Privacy Policy

This Privacy Policy sets out the personal data we process in connection with our activities and operations, including our www.salenture.com website In particular, we provide information about what personal data we process, for what purpose, how and where. We also provide information about the rights of individuals whose data we process.

For individual or additional activities and operations, further data protection declarations as well as 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 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 an adequate level of data protection.

1. Contact addresses

Responsibility for processing personal data:

privacy@salenture.com

We point out if there are other persons responsible for processing personal data in individual cases.

2. Terms and legal basis

2.1 Terms

Personal data is any information relating to an identified 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, the querying, matching, adapting, archiving, storing, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, ordering, organising, storing, modifying, disseminating, linking, destroying and using of personal data.

The European Economic Area (EEA) comprises the Member States of the European Union (EU) and 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 Data Protection Act (Data Protection Act, DPA) and the Data Protection Ordinance (Data Protection Ordinance, DPA).

We process - if and to the extent that 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 and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner and to communicate about them, the guarantee of information security, protection against misuse, 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 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.
• Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.

3. nature, scope and purpose

We process those personal data that are necessary to carry out our activities and operations in a durable, 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 data and contract and payment data.

We process personal data for the period necessary for the relevant purpose(s) or as required by law. Personal data that is no longer required to be processed will be anonymised or deleted.

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

We process personal data basically only with the consent of the persons concerned. If and to the extent that the processing is permitted for other legal reasons, we may choose not to obtain consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.

In this context, we process in particular information that a data subject provides to us voluntarily when contacting us - for example, by letter post, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management (CRM) system or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of this personal data.

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

4. Personal data abroad

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

Personal data is processed in Switzerland and in the European Economic Area (EEA).

We may export personal data to all states and territories on Earth as well as elsewhere in the universe, provided that the law there in accordance with Decision of the Swiss Federal Council and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - according to Decision of the European Commission

We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate 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 performance of a contract. We will be happy to provide data subjects with information on any guarantees or a copy of any guarantees on request.

5. Rights of data subjects

5.1 Data protection rights

We grant data subjects all rights under applicable data protection law. Data subjects have the following rights in particular:

• Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what that personal data is. Data subjects also receive the information necessary to assert their data protection rights 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: Data subjects may have incorrect personal data corrected, incomplete data completed and have the processing of their data restricted.
• Deletion and objection: Data subjects may have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
• Data surrender and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

We may suspend, restrict or refuse the exercise of data subjects' rights to the extent permitted by law. We can draw the attention of data subjects to any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to legal obligations to retain data.

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

We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

5.2 Right to complain

Data subjects have the right to enforce their data protection claims by legal means or to lodge a complaint with a competent data protection supervisory authority

The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Data subjects have the right to lodge a complaint with a competent European data protection supervisory authority, if and to the extent that the General Data Protection Regulation (GDPR) is applicable.

6. Data security

We take appropriate technical and organisational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security

Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communications - like basically all digital communications - are subject to mass surveillance without cause or suspicion and other monitoring 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 secret services, police agencies and other security authorities.

7. Use of the website

7.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as 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 cookies in text form.

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. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies, at least if and to the extent necessary.

For cookies 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).

7.2 Server logfiles

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure 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 website 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.

We store such information, which may also represent personal data, in server log files.

7.3 Tracking pixel

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. With pixel counters, the same information can be collected as in server log files.

8. Notifications and notices

We send notifications and communications by email and through other communication channels, such as instant messaging or SMS.

8.1 Performance and reach measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message 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 send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.

8.2 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, we use the "double opt-in" procedure where possible, i.e. you 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 opt out of receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is without prejudice to necessary notifications and communications in connection with our activities and operations.

8.3 Service providers for notifications and communications

We send notifications and communications using specialised service providers

We use in particular:

• Amazon Simple Email Service (SES): email delivery platform; provider: Amazon Web Services Inc (USA); privacy information: privacy statement, "Privacy Centre", "Frequently Asked Questions about Privacy"
• Mailgun: Platform for transactional emails; Providers: Mailgun Technologies Inc (USA) together with affiliates ("Mailgun Group"); Privacy information: Privacy Policy
• Twilio: Communication platform; Providers: Twilio Inc (USA) / Twilio Ireland Limited (Ireland); data protection information: Privacy Policy

9. Social Media

We are present on social media platforms and other online platforms in order to be able to communicate with interested persons and to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA)

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our Social Media presence on Facebook, including the so-called Page Insights, if and to the extent that the General Data Protection Regulation (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 help us deliver our social media presence on Facebook in an effective and user-friendly way.

Further information on the nature, scope and purpose of data processing, information on the rights of data subjects as well as 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 "Responsible Party Addendum" with Facebook and have thereby 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 "Page Insights Information" including "Page Insights Data Information"

10. Third Party Services

We use services provided by specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such services enable us, among other things, to embed functions and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.

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

We use in particular:

• Services of Google: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and Security Principles", privacy policy, "Google is committed to complying with applicable privacy laws", "Privacy Guide for Google Products", "How we use data from websites or apps where our services are used" (provided by Google), "Types of cookies and other technologies used by Google", "Personalised advertising" (enable/disable/settings)

10.1 Digital infrastructure

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

We use in particular:

• Amazon Web Services (AWS): Storage 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); Data protection information: Data protection declaration, "Privacy Centre", "Frequently Asked Questions about Privacy", "Data Protection Regulation (GDPR) Centre"
• Cloudflare: Content Delivery Network (CDN); Cloudflare Inc. (USA); Data protection information: "Privacy Policy", Privacy Policy, Cookie Policy
• StackPath CDN: Content Delivery Network (CDN); Provider: StackPath LLC (USA) / Highwinds Network Group Inc. (USA); privacy information: privacy policy

10.2 Maps

We use third party services to embed maps on our website

We use in particular:

• Google Maps including Google Maps Platform: mapping service; provider: Google; Google Maps-specific disclosures: "How Google uses location information"

10.3 Fonts

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

We use in particular:

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

11. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

We use in particular:

• Google reCAPTCHA: spam protection (distinguishing between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA-specific details: "What is reCAPTCHA?" ("What is reCAPTCHA?")
• hCaptcha: Spam protection (distinguishes between wanted comments from humans and unwanted comments from bots as well as spam); Provider: Intuition Machines Inc. (USA); Privacy policy: Privacy Policy, "AI Ethics Policy"
• jQuery (OpenJS Foundation): Free JavaScript library; Provider: OpenJS Foundation (USA) using StackPath CDN; Privacy information: Privacy Policy (OpenJS Foundation), Cookie Policy (OpenJS Foundation)
• Turnstile: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); Cloudflare Inc. (USA); Privacy information: "Turnstile, a user- and privacy-friendly alternative to CAPTCHA", "Privacy", privacy statement

12. Success-and-reach-measurement

We try to determine how our online offer is used. As part of this, we may, for example, measure the success and reach of our activities and operations and the impact of third party links to our website. But we can also, for example, try out and compare how different parts or versions 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 popular content or make improvements to our online offering.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are basically shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation.

The measurement of success and reach may involve the use of cookies and the creation of user profiles. Any user profiles created include, for example, the individual 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, any user profiles are created exclusively in pseudonymous form and are not used to identify individual users. Individual services of third parties with which users are registered can, if necessary, allocate the use of our online offer to the user account or user profile of the respective service.

We use in particular:

• Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: 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 administration of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: "Data collected with Google Tag Manager"; further information on data protection can be found with the individual integrated and managed services.

13. Final provisions

We may amend and supplement this Privacy Policy at any time. We will inform about such adjustments and additions in an appropriate manner, in particular by publishing the respective current data protection declaration on our website.