Privacy Policy

The responsible party in terms of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

Glowing Blue AG
Eigerstrasse 12
3007 Bern

Phone: +41 31 511 85 80
E-Mail: info@glowingblue.com
Website: https://glowingblue.com/

General notice

Based on Article 13 of the Swiss Federal Constitution and the data protection regulations of the Swiss Confederation (Data Protection Act, DSG), every person has the right to protection of their privacy as well as protection against misuse of their personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with 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 as well as possible against unauthorized access, loss, misuse or falsification.

We would like to point out that data transmission on 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 consent to the collection, processing and use of data in accordance with the following description. This website can generally be visited without registration. Data such as pages accessed or names of files accessed, date and time are stored on the server for statistical purposes without this data being directly related to your person. Personal data, in particular name, address or e-mail address are collected as far as possible on a voluntary basis. Without your consent, the data will not be passed on to third parties.

Processing of personal data

Personal data is any information relating 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, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, deletion, storage, modification, destruction and use of personal data.
We process personal data in accordance with Swiss data protection law. Furthermore, to the extent and insofar as the EU GDPR is applicable, we process personal data in accordance with the following legal bases in connection with Art. 6 (1) GDPR:

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject's request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
    Protection of vital interests (Art. 6 (1) p. 1 lit. d. GDPR) - Processing is necessary to protect the vital interests of the data subject or another natural person.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9(2)(b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9(1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure, so that the controller or the data subject can fulfil the obligations incumbent on him/her under rights under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9(2)(b). GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.

We process personal data for the duration required for the respective purpose or purposes. In the case of longer-term retention obligations due to legal and other obligations to which we are subject, we restrict the processing accordingly.

Relevant legal basis

In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR, the legal basis for processing to fulfill our services and implement contractual measures and respond to inquiries is Art. 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person require processing of personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process the data only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Privacy policy for cookies

This website uses cookies. Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. The primary purpose of a cookie is to store information about a user during or after their visit within an online site. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. We further include in the term cookies other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs")

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal basis: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Privacy policy for Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the data controller on this website is located outside the European Economic Area or Switzerland, then Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as "Google".

The statistics obtained enable us 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 carried out via 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 as part of Google Analytics will not be 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();" to ensure anonymized collection of IP addresses. This means that IP addresses are processed in abbreviated form, which means that they cannot be linked to a specific person. If the data collected about you is personally identifiable, this is immediately excluded and the personal data is deleted immediately.

Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

Google Analytics uses cookies. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. 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: Disable Google Analytics.

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

Privacy policy for the use of Google Web Fonts

This website uses so-called web fonts provided by Google for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly. If your browser does not support web fonts, a standard font is used by your computer.

You can find more information on Google Web Fonts at https://developers.google.com/fonts/faq and in Google's privacy policy: https://www.google.com/policies/privacy/

Changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. Insofar as 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.

Questions to the data security officer

If you have any questions regarding data protection, please write us an e-mail or contact directly the responsible person in our organization listed for data protection at the beginning of the Privacy Policy.

Source: SwissAnwalt