
Data Privacy Notice
In this Data Privacy Notice, we provide information on which personal data we process in connection with our activities and operations, including our axonactive.ch / axonactive.com website. We provide information on what on why, how and where we process personal data. We also provide information about the rights of persons whose data we process.
Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation.
We are subject to Swiss data protection law and any applicable foreign data protection law, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data in the various areas:
We point out if there are other persons responsible for the processing of personal data in individual cases.
Furthermore, we point out, if not explicitly marked, that this privacy policy is valid for Axon Active Schweiz AG and for Axon Active Vietnam Co., Ltd.
2. Data Protection Representation in the European Economic Area (EEA)
We have the following data protection representation pursuant to Art. 27 DSGVO. The data protection representation serves supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries in connection with the General Data Protection Regulation (GDPR):
Am Kaiserkai 69
20457 Hamburg
Germany
3. Terms and legal bases
3.1 Terms
Personal data is any 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, regardless of the means and procedures used, 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) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
3.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (FADP) 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 in order 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 and 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 under 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 which is 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 GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
4. Nature, scope and purpose
We process the personal data that is required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data and contract and payment data.
We process personal data for the period of time 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 jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.
As a matter of principle, we only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons, for example to fulfil a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
Within this framework, we process information that a data subject submits to us voluntarily and of their own accord when contacting us - for example, by letter, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management (CRM) system or with similar tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection with respect to such persons as well as to ensure the accuracy of such 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 by law.
5. Applications
We process personal data about applicants to the extent that it is required for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants provide voluntarily, in particular as part of cover letters, CVs and other application documents.
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants in particular in accordance with Art. 9 (2) lit. b GDPR.
We may allow applicants to submit their details to our talent pool to be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant is eligible for a vacancy based on the information provided, we will notify the applicant accordingly.
6. Personal data abroad
On principle, we process personal data 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 there.
We may export personal data to all countries and territories on earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection according to the assessment of the Federal Data Protection and Information Commissioner (FDPIC) or according to the decision of the Swiss Federal Council and - if and to the extent that the Data Protection Regulation (GDPR) is applicable - according to the decision of the European Commission.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other appropriate guarantees. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, such as 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 a copy of any guarantees on request.
Express permission for Vietnam is automatically granted when communicating directly with Axon Active Vietnam, Co., Ltd. or via axonactive.com.
7. Rights of data subjects
Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information as well as the right to correction, 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 their personal data and, if so, 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.
Data subjects whose personal data we process may - if and insofar as the GDPR is applicable - revoke their consent at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process 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).
8. Data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. Unfortunately, however, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communication - like all digital communication in principle - is subject to mass surveillance without cause and without suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.
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 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. Cookies mainly make it possible to recognize a browser the next time it 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 and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request - at least if and to the extent necessary - 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 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 Server log files
We may collect the following information for each access to our website, provided that this information 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 provide our website permanently in a user-friendly and reliable manner, and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
9.3 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files.
10. Notifications and messages
We send notifications and communications via email and other communication channels such as instant messaging or SMS.
10.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that track whether an individual message has been opened and which web links have been clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.
10.2 Consent and objection
In general, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure where possible, i.e. 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 always object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement.
This is without prejudice to any necessary notifications and communications in connection with our activities and operations.
10.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
In particular, we use:
Brevo: communication platform; provider: Sendinblue French Simplified Joint Stock Company (France); information on data protection: data protection policy, "GDPR".
ClickSend: corporate communication via e-mail, SMS, voice messages and other communication channels; provider: ClickSend Pty Ltd (Australia); information on data protection: privacy policy, "Privacy Policy", "Security & Compliance".
11. social media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
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 also apply in each case. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.
For our social media presence on Facebook, including the so-called Page Insights, we are - if and insofar as - the GDPR is applicable, 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 way.
Further information about the type, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Responsible Party Addendum" with Facebook and have thus agreed 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 on Page Insights" including "Information on Page Insights Data".
12. Third party services
We use third party services to enable us to carry out 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 into our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily 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 an aggregated, anonymized or pseudonymized manner. This is, for example, performance or usage data in order to be able to offer the respective service.
In particular, we use:
Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: "Privacy and security principles", Privacy policy, "Google is committed to complying with applicable data protection laws", "Privacy guide in Google products", "How we use data from websites or apps on or in which our services are used" (information provided by Google), "Types of cookies and other technologies used by Google", "Personalised advertising" (activation / deactivation / settings).
12.1 Digital Infrastructure
We use third party services to provide us with the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from specialist providers.
In particular, we use:
Amazon Web Services (AWS): Storage space and other infrastructure; Providers: Amazon Web Services Inc. (USA) for users in Switzerland / Amazon Web Services EMEA SARL (Luxembourg) for users in the European Economic Area (EEA); Information on data protection: Privacy Policy, "Data Protection Centre", "Frequently Asked Questions on Data Protection", "Data Protection Regulation (GDPR) Centre".
Microsoft Azure: storage and other infrastructure; provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) supplementary for users in the European Economic Area (EEA), the United Kingdom and Switzerland; information on data protection: data protection declaration, "Data protection at Microsoft", "Data protection" ("Microsoft Trust Center"), "Azure data protection", "Microsoft Cloud Services" (General Data Protection Regulation, GDPR)
Wix: website builder and other infrastructure; provider: Wix.com Ltd. (Israel) together with Wix.com Ltd. (USA) / Wix.com Inc. (USA) / Wix.com Luxembourg S.à.r.l. (Luxembourg); Privacy information: Privacy Policy, "Privacy & Security", "Wix Help Center 'Privacy'" including Cookie Policy.
Teliportme: 360° Virtual Reality Photo Viewer: A Good World LLC (USA); Privacy Policy: Terms and Conditions, Cookie Policy
Windy: Live view plugin for webcams on axonactive.com: Windyty, SE (Czech Republic); Privacy information: Privacy policy.
12.2 Contact options
We use third party services to better communicate with you and others, such as customers.
In particular, we use:
Ascend by Wix: customer relationship management (CRM); provider: Wix; Ascend specific information: 'About Ascend by Wix'.
Jira Service Management (Jira Service Desk): Customer Service; Providers: Atlassian Pty Ltd (Australia) / Atlassian Inc (USA); Privacy information: Privacy Policy.
Zalo: online messenger service, only on careers.axonactive.com for job applicants; provider: VNG (Vietnam); Zalo specific information: "About Zalo security".
12.3 Scheduling
We use services of third parties in order to be able to arrange appointments, for example for meetings. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.
Calendly: appointment automation platform; provider: Calendly LLC (USA); information on data protection: data protection declaration, "Security".
Doodle: Online appointment scheduling; Provider: Doodle AG (Switzerland) as a subsidiary of TX Group AG (Switzerland); Data protection information: Data protection declaration, "General Terms and Conditions of the Processing of Personal Data".
12.4 Audio and video conferencing
We use specialized audio and video conferencing services to communicate online. For example, we may use them to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as data protection declarations and terms of use apply in addition.
Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or fading in a virtual background.
In particular, we use:
Microsoft Teams: platform for, among other things, audio and video conferencing; provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; Information on data protection: "Data protection" ("Microsoft Trust Center"), data protection declaration, "Data protection at Microsoft", "Data protection and Microsoft Teams".
Zoom: video conferencing; provider: Zoom Video Communications Inc. (USA); information on data protection: data protection declaration, "Data Protection at Zoom", "Legal Compliance Center".
Skype: audio and video conferencing; provider: Skype Communications SARL (Luxembourg) / Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; Information on data protection: "Legal information on Skype", "Data protection" ("Microsoft Trust Center"), "Data protection at Microsoft", privacy policy.
12.5 Online collaboration
We use the services of third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.
In particular, we use:
MURAL: Whiteboard platform; Provider: Tactivos Inc. (USA); Information on data protection: Data protection declaration, "Security & Compliance".
Miro: whiteboard platform; provider: RealtimeBoard Inc. (USA); information on data protection: data protection declaration, "Trust in Miro" ("Miro Trust Center")
TestGorilla: online test system for job applicants; provider: TestGorilla B.V. (Netherlands); data protection information: privacy policy.
British Council English Score: online English test system for job applicants; provider: BC EnglishScore Limited (UK); data protection information: privacy policy.
12.6 Social media functions and social media content
We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and through other means.
In particular, we use:
Facebook (social plugins): Embedding of Facebook functions and Facebook content, for example "Like" or "Share"; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: data protection declaration.
LinkedIn Consumer Solutions Platform: Embedding of functions and content from LinkedIn, for example with plugins such as the "Share Plugin"; Provider: LinkedIn Ireland Unlimited Company (Ireland) for users in the European Economic Area (EEA) and Switzerland / LinkedIn Corporation USA) for users in the rest of the world; Data protection information: "Privacy", data protection declaration, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.
Twitter for Websites: Embedding functions and content from Twitter, for example for displaying tweets; Providers: Twitter International Company (Ireland) for users in the European Economic Area (EEA) and the United Kingdom / Twitter Inc. (USA) for users in the rest of the world; Data protection information: Privacy policy, "Twitter for websites - information on ads and data protection", "How we use cookies and similar technologies", "Personalisation based on derived identity", "Privacy settings for personalised ads".
Instagram platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: privacy policy (Instagram), privacy policy (Facebook).
Online Certificates: online training certificates that can be obtained from Axon Active after successful training; Sertifier Inc. (USA)
12.7 Maps
We use third party services to embed maps on our website. In particular, we use:
Google Maps including Google Maps Platform: mapping service; provider: Google; Google Maps-specific information: "How Google uses location information".
12.8 Audiovisual media
We use third party services to enable the direct playback of audiovisual media such as music or videos on our website.
In particular, we use:
YouTube: Videos; Provider: Google; YouTube-specific information: "Privacy and Security Center", "My Data on YouTube".
12.9 Documents
We use third party services to enable us to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents.
In particular, we use:
Microsoft 365 (also Microsoft Office 365): text documents as well as forms, presentations and spreadsheets; provider: Microsoft Corporation (USA); information on data protection: data protection declaration, "Data protection at Microsoft", "Data protection" ("Microsoft Trust Center"), "Data protection and security with Microsoft 365".
SlideShare: Presentations; Provider: Scribd Inc. (USA); Privacy information: Privacy policy.
12.10 Fonts
We use third party services to embed selected fonts as well as icons, logos and symbols into our website.
In particular, we use:
Google Fonts: fonts; provider: Google; Google Fonts-specific claims: "What does using the Google Fonts API mean for the privacy of my users? ("What does using the Google Fonts API mean for the privacy of my users?").
12.11 Advertising
We use the option to display targeted advertisements for our activities and operations on third parties 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 who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - information to third parties who enable such advertising. We may also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking). Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our online offer to your profile there.
In particular, we use:
Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Facebook Pixel and Custom Audiences including Lookalike Audiences, data protection declaration, "advertising preferences" (user registration required).
Google Ads: search engine advertising; provider: Google; Google Ads specific claims: Advertising based on, inter alia, search queries, using different domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why am I seeing a particular ad?".
LinkedIn Ads: Social media advertising; Provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Data protection information: remarketing and targeting in particular with the LinkedIn Insight Tag, "Data protection", privacy policy, cookie policy, objection to personalised advertising.
13. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use:
Google reCAPTCHA: Spam protection (distinguishing between wanted comments coming from humans and unwanted comments coming from bots as well as spam); Provider: Google; Google reCAPTCHA specific information: "Was ist reCAPTCHA?". ("What is reCAPTCHA?").
jQuery (OpenJS Foundation): Free JavaScript library; Provider: OpenJS Foundation (USA) using StackPath CDN; Privacy information: Privacy statement (OpenJS Foundation), Cookie policy (OpenJS Foundation).
jQuery (Google Hosted Libraries): Free JavaScript library; Provider: Google; Google Hosted Libraries-specific claims: "What does using the Google Hosted Libraries mean for the privacy of my users?" ("What does using the Google Hosted Libraries mean for the privacy of my users?").
14. Success and reach measurement
We use services and programs to determine how our online offering is used. For example, we may measure the success and reach of our activities and operations and the impact of third-party links to our website. We can also, for example, test and compare how different versions of our online offer or parts of our online offer 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 generally shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymization and thus to 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 on the size of the screen or browser window and the - at least approximate - location. User profiles are always created exclusively on a pseudonymous basis. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.
In particular, we use:
Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, "Privacy", "Browser add-on to deactivate Google Analytics".
Leadfeeder / Dealfront: Success and reach measurement, only on axonactive.com; Provider: Echobot Group GmbH (Germany); B2B Marketer: Measurement also across different browsers and devices (cross-device tracking); Privacy policy, "Dealfront and GDPR compliance".
15. Final provisions
We have created this data protection declaration together with Data Protection Partner Switzerland.
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.
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