Privacy Policy

Privacy Policy

This privacy protection declaration provides information about the processing of personal data in connection with our activities, including our website under the domain name osteorheuma.co.uk. 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 may publish additional privacy statements or other information regarding data protection for individual or additional activities and operations.

1. Contact details

The responsible party in terms of privacy protection law is:

Daniel Beyeler
POMCANYS Marketing AG
Aargauerstrasse 250
8048 Zürich

marketing@pomcanys.ch

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.

Terms and Legal Basis

2.1 Terms

Data subject: Natural person about whom we process personal data.

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

Particularly sensitive personal data: data concerning trade union, political, religious or philosophical views and activities, data concerning 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, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organising, storing, modifying, 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).

Type, scope and purpose of personal data processing

We process the 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 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, insofar as 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 comply with legal obligations or to protect overriding interests. We may also seek the consent of the persons concerned even if their consent is not required.

We process personal data for the period of time necessary for the respective purpose. We anonymise 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 specialised providers whose services we use.

Within the scope 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 economic information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations 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, organisations and companies. In particular, we process data that a data subject provides us with when contacting us, for example by post 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 organisational 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 secret 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 generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular for the purpose of processing it there or having 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 a decision by 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 appropriate 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:

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 on the grounds of 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 on the grounds of 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 take appropriate measures to identify data subjects who request information or assert other rights. 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 are stored in the browser. Such stored data are not necessarily 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 us, in particular, to recognise a browser when it next visits our website and thus, for example, to measure the reach of our website. 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 seek 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 objection (‘opt-out’) is possible for numerous 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).

9.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: 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. This 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 personalised 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 always 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 consent obtained, including the IP address and time stamp, for evidence and security reasons.

You can object to receiving notifications and communications such as newsletters at any time. By doing so, 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.

11. Third Party Services

We use the services of specialised third parties to enable us to carry out our activities and operations in a sustainable, people-friendly, secure and reliable manner. These services enable 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 in connection with our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:Klicken, um Alternative zu verwenden

11.1 Digital Infrastructure

We use the services of specialised third parties in order to be able to utilise 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:

11.2 Digital Content

We use the services of specialised third parties to integrate digital content into our website. Digital content includes, in particular, image and video material, music and podcasts.

In particular, we use:

12. Success and reach measurement

We try to measure the success and reach of our activities and operations. Within this framework, 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 minimisation through the corresponding pseudonymisation.

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 pseudonymised 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 with the respective service.

In particular, we use:

13. Final notes on the data protection declaration

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