinkedIn can assign the visit to our website to your LinkedIn account. If you interact with the plugins, for example by clicking the “LinkedIn” button, the information is also transmitted directly to a LinkedIn server and stored there. The information will also be published on your LinkedIn account and displayed there in your contacts.

5.  

   For the purpose and scope of data collection as well as further processing and use of the data by LinkedIn and your related rights and configuration options for the protection of your privacy, please refer to LinkedIn’s Privacy Policy: www.linkedin.com/legal/privacy-policy.

    

1. Contact Requests

2.  

   If you use decide to contact SwissSalary Ltd. via the website, the information provided by SwissSalary Ltd. will only be used to process your request. Transfer to third parties as well as comparison of the data collected this way with data possibly collected by other components of our website are not made.

    

1. Comments and Posts

2.  

   We look forward to any comment or other posts on our website. Please note that your IP address will be saved in each case. This measure serves as a safeguard in case of illegal content (insults, prohibited political propaganda, etc.) in comments and/or other posts. We may be prosecuted in this case as website operator even for an illegal comment or post, and are therefore interested in the identity of the author.

    

1. Newsletter

2.  

   To be regularly up to date, we have established a newsletter. To subscribe to it, you need a valid email address that requires confirmation. For this reason, we will send you a confirmation message to the email address you provided. Only after the verification of this email you will receive information from SwissSalary Ltd. The required field “Name” in the newsletter serves to address you personally.

    

3.  

4. By registering for our newsletter, we will save your IP address and the date and time of your registration. This as a safeguard in the event a third party abuses your email address and subscribes to our newsletter without your knowledge. The data collected will only be used for the subscription to SwissSalary Ltd. newsletter. We do not collect additional data and do not forward it to third parties. The data collected this way is also not compared with data possibly collected by other components of our website.

5.  

6. Your consent to data storage and use can be revoked at any time. The revocation can be triggered via a link in the newsletter or by sending a message to the address provided in the Legal Notice.

    

1. Rejection of Promotional Emails

2.  

   The use of contact information published in the context of the Legal Notice obligation for sending unsolicited advertising and information materials is hereby rejected. The operators of the sites expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example by means of spam emails.

    

1. Amendments to Privacy Policy

2.  

   Swiss Salary Ltd. reserves the right to amend this Privacy Policy from time to time following the updates to the website. We therefore recommend that you visit this page regularly to ensure that you agree with the amendments. All amendments will also be published in the newsletter.

    

1. Revocation, Amendments, Corrections and Updates

2.  

   You have the right to receive information about your personal data stored, its origin and recipient and the purpose of data processing as well as a right to correct, block or delete this data free of charge and at any time. For this purpose, as well as for further questions about personal data, you can always use the address given in the Legal Notice or contact the Data Protection Officer.

    

1. Data Protection Officer

2.  

   If you have any questions about your personal data processing or need further information on privacy, please contact our Data Protection Officer.

   Head of Leagal & Compliance

   SwissSalary Ltd.

   28, Bernstrasse

   Urtenen-Schönbühl 3322

    

   legal-compliance@swisssalary.ch
   www.swisssalary.ch

    

1. Overview of Partners and Contractors

2.  

   Swiss Salary Ltd. has entered into contracted data processing agreements with strategic partners and other service providers. Swiss Salary Ltd. uses listed service providers as approved subcontractors. An exact overview of the partners can be found here.

    

1. Contracted Data Processing Agreement

2.  

   Under cl. 28 et seq. EU-GDPR, the processing of personal data by a service provider, the so-called contracted data processing (CDP), is a detailed legal provision. If you provide personal information about your company, your business partners or customers to a service provider, it is important that you do so legally and in accordance with the new European Regulation.

    

   If you directly or indirectly process data through SwissSalary Ltd. or make it available for service request processing, we now offer you the opportunity to conclude a GDPR-compliant contract agreement with us that grants legal certainty. Please write to info@swisssalary.ch and we will contact you for elaboration.

    

   Important: No additional costs for contract request, preparation and conclusion are incurred by you!

    

1. Privacy and Data Security at SwissSalary Ltd.

2.  

   Swiss Salary Ltd. constantly takes engineering, personnel, organizational and technical actions to maintain and ensure the safety of objects and data as well as undisturbed operation.

    

   The technical and organizational data protection actions (TOA) are actions with regard to

    

• ·organizational, entry, admission, access, transfer, order, availability control and separation rule
• the type of data exchange, provision of data, nature and circumstances of processing, data management as well as the nature and circumstances of data transmission
• actions taken to permanently safeguard the confidentiality, integrity, availability and resilience of systems and services, and the ability to rapidly restore the availability of personal data and access to it in the event of a physical or technical incident. A procedure for periodical verification, review and evaluation of the effectiveness of these actions.

  In general, you can assume that technical and organizational actions of SwissSalary Ltd. are constantly adapted to technical progress and further development. Swiss Salary Ltd. strives to take comprehensive and state-of-the-art actions required to enhance security.

   

   

  1. Rights of Affected Persons

  2.  

You have the right to receive information about your personal data stored, its origin and recipient and the purpose of data processing free of charge. If we process your data on behalf of a partner or a customer, please understand that the respective parties involved must be consulted. If data is incorrect, you can ask us for the correction of the data and for supplement in case of its incompleteness. If we give your data to third parties with your consent, we will inform them about this under the appropriate legal circumstances.

 

If the processing is carried out in the public interest or on the basis of the balance of interests, you have the right to object to the processing for reasons that arise from your particular situation.

If your data is no longer needed for the original purpose, if you have revoked your consent and there is no other legal basis for data processing or your data is processed unlawfully, you have the right to ask us to delete your data. This also applies if you have legally objected to the data processing or your data must be deleted to fulfill a legal obligation.

 

Please note that before deleting your data, we must verify that there is no legitimate reason or legal obligation to process your personal information.

 

You may request that your data be restricted if the accuracy of the data is contradicted, if we still need the data to assert our rights, if the data is processed unlawfully or if you have objected to data processing and if there is still no proof of your concern.

 

If you provide us with personal information, you have the right to receive it on request in a transferable format or to have that information provided to another person you name.

 

You also have the right to file a complaint at any time with relevant regulatory authority if our conduct in relation to your personal data gives grounds to this.

 

January 2019 - Version 3.0