Privacy policy

Contents

1. What is this privacy policy for and what do we inform you about?
2. When does this privacy policy apply?
3. Who is responsible for processing personal data?
4. Where can you turn if you have questions about data protection?
5. What rights do you have?
6. Which terms do we use in this privacy policy?
7. Which personal data do we process and where does it come from?
8. For what purposes do we process your personal data?
9. On what legal bases do we collect and process your personal data?
10. To whom do we pass on your personal data?
11. Can we transfer your personal data abroad?
12. Do we process sensitive personal data?
13. Do we use automated individual decisions?
14. How long do we keep your data?
15. How do we protect your data?
16. Changes to this privacy policy
17. Website and cookie information

1. What is this privacy policy for and what do we inform you about?

Data protection matters to us. That is why we process your data only with great care and in accordance with the applicable legal requirements. Transparent information is part of effective data protection. With this privacy policy we inform you how and for what purpose we process your personal data. In particular you will learn:

• which data we process and for what purpose;
• who has access to your data and to whom we pass your data on;
• how long we keep your data;
• what rights you have and how you can exercise these rights;
• which cookies and other tools we use on our websites.

2. When does this privacy policy apply?

This privacy policy applies to all operations in which we process your personal data, unless we inform you about them separately. This privacy policy applies in particular to the following operations:

• You visit our websites;
• You use our services or buy from us (online or offline);
• You use our online offerings or apps;
• You subscribe to one of our newsletters;
• You contact us;
• You receive information or marketing communications from us;
• You take part in our competitions or prize draws;
• You take part in one of our events;
• You receive market research, opinion or customer surveys from us.

Please note that in certain circumstances we may also inform you about data processing in addition elsewhere. The general terms and conditions applicable in each case may also contain provisions on data protection (for example the GTC of our online shop).

3. Who is responsible for processing personal data?

Under the data protection rules, the company responsible for processing personal data is the one that determines the purpose for which and the means by which the processing takes place. Several companies can also be jointly responsible for the processing.

Responsible for the data processing under this privacy policy is update Fitness AG, Murgtalstrasse 20, 9542 Münchwilen TG (hereinafter “update Fitness” or “we”).

4. Where can you turn if you have questions about data protection?

If you have concerns or questions about data protection, you can contact the following office:

update Fitness AG

Murgtalstrasse 20

9542 Münchwilen TG

Phone 071 952 63 43

Email: [email protected]

5. What rights do you have?

5.1 Right to information

You can request information at any time about the personal data we process about you. Please send us your request for information together with proof of identity (see section 4).

We may restrict or refuse the information if it conflicts with our legal obligations, with legitimate interests of our own or of the public, or with the interests of a third party. The same applies if the request for information is an abuse of rights. Where the effort involved is disproportionate, we may ask for a contribution to the costs, about which we inform you in advance.

The handling of your request is subject to the statutory processing period of 30 days. However, we may extend this period because of a high volume of enquiries, for legal or technical reasons, or because we need further details from you. You will be informed of the extension in good time, at least in text form.

5.2 Deletion and correction

You can at any time request the deletion or correction of your personal data.

We may refuse the request if legal provisions oblige us to keep the data for longer or unchanged, or if a ground permitting the processing stands in the way of your request.

Please note that exercising your rights may in certain circumstances conflict with contractual agreements and have corresponding effects on the performance of the contract (for example early termination of the contract or cost consequences).

5.3 Legal recourse

If you are affected by the processing of personal data, you can enforce your rights in court or submit a report to the competent supervisory authority. The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner: http://www.edoeb.admin.ch.

6. Which terms do we use in this privacy policy?

In this privacy policy we use certain terms that have a legal meaning. Below we explain the meaning of the most important terms.

6.1 Personal data

Personal data includes all information relating to an identified or identifiable natural person. This includes, for example, name, address, date of birth, email address or telephone number. Data about personal preferences such as leisure activities or memberships also counts as personal data.

6.2 Sensitive personal data

Sensitive personal data means data on religious, ideological, political or trade union views or activities; data on health and, where applicable, information on administrative or criminal proceedings and sanctions as well as data on social assistance measures. Where necessary and appropriate, we may request and process sensitive personal data. In that case its processing is subject to strict confidentiality.

6.3 Processing personal data

Processing is any handling of personal data, irrespective of the means and procedures used, in particular the collection, storage, keeping, use, modification, disclosure, archiving, deletion or destruction of data.

6.4 Anonymisation

Anonymisation describes the process by which personal data is altered so that no conclusions can be drawn about the natural person concerned. Unlike pseudonymisation, anonymisation cannot be reversed.

6.5 Pseudonymisation

The pseudonymisation of personal data describes the process of making personal data unrecognisable. To that end, data that identifies a person (for example name, date of birth, place of residence) is replaced by a pseudonym (for example a code). Whoever holds the key information can use it to assign the data to a particular person (known as depseudonymisation or reidentification).

7. Which personal data do we process and where does it come from?

We process the personal data about you that is necessary to fulfil the respective purposes. You will find more detailed information about the personal data processed with the individual purposes (see section 8).

Normally you give us your personal data yourself, for example by sending it to us or when you communicate with us. To use certain of our services, you have to register as a customer beforehand.

In certain cases we also collect data about you ourselves or automatically, for example when you use our services, buy from us, browse our websites or use our app. This includes in particular behavioural and transaction data, online identifiers, online tracking and traffic data (see section 8.3). In certain cases we can also derive the data from existing data, for example by evaluating the online tracking and traffic data (see section 17.3).

In certain circumstances we also receive your personal data from third parties. These may be, for example, the following third parties:

• people around you (for example address for delivery, powers of attorney);
• banks or other contractual partners (for example for purchases and payments);
• credit reference agencies (for example for obtaining credit information);
• online service providers (for example analytics services) and address brokers (for example for address updates);
• authorities (for example in connection with court proceedings);
• public sources (for example public registers, media, the internet).

The personal data we receive from third parties may cover the following categories:

• master personal data (name, address, dates of birth and the like);
• contact data (mobile number, email address and the like);
• credit information;
• online identifiers (for example cookie identifier, IP addresses).

8. For what purposes do we process your personal data?

We may process your personal data for several purposes. Primarily we process it in order to be able to provide our services to you.

8.1 Performance of the contract

In order to conclude and handle contracts with you, we normally have to process your personal data. This is the case, for example, when you take out a membership with us, book a workshop or a training course, buy products in our online shop or on site in one of our fitness centres, register for a customer account, use one of our apps or take up other offers of ours online or offline. Performance of the contract may involve in particular the following categories of personal data:

• master personal data (for example salutation, first name, surname, date of birth, gender, customer number, user name);
• contact information (for example home address, email address, telephone number, delivery address);
• financial data (for example payment details, credit information);
• transaction data (for example shopping basket);
• data on training goals and health data (for example for putting together a training programme);
• customer history (for example interaction with customer service, information on the handling of defects or complaints).

For the purpose of performing the contract we may carry out all processing that is necessary to initiate, conclude, handle or enforce the contract. For example, before the contract is concluded we may obtain credit information about you (with data on your ability and willingness to pay) in order to decide whether or in what form we enter into a contract with you. In order to be able to deliver goods you have ordered, your data may be passed on to third-party service providers (for example the postal service). For payment processing there is also an exchange with the corresponding payment service provider. We may also process your data in connection with enquiries on your part about the service or the product (a consultation or a trial training session), about training advice, about remedying defects, about handling complaints, about reserving products or about rating services and products. In addition, at less busy times our fitness centres are supervised remotely by video camera in order to support the guests during their training. The video transmission is neither recorded nor stored during opening hours (for video surveillance outside opening hours see section 8.4). The guests are informed about the remote supervision separately on site.

8.2 Communication

In order to communicate with you and deal with your concerns, we have to process your personal data. This can be the case when you use one of our contact forms, contact us by email, post or telephone or in another way, when we contact you, or for customer care. For this we process in particular the following data:

• name and contact details (for example name, address, email address, telephone number);
• content of the communication (for example letter, email, chat, comments on the websites, telephone conversations);
• metadata of the communication (for example details of the type, the time or, where applicable, the place of the communication).

We may carry out all processing operations that are necessary for communicating with you. In particular we may answer your enquiries or contact you if we have questions. We may also use the communication data for quality assurance and training purposes. In that case the data is used, as far as possible, only in pseudonymised or anonymised form. If we record telephone conversations or video conferences or listen in on them for quality assurance and training purposes, we point this out to you specifically. If you do not want a recording in such a case, please tell us or end your participation. Communication in connection with other purposes such as performance of the contract (section 8.1), marketing (section 8.3) or market research (section 8.4) can also be captured. You will receive additional information with the respective purpose.

8.3 Marketing and information

In order to make attractive and suitable offers to you and send you interesting information about products, services, events and the like, we may process your personal data for marketing purposes. This is the case, for example, when you have a membership with us, buy in one of our shops (online or offline), place an order in one of our stores, register for a customer account, use one of our apps, take part in a competition or prize draw, or when you take up other offers of ours online or offline. We may also draw your attention to offers of companies affiliated with us. For marketing purposes we may process in particular the following data about you:

• master personal data (for example salutation, first name, surname, date of birth, gender, customer number, user name);
• contact information (for example home / delivery address, email address, telephone number);
• behavioural and transaction data (for example shopping basket details, behaviour when making purchases, participation in competitions, information on subscribed services);
• online identifiers (for example cookie identifier, IP addresses);
• online tracking and traffic data (for example browsing behaviour, click behaviour on receiving newsletters);
• profile data or data on personal preference (for example preferences regarding products or services).

The marketing purpose covers all processing that allows us to inform you appropriately about our offers. We may send you written and electronic information or offers. This includes, for example, sending newsletters, emails, push notifications in apps or other electronic messages electronically, as well as sending advertising brochures, magazines or other printed matter by post. It also covers digital advertising messages such as search, display, video or social ads. We may also send you vouchers or invite you to events, prize draws and competitions. We may also show you recommendations for products or services on our websites and in our app.

We may also personalise the corresponding offers and information on the basis of the data we hold about you, so that as far as possible you only receive information and offers that are actually relevant and interesting for you. We also measure the effectiveness of our advertising activities and evaluate them.

We may also commission third-party providers to place advertising activities and advertising campaigns, to measure conversions and to carry out the corresponding evaluations (for example by using third-party cookies, see sections 17.2 and 17.3).

You can unsubscribe from marketing communications you receive at any time. Email communications always contain a corresponding unsubscribe link. You will find the corresponding instructions for preventing marketing cookies (which lead, for example, to personalised ads) in the cookie provisions (section 18.2).

8.4 Further purposes

In addition we may also process your personal data for further purposes. These include:

Market and opinion research: in order to keep developing and improving our offers, we may process your personal data. For example, we carry out customer surveys or polls.

Enforcement of legal claims: in order to be able to enforce legal claims or to defend against unjustified claims, we may in certain circumstances have to process your personal data. Depending on the case concerned, this can affect different categories of personal data.

Compliance with legal requirements and the prevention and investigation of criminal offences or other misconduct: in certain circumstances we are obliged to check compliance with legal requirements and to cooperate with the authorities in the event of legal violations. Personal data may be processed for these purposes. All relevant personal data can be affected. This is the case, for example, when regulatory requirements are enforced, when information or documents are disclosed to authorities where we are legally obliged to do so, or when we cooperate in an official investigation (for example criminal prosecution or a supervisory authority) where there is a legal obligation to do so.

Security: in order to guarantee the security of our operations, we may in certain circumstances have to process your personal data. This can affect all of your personal data. It includes in particular video surveillance in our fitness centres to safeguard our inventory and the products for sale and to detect criminal offences. The video surveillance systems are limited in location and marked accordingly. Surveillance takes place only outside opening hours (for remote supervision see section 8.1).

Further purposes: we may process your personal data for further purposes, for example within our internal processes and administration. These further purposes include, for example, administrative purposes (such as managing master data, accounting, data archiving and the review, management and continuous improvement of the IT infrastructure) and the evaluation and improvement of internal processes. This also includes, for example, analysing usage behaviour on our apps and websites in order to optimise them (see also section 17.3). Safeguarding further legitimate interests is also one of the further purposes, which cannot be listed exhaustively.

9. On what legal bases do we collect and process your personal data?

The legal basis for collecting and processing your personal data depends in each individual case on the respective purpose of the data processing. The following principles apply:

We process your data in good faith and for the purposes set out in this privacy policy (see section 8). In doing so we make sure that the processing is transparent and proportionate.

Where this is necessary, we rely on a ground of justification for the processing. In particular the following may serve as a ground of justification:

• your consent;
• the performance of a contract or of pre-contractual measures;
• compliance with legal provisions;
• our legitimate interests, provided your interests do not outweigh them.

You can withdraw any consent you have given at any time. You can write us an email for this or, where available, use a corresponding unsubscribe link. The lawfulness of the data processing that has already taken place is not affected by the withdrawal.

In particular the following may serve as legitimate interests:

• the provision and further development of our offers, services, websites, apps and other platforms on which we are present;
• communication with third parties and handling their enquiries (for example for the delivery of products and services to third parties);
• the review and optimisation of procedures for needs analysis for the purpose of addressing customers directly;
• carrying out advertising and marketing activities and conducting market and opinion research;
• combating fraud and complying with legal provisions.

10. To whom do we pass on your personal data?

We may pass your personal data on to third parties where this is necessary in the course of handling the contract or for further purposes (section 8) (for example to the company entrusted with delivering the goods or to the credit institution commissioned with processing the payment), or in order to use necessary technical or organisational services. Such third parties are contractually obliged to process your personal data exclusively on our behalf and according to our instructions. Third parties must also ensure the security of your personal data by means of appropriate technical and organisational measures. Such processing on our behalf may involve in particular service providers in the following areas:

• shipping and logistics (for example for sending ordered goods);
• advertising and marketing (for example for sending communications such as mailings, postcards, newsletters, display advertising; running competitions, surveys and market research);
• organising and running events;
• company administration and fiduciary services;
• payment services;
• debt collection services;
• IT services;
• consulting services and others.

In certain circumstances our service providers may also process data on how their services are used, and further data arising in the course of the use of their service, as independent parties responsible for the processing, for their own legitimate interests (for example for statistical evaluation or billing). The service providers give information about independent data processing in their respective privacy policies.

In certain circumstances we may also pass your personal data on to further third parties for their own data processing. These may in particular be contractual partners where the transfer of the data follows from the corresponding contracts.

In certain circumstances we may also pass personal data on to authorities in Switzerland and abroad, where we are legally obliged or entitled to do so or where this is necessary to safeguard our legitimate interests. The authorities process the data they have received from us under their own responsibility.

11. Can we transfer your personal data abroad?

We process your personal data in Switzerland or in the European Economic Area (EEA) as far as possible. In certain circumstances your personal data may be transferred to service providers abroad in the course of processing on our behalf (see section 10). The transfer can take place worldwide.

Where there is no adequate data protection in the third country concerned, a data transfer to that third country only takes place if the processor has provided safeguards regarded by the legislator as suitable for ensuring data protection (for example the EU standard contractual clauses). A transfer based on standard contractual clauses only takes place after a prior risk assessment. If the risk assessment shows that the processor cannot comply with the standard contractual clauses, we will ensure that additional technical measures are taken to preserve the integrity and confidentiality of the personal data transferred.

12. Do we process sensitive personal data?

We only process sensitive personal data (see section 6.2) where this is absolutely necessary for providing the service and where you have disclosed the corresponding data to us or have consented to the processing.

13. Do we use automated individual decisions?

One speaks of an automated individual decision when decisions that have legal consequences for the person concerned or significantly affect that person in another way are taken in a fully automated manner, that is without the involvement of a human being.

As a rule we do not use automated individual decisions. If we do use them after all, you will be informed about it separately.

14. How long do we keep your data?

We store personal data only for as long as is necessary to fulfil the individual purposes for which the data was collected, or where we are legally obliged to keep it for longer.

In particular we have to keep business communication, concluded contracts and accounting vouchers for up to 10 years (see in particular art. 958f of the Swiss Code of Obligations [CO]). As soon as we no longer need such data of yours to provide the services, the data is blocked. After that we use it only for accounting and tax purposes.

15. How do we protect your data?

We keep your personal data securely and take appropriate technical and organisational measures to protect your personal data against loss, access, misuse or alteration. Our contractual partners and employees who have access to your personal data are obliged to comply with the data protection provisions.

For security reasons and to protect the transmission of confidential information (for example your orders or enquiries), our websites use SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the padlock symbol in your browser bar. Payment transactions using the common means of payment (for example Visa/MasterCard and the like) take place exclusively over an encrypted SSL or TLS connection.

Since complete data security cannot be guaranteed for communication by email, we recommend choosing a secure form of transmission for confidential information.

16. Changes to this privacy policy

We may change this privacy policy over time, for example if processing operations or the legal situation change. Where this is possible with proportionate effort, you will be notified separately of significant changes.

17. Website and cookie information

The following information shows you how we process personal data or other data in connection with our websites or apps. This happens in particular through cookies or similar technologies. The following provisions apply to our websites as well as to apps, even where only a website is mentioned in each case.

17.1 Providing the website and creating log files

Which information do we receive and how do we use it?

When you visit our website, certain data is stored automatically on our servers or on servers of services and products that we obtain and/or have installed. This happens for the purposes of system administration, backup, tracking or statistical evaluation. The data concerned is as follows:

• the name of your internet service provider;
• your IP address (in certain circumstances);
• the version of your browser software;
• the operating system of the computer with which our website is accessed;
• the date and the time of access;
• the website you visited before;
• the search terms you used to find our website;
• browser type;
• host name of the computer;
• type of access;
• login status.

How can you prevent the collection of data?

The data is stored only for as long as is necessary to achieve the purpose of its collection. Accordingly the data is normally deleted at the end of each session. Storing the log files is absolutely necessary for operating the websites. You therefore have no way of objecting to it.

17.2 Cookies

How do cookies work and what are they for?

Cookies are text files that are placed on the operating system of your device with the help of the browser when you call up a website. Cookies contain a unique identification number (ID) by which we can distinguish individual visitors from others. As a rule, however, you are not identified. Cookies do no damage to your computer and contain no viruses. They also serve to improve user interaction considerably, so that certain settings remain stored for you, and they are indispensable for some technical controls (for example session or shopping basket management).

What types of cookies are there?

Most of the cookies we use are so-called “session cookies”, which are deleted automatically at the end of your visit.

Other cookies remain stored on your device until you delete them (normally, however, they are deleted after 2 years at the latest). The purpose of these cookies is to store your preferences (for example language and location settings), to deliver the website content quickly and present it attractively (for example by using fonts and content delivery networks), to analyse the use of this website for statistical evaluation as well as for continuous improvements and marketing purposes (as a rule by means of third-party cookies, see below).

We may also use similar technologies such as pixel tags, fingerprints or other technologies for storing data in the browser. Pixel tags allow certain information to be transmitted to the operator of the server by means of small, normally invisible images or program code that are loaded from a server (for example whether and when a website was visited). Fingerprints collect information about the configuration of your device or your browser during your website visit in order to distinguish your device from other devices. Most browsers also support additional technologies (for example web storage) which we may likewise use.

Which cookies or similar technologies do we use?

We may use the following types of cookies or similar technologies:

• Necessary cookies: these are cookies that are necessary so that a website and its functions can be used. These cookies ensure, for example, that form data already entered is not deleted when moving between pages and that shopping basket contents are not lost.
• Performance cookies: performance cookies allow us to carry out analyses by collecting information about the way a website is used. This shows us, for example, how visitors move around a website. We can also measure the loading times or the behaviour of the website with different browser types. Thanks to performance cookies we can continuously improve our websites and the user experience.
• Functional cookies: thanks to these cookies we can store certain data that you enter on our websites so that you do not have to enter it again (for example location, language, form data and the like). This allows us to increase the user-friendliness of our websites.
• Marketing cookies: marketing cookies allow us (or our marketing partners) to present advertisements to you on our websites (or on the websites of third parties) that are adapted to your browsing behaviour and are interesting for you.

Do we use cookies from third-party providers?

We may also use third-party cookies. In that case the cookies are not placed by us when the website is visited, but by the third-party provider. Such providers may also be based outside the European Economic Area (EEA); in that case data protection is ensured with appropriate measures (see section 11).

Cookies from third-party providers can be, for example, analytics services, but also tracking and retargeting measures. They allow us to address you with advertisements on our websites or on the websites of third parties and to measure the effectiveness of those advertisements. The third-party providers can record your use of our websites and, where applicable, combine data that has been collected on other websites. The provider concerned may also use this data for its own purposes, for example for personalised advertising on its own websites or on other websites for which it supplies advertisements. Where the provider can identify you (for example because you have a customer account), it can assign the usage data to you. The corresponding processing takes place in accordance with the data protection provisions of the third-party provider. The most important third-party providers are Google and Facebook. Below you will find a description of the most important tools we use (see section 17.3).

How can you prevent data collection via cookies?

For some of our digital services you can control the use of cookies through a consent banner. There you can activate or deactivate certain categories of cookies.

Which further methods of online advertising do we use?

In addition to marketing and cookies from third-party providers, we use further techniques to control online advertising on other websites and thereby prevent wasted coverage. For example, we may pass the email addresses of our users on to third-party companies in pseudonymised form (so-called hashing) (see section 6.6 for the definition). By matching the database, the advertising company (as a rule a social media provider) recognises those contact details that are already present in its own database and can serve you advertisements tailored to your interests (see for example the cookies used under section 18.3). The third-party companies do not receive personal email addresses of people who are not already known to them. You can prevent personalised advertising from being served through the corresponding cookie settings (see above).

Can we include offers of third parties on our websites?

We may embed further offers of third parties on our websites, in particular of social media providers (for example embedded YouTube videos). These offers are deactivated by default. As soon as you activate them (for example by clicking a switch), the corresponding providers can determine that you are on our website. If you have an account with that social media provider, it can assign this information to you and thus track your use of online offers. The social media providers process this data under their own responsibility.

Which data do we process on our pages in social networks?

We may operate pages and other online presences on social networks and on other platforms operated by third parties (“fan pages”, “channels”, “profiles” and the like) and collect there the data about you described in section 7 and below. We receive this data from you and from the platforms when you get in touch with us through one of our online presences (for example when you communicate with us, comment on our content or visit our presence). At the same time the platforms evaluate your use of our online presences and combine this data with further data about you known to the platforms (for example about your behaviour and your preferences). The platforms process this data under their own responsibility, also for their own purposes, in particular for marketing and market research purposes (for example to personalise advertising) and to steer their platforms (for example which content they show you).

We process this data for the purposes described in section 8, in particular for communication, for marketing purposes (including advertising on these platforms, see section 17.2) and for market research. Content you have published yourself (for example comments on an announcement) may be further distributed by us (for example in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from you or about you in accordance with the usage guidelines (for example inappropriate comments).

For further details about the processing carried out by the platform operators, please refer to the data protection notices of the platform concerned. There you will also learn in which countries they process their data, what rights to information, deletion and other data subject rights you have and how you can exercise them or obtain further information.

17.3 Tracking tools

On our websites and apps we may use tracking tools with the help of which we can carry out evaluations of the use of our online offers and address visitors with targeted marketing activities. Below you will find a list and an explanation of the most important tracking tools that we use.

a) Google Analytics

How does Google Analytics work?

Our website uses Google Analytics, a service of Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland). Google uses cookies which are stored on your device and allow the use of the website to be analysed. The information generated by the cookie about your use of the website is normally transferred to a Google server in the USA and stored there. We have added the code “anonymizeIP” to Google Analytics. This ensures that all data is collected anonymously. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.

Why do we use Google Analytics?

Google evaluates the collected data on our behalf so that we can get a picture of the visits and the user behaviour on our websites. This allows us to improve our services and the website content as well as its design.

Which additional functions do we use?

We additionally use cookies for remarketing campaigns. This function makes it possible to link the advertising audiences created with Google Analytics Remarketing to the cross-device functions of Google DoubleClick. In this way, interest-based, personalised advertising messages that have been adapted to you on the basis of your previous usage and browsing behaviour on one device (for example a smartphone) can also be shown on another of your devices (for example a tablet or PC). If you have given Google a corresponding consent, Google links your web and app browsing history to your Google account for this purpose. In this way the same personalised advertising messages can be served on every device on which you log in with your Google account. To support this function, Google Analytics collects Google-authenticated IDs of the users, which are temporarily linked to our Google Analytics data in order to define and create audiences for cross-device display advertising.

How can you prevent your data from being collected via Google Analytics?

You can deactivate Google Analytics through the corresponding settings, provided a consent banner is available.

b) Google Ads conversion tracking or similar services from other providers

With Google Ads conversion tracking services, Microsoft Ads Advertising or comparable services from other providers, a cookie is set on your computer if you reached one of our websites via a corresponding advertisement. This is done for the purpose of tracking and measuring performance. No information is collected with which the user could be identified. Our legitimate interests in measuring performance serve as the legal basis. The cookies are deleted automatically after 30 days.

Right to object

If you do not want to take part in the tracking procedure, you can prevent the necessary cookie from being set in your browser settings.

You will find more information about conversion tracking services in the data protection provisions of Google at https://www.google.de/policies/privacy/.

c) Google Customer Match and Meta Custom Audience

In order to be able to serve personalised advertisements through the services of Google and Meta, we may forward lists of encrypted and pseudonymised personal data of our customers (for example email address) to Google and Meta (see also section 8.3). This data is then matched, so that advertising can be served through the Google or Meta network to the people who are logged in to Google or Meta.

If you have a Google or Meta account, you can deactivate personalised advertisements in the respective account settings of Google and Meta.

Right to object

You can object to the forwarding of your encrypted and pseudonymised personal data (for example email address) to Google or Meta by notifying us of your objection by email to [email protected]. In that case we will not forward any information to Google or Meta.

d) Meta Pixel

How does Meta Pixel work

For conversion measurement our website uses the visitor action pixel of Facebook (Meta Platforms Ireland Ltd., Harbour 4, Grand Canal Quay, Grand Canal Bridge, Dublin 2, Ireland). Meta Pixel allows us to track your behaviour after you have been redirected to our website by clicking on a Facebook advertisement. The data collected is anonymous for us as the operator of these websites and therefore allows no conclusions to be drawn about you as a person.

Why do we use Meta Pixel?

We use Meta Pixel to evaluate the effectiveness of the Facebook advertisements for statistical and market research purposes and to optimise future advertising activities.

If you do not want personalised advertisements from Facebook, you can set this accordingly in the Facebook account settings. Where a consent banner is available, you can also deactivate Meta Pixel through the corresponding settings.

Who is responsible for the data processing?

We are jointly responsible with Facebook for the exchange of data that Facebook collects or receives via Meta Pixel or comparable functions, for the display of advertising information that matches the visitors, for improving the delivery of advertisements and for personalising functions and content. You can therefore also address requests for information or other data protection concerns directly to Facebook.

We are not responsible for further data processing. In this respect your data may be processed by Facebook. In particular a link to your respective user profile is possible and Facebook may use the collected data for its own advertising purposes.

Which data do we process on our pages in social networks?

We may operate pages and other online presences on social networks and on other platforms operated by third parties (“fan pages”, “channels”, “profiles” and the like) and collect there the data about you described in section 7 and below. We receive this data from you and from the platforms when you get in touch with us through one of our online presences (for example when you communicate with us, comment on our content or visit our presence). At the same time the platforms evaluate your use of our online presences and combine this data with further data about you known to the platforms (for example about your behaviour and your preferences). The platforms process this data under their own responsibility, also for their own purposes, in particular for marketing and market research purposes (for example to personalise advertising) and to steer their platforms (for example which content they show you).

We process this data for the purposes described in section 8, in particular for communication, for marketing purposes (including advertising on these platforms, see section 17.2) and for market research. Content you have published yourself (for example comments on an announcement) may be further distributed by us (for example in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from you or about you in accordance with the usage guidelines (for example inappropriate comments).

For further details about the processing carried out by the platform operators, please refer to the data protection notices of the platform concerned. There you will also learn in which countries they process their data, what rights to information, deletion and other data subject rights you have and how you can exercise them or obtain further information.

17.4 App access rights

In order to provide the services in our apps we may need the access rights listed below, which allow us to access certain functions of your device:

• Location data up to the level of precise location: location data is collected, for example, in order to be able to show the nearest point of sale. The data is not stored.
• Photos, videos: these are collected, for example, in order to be able to ensure the quick use of functions such as Google Maps. Elsewhere, photos and videos can be used to supplement entries you have created yourself (for example for the shopping list or the recipe book).
• Notifications (iOS only): these are collected in order to control the receipt of push messages.
• Camera: this is collected in order to be able to read barcodes (on cards and products) and QR codes (for example for links to further product information) and to take photos and videos (for example for the shopping list or the recipe book).
• Calendar (iOS only): this is collected in order to be able to set appointments in the calendar (for example for Mondovino wine fairs).
• Deactivate sleep mode (Android only): this is collected in order to be able to receive push messages.
• Reading the Google service configuration: this is collected, for example, in order to enable the linked use of Google Maps.
• Vibration function: this is collected, for example, in order to confirm the scanning of a barcode or QR code with a vibration.
• Retrieving a network connection: this is collected in order to determine whether a network connection exists.
• Use all networks / mobile data: this is collected in order to be able to access the internet (for example for updating data, for logins, for activating vouchers).
• Light indicator (flash): this is collected in order to be able to switch on the flash when the camera is used.
• WLAN connection information: this is collected in order to be able to retrieve the WLAN connections and show the WLAN status.
• Siri and search (iOS only): this is collected in order to be able to make suggestions when you type something in the app.
• Background refresh (iOS only): this is collected in order to be able to refresh the app in the background.