Version from 26 September 2022
1. Data protection policy and competent authority
This data protection policy is intended to inform the users of this website (hereinafter referred to as “Users”) about the nature, scope and purpose of the collection, processing and use of personal data by the responsible provider of this website.
The responsible provider of this website is Reuss Private AG, Wiesenstrasse 8, CH-8008 Zurich, Switzerland. For questions or comments regarding data protection, you can contact us by email at: email@example.com
2. Collection, processing and use of personal data in general
We collect, process and use Users’ personal data in compliance with the applicable data protection regulations of Switzerland and the European Union. Reuss Private AG processes personal data that has been collected in good faith and in a lawful manner that is comprehensible to the data subject in accordance with the following provisions. Unless otherwise stated, the terms referred to follow the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter “GDPR”).
During each visit to the website, certain personal data are automatically collected. Please refer to the relevant sections for details on the data collected (cookies, plug-ins, etc.).
3. Legal basis in general
The personal data of Users are only processed with the consent of the user. An exception applies in cases where consent cannot be obtained in advance for factual reasons and the processing of the data is permissible due to legal provisions or overriding interests.
In cases where we obtain consent from the data subject to process personal data, Art. 6 para. 1 (a) of the GDPR or Art. 13 para. 1 in conjunction with Art. 4 para. 5 of the Swiss Federal Act on Data Protection (hereinafter “FADP”) shall serve as the legal basis.
If the processing of personal data is necessary for the fulfilment of a contractual relationship with the data subject as the contracting party, Art. 6 para. 1 (b) GDPR and Art. 13 para. 2 (a)FADP serve as the legal basis. This also applies to processing that is necessary for the implementation of pre-contractual measures.
If the processing of personal data is necessary to protect a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 (f) GDPR and Art. 13 para. 2 FADP serve as the legal basis for the processing of personal data.
4. Purpose of processing in general
The personal data collected from Users may be used for marketing purposes. For more information, please see the provisions below.
When contacting Reuss Private AG, for example via the contact form, the details and contents of the form are stored for the purpose of processing the enquiry and in the event of follow-up questions.
Reuss Private AG may disclose personal data to its affiliated companies (hereinafter collectively referred to as “Reuss Private Group”) for the aforementioned purposes. In any case, the specific purpose of the data collection remains.
5. Collection of general information when visiting the website (log files)
Each time the website is accessed, the web space provider automatically collects certain information. This information is referred to as server log files.
The information collected includes: Date and time of access, web browser and version used, referrer URL (the page from which you access our website) and the IP address.
The data are stored in the log files for troubleshooting purposes and for identifying a perpetrator in the event of cyber attacks (hacking, etc.). The collection of personal data is therefore obligatory, whereas restricting or objecting to data processing could lead to the loss of the full functionality of the website, which is why such a restriction or objection is only partially possible.
Art. 6 para. 1 (f) GDPR and Art. 13 para. 2 FADP serve as the legal basis for the temporary storage of data and log files.
6. Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus analyse the activities of a user on multiple devices.
We only use Google Analytics with IP anonymisation activated. This means that the IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Reuss Private AG is then no longer able to assign the address to a person.
7. Newsletter and consent information
The following information serves to explain the content of our newsletter as well as the registration, delivery and statistical evaluation process and your rights of objection. By subscribing, you agree to receive our newsletter and to the procedures described.
Our website provides the option of subscribing to a free newsletter. In the process, the data entered for the subscription to the newsletter (all required data: email address, first and last name, company) as well as the log data (see b) are transmitted to us. When you sign up for our newsletter, we only use the data you enter to personalise the newsletter or to inform you of circumstances relevant to that service or subscription.
a) Content of the newsletter
We only send newsletters, emails and other electronic communications containing advertising (hereinafter referred to as “newsletters”) with the consent of the recipient or on the basis of statutory provisions.
b) Double opt-in and logging
If you subscribe to our newsletter, this is done via a double opt-in procedure. This means that after registration you will receive an email asking you to confirm that you wish to subscribe to the newsletter. This confirmation is necessary to ensure that it is not possible for anyone to subscribe with other people’s email addresses. Your subscription to the newsletter is logged so that the subscription process can be traced within the framework of the legal provisions. This includes storing the time of your subscription and confirmation as well as your IP address.
You can unsubscribe from our newsletter at any time, i.e. you can revoke your consent.
At the end of each newsletter you will find a link to unsubscribe.
We delete the personal data as soon as they are no longer required for the purpose for which they were collected. The user’s email address is therefore stored for as long as the subscription to the newsletter is active. The other personal data collected as part of the registration process are stored for as long as it is required to prove subscription to the newsletter.
8. Contact form
Our website contains contact forms that can be used to contact us electronically. If a user makes use of this option, the data entered in the form will be transmitted to us and stored. These data are:
> Email address
The following data are also stored at the time the contact form is submitted:
> IP address of the user
> Date and time of communication
Alternatively, it is possible to contact us via the email address provided. In this case, the user’s personal data transmitted by email will be stored.
The personal data from the input form are processed exclusively for contact and communication purposes. The other personal data processed during the submission process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
The legal basis for data processing is the user’s consent pursuant to Art. 6 para. 1 (a) GDPR and Art. 13 para. 1 FADP. The legal basis for the processing of data transmitted in the process of sending an email is Art. 6 para. 1 (f) GDPR and Art. 13 para. 2 FADP. In the event that the email correspondence is intended to conclude a contract, the additional legal basis for processing is Art. 6 para. 1 (b) GDPR and Art. 13 para. 2 (a) FADP.
Users have the option to revoke their consent to the processing of personal data at any time. If Users contact us by email, they can refuse to allow their personal data to be stored at any time. In such a case, however, the communication cannot be continued. In this case, all personal data stored in the course of contacting us will be deleted. If consent is not revoked, the data will be deleted as soon as they are no longer required. The previous statutory provisions shall remain reserved.
9. User rights
a) Right to information
You may request confirmation that personal data relating to you are being processed by us. If any such processing takes place, you can find details of the information provided in accordance with Art. 15 GDPR and Art. 8 (f) FADP.
b) Right to correction
You have the right to have your personal data corrected and/or completed if the personal data concerning you are inaccurate or incomplete. Reuss Private AG will correct the data without delay.
c) Right to restriction of processing
Under the conditions of Art. 18 GDPR, you may request the restriction of the processing of your personal data. If the processing of personal data relating to you has been restricted, this data – with the exception of storage – may only be processed with your consent or other legal exemption.
d) Right to deletion
You may request that personal data relating to you be deleted without delay, and Reuss Private AG is obliged to delete such data without delay, provided that one of the conditions set out in Art. 17 GDPR is met and no exemption applies.
e) Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 (e) or (f) GDPR.
f) Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of consent up to the time of revocation.
g) Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR and that this Regulation applies. The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
For data processing under Swiss law, the legal remedies are regulated in the FADP.
The rights described can be exercised in writing by sending a letter to the above address or by sending an email to the above email address.
10. Storage / back-up
Unless otherwise stated in individual cases, the data stored by us will be deleted as soon as they are no longer required for the intended purpose and the deletion does not conflict with any statutory retention obligations.
12. More information
Reuss Private AG endeavours to store your personal data in such a way that they are not accessible to third parties by taking appropriate technical and organisational measures. When communicating by email, we cannot guarantee complete data security, so we recommend that you send confidential information by post.
The employees and service providers commissioned by Reuss Private are obliged to maintain confidentiality and to comply with the applicable data protection provisions.
We use state-of-the-art organisational, contractual and technical security measures to ensure compliance with data protection regulations and to protect the data we manage against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.
The representative for data protection issues in Switzerland is
Reuss Private AG
T: +41 56 511 41 00
If you have any questions about data protection, please contact our data protection representative at firstname.lastname@example.org.
Data protection officer within the European Union in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation):
BN & Partners Capital AG
60329 Frankfurt am Main
T: +49 69 247 51 27 60