Privacy Policy

This is an automated translation of the original version in German.

With this privacy policy we inform about the processing of personal data in connection with our activities including our website under the domain name gladschweiz.ch. We inform in particular for what purpose, how and where we process which personal data. We also inform about the rights of persons whose data we process.

For individual or additional activities we may publish further privacy policies or other information on data protection.

We are subject to Swiss law as well as, where applicable, foreign law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR).

By decision of 26 July 2000, the European Commission recognized that Swiss data protection law ensures an adequate level of data protection. By report of 15 January 2024, the European Commission confirmed this adequacy decision.

Table of Contents

1. Contact addresses

Responsible within the meaning of data protection law is:

GLA:D® Schweiz, Suisse, Svizzera
GLA:D® Schweiz, Suisse, Svizzera
c/o ZHAW, Institute of Physiotherapy
Katharina-Sulzer-Platz 9, P.O. Box
8401 Winterthur

gladschweiz.gesundheit@zhaw.ch

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

2. Terms and legal bases

2.1 Terms

Data subject: A natural person about whom we process personal data.

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

Particularly sensitive personal data: Data on trade union, political, religious or philosophical views and activities, data concerning health, the intimate sphere or affiliation with an ethnicity or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal or administrative sanctions or proceedings, and data on social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, for example querying, comparing, adapting, archiving, storing, retrieving, disclosing, obtaining, capturing, collecting, deleting, disclosing, arranging, organizing, storing, altering, disseminating, linking, destroying and using personal data.

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

2.2 Legal bases

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

Insofar and to the extent that the European General Data Protection Regulation (GDPR) applies, we process personal data on the basis of at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for the processing of personal data required for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6(1)(f) GDPR for the processing of personal data required to safeguard legitimate interests, including the legitimate interests of third parties, provided that the fundamental freedoms and rights as well as the interests of the data subject do not prevail. Such interests include in particular the permanent, human-friendly, secure and reliable conduct of our activities, ensuring information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6(1)(c) GDPR for the processing of personal data required to fulfil a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6(1)(e) GDPR for the processing of personal data required for the performance of a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6(1)(d) GDPR for the processing of personal data required to protect the vital interests of the data subject or of another natural person.
  • Art. 9(2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

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

3. Type, scope and purpose of the processing of personal data

We process the personal data that is necessary to be able to carry out our activities on a permanent, human-friendly, secure and reliable basis. The processed personal data may in particular fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including customer and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute particularly sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities, insofar as such processing is permitted.

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

We process personal data for the period required for the respective purpose. We anonymize or delete personal data in particular depending on statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use. Such third parties may in turn disclose personal data to other third parties.

In connection with our activities, we may disclose personal data in particular to banks and other financial service providers, authorities, education and research institutions, consultants and lawyers, accounting and fiduciary service providers, debt collection companies, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurers and payment service providers.

5. Communication

We process personal data in order to be able to communicate with individual persons as well as with authorities, organizations and companies. In doing so, we process in particular data that a data subject provides to us when making contact, for example by letter or email. We may store such data in an address book or comparable tool.

Third parties who transmit data about other persons to us are legally obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that they are permitted to transmit such data, as well as ensure the accuracy of the data transmitted.

6. Data security

We take appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the processed personal data, without however being able to guarantee absolute data security.

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

Our digital communication is subject – like basically all digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, elsewhere in Europe, in the United States of America (USA) and in other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police authorities and other security authorities. Nor can we rule out that a data subject is being specifically monitored.

7. Personal data abroad

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

We may export personal data to all countries on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection according to a decision of the Swiss Federal Council and, where and to the extent that the General Data Protection Regulation (GDPR) applies, also according to a decision of the European Commission.

We may transmit personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if the special data protection law requirements for this are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information about any safeguards or deliver a copy of any safeguards.

8. Rights of data subjects

8.1 Data protection claims

We grant data subjects all claims under applicable law. Data subjects in particular have the following rights:

  • Access: Data subjects may request information as to whether we process personal data about them, and if so, which personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also, among other things, information on the purpose of processing, the retention period, any disclosure or export of data to other countries, and the origin of the personal data.
  • Rectification and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed, and have the processing of their data restricted.
  • Ability to present one’s own view and human review: With regard to decisions based exclusively on automated processing of personal data that have a legal effect on the data subject or significantly affect them (automated individual decisions), data subjects may present their own view and demand review by a human being.
  • Deletion and objection: Data subjects may have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data disclosure and data portability: Data subjects may demand the disclosure of personal data or the transfer of their data to another controller.

We may, within the legally permissible framework, postpone, restrict or refuse the exercise of the rights of data subjects. We may inform data subjects of any requirements that need to be met in order to exercise their data protection claims. For example, we may refuse access wholly or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. We may also, for example, refuse the deletion of personal data wholly or in part, in particular with reference to statutory retention obligations.

We may exceptionally provide for costs for the exercise of rights. We inform data subjects in advance of any such costs.

We are obliged to identify data subjects who request information or assert other rights with appropriate measures. Data subjects are obliged to cooperate.

8.2 Legal remedies

Data subjects have the right to enforce their data protection claims through legal action or to file a complaint with a data protection supervisory authority.

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

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

9. Use of the website

9.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that is stored in the browser. Such stored data need not be limited to traditional text-based cookies.

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

Cookies can be disabled, restricted or deleted, in whole or in part, at any time in the browser settings. Browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least insofar and to the extent required under applicable law – explicit consent to the use of cookies.

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

9.2 Logging

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

We log such information, which may also constitute personal data, in log files. This information is necessary to be able to provide our digital presence on a permanent, human-friendly and reliable basis. The information is also necessary to be able to ensure data security – including through or with the assistance of third parties.

9.3 Tracking pixels

We may embed tracking pixels in our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to collect at least the same information as logging in log files.

10. Notifications and messages

10.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages effectively and in a human-friendly manner, based on the needs and reading habits of recipients, as well as on a permanent, secure and reliable basis.

10.2 Consent and objection

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

You may generally object to receiving notifications and messages, such as newsletters, at any time. With such an objection, you may simultaneously object to the statistical recording of usage for success and reach measurement. Necessary notifications and messages in connection with our activities remain reserved.

11. Third-party services

We use services from specialized third parties in order to be able to carry out our activities on a permanent, human-friendly, secure and reliable basis. With such services, we can, among other things, embed functions and content in our website. When embedding such content, the services used collect at least temporarily, for technically necessary reasons, the IP addresses of users.

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

We use in particular:

11.1 Digital infrastructure

We use services from specialized third parties in order to be able to make use of required digital infrastructure in connection with our activities. This includes, for example, hosting and storage services from selected providers.

We use in particular:

11.2 Map material

We use third-party services in order to be able to embed maps in our website.

We use in particular:

11.3 Digital content

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

We use in particular:

11.4 Fonts

We use third-party services in order to be able to embed selected fonts as well as icons, logos and symbols in our website.

We use in particular:

12. Extensions for the website

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

We use in particular:

13. Success and reach measurement

We attempt to measure the success and reach of our activities. In this context, we may also measure the effect of third-party references or examine how different parts or versions of our digital presence are used (“A/B testing” method). Based on the results of the success and reach measurement, we may in particular fix errors, strengthen popular content or make improvements.

For success and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are generally shortened (“IP masking”) in order to follow the principle of data minimization through the corresponding pseudonymization.

Cookies may be used and user profiles created during success and reach measurement. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information on the size of the screen or browser window, and the – at least approximate – location. As a rule, any user profiles are created exclusively on a pseudonymized basis and are not used to identify individual users. Individual third-party services with which users are logged in may, where applicable, assign the use of our online offering to the user account or user profile with the respective service.

We use in particular:

14. Concluding remarks on the privacy policy

We created this privacy policy with the privacy policy generator by Datenschutzpartner .

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

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