Data protection
The protection of your data is essential to Sulista GmbH. Below, therefore, provide you with an overview of your data processing and rights. How and which personal data we process in each case, and in what way it is used, depends mainly on the particular usage, legal and contractual relationship. When processing personal data, we comply with the requirements of the applicable data protection laws.
If you have any questions or concerns, please do not hesitate to contact us. We will be happy to assist you at any time.
Table of contents:
1. Responsible body
2. Scope and data
3. Sources and data used
4. Purpose od data processing
5. Disclosure of personal data
6. Retention of personal data
7. Confidentiality/Security
8. Your rights
9. Obligation to provide personal data
10. Cookies and social media
11. We analytics
12. Changes to the data protection notice
1. Responsible body
The responsible body for collecting, processing and using your personal data in the sense of data protection law is Sulista GmbH. Please direct any enquiries about this statement or concerns relating to data protection to the following address:
Sulista Consulting
St. Jakobstrasse 2Aesch 4147
Switzerland
consulting@sulista.ch
2. Scope of application and data
This privacy policy applies to the personal data of the following natural persons:
- Customers of Sulista GmbH.
- All other natural persons who are in contact with Sulista GmbH, e.g. suppliers, service providers, representatives and employees of legal entities, visitors to our website, tradesmen, etc.
Until the data protection statement and the legal situation change, this information also applies to legal persons insofar as the Swiss Data Protection Act (DSG) is applicable.
The subject of data protection is personal data. This is all information that relates to an identified or identifiable person. Personal data can be, for example, personal details (including surname, first name, date of birth, address, e-mail address, account number/account details, telephone number, etc.). In addition, order data, data for the fulfilment of contractual obligations, documentation data, and other data comparable to the categories mentioned may also be personal data. We only process your personal data if this is permitted by law, if there is a legal basis for doing so, or if you have given us your consent in this regard.
3. Sources and data used
The subject of data protection is personal data. This is information that relates to an identified or identifiable person or specific or identifiable individual. Sulista GmbH collects your personal data when you contact us as a customer. However, personal data may also be collected if you contact us as an interested party, service provider, applicant, website user or in any other capacity. In addition, we also process personal data in the course of our other business activities. In addition, we process personal data that we permissibly obtain from publicly accessible sources in connection with the provision of our services. We also process data that arises in connection with the use of our website or data that you provide there (e.g. by filling out the web form or entering your name in the newsletter mailing list).
4. Purpose of data processing
Personal data is processed for the following purposes:
a) To fulfil our contractual obligations/provide our services.
Sulista GmbH stores and processes your data for the purpose you have voluntarily provided it to us, i.e. in particular, for the provision of digital marketing services. Sulista GmbH also stores and processes personal data for the provision, administration and execution of customer communication by telephone and via electronic means of communication, as well as for communication with users of our website. In addition, data processing is carried out to implement pre-contractual measures (e.g. clarifications with customers, suppliers and service providers before the order), which are carried out upon request.
b) Within the framework of a balancing of interests
Where necessary, we process your data beyond the actual provision of our services to protect our legitimate interests or those of third parties. Examples of this are:
- Asserting legal claims and defending legal disputes.
- Ensuring IT security and IT operations.
- Information events, advertising and marketing measures, provided there is no objection to the corresponding use of data.
- Business management measures and information about our services.
- Analysis of internet traffic on our website to improve the functionality of our website.
- Prevention and investigation of criminal offences.
c) Based on your consent
Suppose you have given us your consent to process personal data for specific purposes. In that case, the lawfulness of these processing operations is based on your consent and other possible reasons for lawful processing. Consent given can be revoked at any time. The revocation of consent does not affect the lawfulness of the data processing until the time of revocation.
d) Due to legal requirements or due to public interesData may also be processed or disclosed if this is required by law or in the public interest.
5. Disclosure of personal data
At Sulista GmbH, employees only receive access to your data if this is necessary to fulfil contractual and legal obligations.
Personal data will only be disclosed if this is permitted by law or if there is a sufficient legal basis for doing so (e.g. the purpose of fulfilling a contract, a legitimate interest or your consent). In addition, data may be transferred to other responsible parties if we are obliged to do so by law or by enforceable official or court order. In the course of our business activities, personal data may also be transferred to recipients who are based outside Switzerland, the EU or the EEA in so-called third countries, subject to compliance with the legal requirements for the transfer of data.
Service providers we use may also receive data, subject to compliance with the legal requirements for data transfer, if they maintain the corresponding confidentiality. These include companies in the categories of IT services, payment services, services on our website, telecommunications, legal and tax advice, accounting, CRM (customer relationship management system), sales and marketing. We have carefully selected these service providers and oblige them to handle and secure the respective data with care.
6. Storage of personal data
We process and store your personal data as long as it is necessary to fulfil our contractual and legal obligations or other purposes pursued with the processing and as long as we have a legitimate interest in storing the respective personal data.
In addition, we retain personal data subject to statutory retention periods or still required for criminal prosecution or to secure, assert or enforce legal claims.
A – temporary – further processing of personal data is necessary for the following purposes, among others:
- Fulfilment of retention obligations under commercial and tax law, e.g. from the Swiss Code of Obligations (OR) and the tax laws. The periods specified there for storage or documentation are usually ten years.
- Preservation of evidence within the framework of the statutory limitation provisions under Art. 127 et seq. of the Swiss Code of Obligations (OR).
7. Confidentiality/security
All personal data collected, processed and stored is treated confidentially by Sulista GmbH and our employees. To adequately protect this data from unauthorised access and misuse, we have implemented technical and organisational measures (e.g. controlled access and access restrictions to data, IT security applications and measures, etc.). In addition, electronic data is stored with all due care and stored on our servers in the European Union.
We would like to point out that unencrypted data transmission takes place in the event of data being sent via e-mail. It can, therefore, not be ruled out that data may be lost en route or may be viewed by third parties. Such online transmission of personal data is, therefore at your own risk.
8. Your rights
You have various rights, depending on the applicable legal basis.
You can assert your rights at the contact address above (under point 1).
You are entitled to assert the right to information, the right to correction, the right to deletion and the right to restriction of data processing, and the right to data transferability. Furthermore, you are entitled to object to the processing of data by us.
Furthermore, you may revoke any consent you have given us to process your personal data. Please note that the revocation is only effective for the future. Data processing that took place before the revocation is not affected by this.
Any data subject has the right to complain with the competent data protection authority, the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch), without prejudice to any other administrative or judicial remedy.
9. Obligation to provide personal data
Personal data is required to establish, implement and fulfil the business and customer relationship so that we can meet our contractual obligations and collect or process the data that we are legally obliged to collect. Without this data, we will generally be unable to enter into a business and customer relationship with you or execute a corresponding contract.
10. Cookies and social media
a) Cookies
We use so-called cookies on our website. This technology can be used to identify your browser or device. They are small text files placed and stored on the computer system via an internet browser. A cookie may be stored on the user’s operating system when a user accesses a website. A cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.
As a data subject, you can prevent the storage of cookies by our website at any time by using an appropriate setting of the Internet browser and thus permanently object to the setting of cookies. Furthermore, you can delete cookies that have already been set at any time using an internet browser or other software programmes.
The respective browser can be set in such a way that information about the setting of cookies is provided and thus, it can be decided individually whether the respective cookie is desired or its use is not desired. The corresponding cookie setting differs depending on the browser used. An explanation of how the respective cookie setting can be changed can usually be found in the browser’s help menu. For the following browsers, the help menu can be found under the following links:
Internet Explorer
Firefox
Chrome
Safari
Opera
Suppose a cookie is not accepted by the user for application. In that case, the display of the usability of our website may be restricted for the respective user
b) Facebook
We operate a page in the form of a presence on Facebook, on which we regularly post current articles and photos concerning our offers in the area of digital marketing. In addition to positioning our services, this Facebook page is used to exchange information with customers, users and interested parties.
When you access our Facebook page, your data is processed by Facebook Ireland Ltd. This involves a statistical evaluation of the user data of our company page on Facebook. On the part of the operator, Facebook Ireland Ltd., the data is used for market research purposes as well as for advertising, and user profiles are also created. If you, as a Facebook user, are also logged in to Facebook at the time of accessing our Facebook page, Facebook Ireland Ltd. can link the data with your respective user account.
If you visit or like our Facebook page as a Facebook user, Facebook collects personal data from you. In addition, if you are not registered with Facebook and visit the Facebook page, Facebook may collect pseudonymous usage data from you.
Please note that in this context, there is also the possibility that Facebook Ireland Ltd. may also set cookies when you use Facebook. If you do not agree to this, you have the option of preventing the use of cookies by setting your browser accordingly or, in the case of Flash cookies, by setting your Flash player accordingly. Existing cookies can also be deleted at any time. If you prevent or restrict the use of cookies, this may mean that not all functions of Facebook can be fully used.
If you are currently logged in to Facebook as a user, a cookie with your Facebook ID is stored on your end device. This enables Facebook to track that you have visited this site and how you have used it. If you would like to avoid this, you can log out of Facebook or deactivate the “stay logged in” function, delete the cookies on your device and close and restart your browser. This will delete Facebook information that can directly identify you. In addition, when you access interactive functions on Facebook (“Like”, “Comment”, “Share”, “Message”, etc.), a Facebook login screen appears. Suppose you log in to Facebook again with your login data. In that case, you will again be recognisable to Facebook as an identifiable user.
Information on how information is processed and how you can manage or delete existing information can be found in the Facebook data policy.
If you contact us via our Facebook page, the data you enter will be used by us to process the contact. After processing your contact, the corresponding data will be deleted by us unless there is a legal obligation to retain it.
Collecting and processing your personal data is based on the legitimate interest in processing the data. The legitimate interest on our part is the evaluation of the collected data and the corresponding communication with customers, potential customers and users, as well as the advertising, offer and sale of our services in the area of digital marketing.
Regarding processing your data when visiting our Facebook page, we have a joint responsibility with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. To this end, we have entered into a joint data processing responsibility agreement with Facebook.
There is also an agreement with Facebook regarding the data security measures that must be observed by Facebook (“Information on Page Insights“).
Data Security Terms
In addition, Facebook agrees to fulfil the rights of data subjects (users can, among other things, address requests for information or deletion directly to Facebook). Users’ rights (including the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.
Further information in connection with Facebook’s data processing can be found in the Facebook data protection policy.
Finally, we would like to point out that you use our Facebook page and its functions on your responsibility. This applies to interactive functions (e.g. commenting, sharing, rating).
c) Instagram
We operate a page in the form of a presence on Instagram, on which we regularly post current articles and photos concerning our offers in the area of digital marketing. In addition to positioning our services, this Instagram page is used to exchange information with users and interested parties.
When you visit our Instagram page, and like posts or photos, Instagram collects personal data from you. If you are not registered with Instagram and visit our Instagram page, Instagram may collect pseudonymous usage data from you.
When you visit our Instagram page, your data is processed by Facebook Ireland Ltd. as the operator. This involves a statistical evaluation of the user data on our company page. The operator, Facebook Ireland Ltd., uses the data for market research purposes and for advertising and also creates user profiles. Suppose you, as an Instagram user, are also logged into Instagram at the time of accessing our Instagram page. In that case, Facebook Ireland Ltd. can link the data with your respective user account.
Please note that in this context, cookies may also be set by Facebook Ireland Ltd. when using Instagram. If you do not agree to this, you have the option of preventing the use of cookies by setting your browser accordingly or, in the case of Flash cookies, by setting your Flash player accordingly. Existing cookies can also be deleted at any time. If you prevent or restrict the use of cookies, this may mean that not all functions of Instagram can be fully used.
If you contact us via our Instagram page, the data you enter will be used by us to process the contact. After processing your contact, the corresponding data will be deleted by us, unless there is a legal obligation to retain it.
Collecting and processing your personal data is based on the legitimate interest in processing the data. The legitimate interest on our part is the evaluation of the collected data and the corresponding communication with customers, potential customers and users, as well as the advertising, offer and sale of our services in the area of digital marketing.
Regarding processing your data when visiting our Instagram page, we have a joint responsibility with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. To this end, we have entered into a joint data processing responsibility agreement with Facebook.
Data Security Terms
In addition, Facebook agrees to fulfil the rights of data subjects (users can, among other things, address requests for information or deletion directly to Facebook). Users’ rights (including the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.
Further information can be found on these pages.
Further information in connection with Facebook’s data processing via Instagram can be found in the Instagram privacy policy.
Meta Privacy Policy
Finally, we would like to point out that you use our Instagram page and its functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, liking).
d) LinkedIn
Our website also contains a link to a presence page in the LinkedIn network. The LinkedIn network is operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, a subsidiary of LinkedIn Corporation, 1000 W. Maude Avenue, Sunny Avenue. Maude Avenue, Sunnyvale, CA 94085 USA.
The linking is done by integrating a graphic of the LinkedIn network on our website. Using the linked graphic prevents a connection to LinkedIn or the LinkedIn servers from being established at the same time simply by calling up our website. A connection to LinkedIn is only established independently when the respective user clicks on the graphic. Only then is the user connected to the LinkedIn network. If forwarding to LinkedIn has taken place, information about the user (e.g. IP address, date, time) is collected by LinkedIn.
If you, as a LinkedIn user, are also logged in to LinkedIn at the time of accessing our LinkedIn presence, LinkedIn can assign the data to your user account. If you as a user use the “Like” button or the “Share” button or other functions for interaction in the LinkedIn network, this information is stored in the respective user account and, depending on the form of interaction, also published. If you wish to prevent a corresponding collection and assignment of information, it is necessary that you log out of your LinkedIn user account before clicking on the LinkedIn graphic on our website. Furthermore, it is possible to set settings in the respective user account regarding the collection, use and sharing of data, see LinkedIn Privacy Policy.
If you contact us via our LinkedIn presence, the data you enter will be used by us to process the contact. After processing your contact, the corresponding data will be deleted by us unless there is a legal obligation to retain it.
Collecting and processing your personal data is based on the legitimate interest in processing the data. The legitimate interest on our part is the evaluation of the collected data and the corresponding communication with customers, potential customers and users as well as the advertising, offer and sale of our services in the area of digital marketing.
Regarding processing your data when visiting our Facebook page, we have a joint responsibility with LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For this purpose, we have entered into a joint data processing responsibility agreement with LinkedIn.
Further information in connection with LinkedIn’s data processing is contained in the LinkedIn Privacy Policy:
- Further information in connection with cookies is contained in the Cookie-Policy.
An objection option (opt-out): exists under the following link.
If forwarding to LinkedIn has taken place, information about the user (e.g. IP address, date, time) is collected by LinkedIn. The data collected may be processed in the USA.
Therefore, we advise you to use our LinkedIn page and its functions on your own responsibility. This applies in particular to interactive functions (e.g. commenting, sharing, rating).
e) Youtube
We maintain a presence on the video platform YouTube to present Sulista GmbH and our services. YouTube is a platform that enables the playback of audio and video files. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.
If you contact us via our YouTube presence, the data you enter will be used by us to process the contact. After processing your contact, the corresponding data will be deleted by us, unless there is a legal obligation to retain it.
Collecting and processing your personal data is based on the legitimate interest in processing the data. The legitimate interest on our part is the evaluation of the collected data and the corresponding communication with customers, potential customers and users, as well as advertising, the offer and sale of our services in the area of digital marketing and for customer retention.
Beyond the contact data, no personal data is processed by us via the YouTube presence.
Whether and to what extent data processing takes place outside of the aforementioned use of contact data by YouTube as a result of your account with YouTube is beyond our knowledge. Any corresponding use of the account is exclusively your responsibility and outside our area of responsibility.
We would like to point out that using the YouTube account and YouTube service is your responsibility. We would also like to point out that you use our YouTube site and its functions under your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting, sharing, rating).
We would like to point out that there is a possibility that user data may be processed outside of Switzerland or the European Union, in particular in the USA. This may result in increased risks for users. We have no access to this user data. The possibility of access lies exclusively with YouTube.
If you, as a YouTube user or Google user, are also logged in to YouTube or Google at the time of accessing our YouTube presence, the data generated can be assigned to your user account by Google. If you wish to prevent the corresponding collection and allocation of information, you must log out of your YouTube or Google user account before accessing our YouTube presence.
YouTube Privacy Policy.
f) Links to social media platforms and external websites/content
If users or customers integrate links and/or videos (e.g. via Youtube, etc.) and other services (e.g. Facebook, Twitter, etc.) in connection with the use of social media platforms, this is always done at the responsibility of the respective person. Under no circumstances does this imply Sulista GmbH’s approval of third-party websites’ content, presentation, etc.,. Sulista GmbH accepts no responsibility for the availability or content of such external websites, nor does it accept any liability for damage or injury resulting from using external websites and their content.
Sulista GmbH provides links to social media platforms such as Facebook, Instagram and LinkedIn. The share links to social media platforms used behave like normal links. If the links are not clicked and the user does not leave our website or switch to the social media platform within the browser, no user data is transmitted to the respective social media platform.
When visiting our website, the social plugins are therefore deactivated, and no data is transmitted to the operators of the social media platforms without further action. If you wish to use a social media platform, click on the respective link to establish a direct connection with the server of the respective network.
Suppose you have a user account with the respective social media platform and are logged in there at the moment of clicking on the link. In that case, the respective social media platform can assign the visit to our websites to your user account. If you wish to avoid this, please log out of the respective social media platform before using the link (=activating the social plugin).
Suppose you activate a social plugin by using the corresponding link. In that case, the social media platform transmits the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions that are initiated and controlled by the respective social network may also take place. We do not influence this. Your connection to a social media platform, the data transfers that take place between the network and your system and your interactions on this platform are governed exclusively by the data protection provisions of the respective social media platform. There is no data transfer between us and the respective social media platform in this context. Please note that the social plugin remains active until you deactivate it or delete the corresponding cookies.
Please also note that when you click on or activate a social plugin, personal data may be transferred to providers in countries outside Switzerland, the EU and the European Economic Area (EEA), which, from the perspective of Switzerland and the EU, do not ensure an adequate level of protection for the processing of personal data following the standards set there. Therefore, please bear this in mind before clicking on a link or activating a social plugin, triggering a transfer of your data.
We want to point out the concerns of the data protection authorities in connection with data transfer by Facebook, as it is not conclusively and clearly stated on the part of Facebook how long Facebook stores data and whether data from a visit to a Facebook page or Instagram page is transferred to third parties within the group. Therefore, we must point out to you that calling up Facebook or Instagram pages and using the interactive functions (e.g. commenting, sharing, rating, etc.) is your responsibility.
11.Webanalyse
Sulista GmbH uses web analysis or tracking technologies to improve the internet offer constantly.
a) Google Analytics
We use Google Analytics, a web analysis service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The analysis is carried out for market research, advertising and marketing purposes as well as for the purpose of analysing, optimising and economically operating our online offer and serves our legitimate interest. In addition, we obtain consent from the user of our website before using Google Analytics. To deactivate Google Analytics, Google provides a browser add-on at http://tools.google.com/dlpage/gaoptout?hl=de. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site (see above). The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Google will use this information to evaluate your use of the website, compile reports on website activity and provide other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google and will only pass it on to us in an anonymised form.
You may refuse the use of cookies by selecting the appropriate settings on your browser. However, we would like to point out that in this case, you may not be able to use all the functions of this website to their full extent.
Further information on Google Analytics and the Google Analytics privacy policy can be found here.
b) Google Data Studio
In connection with the website’s operation, we also use the “Google Data Studio” application. This is an application for visualising data in the form of graphical reports concerning user behaviour on our website and on Facebook and Instagram. For this purpose, Google Data Studio is connected to Google Analytics.
The Google Data Studio application provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View CA 94043, USA.
The Google Data Studio application is used to analyse, optimise and economically operate our online offer.
The Google data protection declaration can be found here.
c) Google Maps
We also use Google Maps on our website to display our location and map information. Google Maps is a mapping service provided by Google LLC, for displaying an interactive map and creating directions. Google Maps is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Suppose you call up the Google Maps component integrated into our website. In that case, Google stores a cookie on your terminal device via your internet browser. In order to display our location and provide directions, your user settings and data are processed. The connection to Google established in this way enables Google to determine the website from which your request was sent and the IP address to which the directions are to be sent.
The Google privacy policy and additional terms of use for Google Maps can be found here.
You can also stop the loading of Google plugins in your privacy settings.
d) Google Ads (früher Google AdWords)
We also use the application “Google Ads” (formerly “Google AdWords”) on our website. This is a service provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
Through Google Ads, we would like to draw attention to our services – using advertising media on external websites. Google delivers the advertising material via so-called “ad servers”. This enables us to determine how successful the respective advertising media are. So-called AdServer cookies are used for this purpose—these measure various parameters, such as the display of the ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your PC. These cookies usually expire after 30 days.
We use Google Ads to market our digital marketing services and to optimise our offer and website.
The cookie used establishes a direct connection between your browser and the Google server. The following information is usually stored in such a cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). This enables Google to recognise your web browser. Google can recognise via the cookie (provided it has not yet expired) that the user has clicked on a specific advertisement and was redirected to the corresponding website.
We do not process any personal data in this context but are merely provided with a statistical evaluation by Google. This enables us to identify which advertising measures are commercially viable. We can’t identify users under any circumstances.
If you have a Google account and are logged in, Google can assign your visit to a website to your user account. You can prevent the use of Google Ads by deleting existing cookies and deactivating the cookies’ storage in your web browser’s settings. Please note that in this case you may not be able to use all the functions of our website to their full extent.
The storage of cookies can also be prevented by setting your web browser to block cookies from the domain “www.googleadservices.com” (https://www.google.de/settings/ads). Please note that this setting will be deleted when you delete your cookies. Furthermore, you can deactivate interest-based ads via the link http://optout.aboutads.info. Please note that this setting will be deleted when you delete your cookies.
The Google privacy policy can be found here.
12. Changes to the data protection information
We reserve the right to change this privacy policy at any time. The current version published on our website will apply. The date of the last update can be found at the end of this data protection notice.
Status: September 2021
