Privacy policy & commissioned data processing

1. Definitions

The data protection declaration of SUBRIS GmbH is based on the terms used by the Swiss Confederation in the adoption of the Swiss Data Protection Act (DSG). Our data protection declaration aims to be easily understandable and comprehensible for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use the following terms, among others:

a) Personal data

Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Person concerned

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing refers to the marking of stored personal data with the aim of limiting its future processing.

e) Profiling

Profiling is any form of automated processing of personal data in which these data are used to evaluate certain personal aspects relating to a natural person. This is done in particular to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or relocation of this natural person.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a way that the data can no longer be attributed to a specific data subject without additional information. Additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data cannot be attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

A recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party

A third party is a natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons under the direct authority of the controller or processor who are authorized to process personal data.

k) Consent

Consent is any voluntary, informed and unambiguous declaration of intent by a data subject for a specific case, which is given in the form of a declaration or other unambiguous confirmatory act. With this declaration, the data subject indicates that they consent to the processing of their personal data.

2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the:

SUBRIS GmbH
Blegistrasse 23
CH – 6340 Baar

+41 (0)41 552 48 84
contact@subris.ch
www.subris.ch

3. Cookies

The Internet pages of the SUBRIS GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, the SUBRIS GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie for a shopping basket in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

4. Collection of general data and information

The website of the SUBRIS GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using these general data and information, the SUBRIS GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the SUBRIS GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

The data subject has the option of registering on the controller’s website by providing personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the data to be passed on to one or more processors, such as a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.

By registering on the controller’s website, the IP address assigned by the data subject’s Internet service provider (ISP), the date and time of registration are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate criminal offenses committed. In this respect, the storage of this data is necessary to safeguard the controller. This data is not passed on to third parties unless there is a legal obligation to pass it on or it serves the purpose of criminal prosecution.

The registration of the data subject with voluntary provision of personal data serves the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller’s database.

The controller shall provide any data subject at any time upon request with information about what personal data is stored about the data subject. Furthermore, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as this does not conflict with any statutory retention obligations. All of the controller’s employees are available to the data subject as contact persons in this context.

6. Subscription to our newsletter

On the website of the SUBRIS GmbH, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted to the controller when the newsletter is ordered.

The SUBRIS GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. Our company’s newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation e-mail is sent to the e-mail address entered by a data subject for the first time for the newsletter mailing using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as legal protection for the controller.

The personal data collected when registering for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter dispatch, can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to inform the controller of this in another way.

7. Newsletter tracking

The SUBRIS GmbH newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, the SUBRIS GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the controller in order to optimize the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After revocation, this personal data will be deleted by the controller. The SUBRIS GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website

The website of the SUBRIS GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

9 Routine deletion and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

10. Rights of the data subject

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right to information

Any person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller free information about the personal data stored about him/her and a copy of this information at any time. Furthermore, the European legislator has granted the data subject access to the following information:

the purposes of processing;
the categories of personal data that are processed;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the existence of a right of appeal to a supervisory authority;
if the personal data are not collected from the data subject: All available information about the origin of the data;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary

The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject withdraws consent on which the processing is based according to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 para. 2 GDPR, the data subject objects to the processing.
The personal data was processed unlawfully.
The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data was collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO collected.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the SUBRIS GmbH, he or she may, at any time, contact any employee of the controller. An employee of SUBRIS GmbH shall promptly ensure that the erasure request is complied with immediately.

If the personal data have been made public by the SUBRIS GmbH and our company, as the controller, is obliged pursuant to Article 17(1) of the GDPR to erase the personal data, the SUBRIS GmbH shall implement suitable measures, including technical measures, to safeguard the personal data. 1 GDPR to erase the personal data, SUBRIS GmbH shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the SUBRIS GmbH will arrange the necessary measures in individual cases.

e) Right to restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Art. Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the SUBRIS GmbH, he or she may at any time contact any employee of the controller. The employee of the SUBRIS GmbH will arrange the restriction of the processing.

f) Right to data portability

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to receive the personal data concerning him or her, which has been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR or on a contract pursuant to Art. 6 para. 1 letter b GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Art. 20 para. 1 GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the SUBRIS GmbH.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. 1 (e) or (f) of the GDPR. This also applies to profiling based on these provisions.

The SUBRIS GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the SUBRIS GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to the SUBRIS GmbH to the processing for direct marketing purposes, the SUBRIS GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the SUBRIS GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 1 GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the SUBRIS GmbH. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated decisions in individual cases, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the SUBRIS GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.

i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.

11. Data protection provisions about the application and use of Google reCAPTCHA

The controller has integrated “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The purpose of reCAPTCHA is to check whether the data input on our websites (e.g. in a contact form) is made by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent on the website by the website visitor or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run completely in the background. Website visitors are not informed that an analysis is taking place.

Data processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website from abusive automated spying and SPAM.

Further information about Google reCAPTCHA and Google’s privacy policy can be found at the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.

12. Data protection provisions about the application and use of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, gathering and evaluation of data about the behavior of visitors to websites. Among other things, a web analysis service collects data about the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The data controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the data subject is shortened and anonymized by Google if access to our Internet pages is from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s IT system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website is accessed, which is operated by the data controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. During the course of this technical procedure, Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the data subject’s IT system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject’s IT system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person who is attributable to their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/ and under http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link https://www.google.com/intl/de_de/analytics/.

13. Data protection provisions about the application and use of Google Remarketing

The data controller has integrated Google Remarketing services on this website. Google Remarketing is a function of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user-related advertising and consequently to display advertisements relevant to the interests of the Internet user.

The operating company of the Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google Remarketing is to display interest-based advertising. Google Remarketing enables us to display advertisements via the Google advertising network or on other websites that are tailored to the individual needs and interests of Internet users.

Google Remarketing places a cookie on the data subject’s IT system. What cookies are has already been explained above. By setting the cookie, Google is able to recognize the visitor to our website when he or she subsequently visits websites that are also members of the Google advertising network. Each time a website on which the Google Remarketing service has been integrated is accessed, the data subject’s internet browser automatically identifies itself to Google. As part of this technical process, Google receives knowledge of personal data, such as the IP address or the surfing behavior of the user, which Google uses, among other things, to display interest-relevant advertising.

The cookie is used to store personal information, such as the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the Internet connection used by the data subject, is therefore transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/.

14. Data protection provisions about the application and use of Google AdWords

The data controller has integrated Google AdWords on this website. Google AdWords is an Internet advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, which are used to display an ad in Google’s search engine results exclusively when the user uses the search engine to retrieve a keyword-relevant search result. In the Google advertising network, the ads are distributed to relevant websites using an automatic algorithm and taking into account the previously defined keywords.

The operating company of the Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by displaying interest-relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party advertising on our website.

If a data subject reaches our website via a Google ad, a so-called conversion cookie is stored on the data subject’s IT system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, such as the shopping cart from an online store system, have been accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who has reached our website via an AdWords ad has generated sales, i.e. completed or canceled a purchase.

The data and information collected through the use of the conversion cookie is used by Google to compile visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the data subject.

The conversion cookie is used to store personal information, such as the websites visited by the data subject. Each time our website is visited, personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the data subject’s IT system. In addition, a cookie already set by Google AdWords can be deleted at any time via the Internet browser or other software programs.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/.

15. Legal basis of the processing

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance details or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d of the GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f of the GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

16. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

17. Duration for which the personal data is stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. Once this period has expired, the corresponding data is routinely deleted, provided it is no longer required for the fulfillment or initiation of a contract.

18. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

19. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

20 Google API Services User Data Policy

SUBRIS’s use of information obtained from Google APIs and its disclosure to another app is governed by the Google API Services User Data Policy, including the Restricted Use Requirements. For more information, see Google API Services User Data Policy

21 Order data processing contract

Contract data processing agreement acc. Article 9 DSG (valid from September 1, 2023), the person responsible within the meaning of the DSG is obliged to agree a contract with a commissioned data processor in which the obligations under data protection law are defined. Below you can download the contract drawn up with our external data protection consultant.

231218_ADV_Datenschutz Download