Privacy Policy

With this privacy policy, we inform you about the personal data we process in connection with our activities and operations, including our claudekeller.com website. We specifically inform about the purposes, methods, and locations of how we process personal data. We also inform about the rights of individuals whose data we process.

Additional privacy policies and other legal documents such as General Terms and Conditions (GTC), Terms of Use, or participation conditions may apply to individual or additional activities and operations.

We are subject to Swiss data protection law and any applicable foreign data protection law, especially that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsible for the processing of personal data:

Claude Keller
Claude Keller & Partner Ltd.
Bederstrasse 94
CH-8002 Zürich

ck@claudekeller.com

In individual cases, there may be other parties responsible for the processing of personal data or joint responsibility with at least one other party.

2. Terms and Legal Bases

2.1 Terms

Personal data are all information relating to an identified or identifiable natural person. An affected person is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adjusting, archiving, storing, retrieving, disclosing, obtaining, recording, collecting, deleting, revealing, ordering, organizing, storing, altering, distributing, linking, destroying, and using personal data.

The European Economic Area (EEA) includes the Member States of the European Union (EU), as well as the Principality of Liechtenstein, Iceland, and Norway. Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal Bases

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

We process personal data – as far as the General Data Protection Regulation (GDPR) is applicable – according to at least one of the following legal bases:

  • Art. 6 (1) lit. b GDPR for processing personal data necessary for the performance of a contract with the data subject or to carry out pre-contractual measures.
  • Art. 6 (1) lit. f GDPR for processing personal data necessary to protect the legitimate interests of us or a third party, unless the fundamental freedoms and rights and interests of the data subject override. Legitimate interests include our interest in being able to exercise our activities and operations permanently, user-friendly, securely, and reliably and to communicate about it, ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
  • Art. 6 (1) lit. c GDPR for processing personal data necessary for compliance with a legal obligation to which we are subject according to any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 (1) lit. e GDPR for processing personal data necessary for the performance of a task carried out in the public interest.
  • Art. 6 (1) lit. a GDPR for processing personal data with the consent of the data subject.
  • Art. 6 (1) lit. d GDPR for processing personal data necessary to protect the vital interests of the data subject or another natural person.

3. Type, Scope, and Purpose

We process the personal data necessary to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data can fall into categories such as inventory and contact data, browser and device data, content data, meta/communication data, usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration necessary for the respective purpose or purposes, or as required by law. Personal data that is no longer necessary for processing is anonymized or deleted.

We may have personal data processed by third parties. We may process personal data together with third parties or transfer personal data to third parties. These third parties are particularly specialized providers whose services we use. We also ensure data protection with such third parties.

We generally process personal data only with the consent of the individuals concerned. To the extent that processing is permitted for other legal reasons, we may forgo obtaining consent. For example, we may process personal data without consent to fulfill a contract, comply with legal obligations, or protect overriding interests.

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, provided such processing is legally permissible.

4. Communication

We process personal data to communicate with third parties. In this context, we specifically process data transmitted by an affected person when making contact, for example, by postal mail or email. We may store such data in an address book or with similar tools.

Third parties transmitting data about other individuals are required to ensure data protection for such affected individuals. Among other things, this includes ensuring the accuracy of the transmitted personal data.

5. Data Security

We implement appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we especially ensure the confidentiality, availability, traceability, and integrity of the processed personal data, although we cannot guarantee absolute data security.

Access to our website and our other online presence is secured through transport encryption (SSL / TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

Our digital communication is subject 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, as is generally the case with any digital communication. We cannot directly influence the corresponding processing of personal data by intelligence services, police departments, and other security authorities. We also cannot exclude the possibility that individual affected persons are being specifically monitored.

6. Personal Data Abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other states, in particular, to process or have them processed there.

We can export personal data to all states and territories on Earth and elsewhere in the universe, provided the law there ensures adequate data protection according to the decision of the Swiss Federal Council and – as far as the General Data Protection Regulation (GDPR) is applicable – according to the decision of the European Commission.

We may transmit personal data to states whose law does not ensure adequate data protection, provided data protection is guaranteed for other reasons, especially based on standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to states without adequate or appropriate data protection if the specific data protection requirements are met, for example, the explicit consent of the affected persons or a direct connection with the conclusion or execution of a contract. We are happy to provide affected individuals with information about any guarantees upon request or provide a copy of any guarantees.

7. Rights of Data Subjects

7.1 Data Protection Claims

We grant data subjects all claims according to applicable data protection law. In particular, data subjects have the following rights:

  • Access: Data subjects can request information on whether we process personal data about them, and if so, which personal data. Furthermore, data subjects receive the information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data itself, as well as information on the purpose of processing, the duration of storage, any disclosure or export of data to other states, and the origin of the personal data.
  • Correction and Restriction: Data subjects can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Deletion and Objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data Release and Data Transfer: Data subjects can request the release of personal data or the transfer of their data to another controller.

We may defer, restrict, or refuse the exercise of the rights of data subjects within the legally permissible framework. We can point out to data subjects any conditions that may need to be met for the exercise of their data protection claims. For example, we may partially or fully refuse access with reference to trade secrets or the protection of other persons. Similarly, we may partially or fully refuse the deletion of personal data with reference to statutory retention obligations.

We may exceptionally provide for costs for exercising rights. We inform data subjects in advance about any costs.

We are obligated to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are required to cooperate.

7.2 Legal Protection

Data subjects have the right to enforce their data protection claims through legal proceedings or to file a complaint with a competent data protection supervisory authority.

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

European data protection supervisory authorities for complaints from data subjects – as far as the General Data Protection Regulation (GDPR) is applicable – are organized as members in the European Data Protection Board (EDPB) In some Member States in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, especially in Germany.

8. Website Usage

8.1 Cookies

We may use cookies. These cookies – both our own (first-party cookies) and those from third parties whose services we utilize (third-party cookies) – are data stored in the browser. Such stored data are not limited to traditional cookies in text form.

Cookies can be temporarily stored in the browser 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 duration. Cookies, in particular, allow a browser to be recognized on the next visit to our website, thereby enabling us to measure the reach of our website, for example. Permanent cookies can also be used for online marketing, for example.

Cookies can be disabled or deleted in the browser settings at any time, either wholly or partially. Without cookies, our website may not be fully available. We actively request – at least as far and as necessary – explicit consent to the use of cookies.

For 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).

8.2 Logging

We may log at least the following information for each access to our website and our other online presence, provided these 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 interface and version, browser including language and version, called individual sub-page of our website including the amount of data transmitted, the last webpage called in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary to provide our online presence permanently, user-friendly, and reliably. Furthermore, this information is necessary to ensure data security – also by third parties or with the help of third parties.

8.3 Tracking Pixels

We may integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we utilize – typically consist of small, invisible images or scripts formulated in JavaScript that are automatically retrieved when accessing our online presence. Tracking pixels can capture at least the same information as logged in log files.

9. Notifications and Communications

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

9.1 Success and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also capture the use of notifications and communications on a personal basis. We require this statistical capture of use for success and reach measurement, to be able to send notifications and communications effectively and user-friendly based on the needs and reading habits of the recipients, as well as permanently, securely, and reliably.

9.2 Consent and Objection

You generally need to consent to the use of your email address and other contact addresses unless the use is permitted for other legal reasons. For obtaining confirmed consent, we may use the “double opt-in” procedure. In this case, you will receive a notification with instructions for the 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 also object to the statistical capture of use for success and reach measurement. Mandatory notifications and communications related to our activities and operations are reserved.

9.3 Service Providers for Notifications and Communications

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

In particular, we use:

10. Social Media

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

The general terms and conditions (GTC), terms of use, privacy policies, and other provisions of the individual operators of these platforms also apply. These provisions specifically inform about the rights of affected individuals directly against the respective platform, which includes, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – to the extent that 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 those in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly provide our social media presence on Facebook.

Further information on the nature, scope, and purpose of data processing, information on the rights of affected individuals, 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, agreeing in particular that Facebook is responsible for ensuring the rights of affected individuals. For the so-called Page Insights, the relevant information can be found on the “Information about Page Insights” page including “Information about Page Insights Data“.

11. Third-Party Services

We use services from specialized third parties to carry out our activities and operations permanently, user-friendly, securely, and reliably. With such services, we can embed functions and content into our website. For such embedding, the services used technically capture the IP addresses of users at least temporarily for mandatory reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. These are, for example, performance or usage data to be able to offer the respective service.

We use in particular:

11.1 Digital Infrastructure

We use services from specialized third parties to utilize the required digital infrastructure related to our activities and operations. These include, for example, hosting and storage services from selected providers.

We use in particular:

11.2 Audio and Video Conferences

We use specialized services for audio and video conferences to communicate online. This allows us to hold virtual meetings or conduct online classes and webinars. The legal texts of the individual services, such as privacy policies and terms of use, additionally apply to participation in audio and video conferences.

We recommend, depending on the situation, to mute the microphone by default and to blur the background or use a virtual background when participating in audio or video conferences.

We use in particular:

11.3 Maps

We use third-party services to embed maps into our website.

We use in particular:

11.4 Digital Audio and Video Content

We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.

We use in particular:

12. Website Extensions

We use extensions for our website to utilize additional functionalities. We may use selected services from suitable providers or deploy such extensions on our own server infrastructure.

In particular, we use:

  • Google reCAPTCHA: Spam protection (differentiating between desired content from humans and undesirable content from bots and spam); Provider: Google; Specific information on Google reCAPTCHA: “What is reCAPTCHA?”.

13. Success and Reach Measurement

We attempt to determine how our online offer is used. In this context, we can measure, for example, the success and reach of our activities and operations as well as the impact of third-party links to our website. We can also try out and compare how different parts or versions of our online offer are used (using the “A/B test” method). Based on the results of the success and reach measurement, we can particularly fix errors, reinforce popular content, or make improvements to our online offer.

For success and reach measurement, IP addresses of individual users are most often stored. In this case, IP addresses are generally shortened (“IP masking”) to comply with the principle of data minimization through the corresponding pseudonymization.

Cookies may be used for success and reach measurement, and user profiles created. Any created user profiles may 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 a pseudonymized manner and not used for identifying individual users. Individual third-party services where users are registered may possibly associate the use of our online offer with the user account or user profile at the respective service.

We use in particular:

14. Final Provisions

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