FADP

DATA PRIVACY

conceptual and legal matters

Data Privacy Policy

With this privacy policy, we, Leap Partners AG, inform regarding the processing of personal data by our company in the context of maintaining our website [leap-partners.com]. This privacy policy applies to the use of our website and describes how we collect, process, and use personal data, what rights the data subjects have and how these can be exercised.

We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR).

1. CONTACT ADRESSES

Responsible for the processing of personal data is:

Leap Partners AG
Wolfbachstrasse 19
8032 Zürich Schweiz

E-Mail: dataprivacy@leap-partners.com

Please address your data protection concerns directly to the above address.

2. TERMS AND LEGAL BASIS

 

2.1 Terms

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, such as Querying, Comparing, Adapting, Archiving, Storing, Reading, Disclosing, Obtaining, Collecting, Recording, Deleting, Disclosing, Arranging, Organizing, Storing, Modifying, Disseminating, Linking, Destroying and Using personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of personal data.

 

2.2 Legal Basis

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

We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or 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, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill 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 GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.

3. NATURE, SCOPE, AND PURPOSE

We process the personal data that is necessary in order to carry out our activities and operations in a permanent, 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 for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymized or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.

We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permitted, for example, to fulfill a contract with the data subject and for corresponding pre-contractual measures to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example by post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such data in an address book, in a Customer Relationship Management System (CRM system) or with comparable tools, for example. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection for these persons and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.

4. APPLICATIONS

We process the personal data of applicants who are interested in a position within our company. As applications are processed centrally via Jung von Matt AG, we forward interested applicants to [jvm.ch], where job advertisements and the application process are handled by the service provider Personio.

Applicants can submit their data via Personio and have the option of deciding by means of explicit consent whether their data should be retained for future job offers or deleted immediately.

For more information on your rights as a data subject, including the right of access, rectification, erasure, and objection, please refer to our section [6. Rights of data subjects].

5. PERSONAL DATA ABROAD

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

Personal data is only transferred to countries outside Switzerland and the EEA if the Swiss Federal Council and – if the GDPR is applicable – the European Commission are of the opinion that the country in question guarantees adequate data protection.

In countries where adequate data protection is not guaranteed, personal data will only be transferred if other protective measures such as standard data protection clauses or similar suitable guarantees are in place. In exceptional cases, personal data may also be transferred to countries without adequate or appropriate data protection, provided that special data protection conditions are met, such as the express consent of the data subjects or if the transfer is necessary for the performance or execution of a contract.

Data subjects can contact us to obtain further information about the security measures or to view a copy of the guarantees.

6. RIGHTS OF DATA SUBJECTS

 

6.1 Data Protection Claims

We grant data subjects all rights in accordance with the applicable data protection law. In particular, data subjects have the following rights:

  • Disclosure: 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 required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also 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 can have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.
  • Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data disclosure and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another controller.

We may defer, restrict, or refuse the exercise of data subjects' rights to the extent permitted by law. We may inform data subjects of 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.

For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.

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

 

6.2 Right of Complaint

Data subjects have the right to enforce their data protection claims through legal action or to lodge a complaint with a competent 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).

Data subjects have the right - if and insofar as the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European Data Protection Board authority.

7. DATA SECURITY

We are aware of the importance of protecting your personal data and therefore take appropriate technical and organizational measures to ensure a level of security appropriate to the risk involved. This includes access control measures, data encryption, regular security checks, employee training and awareness, and precautions to safeguard against physical and digital security risks.

Our website is accessed using transport encryption (SSL/TLS) to ensure the security of data transmission. Most web browsers indicate this encryption with a padlock symbol in the address bar.

We are aware that no digital platform can guarantee absolute security. Our digital communications may potentially be subject to surveillance by security authorities. However, we are committed to taking all legal and practical measures to maximize the protection of your data and minimize unauthorized access and surveillance.

In the event of a security incident, we will take appropriate action, including reporting it to the relevant authorities and, if necessary, notifying the individuals concerned. We regularly review and update our security protocols and measures to maintain a high level of protection.

8. USE OF THE WEBSITE

 

8.1 Cookies

We use cookies on our website, which are small files that are stored on your device to improve user-friendliness and enable certain functions. There are first-party cookies, which are set by our own website, and third-party cookies, which come from external service providers.

Session cookies are temporary cookies that are automatically deleted when you close your browser, while permanent cookies remain on your device for a set period of time. We use cookies to save your settings and to collect statistical data on the use of our website, which helps us to improve our services.

In accordance with Swiss data protection law, we are not obliged to provide a mechanism for deactivating cookies. However, we would like to point out that you have the option of deactivating or deleting cookies in your browser settings at any time. Please note that some functions of our website may no longer be fully available if cookies are deactivated.

For cookies that are used for marketing purposes or to measure success, we offer you information on general opt-out options via AdChoices, the Network Advertising Initiative (NAI), YourAdChoices or Your Online Choices (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, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. The information is required 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.

 

8.3 Tracking Pixels

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

9. NOTIFICATIONS AND COMMUNICATIONS

We use various communication channels to inform you of relevant matters, which may include email, instant messaging, SMS, or other channels. These communications may include important notifications about our services, security information or other necessary updates.

We will only use these communication channels in accordance with your explicit consent, especially when it comes to marketing or promotional content. You have the option to change your preferences or unsubscribe from non-essential communications at any time.

We are committed to protecting your contact information and ensuring that all communications are made in compliance with applicable data protection regulations.

 

9.1 Success and Reach Management

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We need this statistical recording of usage to measure success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

 

9.2 Consent and Objection

You must always expressly consent to the use of your email address and your other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the "double opt-in" procedure to obtain consent, i.e. you will receive an email with a web link that you must click on to confirm, to prevent misuse by unauthorized third parties. We may log such consents, including the Internet Protocol (IP) address, date, and time, for evidence and security reasons.

You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.

 

9.3 Service Providers for Notifications and Communications

We send notifications and messages with the help of specialized service providers.

10. SOCIAL MEDIA

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, 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). The 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 way.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as the Facebook data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's Privacy Policy. We have concluded the so-called "Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information about Page Insights" including "Information on Page Insights Data".

11. SERVICES FROM THIRD PARTIES

In order to improve the performance, user-friendliness, security and reliability of our activities, we use specialized services from third-party providers. These services may include functions and content integrated into our website. When embedding these services, the providers collect the IP addresses of users for technical reasons, but only to the extent and for the duration necessary to provide the service.

Third parties may process data for necessary security purposes, statistical analysis, and technical optimization in aggregated, anonymized or pseudonymized form. This includes performance and usage data required for the provision of their services.

In particular, we use services from:

  • Google: For users in the EEA and Switzerland by Google Ireland Limited. For more information about Google's privacy practices, please see their Privacy Policy and Privacy and Security Principles. You can adjust your settings for personalized advertising on Google in the ad settings.
  • Microsoft: For users in the EEA, UK and Switzerland through Microsoft Ireland Operations Limited. Microsoft's privacy practices are outlined in the Trust Center and in their Privacy Policy. Users can manage their privacy settings in the Microsoft Privacy Dashboard.

 

11.1 Digital Infrastructure

‍We obtain the necessary digital infrastructure for our activities and services from specialized third-party providers. This includes hosting and storage services provided by carefully selected providers. We take precautions to ensure that these providers apply reliable security measures and comply with data protection standards that serve to protect your data.

The services we use may store and process data at locations both inside and outside Switzerland and the European Economic Area (EEA). Regardless of the location of the data processing, we ensure through contractual agreements with our providers that the privacy and security of your data is guaranteed in accordance with the applicable data protection laws.

The use of these services requires your consent to the data protection practices and terms of use of the respective providers. We recommend that you familiarize yourself with these terms and conditions, as they contain important information about your data protection rights and how you can exercise them.

 

11.2 Contact Options

To improve our communication with interested parties and potential and existing customers, we use services from selected providers for Customer Relationship Management (CRM) and other communication services.

In particular, we use services from:

  • HubSpot: For CRM and related functions. HubSpot Inc. in the USA and HubSpot Ireland Limited in Ireland provide this service for users in the European Economic Area (EEA) and the UK. Your data is processed securely and in accordance with high data protection standards. Details on HubSpot's data protection practices can be found in their Privacy Policy. HubSpot is committed to complying with applicable data protection laws and offers various security and control mechanisms to protect your data.

Your consent to the processing of your data by these services is important to us. You have the right to withdraw your consent at any time and can access, update, or delete your data via HubSpot's privacy dashboard. We are committed to taking the necessary measures to respect users' rights and protect their data.

 

11.3 Scheduling

We use the services of specialized third parties to arrange appointments online, for example for meetings. In addition to this privacy policy, any directly visible terms and conditions of the services used, such as terms of use or privacy policies, also apply.

 

11.4 Social Media Functions and Social Media Content

We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

We use in particular:

 

11.5 Digital Audio and Video Content

We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:

 

11.6 Advertising

We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.

We would like to use such advertising in particular to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit relevant - possibly also personal - data 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 logged in as a user may be able to assign the use of our online offering to your profile there.

We use in particular:

12. SUCCESS AND REACH MANAGEMENT

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. We can also, for example, test and compare how different parts or versions of our online offering are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.

In most cases, the Internet Protocol (IP) addresses of individual users are stored to measure success and reach. 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 to measure success and reach, and user profiles may be created. 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 in pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offer to the user account or user profile with the respective service.

We use in particular:

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (Cross-Device Tracking) and with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, "Data protection", "Browser add-on to deactivate Google Analytics".
  • Google Tag Manager: Integration and management of other services for measuring success and reach 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 in the individual integrated and managed services.

13. FINAL PROVISIONS

This Privacy Policy has been prepared and adapted in accordance with applicable data protection laws and standards and with the support of data protection resources and tools, including the data protection generator of data security partner. The final responsibility for the content lies with Jung von Matt AG.

We reserve the right to amend this Privacy Policy at any time to adapt it to new legal requirements or changes in our data protection practices. Changes will take effect as soon as they are published on our website. We recommend that you check this page regularly for updates. We will notify you of material changes as far as practicable, for example by email or via a clearly visible notice on our website.

Date of the last update: 22.05.2024