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Data protection statement
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In this data protection statement we (comtexto AG) explain how we collect and process personal data. This description is not exhaustive; other data protection statements govern specific issues as required. Personal data is defined as any information relating to an identified or identifiable person.

When you provide us with the personal data of other persons, please ensure that these persons are aware of this data protection statement, and only share their personal data with us if you are allowed to do so, and if such personal data is correct.

This data protection statement is based on the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union (EU), it is of importance to us. The Swiss Federal Act on Data Protection (FADP) is strongly influenced by EU law, and enterprises outside the European Union or the European Economic Area (EEA) must comply with the GDPR under certain circumstances. We have therefore based this data protection statement on the standards of the GDPR.

1. Responsible party
comtexto is responsible for data processing as described here, unless otherwise agreed in specific cases. If you have any questions regarding data protection, please contact us at the following address: comtexto AG, Dufourstrasse 107, 8008 Zurich, Switzerland, tel.: +41 (44) 885 08 08, e-mail: media@comtexto.ch

2. Collection and processing of personal data
We mainly process personal data received in the course of contractual relationships with our business partners, either from them or from additional persons involved. We also process personal data collected from users during the operation of our websites and other applications.

Insofar as this is permitted, we also obtain data from publicly accessible sources (e.g. debt collection register, land registers, commercial register, press, Internet). In addition to the information you provide us with directly, the categories of personal data we receive about you from third parties include information about you from the media and the Internet, your addresses and, where applicable, interests and other socio-demographic data, data relating to the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location information).

3. Purposes of data processing
We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners and to comply with our legal obligations in Switzerland and abroad.

Furthermore, we also process your personal data and that of other data subjects, insofar as this is allowed and seems appropriate to us, for the following purposes in which we (and at times, third parties) have a legitimate interest in accordance with the purpose:

offers and further development of our offers, services and websites and other platforms on which we are present; communication with third parties and processing of their requests (e.g. applications, media enquiries); advertising and marketing (including the organisation of events), unless you have objected to the use of your data (if we send you advertising as an existing customer); market and opinion research, media monitoring; guarantees regarding our operations, in particular IT, our websites and other platforms; if you have given us your consent to process your personal data for specific purposes, we will process your data within the scope of and based on this consent, unless we have another legal basis for doing so and such a legal basis is required. Once consent has been granted, it may be withdrawn at any time. This will not affect data processing which has already been completed.

If the processing of personal data is required in order to comply with a legal obligation to which comtexto AG is subject, this fulfilment obligation serves as a legitimate basis.

If data processing is required to safeguard a legitimate interest of comtexto AG or of a third party, and the interests, fundamental rights and freedoms of the data subject do not override the interest of the former, these legitimate interests will serve as a legitimate basis for data processing.

4. Cookies
Internet sites, including that of comtexto, sometimes use cookies. Cookies neither harm your computer nor contain viruses. They help to make our services more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are session cookies. They are automatically deleted at the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to recognise your browser on your next visit.

You can set your browser so that you are informed about the placement of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. Deactivating cookies may restrict the functionality of this website.

5. Disclosure and transfer of data abroad
If authorised and appropriate, we also disclose data to third parties in the course of our business activities and for the purposes set out in section 3, whether they process the data for us or want to use it for their own purposes. This relates to the following bodies in particular:

Our service providers (such as banks or insurance companies), including order processors (such as IT providers); retailers, suppliers, auxiliary persons (such as, in particular, linguists and experts consulted in Switzerland and abroad) and other business partners; domestic and foreign authorities, official agencies or courts and arbitration tribunals; the media, the public, including visitors to websites and social media; competitors, industry organisations, associations, organisations and other bodies; all general recipients.

Some of these recipients are in Switzerland, but may be in any country of the world. The data may be transferred in particular to those countries in which our service providers or experts are located.

6. Duration of retention of personal data
We process and store your personal data for as long as it is required to meet our contractual and legal obligations or for the purposes pursued by its processing, i.e. for the full duration of the business relationship, for example (from the drafting and processing of a contract until its termination) and beyond, as set out by the statutory retention and documentation obligations. It is possible that personal data may be stored throughout the period during which claims may be asserted against our enterprise (i.e. during the statutory limitation period in particular), or for as long as we are required to do so by law or due to legitimate business interests (e.g. for evidentiary and documentation purposes). In principle we delete your personal data or render data anonymous wherever possible as soon as it is no longer required for the purposes stated above.

7. Data security
We take technical and organisational security measures to protect your personal data against unauthorised access and misuse.

8. Obligation to provide personal data
In the course of our business relationship, you must provide personal data which is required for the establishment and implementation of a business relationship and the performance of the related contractual obligations (as a rule, you do not have a statutory obligation to provide us with data). Without this data, we will generally be unable to conclude or carry out a contract with you (or with the body or person you represent).

9. Rights of the data subject
Within the scope of the data protection law which applies to you, and insofar as the law provides for it (as in the case of the GDPR), you have the right to access, rectification, erasure, the right of restriction of data processing, and also the right to object to our data processing and to the provision of certain personal data for the purposes of transmission to another body (data portability). Please be aware however that we reserve the right to exercise the statutory restrictions applicable to us if we are obliged to retain or process certain data, have an overriding interest in such data (insofar as we are allowed to invoke this interest), or need it to assert claims. We will inform you of any costs incurred in advance. We have already notified you of the option to withdraw your consent in section 3. Please note that the exercising of these rights may conflict with contractual agreements, and could lead to early termination of the contract or result in costs, for example. We will inform you in advance in cases in which this is not already governed by the contract.
The exercising of such rights generally requires that you provide clear proof of your identity (e.g. by submitting a copy of your ID if your identity is otherwise unclear or cannot be verified). To assert your rights, you may contact us at the address given in section 1.
Moreover, every data subject has the right to assert their claims in a court of law or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).

10. Amendments
We may amend this data protection statement at any time without prior notice. The latest version published on our website is the applicable version at any given time. Insofar as the data protection statement forms part of an agreement with you, we will inform you of any updates by e-mail or other suitable means (e.g. via the legal notice on our website).