Privacy Policy

With this Privacy Policy we inform you about the processing of personal data in connection with our activities and operations, including our website under the domain name hkg.ch. In particular, we inform you which personal data we process for which purpose, in which manner and at which location. We also inform you about the rights of persons whose data we process.

We have drafted this Privacy Policy in German. If it is published in another language, the German-language Privacy Policy shall prevail.

For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.

We are subject to Swiss law as well as to any applicable foreign law, such as in particular the law of the European Union (EU) with the European General Data Protection Regulation (GDPR).

By decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. In its report of 15 January 2024, the European Commission confirmed this adequacy decision.

Table of Contents

1. Contact addresses

The controller within the meaning of data protection law is:

Herzog Kull Group Holding AG
Grundstrasse 12
6343 Rotkreuz

info@hkg.ch

In individual cases, third parties may be responsible for the processing of personal data, or responsibility may be shared jointly with third parties. We are happy to provide data subjects with information about the respective responsibility upon request.

Data Protection Officer or Data Protection Advisor

We have appointed the following Data Protection Officer or Data Protection Advisor as the point of contact for data subjects and authorities in the case of enquiries relating to data protection:

Marc Herzog
Grundstrasse 12
6343 Rotkreuz

info@hkg.ch

2. Terms and legal bases

2.1 Terms

Data subject: Natural person whose personal data we process.

Personal data: All information relating to an identified or identifiable natural person.

Particularly sensitive personal data: Data on trade union, political, religious or ideological views and activities, data on health, the intimate sphere or affiliation with an ethnicity or race, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or proceedings, and data on social assistance measures.

Processing: Any handling of personal data, irrespective of the means and procedures applied, for example the querying, matching, adapting, archiving, retaining, reading out, disclosing, obtaining, recording, collecting, deleting, revealing, ordering, organising, storing, altering, disseminating, linking, destroying and using of personal data.

European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

2.2 Legal bases

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

Where and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of 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 carrying out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests – including the legitimate interests of third parties – provided that the fundamental freedoms and fundamental rights as well as the interests of the data subject do not prevail. Such interests are in particular the lasting, people-friendly, secure and reliable pursuit of our activities and operations, the safeguarding 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 in order 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 carried out 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 in order to protect the vital interests of the data subject or of another natural person.
  • Art. 9 para. 2 et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and to the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. Nature, scope and purpose of the processing of personal data

We process those personal data which are necessary in order to pursue our activities and operations in a lasting, people-friendly, secure and reliable manner. The personal data processed may in particular fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may furthermore constitute particularly sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of pursuing our activities and operations, insofar as such processing is permissible.

We process personal data with the consent of the data subjects where this is necessary. In many cases we may process personal data without consent, for example in order to comply with legal obligations or to safeguard overriding interests. We may also ask data subjects for their consent even where their consent is not required.

We process personal data for the period that is necessary for the respective purpose. We anonymise or delete personal data in particular depending on statutory retention periods and limitation periods.

4. Disclosure of personal data

We may disclose personal data to third parties, have them processed by third parties or process them jointly with third parties. Such third parties may, for example, be specialised providers whose services we use. Such third parties may in turn disclose personal data to third parties.

In the course of our activities and operations, we may in particular disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, accounting and fiduciary service providers, debt collection companies, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

5. Communication

We process personal data in order to be able to communicate with individuals as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject transmits to us when contacting us, for example by postal mail or email. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons to us are legally obliged to ensure the data protection of these data subjects themselves. In particular, they must ensure that they are permitted to transmit such data, and they must also ensure the accuracy of the transmitted data.

6. Job applications

We process personal data about applicants insofar as they are necessary for assessing suitability for an employment relationship or for the subsequent performance of an employment contract. The necessary personal data result in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and recruitment platforms.

We furthermore process those personal data that applicants disclose or publish voluntarily, in particular as part of cover letters, curricula vitae and other application documents as well as as part of online profiles.

Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular pursuant to Art. 9 para. 2 lit. b GDPR.

7. Data security

We take appropriate technical and organisational measures in order to ensure a level of data security appropriate to the respective risk. With our measures we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without, however, being able to guarantee absolute data security.

Access to our website and our other digital presence takes place by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.

Our digital communication is subject – like in principle any digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, in the rest of Europe, in the United States of America (USA) and in other countries. We cannot exert any direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities. Nor can we rule out that a data subject may be subject to targeted surveillance.

8. Personal data abroad

We generally process personal data 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 them there or have them processed there.

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection pursuant to a decision of the Swiss Federal Council and – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – also pursuant to a decision of the European Commission.

We may transfer personal data to countries whose law does not ensure an adequate level of 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 requirements for doing so are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. We are happy to provide data subjects with information about any safeguards upon request, or to supply a copy of any safeguards.

9. Rights of data subjects

9.1 Data protection claims

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

  • Information: Data subjects may request information as to whether we process personal data about them and, if so, which personal data are involved. Data subjects furthermore receive that information which is necessary in order to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but among other things also information on the purpose of processing, on the retention period, on any disclosure or export of data to other countries and on the origin of the personal data.
  • Rectification and restriction: Data subjects may have inaccurate personal data rectified, incomplete data completed and the processing of their data restricted.
  • Opportunity to state their own point of view and human review: In the case of decisions that are based exclusively on automated processing of personal data and that have a legal consequence for them or significantly affect them (automated individual decisions), data subjects may state their own point of view and request a review by a human being.
  • Erasure and objection: Data subjects may have personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data disclosure and data portability: Data subjects may request the release of personal data or the transfer of their data to another controller.

We may postpone, restrict or refuse the exercise of the rights of data subjects within the legally permissible scope. We may inform data subjects about any conditions that must be met in order to exercise their data protection claims. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse the erasure of personal data in whole or in part, in particular with reference to statutory retention obligations.

By way of exception, we may charge costs for the exercise of these rights. We inform data subjects in advance about any such costs.

We are obliged to identify data subjects who request information or assert other rights by means of appropriate measures. Data subjects are obliged to cooperate.

9.2 Legal protection

Data subjects have the right to enforce their data protection claims through the courts or to lodge a report or complaint with a data protection supervisory authority.

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

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some Member States of the European Economic Area (EEA), the data protection supervisory authorities have a federal structure, in particular in Germany.

10. Use of the website

10.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies of 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 may be stored in the browser temporarily 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 make it possible in particular to recognise a browser on its next visit to our website and thereby, for example, to measure the reach of our website. However, permanent cookies may for example also be used for online marketing.

Cookies can be deactivated, restricted or deleted in whole or in part at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be available to its full extent. We actively request explicit consent to the use of cookies – at least where and to the extent that this is required under applicable law.

For cookies that are used for success 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).

10.2 Logging

For each access to our website and our other digital presence, we may log at least the following information, provided that it is determined or transmitted to our digital infrastructure by default during such accesses: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including the volume of data transferred, web page last accessed in the same browser window (referer or referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary in order to be able to provide our digital presence in a lasting, people-friendly and reliable manner. The information is furthermore necessary in order to be able to ensure data security – also by third parties or with the help of third parties.

10.3 Tracking pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those of third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as logging in log files.

11. 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 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).

The general terms and conditions and terms of use as well as the privacy policies 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 include, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – where and 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 (among others in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights in order to be able to provide our social media presence on Facebook effectively and in a people-friendly manner.

Further information on the nature, scope and purpose of the data processing, information on the rights of data subjects as well as the contact details of Facebook and of Facebook’s data protection officer can be found in Facebook’s privacy policy. We have concluded the so-called “Controller 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 “Information about Page Insights” including “Information about Page Insights Data”.

12. Third-party services

We use services of specialised third parties in order to be able to pursue our activities and operations in a lasting, people-friendly, secure and reliable manner. Among other things, such services allow us to embed functions and content into our website. In the case of such embedding, the services used capture the IP addresses of 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 concerns, for example, performance or usage data required in order to be able to offer the respective service.

We use in particular:

12.1 Digital infrastructure

We use services of specialised third parties in order to be able to make use of the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services of selected providers.

We use in particular:

12.2 Audio and video conferencing

We use specialised services for audio and video conferencing in order to be able to communicate online. This allows us, for example, to hold virtual meetings or to conduct online lessons 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.

Depending on the situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or displaying a virtual background.

We use in particular:

12.3 Social media functions and social media content

We use services and plugins of third parties in order to be able to embed functions and content from social media platforms as well as to enable the sharing of content on social media platforms and by other means.

We use in particular:

12.4 Maps

We use services of third parties in order to be able to embed maps into our website.

We use in particular:

12.5 Digital content

We use services of specialised third parties in order to be able to integrate digital content into our website. Digital content includes in particular image and video material, music and podcasts.

We use in particular:

12.6 Fonts

We use services of third parties in order to be able to embed selected fonts as well as icons, logos and symbols into our website.

We use in particular:

13. Success and reach measurement

We seek to measure the success and reach of our activities and operations. In this context, we may also measure the effect of references by third parties or test how different parts or versions of our digital presence are used (“A/B testing” method). On the basis of the results of the success and reach measurement, we can in particular fix errors, strengthen popular content or make improvements.

For success and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are generally truncated (“IP masking”) in order to follow the principle of data minimisation through corresponding pseudonymisation.

Cookies may be used and user profiles may be created in the course of success and reach measurement. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or of the browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services in which users are logged in may possibly assign the use of our online offering to the user account or user profile with the respective service.

We use in particular:

14. Concluding notes on this Privacy Policy

We created this Privacy Policy with the Privacy Policy Generator by Datenschutzpartner .

We may update this Privacy Policy at any time. We inform about updates by publishing the respective current Privacy Policy on our website.

Privacy settings

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