Privacy Policy

This data protection declaration provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name . In particular, we provide information about why, how and where we process personal data. We also provide information about the rights of individuals whose data we process.

We can publish further data protection declarations or other information on data protection for individual or additional activities and operations.

1. Contact address

The responsible party in terms of data protection law is:

ENYO Cyber Intelligence AG
Baarerstrasse 77
6300 Zug

compliance(at)enyo-ci.com

In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.

2. Terms and legal basis

2.1 Terms

Data subject: Natural person whose personal data we process.

Personal data: All information relating to an identified or identifiable natural person.

Sensitive personal data: Data relating to trade union, political, religious, or ideological views and activities, data relating to health, privacy, or ethnicity or race, genetic data, biometric data that uniquely identifies a natural person, data on criminal and administrative sanctions or prosecutions, and data on social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, for example, querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, saving, changing, distributing, linking, destroying, and using personal data.

2.2 Legal basis

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

3. Nature, scope, and purpose of personal data processing

We process personal data that is necessary to enable us to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute particularly sensitive 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, to the extent that such processing is permissible.

We process personal data, where necessary, with the consent of the persons concerned. In many cases, we may process personal data without consent, for example to fulfill legal obligations or to protect overriding interests. We may also seek the consent of the persons concerned if their consent is not required.

We process personal data for the period of time necessary for the respective purpose. We anonymize or delete personal data, in particular in accordance with statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.

In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, authorities, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by letter or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must guarantee that such data is accurate and may be transmitted.

6. Data security

We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without, however, being able to guarantee absolute data security.

Access to our website and our other digital presence is provided via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn against visiting a website without transport encryption.

Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the processing of personal data by intelligence services, police stations, and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.

7. Personal data abroad

We process personal data in principle in Switzerland. However, we may also disclose or export personal data to other countries, in particular for processing or to have it processed there.

We may disclose personal data to all countries on Earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with the decision of the Swiss Federal Council.

We may disclose personal data in countries whose laws do not guarantee adequate data protection, provided that adequate data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the persons concerned or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees.

8. Rights of data subjects

8.1 Data protection claims

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

  • Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed 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.
  • Rectification and restriction: Data subjects can rectify inaccurate personal data, complete incomplete data, and have the processing of their data restricted.
  • Opportunity to express one's own point of view and human review: Data subjects can express their own point of view and request human review in the case of decisions that are based exclusively on automated processing of personal data and have legal consequences for them or significantly affect them (automated individual decisions).
  • Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data disclosure and data transfer: Data subjects can request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests, or the protection of other persons. We may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.

We may charge a fee for exercising these rights in exceptional cases. We will inform the persons concerned in advance of any costs.

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

8.2 Legal protection

Affected persons have the right to enforce their data protection claims through legal action or to file a complaint with a 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).

9. Use of the website

9.1 Cookies

We may use cookies. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data that is stored in the browser. Such stored data is not limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a specific 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. Cookies enable, in particular, a browser to be recognized the next time you visit 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, restricted, or deleted at any time in the browser settings. The browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies, at least to the extent required by applicable law.

For cookies used to measure success and reach or for advertising, a general opt-out is possible for numerous services via 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).

9.2 Logging

We can log at least the following information for every access to our website and our other digital presence, provided that this information is transmitted to our digital infrastructure during such access: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. The information is necessary in order to be able to provide our digital presence in a permanent, user-friendly, and reliable manner. The information is also necessary to ensure data security—including by third parties or with the help of third parties.

9.3 Tracking pixel

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is recorded in log files.

10. Notifications and communications

10.1 Success and reach measurement

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 may also record the use of notifications and messages on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner, as well as permanently, securely, and reliably, based on the needs and reading habits of the recipients.

10.2 Consent and objection

You must in principle consent to the use of your email address and other contact details, unless such use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double confirmation of your consent. In this case, you will receive a message with instructions for double confirmation. We may log the consents obtained, including your IP address and time stamp, for evidence and security reasons.

You can in principle object to receiving notifications and communications such as newsletters at any time. By objecting, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.

10.3 Service provider for notifications and communications

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

In particular, we use:

11. Third-party services

We use services provided by specialized third parties to enable us to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed functions and content in our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to be able to offer the respective service.

Digital Infrastructure

We use the services of specialized third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

12. Success and reach measurement

 

We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party feedback or check how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.

In most cases, the IP addresses of individual users are recorded for success and reach measurement. In this case, IP addresses are always shortened (“IP masking”) in order to comply with the principle of data minimization through pseudonymization.

Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.

In particular, we use:

13. Final notes on the privacy policy

We have created this privacy policy using the privacy policy generator from Datenschutzpartner.

We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.

 

Note: This text has been automatically translated. The German version is legally binding.

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