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Privacy Policy

With this privacy policy, we inform about the processing of personal data in connection with our activities and operations, including our website under the domain name www.lumega.ch. We specifically inform about the purposes, methods, and locations of our data processing activities. We also provide information about the rights of individuals whose data we process.

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

We are subject to Swiss law and, where applicable, foreign laws such as those of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized with the decision of July 26, 2000, that Swiss data protection law provides adequate data protection. With the report of January 15, 2024, the European Commission confirmed this adequacy decision.

1. Contact Addresses

Responsible in the data protection sense is:

LUMEGA AG
Kirchweg 13
5415 Nussbaumen/Baden
info@lumega.ch

In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We are happy to provide affected individuals with information about the respective responsibility upon request.

Data Protection Officer or Data Protection Advisor

We have the following data protection officer or data protection advisor as a contact point for affected individuals and authorities for inquiries related to data protection:

Andreas Lustenberger
Kirchweg 13
5415 Nussbaumen/Baden
info@lumega.ch

2. Terms and Legal Bases

2.1 Terms

Affected Person: Natural person whose personal data we process.

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

Particularly Sensitive Personal Data: Data about union, political, religious, or philosophical views and activities, data about health, intimate sphere, or ethnic or racial affiliation, genetic data, biometric data that uniquely identify a natural person, data about criminal and administrative sanctions or prosecutions, and data about social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, acquiring, recording, collecting, deleting, revealing, arranging, organizing, storing, altering, distributing, linking, destroying, and using personal data.

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

2.2 Legal Bases

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

We process – if and to the extent that the European General Data Protection Regulation (GDPR) is applicable – personal data according to at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for the necessary processing of personal data to fulfill a contract with the affected person and to carry out pre-contractual measures.
  • Art. 6(1)(f) GDPR for the necessary processing of personal data to safeguard legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and rights and interests of the affected person prevail. Such interests include the permanent, humane, secure, and reliable conduct of our activities and operations, ensuring information security, protection against misuse, enforcement of own legal claims, and compliance with Swiss law.
  • Art. 6(1)(c) GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under applicable law of member states in the European Economic Area (EEA).
  • Art. 6(1)(e) GDPR for the necessary processing of personal data to perform a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for the processing of personal data with the consent of the affected person.
  • Art. 6(1)(d) GDPR for the necessary processing of personal data to protect vital interests of the affected person or another natural person.
  • Art. 9(2) et seq. GDPR for the processing of special categories of personal data, especially with the consent of the affected persons.

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

3. Type, Scope, and Purpose of Processing Personal Data

We process the personal data that is necessary to conduct our activities and operations permanently, humanely, securely, and reliably. The processed personal data may fall into categories such as browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute particularly sensitive personal data.

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

We process personal data, where necessary, with the consent of the affected persons. In many cases, we can process personal data without consent, for example, to fulfill legal obligations or to safeguard overriding interests. We may also ask affected persons for their consent when their consent is not required.

We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data, particularly depending on legal retention and limitation periods.

4. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include specialized providers whose services we use.

We may disclose personal data in the context of our activities and operations, particularly to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

5. Communication

We process personal data to communicate with individuals and authorities, organizations, and companies. In doing so, we particularly process data provided to us by an affected person when contacting us, for example, by postal mail or email. We may store such data in an address book or similar tools.

Third parties who transmit data about other persons to us are required to independently ensure the data protection of these affected persons. They must, in particular, ensure that such data is correct and may be transmitted.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also manage and otherwise process the data of affected persons beyond direct communication with such services.

6. Applications

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data is derived, in particular, from the requested information, for example, as part of a job advertisement. We may publish job advertisements with the help of suitable third parties, such as in electronic and print media or on job portals and job platforms.

We also process personal data that applicants voluntarily disclose or publish, especially as part of cover letters, resumes, and other application documents, as well as online profiles.

We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular according to Art. 9(2)(b) GDPR.

We use selected services from suitable third parties to advertise positions through e-recruitment and to facilitate and manage applications.

7. Data Security

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

Access to our website and our other digital presence is via transport encryption (SSL / TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.

Our digital communication is subject – as generally all digital communication – to mass surveillance without cause and suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police stations, and other security authorities. We also cannot rule out that an affected person is being specifically monitored.

8. Personal Data Abroad

We process personal data primarily in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, particularly to process it there or have it processed.

We can export personal data to all countries on Earth and elsewhere in the universe if the law there provides adequate data protection according to the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also according to the decision of the European Commission.

We may transmit personal data to countries whose law does not provide adequate data protection if data protection is ensured for other reasons, particularly based on standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example, the explicit consent of the affected persons or a direct connection with the conclusion or execution of a contract. We are happy to provide affected persons with information about possible safeguards or provide a copy of any guarantees upon request.

9. Rights of Affected Persons

9.1 Data Protection Claims

We grant affected persons all claims according to the applicable law. Affected persons have the following rights in particular:

  • Information: Affected persons can request information about whether we process personal data about them, and if so, what personal data is involved. Affected persons also receive the information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data itself and, among other things, information about the processing purpose, retention period, any disclosure or export of data to other countries, and the origin of the personal data.
  • Correction and Restriction: Affected persons can correct inaccurate personal data, complete incomplete data, and restrict the processing of their data.
  • Opportunity for Own Viewpoint and Human Review: Affected persons can present their own viewpoint and request human review for decisions based solely on automated processing of personal data and that have a legal effect on them or significantly affect them (automated individual decisions).
  • Deletion and Objection: Affected persons can have personal data deleted ("right to be forgotten") and object to the processing of their data with future effect.
  • Data Release and Data Transfer: Affected persons can request the release of personal data or the transfer of their data to another controller.

We can defer, restrict, or refuse the exercise of affected persons' rights within the legally permissible framework. We can inform affected persons of any conditions that must be met to exercise their data protection claims. For example, we may refuse information with reference to confidentiality obligations, overriding interests, or the protection of other persons, in whole or in part. We may also refuse to delete personal data, particularly with reference to legal retention obligations, in whole or in part.

We may provide for costs for the exercise of rights in exceptional cases. We inform affected persons in advance about any costs.

We are obliged to identify affected persons who request information or assert other rights with appropriate measures. Affected persons are required to cooperate.

9.2 Legal Protection

Affected persons have the right to enforce their data protection claims in court or to file a complaint with a data protection supervisory authority.

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

European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), data protection supervisory authorities are federally structured, especially in Germany.

10. Use of the Website

10.1 Cookies

We may use cookies. Cookies – both first-party cookies and third-party cookies – are data stored in the browser. Such stored data does not have to be limited to traditional text cookies.

Cookies can be stored temporarily in the browser as "session cookies" or for a certain period as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable, in particular, the recognition of a browser on the next visit to our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated, restricted, or deleted in the browser settings at any time. The browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be available in full. We request – at least to the extent required by applicable law – active explicit consent to the use of cookies.

For cookies used for success and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

10.2 Logging

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

We log such information, which may also constitute personal data, in log files. The information is necessary to provide our digital presence permanently, humanely, and reliably. The information is also necessary to ensure data security – also by third parties or with the help of third parties.

10.3 Counting Pixels

We may integrate counting pixels into our digital presence. Counting pixels are also referred to as web beacons. Counting pixels – also from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when accessing our digital presence. With counting pixels, at least the same information as in the logging of log files can be collected.

11. Notifications and Communications

11.1 Success and Reach Measurement

Notifications and communications may contain web links or counting pixels that record whether an individual communication was opened and which web links were clicked. Such web links and counting pixels can also capture the use of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement to effectively and humanely send notifications and communications based on the needs and reading habits of the recipients, as well as permanently, securely, and reliably.

11.2 Consent and Objection

You must generally consent to the use of your email address and other contact addresses unless the use is permitted for other legal reasons. For obtaining a double-confirmed consent, we may use the "double opt-in" procedure. In this case, you will receive a notification with instructions for double confirmation. We may log obtained consents, including IP address and timestamp, for evidential and security reasons.

You can generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also simultaneously object to the statistical recording of usage for success and reach measurement. Required notifications and communications related to our activities and operations remain reserved.

11.3 Service Providers for Notifications and Communications

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

We specifically use:

12. Social Media

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

The general terms and conditions (GTC) and terms of use, as well as privacy policies and other provisions of the individual operators of such platforms, apply. These provisions inform, in particular, about the rights of affected persons directly against the respective platform, including the right to information.

For our social media presence on Facebook, including the so-called page insights, we are – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use page insights to provide our social media presence on Facebook effectively and humanely.

Further information about the type, scope, and purpose of data processing, information about the rights of affected persons, and the contact details of Facebook and Facebook's data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called «Controller Addendum» with Facebook and have agreed, in particular, that Facebook is responsible for ensuring the rights of affected persons. For the so-called page insights, the corresponding information can be found on the page «Information about Page Insights», including «Information about Page Insights Data».

13. Services from Third Parties

We use services from specialized third parties to conduct our activities and operations permanently, humanely, securely, and reliably. With such services, we can, among other things, embed functions and content into our website. For such embedding, the services used must at least temporarily capture the IP addresses of users for technical reasons.

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

We specifically use:

13.1 Digital Infrastructure

We use services from specialized third parties to obtain the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

We specifically use:

13.2 Appointment Scheduling

We use services from specialized third parties to schedule appointments online, for example, for meetings. In addition to this privacy policy, any directly visible terms of the services used, such as terms of use or privacy policies, apply.

13.3 Audio and Video Conferences

We use specialized services for audio and video conferences to communicate online. We can thus hold virtual meetings or conduct online classes and webinars. For participating in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, apply additionally.

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

13.4 Map Material

We use services from third parties to embed maps into our website.

We specifically use:

13.5 Digital Content

We use services from specialized third parties to embed digital content into our website. Digital content includes, in particular, image and video material, music, and podcasts.

We specifically use:

13.6 Advertising

We use the option to display targeted advertising with third parties such as social media platforms and search engines for our activities and operations.

We aim to reach with such advertising, in particular, individuals who are already interested in our activities and operations or might be interested in them (Remarketing and Targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e., whether it leads to visits to our website (Conversion Tracking).

Third parties with whom we advertise and where you are registered as a user may associate the use of our website with your profile there.

We specifically use:

14. Website Extensions

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

We specifically use:

  • Google reCAPTCHA: Spam protection (distinguishing between desired content from humans and unwanted content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: «What is reCAPTCHA?».

15. Success and Reach Measurement

We attempt to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party references or examine how different parts or versions of our digital presence are used («A/B Test» method). Based on the results of success and reach measurement, we can specifically fix errors, strengthen popular content, or make improvements.

For success and reach measurement, in most cases, the IP addresses of individual users are captured. IP addresses are generally shortened («IP Masking») in this case to follow the principle of data minimization through the corresponding pseudonymization.

In success and reach measurement, cookies may be used, and user profiles may be created. Any created user profiles include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the – at least approximate – location. Generally, any created user profiles are exclusively pseudonymized and not used to identify individual users. Individual services from third parties, where users are registered, may associate the use of our online offer with the user account or user profile at the respective service.

We specifically use:

16. Video Surveillance

We use video surveillance to prevent crimes, secure evidence in the event of crimes, exercise and assert our own legal claims, defend against third-party legal claims, and exercise our house rights. This constitutes – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – overriding legitimate interests according to Art. 6(1)(f) GDPR, with particular reference to Art. 9(2)(f) GDPR for particularly sensitive personal data.

We store recordings from our video surveillance as long as necessary for evidence or another stated purpose.

We may secure recordings from our video surveillance and transmit them to competent authorities, such as courts or law enforcement agencies, if the transmission is necessary for a stated purpose, in our other legitimate overriding interest, or due to legal obligations.

17. Concluding Notes on the Privacy Policy

We have created this privacy policy with the Privacy Policy Generator from Datenschutzpartner.

We may update this privacy policy at any time. We inform about updates in an appropriate manner, particularly by publishing the current privacy policy on our website.

LUMEGA Family