A. Data Privacy Policy

1. Data protection in brief:

The following data protection information is intended to provide you with an overview of the collection and processing of your data when visiting our website (www.also.com) and as a customer of ALSO Holding AG (hereinafter "ALSO"), Meierhofstrasse 5, CH-6032 Emmen, which is carried out in application of the respective legal provisions applicable to the processing. Depending on the processing of personal data, in addition to the applicable Swiss law (Federal Act on Data Protection (DSG) of 19 June 1992, SR 235.1), European data protection law (Ordinance (EU) 2016/679, Basic Data Protection Ordinance (EU-DSGVO)) may also apply.

B. Detailed Privacy Notice:

1. General:

ALSO Holding AG, Meierhofstrasse 5, 6032 Emmen has implemented numerous technical and organisational measures for processing by the individuals responsible in order to ensure that the personal data processed via this website, in addition to customer data, is protected to the best possible extent also outside this website. However, processes cannot be fully monitored and controlled, so absolute protection cannot be guaranteed. For this reason, each person concerned is free to provide us with personal data when making contact via our website, including by alternative means such as telephone.

2. What data do we collect and how is it used based on what justification?

2.1 Website visitors:

We record the IP address from which you access our website, the browser version used, the operating system used, the date and time of access, the country of origin, the website from which you accessed our website (referrer). We collect this data on the basis of our legitimate interest, which is concerned with your system and data security and system stability, for the purpose of establishing the website connection, recognising and protecting against attack attempts, for statistical evaluation, to answer and process your inquiries and to optimise and offer our online services. This data will not be used to create individual user profiles and will not be passed on to third parties.

Cookies:

We use cookies for certain offers. These are small text files that are stored on your computer. This allows us to recognise when you repeatedly visit a website from the same computer. Cookies serve your and ALSO’s interest in making our website more attractive, effective, secure and user-friendly. With the help of tracking services and cookies, so-called third-party cookies, we record user profiles under a pseudonym. Such a usage profile contains information about the behaviour of a visitor to a website. It is not possible to draw any direct conclusions about you. You can object to the creation of user profiles at any time. You can set your browser so that these cookies are not saved and deleted at the end of your Internet session.

Session Cookies:

These are cookies that are only stored on your computer for the duration of an Internet session and are required for transactions. These session cookies are used exclusively for connection control and navigation and enable you to surf our Internet pages in a user-friendly manner (e.g. for processing a purchase while you are logged on to our shop systems). Session cookies are deleted again when you end your browser session.

For certain offers we use persistent cookies, which serve to recognise visitors and are stored on your computer for future sessions. These cookies are valid for 6 to 24 months (e.g. a persistent cookie is required in order not to record your surfing behaviour by means of tracking tools used).

You have the option of setting your browser so that these cookies are not stored in the first place or that the cookies are deleted at the end of your Internet session. You can revoke your consent to cookies at any time by deleting the cookies that have already been saved. See also the instructions of the corresponding search engine operators:

Internet Explorer:
https://support.microsoft.com/en-in/help/278835/how-to-delete-cookie-files-in-internet-explorer

Mozilla Firefox:
https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-Webseites-stored

Google Chrome:
https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=de

Safari:
https://support.apple.com/kb/ph21411?locale=de_US

Opera:
https://www.opera.com/help/tutorials/security/privacy/

However, please note that in this case you may not be able to use all the functions of our website.

In addition, you can manage the use of cookies in our Consent Management Tool (see section 8) at any time. You have the option at any time to change the decision made there and to subsequently give or revoke your consent. For this you can here to call up the setting options.

Social Media Plugins:

We use the following social media plug-ins on our website to make our company better known and market it efficiently. The responsibility for the data protection-compliant operation is to be guaranteed by the respective provider of the social media plugin. The purpose and scope of the data collection are determined by the data protection information of the respective provider of the social media plugin. ALSO itself does not collect personal data using social media plugins or information about their use. ALSO uses the following plugins on its website:

• LinkedIn: The LinkedIn plugin used by ALSO is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). The link to LinkedIn’s Privacy Policy can be found here: https://www.linkedin.com/legal/privacy-policy.
• Twitter: The Twitter plugin used by ALSO is operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). The link to Twitter’s Privacy Policy can be found here: https://twitter.com/privacy.
• The Facebook plugin used by ALSO is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The link to Facebook’s Privacy Policy can be found here: https://www.facebook.com/policy.php.
• The YouTube plugin used by ALSO is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (“YouTube”). YouTube, LLC is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The link to Facebook’s Privacy Policy can be found here: https://policies.google.com/privacy?hl=de&gl=de .

No further personal data is collected via the website, unless you provide this information voluntarily or it is processed within the scope of the customer relationship on the basis of legitimate interests. Your personal data will be processed in this context on the basis of ALSO’s overriding legitimate interest.

Usercentrics Consent Management Platform

We use the Usercentrics Consent Management Platform (Usercentrics) of Usercentrics GmbH, Rosental 4, 80331 Munich. Usercentrics collects log file data and consent data using JavaScript. This JavaScript enables us to inform the user of their consent to certain cookies and other technologies on our website and to obtain, manage and document this consent.

The legal basis for the processing of the data is Art. 6 para. 1 lit. c DSGVO. The aim is to know the preferences of the users and to act accordingly.

The data is deleted as soon as it is no longer required for our logging. The shelf life of the cookie is 60 days. The certificate of withdrawal of a previously given consent is kept for three years. The retention is based on the one hand on our accountability according to Art. 5 (2) DSGVO. This obliges compliance with the processing of personal data in accordance with the General Data Protection Regulation.

You can permanently prevent the execution of JavaScript at any time by making the appropriate settings in your browser, which would also prevent Usercentrics from executing the JavaScript.

Webtrekk:

ALSO uses Webtrekk, a web analysis service provided by Webtrekk GmbH, on its Internet pages. Some data collected during your visit to our website is processed for statistical analysis. For this reason, we pass this data on to Webtrekk GmbH. This statistical evaluation helps us to optimise our offer accordingly. Webtrekk GmbH is certified for data protection in the area of web controlling. Your IP address is transmitted with each server inquiry. Your IP address will only be stored anonymously. Conclusions for personally identifying you are basically impossible. Collection of your data occurs by setting a pixel, which is integrated on the website. Webtrekk uses so-called “session cookies” as well as “last-click cookies”, which are deleted when you end your browser session. Webtrekk also uses so-called “evercookies”, whose duration does not exceed six months and are deleted at the latest after a defined number of uses. Webtrekk does not merge this user data with other data concerning the bearer of the pseudonym. This data will be deleted as soon as storage is no longer required for the creation of the usage analysis, or if the user requests this.

Google Analytics:

This website uses Google Analytics, a web analysis service of Google LLC, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and Internet usage to the website operator. We would like to point out that on this website Google Analytics has been extended by the code “anonymizeIp” in order to guarantee an anonymous recording of IP addresses (so-called IP masking). Your IP address will first be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.

The legal basis for the use of Google Analytics is § 15 Abs.3 TMG or Art. 6 Abs. 1 lit. f DSGVO. Sessions and campaigns are terminated after a certain period of time. By default, sessions are terminated after 30 minutes without activity and campaigns after six months. The time limit for campaigns can be a maximum of two years. Further information on terms of use and data protection can be found at https://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/ . Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do so you may not be able to utilise the full functionality of this website. In addition, you can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plugin https://tools.google.com/dlpage/gaoptout?hl=de .

2.2 Customer:

The following data may be processed based on your registration, order, complaint, registration for the newsletter (double opt-in) as well as via the ALSO myStore, ALSO Shop, the Corvice website ( https://www.corvice.ch/ ) or event registrations, including sending invitations and customer satisfaction surveys recorded by ALSO: name, contact details, payment details, address and order details.

Specifically, ALSO collects your data as a customer on its own and external servers:

• reception during the preparation of meetings, creation of name boards, setting up WLAN access points
• answering, recalling or transferring your calls
• the order processing of export orders, collection orders and repair entries
• invitation, dispatch, reminder and feedback concerning trainings and events
• customer care in the CRM system
• the initiation of investigations into transport damage
• manufacturer reporting for validation of project credits
• the material plant for specific customer materials
• for the logistical dispatch of goods and warehouse management; goods issue, returns recording and archiving of delivery notes / return notes
• for the initiation of debt collection

In this context the processing of your personal data takes place for the implementation of pre-contractual measures, which occur at your request for the fulfilment of a contract or for the fulfilment of a legal obligation.

For the dispatch of our newsletter we use the so-called double opt-in procedure, i.e. we only send you a newsletter by e-mail if you have expressly consented to this beforehand. You will receive a notification e-mail asking you to confirm the link contained in the e-mail. Only then have you given us your consent to send the newsletter.

3. How do we collect your data?

3.1 Website visitors:

The data that is accumulated when you visit our website is collected automatically. Further data is collected in particular via your entries on our website and via cookies.

3.2 Customer:

Your data as a customer will be collected via the website or collected in personal interaction with you by our employees. If necessary, the data will then be adjusted manually on your behalf.

4. What do we use your data for?

4.1 Website visitors: 

To provide, optimise and administer the ALSO website and to create pseudonymised user profiles, unless you object to this. Furthermore, we use your data to detect misuse and eliminate faults and, if necessary, to provide information to government agencies. The processing of the data is based on ALSO’s legitimate interest that the website be user-friendly, that the information be constantly updated to meet the needs of customers and website visitors and that the business interest be met to the best satisfaction of all parties involved. We process these data on the basis of predominantly justified private interests.

4.2 Customer:

We use your data as a customer for the efficient processing of our mutual contracts, in particular for answering your enquiries, for the execution and adaptation of your orders, invoices and commissions, for ALSO’s legitimate marketing purposes and for sending you interesting information about ALSO (newsletters, invitations to events/trainings). We process this data for the implementation of pre-contractual measures, which occur at your request for the fulfilment of a contract or for the fulfilment of a legal obligation.

5. Where is my data processed?

Your data is processed in Switzerland. To the extent permitted by law, data processing also takes place in other European and non-European countries.

If data is processed in third countries without an equivalent level of data protection, ALSO shall ensure that it is available.

6. Data security

To protect your data, we have taken extensive technical and organisational measures to protect the security of your personal data and to protect your session data, personal data and customer data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure or access. However, you should always be aware that the transmission of information via the Internet and other electronic means involves certain security risks and that we cannot guarantee the security of information transmitted in this way.

Your personal data in connection with our website will be transferred to us from this website in TLS-encrypted form.

7. Data transfer

ALSO partially uses other companies for order data processing. The responsibility for data processing remains with ALSO. If processing is carried out on behalf of ALSO, ALSO will only work with contract data processors who offer sufficient guarantees that appropriate technical and organisational measures will be implemented to protect the rights of the data subjects to the same extent that ALSO provides them. The contract data processors are contractually bound to these guarantees.

In the event of legal obligations, we will forward the requested data to the requesting government authority. Beyond that we do not pass on any personal data unless you have consented to this, it serves a purpose stated in this Data Privacy Policy, or we are subject to an enforceable decision of a competent court or authority.

7.1 What rights do you have?

To request information about your personal data processed by us. In particular, information may contain information:

• about the processing purposes
• the category of personal data
• the categories of recipients to whom your information has been or will be disclosed
• the planned storage period
• the existence of a right of rectification, erasure, limitation or opposition
• the existence of a right of appeal
• the origin of your data, if these were not collected with us
• and on the existence of automated decision making, including profiling and, where appropriate, meaningful information on its details

In the event of a disproportionately high expense, we reserve the right to demand from you in advance an identity card and the assumption of the actual costs.

• Objection to processing with predominant private interest.
• To demand the correction of incorrect or incomplete personal data stored by us without delay.
• To request the deletion of your personal data stored by us, unless processing is necessary for the exercise of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims.
• To demand the restriction of the processing of your personal data, insofar as the correctness of the data is disputed by you, the processing is unlawful, but you refuse its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing.
• To receive your personal data that you have provided to us in a structured, common and machine-readable format, or to request transmission to another responsible person.
• To revoke your consent once given to us at any time. The consequence of this is that we may no longer continue the data processing based on this consent in the future. Right of appeal to the supervisory authority

8. When will your personal data be deleted?

ALSO will delete your personal data as soon as the purpose for which it was collected no longer applies. We will delete your personal data as soon as they are no longer needed and in any case after the legally prescribed maximum retention period of five and ten years respectively has expired. Data that is no longer necessary and for which there is no legal obligation to retain will be destroyed after the purpose and justification have ceased to apply.

9. Data Protection Officer:

If you have any questions about data protection, please contact our customer service, our employees or our data protection advisor at privacy.ch@also.com .

10. Data Protection Agency:

Federal Public Information and Data Protection Commissioner, FDPIC
Feldeggweg 1
3003 Bern
Switzerland
https://www.edoeb.admin.ch/edoeb/de/home.html