Privacy Policy

With this privacy policy, we inform you about the processing of personal data in connection with our activities and operations, including our website www.salenture.com and other websites operated by us. We inform you in particular about the purposes, methods, and locations where we process personal data. We also inform you about the rights of individuals whose data we process.

For specific or additional activities and operations, additional privacy policies or other information about data protection may apply.

We are subject to Swiss data protection law and, where applicable, foreign data protection law, such as the European Union (EU) with the General Data Protection Regulation (GDPR).

The European Commission recognized on July 26, 2000, that Swiss data protection law ensures adequate data protection. On January 15, 2024, the European Commission confirmed this adequacy decision.

1. Contact Address

Responsibility for the processing of personal data:

In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties.

2. Terms and Legal Bases

2.1 Terms

Affected Person: A natural person whose personal data we process.

Personal Data: Any information relating to an identified or identifiable natural person.

Special Categories of Personal Data: Data concerning trade union membership, political, religious, or philosophical views and activities, data concerning health, intimate life, or racial or ethnic origin, genetic data, biometric data that uniquely identify a natural person, data concerning criminal and administrative sanctions or prosecutions, and data concerning social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adjusting, archiving, storing, reading, disclosing, obtaining, collecting, deleting, revealing, organizing, storing, modifying, distributing, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

Note: The European General Data Protection Regulation (GDPR) refers to the processing of personal data as processing personal data and the processing of special categories of personal data as processing special categories of personal data (Art. 9 GDPR).

2.2 Legal Bases

We process personal data in accordance with Swiss data protection law, particularly the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

We process personal data, where and to the extent the General Data Protection Regulation (GDPR) is applicable, according to at least one of the following legal bases:

• Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the fulfillment of a contract with the affected person and for the implementation of pre-contractual measures.
• Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to protect legitimate interests – including those of third parties – provided that the fundamental freedoms and rights and interests of the affected person do not prevail. Such interests include, in particular, the permanent, humane, secure, and reliable performance of our activities and operations, ensuring information security, protection against misuse, enforcement of legal claims, and compliance with Swiss law.
• Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under 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 to perform a task in the public interest.
• Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the affected person.
• Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the affected person or another natural person.
• Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, especially with the consent of the affected persons.

3. Type, Scope, and Purpose of Processing Personal Data

We process the personal data necessary to perform our activities and operations permanently, humanely, securely, and reliably. The processed personal data may particularly fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during our activities and operations, as long as such processing is legally permissible.

We process personal data, as necessary, with the consent of the affected persons. We may process personal data without consent in many cases, for example, to fulfill legal obligations or to protect overriding interests. We may also seek consent from affected persons even if their consent is not required.

We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data, particularly depending on legal retention and limitation periods.

4. Disclosure of Personal Data

We may disclose personal data to third parties, have them processed by third parties, or process them jointly with third parties. Such third parties are particularly specialized providers whose services we utilize.

We may disclose personal data, for example, to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and economic information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, and insurance companies.

5. Communication

We process personal data to communicate with third parties. In this context, we process in particular data that an affected person transmits when contacting us, for example, by letter mail or email. We may store such data in an address book or similar tools.

Third parties transmitting data about other persons are obligated to ensure data protection towards such affected persons. This includes ensuring the accuracy of the transmitted personal data.

6. Data Security

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and other online presences occurs via transport encryption (SSL / TLS, particularly with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting websites without transport encryption.

Our digital communication is subject – like any 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 other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police authorities, and other security authorities. We also cannot exclude the possibility that an affected person is specifically monitored.

7. Personal Data Abroad

We primarily process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, particularly to process them there or have them processed.

We may export personal data to all states and territories on earth, provided that the local law ensures adequate data protection according to a decision by the Swiss Federal Council and – where the General Data Protection Regulation (GDPR) is applicable – also according to a decision by the European Commission.

We may transfer personal data to countries whose law does not ensure adequate data protection if data protection is guaranteed for other reasons, particularly based on standard data protection clauses or other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, such as the explicit consent of the affected persons or a direct connection with the conclusion or fulfillment of...

8. Rights of Affected Persons

8.1 Data Protection Claims

We grant affected persons all claims according to the applicable data protection law. Affected persons particularly have the following rights:

• Information: Affected persons can request information about whether we process personal data about them and, if so, which personal data it is. Affected persons also receive the information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information about the processing purpose, 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 have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.
• Deletion and Objection: Affected persons can have personal data deleted ("right to be forgotten") and object to the processing of their data with future effect.
• Data Release and Data Transfer: Affected persons can request the release of personal data or the transfer of their data to another controller.

We may postpone, restrict, or refuse the exercise of the rights of affected persons within the legally permissible framework. We may inform affected persons about any prerequisites for the exercise of their data protection claims. For example, we may refuse to provide information entirely or partially by referring to business secrets or the protection of other persons. We may also refuse the deletion of personal data entirely or partially by referring to legal retention obligations.

We may, exceptionally, provide for costs for the exercise of rights. We inform affected persons in advance about any costs.

We are obligated to identify affected persons requesting information or asserting other rights with reasonable measures. Affected persons are required to cooperate.

8.2 Legal Protection

Affected persons have the right to assert their data protection claims through legal channels or to file a complaint with a 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).

European data protection supervisory authorities – where the General Data Protection Regulation (GDPR) is applicable – are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), data protection supervisory authorities are federally structured, particularly in Germany.

9. Use of the Website

9.1 Cookies

We may use cookies. Cookies – both our 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 need not be limited to traditional text-form cookies.

Cookies can be stored in the browser temporarily as "session cookies" or for a specific period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies allow, in particular, recognizing a browser on the next visit to our website and thus, for example, measuring the reach of our website. Permanent cookies can also be used for online marketing.

Cookies can be disabled or deleted entirely or partially at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request – at least where necessary – explicit consent for the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection ("opt-out") is possible for many 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).

9.2 Logging

We may log at least the following information for each access to our website and other online presences, provided they are 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, accessed individual sub-page of our website including transferred data volume, and the last website accessed in the same browser window (refe...

We log such information, which may also be personal data, in log files. The information is necessary to provide our online presence permanently, humanely, and reliably. The information is also necessary to ensure data security – also through third parties or with the help of third parties.

9.3 Counting Pixels

We may embed counting pixels in our online presence. Counting pixels are also known as web beacons. Counting pixels – also from third parties whose services we use – are usually small, invisible images or JavaScript scripts automatically retrieved when accessing our online presence. Counting pixels can collect at least the same information as log files.

10. Notifications and Communications

10.1 Success and Reach Measurement

Notifications and communications can contain web links or counting pixels that record whether an individual message has been opened and which web links have been clicked. Such web links and counting pixels can also capture the use of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement to send notifications and communications effectively, user-friendly, permanently, securely, and reliably based on the needs and reading habits of the recipients.

10.2 Consent and Objection

You must generally consent to using your email address and other contact addresses unless the use is permissible for other legal reasons. For obtaining double-confirmed consent, we may use the "Double Opt-in" procedure. In this case, you will receive a notification with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidence and security reasons.

You can generally object to receiving notifications and communications, such as newsletters, at any time. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Necessary notifications and communications related to our activities and operations remain reserved.

10.3 Service Providers for Notifications and Communications

We send notifications and communications with the help of specialized service providers.

We particularly use:

• Amazon Simple Email Service (SES): Email sending platform; Provider: Amazon Web Services Inc. (USA); Privacy information: Privacy Policy, "Data Privacy Center", "Frequently Asked Questions on Data Privacy".
• Mailgun: Platform for transactional emails; Providers: Mailgun Technologies Inc. (USA) together with subsidiaries ("Mailgun Group"); Privacy information: Privacy Policy.
• Twilio: Communication platform; Providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); Privacy information: Privacy Policy.

11. Social Media

We are present on social media platforms and other online platforms to communicate with interested persons and provide information about our activities and operations. Personal data may also be processed outside Switzerland and the European Economic Area (EEA) in connection with such platforms.

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, apply. These provisions particularly inform about the rights of affected persons directly towards the respective platform, including the right to information.

For our social media presence on Facebook, including the so-called page insights, we are – where the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta Companies (including in the USA). Page insights provide insights into how visitors interact with our Facebook presence. We use page insights to provide our social media presence on Facebook effectively and user-friendly.

Further information about the type, scope, and purpose of data processing, information about the rights of affected persons, and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook, particularly agreeing that Facebook is responsible for ensuring the rights of affected persons. For the so-called page insights, the corresponding information can be found on the "Information about Page Insights" page, including "Information about Page Insights Data".

Users of social media platforms have the opportunity to log in or register with our online offer using their respective user account ("social login"). The respective terms of the relevant social media platforms apply.

12. Services of Third Parties

We use services of specialized third parties to perform our activities and operations permanently, humanely, securely, and reliably. With such services, we can embed functions and content into our website. In such embedding, the services used capture the IP addresses of the 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, anonymized, or pseudonymized manner. This includes, for example, performance or usage data to provide the respective service.

We particularly use:

• Services from Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and Switzerland; General privacy information: "Privacy and Security Principles", "Information on how Google uses personal data", Privacy Policy, "Google's commitment to compliance with applicable data protection laws", "Data Privacy Guide for Google Products", "How we use data from sites or apps that use our services", "Types of cookies and similar technologies used by Google", "Ads you control" ("Personalized Advertising").

12.1 Digital Infrastructure

We use services of specialized third parties to use the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We particularly use:

• Amazon Web Services (AWS): Storage space and other infrastructure; Providers: Amazon Web Services Inc. (USA) for users in Switzerland / Amazon Web Services EMEA SARL (Luxembourg) for users in the European Economic Area (EEA); Privacy information: Privacy Policy, "Data Privacy Center", "Frequently Asked Questions on Data Privacy", "GDPR Center".
• Cloudflare: Content Delivery Network (CDN); Cloudflare Inc. (USA); Privacy information: "Privacy", Privacy Policy, Cookie Policy.

12.2 Appointment Scheduling

We use services of specialized third parties to schedule appointments online, for example, for meetings. In addition to this privacy policy, the directly visible conditions of the used services, such as terms of use or privacy policies, apply.

12.3 Map Material

We use services of third parties to embed maps into our website.

We particularly use:

• Google Maps, including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".

12.4 Fonts

We use services of third parties to embed selected fonts, icons, logos, and symbols into our website.

We particularly use:

• Font Awesome: Icons and logos; Provider: Fonticons Inc. (USA); Privacy information: Privacy Policy.
• Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: "Your privacy and Google Fonts", "Privacy and Data Collection" (for Google Fonts).

12.5 Payments

We use specialized service providers to process payments from our customers securely and reliably. The terms and conditions of the individual service providers, such as general terms and conditions (GTC) or privacy policies, apply additionally to the processing of payments.

We particularly use:

• Apple Pay: Payment processing; Providers: Apple Inc. (USA) / Apple Distribution International Limited (Ireland) for individuals in the EEA, the United Kingdom, and Switzerland; Privacy information: "Apple Privacy Policy", "Apple Privacy Policy for Customer Data", Transparency Report.
• PayPal (including Braintree): Payment processing; Providers: PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg) / PayPal Pte. Ltd. (Singapore); Privacy information: Privacy Policy, "Cookies and Tracking Technologies Statement".
• Stripe: Payment processing; Providers: Stripe Inc. (USA) / Stripe Payments Europe Limited (SPEL, Ireland) for users in the European Economic Area (EEA) and Switzerland, and partly in the United Kingdom / Stripe Payments UK Limited (United Kingdom) and Stripe Capital Europe Limited (Ireland) partly for users in the United Kingdom; Privacy information: "Stripe Privacy Center", Privacy Policy, Cookie Policy.

13. Website Extensions

We use extensions for our website to utilize additional functions. We can use selected services from suitable providers or use such extensions on our own digital infrastructure.

We particularly use:

• Google reCAPTCHA: Spam protection (distinguishing between desired content from humans and undesired content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?".
• Turnstile: Spam protection (distinguishing between desired content from humans and undesired content from bots and spam); Cloudflare Inc. (USA); Privacy information: "Turnstile, a user and privacy-friendly alternative to CAPTCHA", "Privacy", Privacy Policy.

14. Success and Reach Measurement

We try to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party notices or check how different parts or versions of our online offer are used ("A/B test" method). Based on the results of success and reach measurement, we can particularly fix errors, strengthen popular content, or make improvements.

For success and reach measurement, the IP addresses of individual users are usually captured. IP addresses are generally shortened ("IP masking") in this case to follow the principle of data minimization through corresponding pseudonymization.

Cookies can be used in success and reach measurement, and user profiles can be created. Potentially created user profiles include, for example, the individual pages visited or viewed content on our website, information about the size of the screen or browser window, and the – at least approximate – location. Generally, any user profiles created are exclusively pseudonymized and not used to identify individual users. Individual third-party services, where users are logged in, can potentially assign the use of our online offer to the user account or user profile at the respective service.

We particularly use:

• Google Marketing Platform: Success and reach measurement, particularly with Google Analytics; Provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (Cross-Device Tracking) with pseudonymized IP addresses, which are only exceptionally fully transferred to Google in the USA, Privacy Policy for Google Analytics, "Browser Add-on to disable Google Analytics".
• Google Tag Manager: Embedding and managing services from Google and third parties, particularly for success and reach measurement; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further privacy information can be found with the individual embedded and managed services.

15. Final Provisions

We may adjust and supplement this privacy policy at any time. We will inform about such adjustments and supplements in an appropriate form, particularly by publishing the current privacy policy on our website.