Privacy Policy

The responsible person regarding data protection laws, in particular the EU General Data Protection Regulation (GDPR) is:

Flynne Frölich
Via Quieta 2, 06124 Perugia
E-mail: frolichflynne@gmail.com.

1. General note

Based on Article 13 of the Swiss Federal Constitution and the data protection regulations of the Swiss Confederation (Federal Act on Data Protection, FADP), every person is entitled to protection of his or her privacy and protection against misuse of his or her personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and according to the legal data protection regulations as well as this privacy policy.
In cooperation with our hosting providers, we make every effort to protect the databases against unauthorized access, loss, misuse or forgery.
We would like to point out that data transmission over the Internet (e.g. communication by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.

By using this website, you agree to the collection, processing and use of data in accordance with the following description. This website can be visited without registration. Data such as pages called up or the name of the file called up, date and time are stored on the server for statistical purposes without these data being directly related to your person. Personal data, in particular name, address or e-mail address are collected on a voluntary basis as far as possible. The data will not be passed on to third parties without your consent.

 2. Processing of personal data

Personal data is all information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, irrespective of the means and procedures used, in particular the storage, disclosure, procurement, deletion, modification, destruction and use of personal data.

We process personal data in accordance with Swiss data protection law. In addition, we process personal data – insofar and to the extent that the EU-GDPR is applicable – in accordance with the following legal principles in connection with Art. 6 Para. 1 GDPR:

• lit. a) Processing of personal data with the consent of the person concerned.
• lit. b) Processing of personal data for the purpose of fulfilling a contract with the data subject and for the implementation of appropriate pre-contractual measures.
• lit. c) Processing of personal data for the fulfilment of a legal obligation to which we are subject under any applicable law of the EU or under any applicable law of a country in which the DPA is fully or partially applicable.
• lit. d) Processing of personal data to protect vital interests of the data subject or of another natural person.
• lit. f) Processing of personal data to protect the legitimate interests of us or of third parties, except where such interests are overridden by fundamental freedoms and rights or by the interests of the data subject. Legitimate interests are in particular our business interest in being able to provide our website, information security, the enforcement of our own legal claims and compliance with Swiss law.

We process personal data for as long as is necessary for the respective purpose or purposes. In the event of longer-term storage obligations due to legal and other obligations to which we are subjected, we will limit the processing accordingly.

3. Privacy policy for cookies

This website uses cookies. These are small text files that make it possible to store specific user-related information on the user’s terminal device while the user is using the website. Cookies make it possible, in particular, to determine the frequency of use and the number of users of the pages, to analyze the behavior of the page use, but also to make our offer more customer-friendly. Cookies remain stored at the end of a browser session and can be retrieved when the user revisits the site. If you do not wish this, you should set your internet browser to refuse to accept cookies.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

 4. Privacy policy for contact form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not pass on this data without your consent.

 5. Privacy policy for newsletter data

If you would like to receive the newsletter offered on this website, we need an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data will not be collected. We use this data exclusively for sending the requested information and do not pass it on to third parties.
You can revoke your consent to the storage of the data, the e-mail address as well as its use for sending the newsletter at any time, for example by using the “unsubscribe link” in the newsletter.

6. Privacy policy for comment function on this website

For the comment function on this website, in addition to your comment, information on the time of the creation of the comment, your e-mail address and, if you are not posting anonymously, the user name you have chosen are stored.

Storage of the IP address

Our comment function stores the IP addresses of users who post comments. Since we do not check comments on our site before they are activated, we need this data to be able to take action against the author in case of legal violations such as insults or propaganda.

Subscription to comments

As a user of the site, you can subscribe to comments after logging in. You will receive a confirmation email to verify that you are the owner of the email address you entered. You can unsubscribe from this function at any time via a link in the info mails.

7. Privacy policy for Google Analytics

This website uses Google Analytics, a web analysis service of Google Ireland Limited. If the person responsible for data processing on this website is located outside the European Economic Area or Switzerland, Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as “Google”.

We can use the statistics obtained to improve our offer and make it more interesting for you as a user. This website also uses Google Analytics for a cross-device analysis of visitor flows, which is performed using a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your usage in the settings there under “My data”, “Personal data”.

The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f DS-GVO. The IP address transmitted by your browser in the context of Google Analytics is not merged with other data from Google. We would like to point out that on this website Google Analytics has been extended by the code “_anonymizeIp();” in order to ensure anonymous collection of IP addresses. This means that IP addresses are further processed in a shortened form, thus excluding the possibility of personal references. If the data collected about you contains a personal reference, this is immediately excluded and the personal data is immediately deleted.

Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: deactivate Google Analytics.

You can also prevent the use of Google Analytics by clicking on this link: Deactivate Google Analytics. This will cause a so-called opt-out cookie to be stored on your data carrier, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your end device, these opt-out cookies will also be deleted, which means that you will have to set the opt-out cookies again if you want to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/device and must therefore be activated separately for each browser, computer or other device.

8. Privacy policy for Twitter

This website uses features of Twitter, Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. When you access our pages with Twitter plug-ins, a connection is established between your browser and the Twitter servers. Data is already being transferred to Twitter. If you have a Twitter account, this data can be linked to it. If you do not want this data to be linked to your Twitter account, please log out of Twitter before visiting our site. Interactions, especially clicking a “Re-Tweet” button, are also transmitted to Twitter. You can find out more at https://twitter.com/privacy.

 9. Privacy Policy for Instagram

On our website functions of the Instagram service are integrated. These functions are offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA integrated. If you are logged in to your Instagram account, you can link the contents of our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to our sites with your account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram. For more information, please refer to Instagram’s privacy policy: http://instagram.com/about/legal/privacy/

10. Privacy policy for LinkedIn

This website uses features of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of our pages that contains LinkedIn features, a connection to LinkedIn’s servers is established. LinkedIn will be notified that you have visited our sites using your IP address. If you click the LinkedIn “Recommend” button and are logged into your LinkedIn account, LinkedIn will be able to track your visit to our site to you and your account.

11. Newsletter – Mailchimp

The newsletters are sent via the mailing service provider ‘MailChimp’, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection regulations of the mailing service provider here. The Rocket Science Group LLC d/b/a MailChimp is certified under the PrivacyShield Agreement and thus offers a guarantee to comply with the European data protection level (PrivacyShield). The mail order service provider is used on the basis of our legitimate interests according to art. 6 para. 1 lit. f DSGVO and an order processing contract according to art. 28 para. 3 sentence 1 DSGVO.

The dispatch service provider may use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimize or improve its own services, e.g. for technical optimization of dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

12. Changes

We may change this privacy policy at any time without notice. The current version published on our website applies. If the data protection declaration is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.

13. Questions to the data protection officer

If you have any questions regarding data protection, please send us an e-mail or contact the person responsible for data protection in our organization listed at the beginning of this privacy statement.

Perugia, November 16, 2020
Source: SwissAnwalt