Data protection
In this data protection declaration, we provide information on which personal data we process in connection with our activities and operations, including our website. In particular, we provide information on why, how and where we process personal data. We also provide information about the rights of persons whose data we process.
Further data protection declarations and other legal documents such as general terms and conditions, terms of use or conditions of participation may apply to individual or additional activities and operations.
We are subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law guarantees adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
Swissalpine
Gäuggelistrasse 20
7000 Chur
info@swissalpine.ch
We point out if there are other controllers for the processing of personal data in individual cases.
2. Terms and legal bases
2.1 Terms
Personal data is all information relating to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or of third parties, except where such interests are overridden by the fundamental freedoms and rights and interests of the data subject. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the processing of personal data necessary for compliance with a legal obligation to which we are subject under any applicable law of Member States of the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process the personal data required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the duration required for the respective purpose(s) or by law. Personal data whose processing is no longer required will be anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
In principle, we only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons, for example to fulfill a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily and personally transmits to us when contacting us – for example by post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information in an address book, in a customer relationship management system (CRM system) or with comparable tools, for example. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection for such persons and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.
4. Personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We may export personal data to all countries and territories in the world, provided that the law there guarantees adequate data protection in the opinion of the Federal Data Protection and Information Commissioner (FDPIC ) or in accordance with a decision of the Swiss Federal Council and – if and insofar as the General Data Protection Regulation (GDPR) is applicable – in accordance with a decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees on request.
5. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. This includes the right to information and the right to rectification, erasure or blocking of the processed personal data.
Data subjects whose personal data we process can – if and insofar as the General Data Protection Regulation (GDPR) is applicable – obtain confirmation free of charge as to whether we process their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data rectified, erased (“right to be forgotten”), blocked or completed.
Data subjects whose personal data we process can – if and insofar as the GDPR is applicable – withdraw their consent at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC ).
6. Data security
We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. Unfortunately, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication – like all digital communication in general – is subject to mass surveillance without cause and without suspicion, as well as other surveillance 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 secret services, police forces and other security authorities.
7. Use of the website
7.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognize a browser the next time it visits 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 and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request – at least if and insofar as necessary – explicit consent to the use of cookies.
For cookies that are used to measure success and reach 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).
7.2 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).
We store such information, which may also constitute personal data, in server log files. The information is required in order to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to record the same information as in server log files.
8. Notifications and messages
We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.
8.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective, user-friendly, permanent, secure and reliable manner.
8.2 Consent and objection
You must always expressly consent to the use of your e-mail address and your other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the “double opt-in” procedure to obtain consent, i.e. you will receive an e-mail with a web link that you must click on to confirm, so that no misuse by unauthorized third parties can occur. We may log such consents, including the Internet Protocol (IP) address, date and time, for evidence and security purposes.
You can object to receiving notifications and communications such as newsletters at any time . With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Necessary notifications and communications in connection with our activities and operations remain reserved.
8.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
We use in particular:
- Mailchimp:
Communication platform; Provider: The Rocket Science Group LLC d/b/a Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Information on data protection: Privacy Policy (Intuit) including “Country and Region-Specific Terms”, “Frequently Asked Questions about Mailchimp Privacy”, “Mailchimp and European Data Transfers”, “Security”, Cookie Policy, “Privacy Rights Requests“, “Legal Notice”.
9. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The general terms and conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook and Instagram, including the so-called Page Insights, if and to the extent that the GDPR is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). The Page Insights provide information about how visitors interact with our Facebook and Instagram presence. We use Page Insights to provide our social media presence on Facebook and Instagram in an effective and user-friendly way.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Instagram as well as the data protection officer of Facebook and Instagram can be found in Facebook’s privacy policy. We have concluded the so-called “addendum for data controllers” with Facebook and Instagram and thus agreed in particular that Facebook and Instagram are responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page “Information on Page Insights” including “Information on Page Insights data”.
10. Third party services
We use the services of specialized third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Services of Google: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles”, Privacy policy, “Google is committed to complying with applicable data protection laws”, “Privacy policy for Google products”, “How we use data from websites or apps on or in which our services are used” (information from Google), “Types of cookies and other technologies used by Google”, “Personalized advertising” (activation / deactivation / settings).
- Services from Microsoft:
Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Data protection at Microsoft”, “Data protection (Trust Center)”, Privacy Policy.
10.1 Digital infrastructure
We use the services of specialized third parties in order to be able to make use of the necessary digital infrastructure in connection with our activities and operations. These include hosting and storage services from selected providers.
We use in particular:
- Hostpoint:
Hosting; Service provider: Hostpoint AG (Switzerland); Data protection information: Privacy policy.
10.2 Audio and video conferences
We use specialized services for audio and video conferencing to communicate online. For example, we can use it to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.
Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.
We use in particular:
- Microsoft Teams: Platform for audio and video conferencing, among other things; Service provider: Microsoft; Teams-specific information: “Data protection and Microsoft Teams”.
10.3 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.
We use in particular:
- Facebook (social plugins):
Embedding Facebook functions and Facebook content, for example “Like” or “Share”; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy policy. - Instagram platform:
Embedding Instagram content; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy Policy: Privacy Policy (Instagram), Privacy Policy (Facebook).
10.4 Maps
We use third-party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform:
Map service; Provider: Google; Google Maps-specific information: “How Google uses location information”. - Outdooractive: Map service; Service provider: Outdooractive AG (Germany); Privacy policy: Privacy policy
10.5 Digital audio and video content
We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.
We use in particular:
- YouTube:
Video platform; Service provider: Google; YouTube-specific information: “Privacy and Security Center”, “My data on YouTube”.
10.6 Event management
We use the services of specialised third parties to manage competition registration and results.
We use in particular:
- Datasport: Event management; Service provider: Datasport AG (Switzerland); Data protection information: Privacy policy
10.7 Advertising
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would particularly like to reach people who are already interested in our activities and operations or who might be interested in them(remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – data to third parties who enable such advertising. We can also determine whether our advertising is successful, i.e. in particular 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 be able to assign the use of our online offer to your profile there.
We use in particular:
- Facebook advertising (Facebook Ads):
Social media advertising; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Remarketing and targeting, in particular with the Facebook pixel and custom audiences including lookalike audiences, privacy policy, “Advertising preferences” (user registration required). - Google Ads:
Search engine advertising; Service provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, using various domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, “Advertising” (Google), “Why am I seeing a particular ad?”. - Instagram Ads: Social media advertising; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Remarketing and targeting, in particular with Facebook pixels and custom audiences including lookalike audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), “Advertising preferences” (Instagram) (user login required), “Advertising preferences” (Facebook) (user login required).
11. Success and reach measurement
We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the impact of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offering or parts of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are always shortened (“IP masking”) in order to follow the principle of data minimization through the corresponding pseudonymization and thus improve user data protection.
When using services and programs for measuring success and reach, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, user profiles are only created in pseudonymized form. We do not use user profiles to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.
We use in particular:
- Google Analytics:
Performance and reach measurement; Service provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (cross-device tracking) and with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, “Data protection”, “Browser add-on to deactivate Google Analytics”.
12. Final provisions
We may amend and supplement this privacy policy at any time. We will provide information about such adjustments and additions in a suitable form, in particular by publishing the current privacy policy on our website.