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Privacy Policy

1. Data Protection at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data are all data by which you can be personally identified. Detailed information on the subject of data protection can be found in the privacy policy set out below this text.

Data Collection on This Website

Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. The operator’s contact details can be found in the section “Responsibility” in this privacy policy.

How do we collect your data?
On the one hand, your data are collected when you provide them to us. This may include, for example, data that you enter into a contact form.

Other data are collected automatically or after your consent when you visit the website by our IT systems. These are mainly technical data (e.g. internet browser, operating system, or time of page access). These data are collected automatically as soon as you enter this website.

What do we use your data for?
Some of the data are collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. If contracts are concluded or initiated via the website, the transmitted data are also processed for contractual offers, orders, or other inquiries.

What rights do you have regarding your data?
You have the right at any time to obtain free information about the origin, recipients, and purpose of your stored personal data. You also have the right to request correction or erasure of these data.

If you have given consent to data processing, you may revoke this consent at any time with effect for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You may contact us at any time regarding this or any other questions relating to data protection.

2. Hosting

We host the content of our website with the following provider:

dogado

The provider is dogado GmbH, Antonio-Segni-Straße 11, 44263 Dortmund, Germany (hereinafter “dogado”). This website is hosted on servers in Germany.

For details, please refer to dogado’s privacy policy: www.dogado.de/datenschutz (opens in a new tab).

The use of dogado is based on Article 6(1)(f) GDPR. We have a legitimate interest in ensuring the most reliable presentation of our website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Data Processing Agreement

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract required under data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data are data by which you can be personally identified. This privacy policy explains which data we collect and what we use them for. It also explains how and for what purpose this is done.

Please note that data transmission over the Internet (e.g. communication by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Responsibility

Responsible for data processing on this website is:

Spiegelberg Consulting
Bergstraße 23
8810 Horgen
Switzerland

Phone: +41 79 826 27 24
Email: info@spiegelberg.consulting

As a natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial retention periods). In the latter case, deletion will take place once these reasons cease to apply.

Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Article 6(1)(a) GDPR or Article 9(2)(a) GDPR if special categories of data pursuant to Article 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Article 49(1)(a) GDPR.

If you have consented to the storage of cookies or access to information on your end device (e.g. via device fingerprinting), data processing is additionally based on Section 25(1) TDDDG. Consent may be revoked at any time.

If your data are required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Article 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to comply with a legal obligation on the basis of Article 6(1)(c) GDPR. Data processing may also be based on our legitimate interest pursuant to Article 6(1)(f) GDPR. Information on the respective legal bases applicable in individual cases is provided in the following sections of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we cooperate with various external parties. In some cases, it is necessary to transfer personal data to these external parties.

We only disclose personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure to tax authorities), if we have a legitimate interest pursuant to Article 6(1)(f) GDPR, or if another legal basis permits the disclosure. When using processors, we disclose personal data only on the basis of a valid data processing agreement. In the case of joint processing, an agreement on joint processing is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You may revoke consent already given at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Article 21 GDPR)

IF DATA PROCESSING IS BASED ON ARTICLE 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ARTICLE 21(1) GDPR).

IF YOUR PERSONAL DATA ARE PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ARTICLE 21(2) GDPR).

Right to Lodge a Complaint with the Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged infringement. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedies.

Right to Data Portability

You have the right to receive data which we process automatically on the basis of your consent or in fulfillment of a contract, in a commonly used, machine-readable format, or to have them transmitted to a third party. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Right of Access, Rectification, and Erasure

Within the framework of applicable legal provisions, you have the right at any time to obtain free information about your stored personal data, their origin and recipients, and the purpose of data processing, and, if applicable, a right to rectification or erasure of these data. You may contact us at any time regarding this or other questions relating to personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

  • If you contest the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request restriction of processing.
  • If the processing of your personal data was or is unlawful, you may request restriction of processing instead of erasure.
  • If we no longer need your personal data, but you require them for the establishment, exercise, or defense of legal claims, you have the right to request restriction instead of erasure.
  • If you have lodged an objection pursuant to Article 21(1) GDPR, a balancing of interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request restriction of processing.

If processing has been restricted, such data may, apart from storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser’s address bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Server Log Files

The provider of this website automatically collects and stores information in so-called server log files, which your browser transmits automatically. These are:

  • browser type and browser version
  • operating system used
  • referrer URL
  • host name of the accessing computer
  • time of the server request
  • IP address

These data are not merged with other data sources. They are collected on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation of the website and in protecting it against misuse; for this purpose, server log files must be recorded.

No Content from Third Parties

This website loads all of its content, including fonts and images, from its own server. No fonts, scripts, maps, videos, or other resources are retrieved from third-party providers, and no cookies are set. Your browser therefore does not establish a connection to any third party when you open a page of this website, and no data are transmitted to third parties in the process.

Inquiries by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass these data on without your consent.

The processing of these data is based on Article 6(1)(b) GDPR if your inquiry is related to the performance of a contract or necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Article 6(1)(f) GDPR) or on your consent (Article 6(1)(a) GDPR), if requested. Consent may be revoked at any time.

The data you send to us via contact inquiries remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions, especially statutory retention periods, remain unaffected.

Contact Form on This Website

If you use the contact form, the details you enter there – your name, your email address, your organisation if you give one, and your message – are transmitted over an encrypted connection (TLS) to our web server in Germany and forwarded from there by email to our office mailbox. The web server passes the message on and does not store it: it is not written to a database and not kept in a file. The email itself remains in our mailbox and is handled as described under “Inquiry by Email, Telephone, or Fax” above.

No third-party form or captcha service is involved. To keep automated spam out, the form contains a field that is invisible to you and evaluated by our server, and it discards submissions that arrive within a few seconds of the page being opened. Neither procedure profiles you or sets a cookie.

The legal basis is Article 6(1)(b) GDPR where your enquiry concerns a contract or steps taken before entering into one, and otherwise our legitimate interest in answering enquiries addressed to us (Article 6(1)(f) GDPR).

If your browser cannot reach our server, the form falls back to preparing the message in your own email programme, which you then send yourself. In that case no data at all reach this website.

5. Where Your Data Are Processed

Hosting in Germany

This website is hosted on servers in Germany. The data that arise when you visit the site, in particular the server log files described above, are therefore processed within the European Union, by our hosting provider acting as a processor on our instructions.

Controller Established Outside the European Union

The controller named under “Responsibility” above is established in Switzerland and not in the European Union. Insofar as this website is directed at users in the European Union, the GDPR applies to the processing described here alongside Swiss law.

Transfer of Data to Switzerland

When you contact us by email, by telephone, or through the contact form, the content of your enquiry reaches the controller in Switzerland. Personal data are therefore transferred to a country outside the European Union. By decision of the European Commission of 26 July 2000, confirmed when the Commission reviewed its adequacy decisions in January 2024, Switzerland provides an adequate level of protection for personal data within the meaning of Article 45 GDPR. No additional safeguards are required for this transfer.

Swiss Federal Act on Data Protection

In addition to the GDPR, the Swiss Federal Act on Data Protection (FADP) applies to this processing. Under the FADP you have the right to obtain information about the personal data we process about you, to have inaccurate data corrected, to have data deleted, and to receive data you have provided to us in a common electronic format.

Supervisory Authority in Switzerland

You may report a matter to the Swiss supervisory authority: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, Switzerland, www.edoeb.admin.ch (opens in a new tab). This applies in addition to the right, described above, to lodge a complaint with a supervisory authority in the European Union.

Parts of this text are based on a template by www.e-recht24.de (opens in a new tab).

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