Privacy Policy
With this Privacy Policy we inform which personal data we process in connection with rubra as well as our corresponding activities and operations. In particular, we inform about what for, how and where we process personal data. We also inform about the rights of persons whose data we process.
For individual or additional activities and operations as well as offers and services of third parties, further privacy policies as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation may apply.
This Privacy Policy was translated from the German-language version of this Privacy Policy .
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 recognizes that Swiss data protection law ensures an adequate level of data protection.
1. Contact Addresses
Responsibility for the processing of personal data:
rubra ag
Löwenstrasse 3
8001 Zürich
Switzerland
Data-Protection Representation in the European Economic Area (EEA)
We have the following data protection representation pursuant to Art. 27 GDPR. The Data Protection Representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries relating to the General Data Protection Regulation (GDPR)
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
2. Terms and Legal Basis
2.1 Terms
Personal data is all information that relates to an identified or identifiable person. A data subject is a person about whom personal data are processed.
Processing includes any handling of personal data, independent of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) plus the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal Basis
We process personal data in accordance with Swiss data protection law, such as in particular the Federal Data Protection Act (DPA) and the Ordinance to the Federal Data Protection Act (DPO).
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 GDPR 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 GDPR 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 GDPR 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 GDPR 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 GDPR 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, Purpose and Scope
We process those personal data that are required in order to be able 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 data and usage data, location 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 transmit 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 transmits to us voluntarily when contacting us or registering for a user account. 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. Personal Data Abroad
We process personal data in principle 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 in such countries.
We may export personal data to any state or territory on Earth and elsewhere in the universe, provided that the law there is in accordance with assessment of the Federal Data Protection and Information Commissioner (FDPIC) or according to a decision of the Swiss Federal Council an adequate level of 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 or provide a copy of any guarantees upon request.
5. Rights of Data Subjects
People about whom we process personal data have the rights under Swiss data protection law. These include the right to information as well as the right to rectification, deletion or blocking of the personal data processed.
Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – request confirmation free of charge as to whether we are processing personal data concerning them . In this case, data subjects may request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.
Affected persons whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – revoke any consent given at any time with effect for the future and object to the processing of their personal data at any time.
Affected persons about whom we process personal data have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
6. 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.
7. Usage of rubra
7.1 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 possible 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).
7.2 Server Log Files
We may collect the following information for each access to our apps, browser extensions and website, provided that it 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 carry out activities and activities permanently, user-friendly, secure 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.
7.3 Web Beacons
We may use web beacons. Web beacons – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved. Web beacons can be used to collect the same information as in server log files.
8. Notifications and Communications
We send notifications and communications by email and through other communication channels, such as instant messaging or SMS. We also send such notifications and communications with the help of third parties.
8.1 Audience and Performance Measurement
Notifications and communications may contain web links or web beacons that record whether an individual communication was opened and which web links were clicked. Such web links and web beacons may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for audience and performance 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.
8.2 Consent and Objection
You must in principle 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 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 collection of usage for performance and reach measurement. This is subject to necessary notifications and communications in connection with our activities and operations.
9. Social Media
We are present on social media platforms and other online platforms in order to be able to communicate with interested persons as well as to inform about our activities and operations.
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 are applicable. These provisions inform in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right to information.
For our Social Media presence on Facebook including so-called Page Insights, we – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – are jointly responsible with Meta Platforms Ireland Limited (Ireland). 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, purpose and scope 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 Privacy Policy of Facebook. We have concluded the so-called “Controller Addendum” with Facebook, thereby agreeing 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 ” Information about Page Insights “ including information on “Data processing for Page Insights”.
10. 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 the case of such embedding, the services used at least temporarily record the Internet Protocol (IP) addresses of the users 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, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
11. Advertising
We use the option to display targeted advertisements for our activities and operations on third parties platforms 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 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 can also determine whether our advertising is successful, that is, in particular, whether it leads to the use of rubra (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.
12. Audience and Performance Measurement
We use services and programs 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. However, we can also, for example, test and compare how different versions of our online offering or parts 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 offer.
When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are in principle shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymization and thus improve the data protection of users.
When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information about the size of the screen or browser window and the – at least approximate – location. In principle, user profiles are created exclusively pseudonymously. We do not use user profiles to identify individual users. Individual services of third parties, to which users are logged in, can assign the use of our online offer at most to the user account or user profile at the respective service.
13. Final provisions
We can adapt and supplement this privacy policy at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the current privacy policy on our website.