We are subject to Swiss data protection law as well as any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
JLT Company AG
We point out if there are other persons responsible for processing personal data in individual cases.
2. Terms and legal basis
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, for example, the retrieval, comparison, adaptation, archiving, storage, reading out, disclosure, procurement, recording, collection, deletion, disclosure, ordering, organising, storage, modification, dissemination, linking, destruction and use of personal data.
The processing includes any handling of personal data, regardless of the means and procedures used.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) and 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, such as in particular the Federal Data Protection Act (Data Protection Act, DPA) and the Data Protection Ordinance (Data Protection Ordinance, DPA).
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 DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. 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, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e DSGVO 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 DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3. nature, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such personal data may in particular 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 that is necessary for us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner.
We process personal data for the period necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary will be anonymised or deleted.
We may process personal data for the period of time necessary for the purpose(s) in question or required by law.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
We process personal data jointly with third parties.
We process personal data as a matter of principle only with the consent of the persons concerned. If and to the extent that the processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process personal data only with consent.
In this context, we process in particular information that a data subject provides to us voluntarily when contacting us - for example by letter post, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection vis-à-vis these persons as well as to ensure the accuracy of this personal data.
We also process data about other persons on a voluntary basis.
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 for legal reasons.
We process personal data about applicants to the extent that it is necessary for the assessment of suitability for an employment relationship or for the subsequent performance of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants provide or publish voluntarily, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants in particular in accordance with Art. 9 para. 2 lit. b GDPR.
We may allow applicants to enter their details into our talent pool in order to consider them for future vacancies. We may also use such details to maintain contact and provide updates. If we believe that an applicant is eligible for a vacancy based on the information provided, we may notify the applicant accordingly.
5. Personal data abroad
We process personal data in principle 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 process personal data abroad.
We may export personal data to all states and territories on Earth and elsewhere in the universe, provided that the law there is in accordance with decision of the Swiss Federal Council provides for adequate data protection and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - according to Decision of the European Commission ensures adequate data protection.
We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees on request or provide a copy of any guarantees.
6. Rights of data subjects
6.1 Data protection rights
We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what that personal data is. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects can have personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future.
- Data surrender and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another controller.
We may suspend, restrict or refuse the exercise of data subjects' rights to the extent permitted by law. We can draw the attention of data subjects to any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to legal obligations to retain data.
We may provide for costs for the exercise of rights exceptionally. We inform data subjects in advance of any costs.
We are obligated to exceptional costs.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
6.2 Right to complain.
Data subjects have the right to enforce their data protection rights through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - the right to lodge a complaint with a competent European data protection supervisory authority.
7. Data security
We take appropriate technical and organisational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject to - as basically any digital communication - mass surveillance without cause and 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 have any direct influence on the corresponding processing of personal data by secret services, police agencies and other security authorities.
8. Use of the website
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. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
For cookies that are not stored on your computer, we ask for your consent.
For cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is available for many services via the 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).
8.2 Server logfiles
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, website last accessed in the same browser window (referer or referrer).
We store such information as follows.
We store such information, which may also constitute personal data, in server log files. The information is necessary 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.
We store such information, which may also represent personal data, in server log files.
8.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - also 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 collect the same information as server log files.
9. Notifications and communications
We send notifications and communications by email and through other communication channels such as instant messaging or SMS.
9.1 Performance and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked on. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.
9.2 Consent and objection
You must basically expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure where possible, i.e. you receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorised third parties can take place. We may log such consents, including Internet Protocol (IP) address, date and time, for evidence and security reasons.
You can in principle 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 use for performance and reach measurement. This is subject to any necessary notifications and communications in connection with our activities and operations.
9.3 Notifications and communications service providers
We send notifications and communications with the help of specialised service providers.
We use in particular:
10. Social Media
We have a presence on social media platforms and other online platforms to communicate with interested individuals and to 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).
In each case, the data protection laws also apply.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our Social Media presence on Facebook including the so-called Page Insights - if and to the extent that the General Data Protection Regulation (GDPR) is applicable -. 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 help us deliver our social media presence on Facebook in an effective and user-friendly way.
More information about our social media presence on Facebook.
Further information on the nature, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in the Data Protection Statement of Facebook. We have entered into the so-called "Responsible Party Addendum" with Facebook and have thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page "Page Insights Information" including "Page Insights Data Information".
11. Third party services
We use services from specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed features and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
11.1 Digital infrastructure
We use services from specialised third parties to access required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers
We use in particular:
- Cyon: hosting; provider: cyon GmbH (Switzerland); data protection information: "Data protection", Data protection declaration.
11.2 Contact options
We use services from selected providers to better communicate with third parties such as potential as well as existing customers.
11.4 Audio and Video Conferencing
We recommend, depending on the life situation, to mute the microphone by default when participating in audio or video conferences as well as to blur the background or have a virtual background fade in.
11.5 Online collaboration
We use third party services to enable online collaboration.
11.6 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content, such as music or podcasts.
We use third party services to enable us to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, spreadsheets and text documents. This enables us not only to view, but also to edit or comment on such documents.
We use third party services to embed selected fonts as well as icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific details: "Privacy and Google Fonts" ("Privacy and Google Fonts"), "Privacy and Data Collection".
We use specialised service providers to process payments from our customers securely and reliably. The legal texts of the individual service providers, such as the General Terms and Conditions (GTC) or data protection declarations, also apply to the processing of payments.
We make use of the possibility to display targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.
With such advertising, we would like to reach in particular 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 relevant information, including personal information, to third parties that 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 website to your profile there.
We use in particular:
- Google Ads: Search engine advertising; Provider: Google; Google Ads-specific claims: Advertising based on search queries, among other things, using various domain names - notably doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why am I seeing a particular ad?".
12. Extensions for the website
We use extensions for our website to enable us to use additional features.
We try to determine how our online offer is used. As part of this, we may, for example, measure the success and reach of our activities and operations and the impact of third party links to our website. But we can also, for example, try out and compare how different parts or versions of our online offer 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.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are basically shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation.
We use in particular:
- Google Analytics: Performance and reach measurement; Provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy", "Browser Add-on to disable Google Analytics".
- Google Tag Manager: Integration and administration of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: "Data collected with Google Tag Manager"; further information on data protection can be found with the individual integrated and managed services.
14. Video Surveillance
We use video surveillance for the prevention of criminal offences and for the preservation of evidence in the event of criminal offences, as well as for the exercise of our house rights. This involves - if and insofar as the General Data Protection Regulation (GDPR) is applicable - overriding legitimate interests according to Art. 6 para. 1 lit. f DSGVO.
We store recordings from our video surveillance for as long as they are necessary for the preservation of evidence.
We may preserve recordings due to legal obligations, to enforce our own legal claims and in case of suspicion of criminal offences, as well as transmit them to competent bodies such as, in particular, judicial or law enforcement authorities.
15. Final provisions
We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.