Privacy Policy
With this Privacy Policy we inform which personal data we process in connection with our activities and activities including our websites:
For individual or additional activities and operations, further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.
We are subject to Swiss data protection law and 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 recognizes that Swiss data protection law ensures adequate data protection.
This privacy policy has been machine-translated from the German version. In case of ambiguities or misunderstandings, the German version is authoritative.
1. contact addresses
Responsibility for the processing of personal data:
Kientalerhof AG
Griesalpstrasse 44
3723 Kiental
Switzerland
We point out if there are other persons responsible for the processing of personal data in individual cases.
Data-protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 DSGVO:
School for Shiatsu Hamburg
Oelkersallee 33
22769 Hamburg
Germany
kientalerhof@schule-fuer-shiatsu.de
The Data Protection Representation serves data subjects and public authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries related to the GDPR.
2. Terms and Legal Bases
2.1 Terms
Personal data is any information that relates 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, independent of the means and procedures used, for example, the querying, matching, adapting, archiving, storing, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using of personal data.
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 to the extent that 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 and 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 permanently, in a user-friendly, secure and reliable manner, as well as 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 pursuant to 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 person concerned.
- 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 permanent, user-friendly, secure and reliable manner. Such personal data may fall in particular 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 and contract and payment data.
We process personal data for the period required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data together with third parties or transfer it to third parties. Such third parties are in particular specialized providers whose services we use. We also ensure data protection with such third parties.
We process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard 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 provides to us voluntarily when contacting us – for example, by letter, e-mail, 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 transmitted, the transmitting persons are obliged to ensure data protection with respect to these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
4. applications
We process personal data about applicants to the extent that it is required for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process those personal data that applicants voluntarily provide or publish, in particular as part of cover letters, resumes and other application documents as well as online profiles.
We process – if and to the extent that the General Data Protection Regulation (DSGVO) is applicable – personal data about applicants in particular pursuant to Art. 9 para. 2 lit. b DSGVO.
5. Personal data abroad
We process personal data basically in Switzerland and in 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 states and territories on Earth and elsewhere in the universe, provided that the law there is compliant with decision of the Swiss Federal Council provides for adequate data protection as well as – 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 laws do 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. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law 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 upon request or provide a copy of any guarantees.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all claims in accordance with applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we process personal data about them, and if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data 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 correct inaccurate personal data, complete incomplete data and have 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 release and data transfer: Data subjects may request the release of personal data or the transfer of their data to another controller.
We can postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We can inform data subjects of any requirements that must be met before they can 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 the rights exceptionally. We will inform affected persons in advance of any costs.
We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are obliged to cooperate.
6.2 Right to complain
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
Data protection supervisory authority for private 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 organizational measures to ensure data security appropriate to the respective risk. 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 mark transport encryption with a padlock in the address bar.
Our digital communications are subject to – as basically all digital communications – mass surveillance without cause or suspicion and other monitoring 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 agencies and other security authorities.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies – our own cookies (first-party cookies) as well as 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 enable us to recognize 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.
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 request – at least if and to the extent necessary – actively for the express consent to the use of cookies.
For cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is required 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 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, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliable, as well as to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
8.3 Counter pixel
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 in server log files.
9. Notifications and communications
We send notifications and communications via email and other communication channels, such as instant messaging or SMS.
9.1 Success and reach measurement
Notifications and communications may contain web links or tracking pixels that record whether an individual communication was opened and which web links were clicked. 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 based on the needs and reading habits of the recipients effectively and in a user-friendly manner 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 whenever possible, which means that you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized 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 basically object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical collection of usage for performance and reach measurement. This is subject to necessary notifications and communications in connection with our activities and operations.
9.3 Notifications and notifications service providers
We send notifications and messages with the help of specialized service providers.
We use in particular:
- ActiveCampaign: email marketing platform; provider: ActiveCampaign LLC (USA); privacy policy details: privacy-policy
- Mailchimp: communications platform; Provider: The Rocket Science Group LLC DBA Mailchimp (USA) as subsidiary of Intuit Inc. (USA); Privacy Disclosures: Privacy Statement (Intuit) including “Country and Region-Specific Terms” (“Country and Region-Specific Terms”), “Frequently Asked Questions about Mailchimp Privacy”, “Mailchimp and European Data Transfers”, “Security”, cookie policy, “Privacy Rights Requests”), “Legal Terms”
10. Social Media
We are present on social media platforms and other online platforms in order to be able to communicate with interested persons 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)
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. These provisions inform in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right to information.
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 provide our social media presence on Facebook in an effective and user-friendly manner.
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 concluded the so-called “Addendum for Responsible Parties” with Facebook and thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page “Page Insights Information” including “Page Insights Data Information”.
11. Third Party Services
We use services of specialized third parties to perform our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. In the case of such an embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security-related, 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 provided by 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 privacy laws”, “Privacy Guide in Google Products”, “How we use data from websites or apps on or in which our services are used” (information provided by Google), “Cookie Types and Other Technologies Used by Google”, “Personalized Advertising” (enable/disable/settings)
- Services provided by Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General privacy information: “Privacy at Microsoft”, “Data Protection and Privacy (Trust Center)”, Privacy Statement, Privacy Dashboard (Data and Privacy Settings)
11.1 Digital infrastructure
We use services from specialized third parties to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
We use in particular:
- Cloudflare: Content Delivery Network (CDN); Cloudflare Inc. (USA); Privacy Statement: “Privacy Policy”, Privacy Policy, Cookie Policy
- Cyon: hosting; provider: cyon GmbH (Switzerland); data protection information: “Privacy Policy”, Privacy Policy
- Squarespace: website builder; Providers: Squarespace Inc (USA) for users in the USA / Squarespace Ireland Limited (Ireland) for users in the rest of the world; privacy disclosures: “Privacy and Security”, privacy policy, cookie policy
- webflow: website builder; provider: Webflow Inc. (USA); data protection information: Privacy Policy for Users in the European Economic Area and the United Kingdom and Switzerland (“EU & Swiss Privacy Policy”), Privacy Policy for Users in the Rest of the World (“Global Privacy Policy”), Cookie Policy
- WordPress.com: Blog hosting and website builder; Providers: Automattic Inc (USA) / Aut O’Mattic A8C Ireland Ltd (Ireland) for users in Europe, among other countries; privacy information: privacy policy, cookie policy
11.2 Audio and video conferencing
We use specialized audio and video conferencing services to communicate online. For example, we can use them 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 apply in addition.
We recommend that, depending on your life situation, you mute the microphone by default when participating in audio or video conferences, as well as blur the background or fade in a virtual background.
We use in particular:
- Zoom: video conferencing; provider: Zoom Video Communications Inc (USA); privacy information: privacy policy, “Privacy at Zoom”, “Legal Compliance Center”
11.3 Social media functions and social media content
We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and through other means.
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; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); privacy information: privacy policy (Instagram), privacy policy (Facebook)
11.4 Cardstock
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 claims: “How Google Uses Location Information”
11.5 Digital audio and video content
We use services from specialized third parties to enable direct playback of digital audio and video content, such as music or podcasts.
We use in particular:
- YouTube: video platform; provider: Google; YouTube-specific disclosures: “Privacy and Security Center”, “My Data on YouTube”
11.6 Documents
We use third-party services in order to be able to integrate documents into our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents. We can thus enable not only viewing, but also editing or commenting on such documents.
We use in particular:
- Google Docs: documents as well as forms, presentations and spreadsheets; provider: Google; Google Docs-specific disclosures: “Privacy in Google Docs, Google Spreadsheets and Google Presentations”.
- Microsoft 365 (also Microsoft Office 365): Text documents as well as forms, presentations and spreadsheets; Provider: Microsoft; Microsoft 365-specific details: “Privacy and Security with Microsoft 365”
11.7 Fonts
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
We use in particular:
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific disclosures: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”
11.8 Advertising
We use the option 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 activities or could be interested in them (Remarketing and Targeting). For this purpose, we may transmit relevant – if necessary also personal – information to third parties that enable such advertising. We may also determine whether our advertising is successful, that is, 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 can, at most, assign the use of our online offer to your profile there.
We use in particular:
- Facebook Advertising (Facebook Ads): Social Media Advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy Disclosures: Remarketing and targeting in particular with the Facebook Pixel as well as Custom Audiences including Lookalike Audiences, Privacy Policy, “Advertising Preferences” (user login required).
- Google Ads: search engine advertising; provider: Google; Google Ads-specific details: Advertising based on search queries, among other things, using various domain names – specifically 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 in order to be able to use additional functions.
We use in particular:
- Akismet: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); Providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among other countries; privacy information: Privacy Notice for Visitors to Our Users’ Sites”, Privacy Notice (from Automattic), Cookie Policy
- EWW Image Optimizer: Image Optimizer; Provider: Exactly WWW LLC (USA); Privacy Statement: privacy-policy
- Jetpack: Various functions for the free blog software WordPress in the form of modules; Providers: Automattic Inc (USA) / Aut O’Mattic A8C Ireland Ltd (Ireland) for users in Europe, among other countries; privacy information: Privacy Notice for Visitors to Our Users’ Sites), Privacy Notice (from Automattic), “Jetpack Privacy Center”, Cookie Policy (Jetpack), Cookie Policy (Automattic)
- TinyPNG: Image Optimization; Provider: Tinify BV (Netherlands); Privacy Information: “Terms of Use” (“Terms of Use”)
13. success-and-reach-measurement
We try 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 effect 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 offering are used (“A/B test” method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
For performance and reach measurement, the Internet Protocol (IP) addresses of individual users are stored in most cases. In this case, IP addresses are basically shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization.
The measurement of success and reach may involve the use of cookies and the creation of user profiles. Any user profiles created include, for example, the individual 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, any user profiles are created exclusively pseudonymously and are not used to identify individual users. Individual services of third parties, to which users are logged in, may assign the use of our online offer to the user account or user profile at the respective service.
We use in particular:
- Google Analytics: Performance and reach measurement; Provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized 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 management of other services for performance and reach measurement as well as other services from Google as well as third parties; Provider: Google; Google Tag Manager-specific information: “Data collected with Google Tag Manager”; further information on data protection can be found at the individual integrated and managed services.
- WordPress.com Stats: Success and reach measurement; Providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among other countries; privacy information: module of the extension Jetpack for the free blog software WordPress, Privacy Notice for Visitors to Our Users’ Sites, Privacy Notice (from Automattic), “Jetpack Privacy Center”, Cookie Policy
14. Final provisions
We created this privacy statement using the Data Privacy Generator from Data Privacy Partners.
We can adapt and supplement this privacy policy at any time. We will inform about such adaptations and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.