We are subject to Swiss data protection law and 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 adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
ANNA GAMMA Institut Zen & Leadership GmbH
We point out if there are other persons responsible for the processing of personal data in individual cases.
Data Protection Officer
We have the following data protection officer as a point of contact for data subjects and as a contact for supervisory authorities in the event of data protection-related enquiries:
ANNA GAMMA Institut Zen & Leadership GmbH
2. Terms and legal basis
Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as 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, in particular the Federal Data Protection Act (DPA) and the Ordinance to the Federal Data Protection Act (DPA).
We process personal data - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR 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 GDPR 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 GDPR 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 GDPR for the necessary processing of personal data for the performance of a task which is in the public interest.
- Art. 6 para. 1 lit. a GDPR 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 the vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process those personal data that are necessary to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. In particular, such personal data may 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 of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required is 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 only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the fulfilment of a contract with the data subject and for corresponding pre-contractual measures, in order to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example, by letter, 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 or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection with regard to these persons and 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 basically in Switzerland and in 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.
We may export personal data to all states and territories on earth as well as elsewhere in the universe, provided that the law there guarantees adequate data protection according to the assessment of the Federal Data Protection and Information Commissioner (FDPIC) or according to the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - according to the 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. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law 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 about any guarantees or a copy of any guarantees on request.
5. Rights of data subjects
Data subjects about whom we process personal data have rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.
Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request confirmation free of charge as to whether we are processing personal data relating to them. In this case, data subjects may request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.
Data subjects whose personal data we process may - if and insofar as the GDPR applies - revoke consent they have given at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects about whom we process personal data have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
6. Data security
We take suitable technical and organisational measures to ensure data security that is appropriate to the respective risk. However, we cannot guarantee absolute data security.
Our website is accessed using 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 communication is subject - as is basically all digital communication - 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
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.
In the case of cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via 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 log files
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. This information is necessary in order 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.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also referred to 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. Counting pixels can be used to collect the same information as in server log files.
We allow you to post comments on our website. In this context, we process in particular those details that a person commenting transmits to us themselves, but also the Internet Protocol (IP) address used as well as the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.
We enable you to subscribe to e-mail notifications of new comments from other people. In this context, we need your e-mail address in particular so that we can notify you or have you notified by e-mail. You can unsubscribe from such comment notifications at any time.
8. Notifications and messages
We send notifications and communications by email and via other communication channels such as instant messaging or SMS.
8.1 Performance and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and messages 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 communications 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
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such 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 which 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.
In principle, you can object to 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 with the help of specialised service providers.
In particular, we use:
9. Social media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland) - 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 provide our social media presence on Facebook in an effective and user-friendly manner.
10. Third party services
We use services from specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into 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-related, statistical and technical purposes, third parties whose services we use may process data in connection with 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 from 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", data protection statement, "Google is committed to complying with applicable data protection laws", "Guide to data protection in Google products", "How we use data from websites or apps on or in which our services are used" (information from Google), "Types of cookies and other technologies used by Google", "Personalised advertising" (activation / deactivation / settings).
10.1 Digital infrastructure
We use the services of specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
In particular, we use:
10.2 Audio and video conferencing
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences as well as blurring the background or having a virtual background superimposed.
We use in particular:
- Zoom: video conferencing; provider: Zoom Video Communications Inc. (USA); information on data protection: data protection declaration, "Data Protection at Zoom", "Legal Compliance Centre".
10.3 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.
In particular, we use:
- YouTube: Video platform; Provider: Google; YouTube-specific information: "Privacy and Security Center", "My Data on YouTube".
11. Success and reach measurement
We use services and programmes to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offer or parts 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 offer.
When using services and programmes for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are always shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation and thus to improve user data protection.
When using services and programmes for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. As a matter of principle, user profiles are only created pseudonymously. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.
We use in particular:
- Matomo: performance and reach measurement; provider: Matomo (free open source software); data protection information: use on our own server infrastructure and with pseudonymised Internet Protocol (IP) addresses, "List of all Matomo Features".
12. Final provisions
We have created this data protection declaration with the data protection generator of Datenschutzpartner.
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.