Privacy Policy

2.                     Who is the controller for processing your data?

​

Unless we tell you otherwise in an individual case, we remain the controller for processing your data under this Privacy Policy.

You may contact us for data protection concerns and to exercise your rights under Section 11 as follows:

​

Shift Health Education Sarl
Chemin de la Douane 24a
CH-1278 La Rippe

dataprotection@shift-health.ch 

 

 

3.                     What data do we process?

​

We process various categories of data about you. The main categories of data are the following: 

​

• Technical data:

When you use our website or other online offerings (e.g. website, booking platform, etc), we collect the IP address of your terminal device and other technical data. To ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 12). Technical data as such does not permit us to draw conclusions about your identity. 

Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This can help us to provide an appropriate layout of the website or to show you a website customized for your region, for example. We know through which provider you access our offerings (and therefore also the region) because of the IP address, but usually this does not tell us who you are. However, this changes for example when you create a user account, because personal data can then be linked with technical data (for example, we can know the browser you use to access an account through our website). Examples of technical data include protocols («logs») that are created in our systems (for example the log of user logins to our website).

​

• Registration data:

This is data that we collect in the context of a registration (e.g. online) which you provide to us (e.g. user name, e-mail). 

Registration data includes the information you provide when you create an account on our website (for example username, password, name, e-mail). It also includes the data that we may require from you before you can use certain free services, such as, for example, our WLAN service, in this case: Name, e-mail and telephone number; or the redemption of vouchers, in this case: Name, address, contact details, time of redemption. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges, biometric data for identification) (see the category «other data»). 

 

• Communication data:

When you are in contact with us via the contact form, by e-mail, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication.

Communication data is your name and contact details, the means, place and time of communication and usually also its content (i.e. the content of e-mails, letters, chats, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID document number or a password set by you or your press pass. For secure identification, the following required information must be provided for media inquiries: Publisher, name of publication, title, first name, surname, postal address, e-mail address and telephone number of the reporter.

 

• Master data:

With master data we mean the basic data that we need, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing and promotional purposes, such as name and contact details, and information about, for example, your role and function, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (for example as a contact person of the business partner), or because we wish to address you for our own purposes. We receive master data from you (for example when you make a registration), from parties you work for, and from public sources such as public registers or the internet (websites, social media, etc.). 

​

Master data includes data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries), reports (for example from the media), or official documents (for example excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives. 
In relation to contact persons and representatives of our customers, suppliers and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates and information about interactions with these persons. 
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity. 

 

• Contract data:

This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, data concerning the provision of services, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about feedback (for example complaints, feedback about satisfaction, etc.). 

Contract data includes information about the conclusion of the contract, about your contracts, for example, the type and date of conclusion, information from the application process (such as the application for the performance of our products or services) and information about the relevant contract (for example its duration) and the performance and administration of the contracts (for example information related to billing, customer service, technical assistance and enforcement of contractual claims). Contract data also includes information about deficiencies, complaints and changes to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contract data also includes financial data, such as credit information (meaning information that allows us to draw conclusions about the likelihood that receivables will be paid), information about reminders and debt collection. We receive this data partly from you (for example when you make payments), but also from credit agencies and debt collection companies and from public sources (for example a commercial register).

​

• Behavioral and preference data:

This is data about your behavior and your preferences, such as responses to electronic messages, navigation on the website, interactions with our social media profiles, etc.), potentially supplemented by information from third parties (including from publicly accessible sources). See the section on “How we use cookies, other tracking technologies and social media plugins” with regard to tracking. 

 

Behavioral data is information about certain actions, such as your response to electronic communications (for example if and when you have opened an e-mail) or your location, as well as your interaction with our social media pages and your participation in sweepstakes, competitions and similar events. For example, we may collect your location data wirelessly through unique codes that your cell phone emits or when you use our website. We will use signage at the relevant locations to tell you about the collection of anonymous motion profiles, and we will only create personalized motion profiles with your consent.
 

Preference data tells us what your needs are, which products or services might be of interest to you or when and how you will likely respond to messages from us. We obtain this information from the analysis of existing data, such as behavioral data, so that we can get to know you better, tailor our advice and offers more precisely to you and generally improve our offers. To improve the quality of our analyses, we may combine this data with other data that we also obtain from third parties, such as address dealers, administrative offices and publicly available sources such as the Internet, for example with information about your household size, income bracket and purchasing power, shopping behavior, contact data of relatives, and anonymous information from statistical offices. 
Behavioral and preference data may be analyzed on a personally identifiable basis (for example to show you personalized advertising), but also on a non-identifiable basis (for example for market research or product development). Behavioral and preference data may also be combined with other data (for example, motion data may be used for contact tracing as part of a health protection concept).

 

• Other data:

This includes data that we collect in connection with official or legal proceedings (e.g. files, evidence, etc.), data collected on the basis of health protection (e.g. as part of protection concepts), access details or rights (e.g. visitor lists), participation in events.

​
 

Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases. If you wish to enter into contracts with us or use our services, you must also provide us with certain data. When using our website, the processing of technical data cannot be avoided. 

​

We can also collect data from public sources (for example debt collection registers, commercial registers, the media, or the internet including social media).

​

​

​

4.                     For what purposes do we process your data?

​

We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

 

The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.

We process data for the conclusion, administration and performance of contractual relationships.

​

We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us.

​

We further process your data for market research, to improve our services and operations, and for product development.

​

We may also process your data for security and access control purposes.

​

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).

​

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

​

We may process your data for further purposes, for example as part of our internal processes and administration.

​

​

5.                     On what basis do we process your data?

​

Where we ask for your consent for certain processing activities we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

​

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law).

 

Where we receive sensitive personal data, we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

​

​

6.                     What applies in case of profiling and automated individual decisions?

​

We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics.

​

In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.

​

​​