HomedividerPrivacy & Cookie Policy

Privacy & Cookie Policy

Last Updated Semptember 2020

Privacy Policy

This privacy policy ("Privacy Policy") applies to the usage of the website thirty3 ("Website") operated by thirty3 GmbH, Nordstrasse 198, 8037 Zurich, Switzerland ("thirty3", "we", "our", or "us"). At thirty3, we are committed to protecting your privacy, and want you to be secure when visiting our Website.

By accessing the Website, you ("User", "you", "your", or "yours") agree to the collection, usage, processing, and disclosure of information in accordance with this Privacy Policy.

We attach great importance to protection and security of your Personal Data. We regard the protection of your private sphere and the compliance with the data protection requirements as the key matter when collecting, processing, and using your Personal Data. Therefore, your Personal Data are collected, processed, and used exclusively in compliance with the provisions of data protection laws, in particular the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR).

Definitions

"Personal Data" is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Data Subject" is an identified or identifiable natural person, i.e. one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Data Controller" means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

"Data Processor" means any natural or legal person who processes Personal Data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your Personal Data more effectively.

Personal Data We Collect

We collect the following Personal Data about you when you use our Website, including taking certain actions within it.

Action Personal Data collected
When you browse our Website Website usage and interaction Technical data Statistical data
When you log into our Website Contact details Login information Uploaded documents
When you sign up for our newsletter and other marketing material Email address
When you communicate with us electronically Contact details
When you apply for a job Contact details Resume Past employment Education Certificates Work permit

We may collect Personal Data for the following purposes:

  • Providing information about offers, services, websites and other platforms where we have an online presence
  • Communicating with third parties and processing their queries (e.g. applications, media queries);
  • Examining and optimising needs analysis procedures for the purpose of directly addressing customers, as well as collecting personal data from publicly accessible sources for the purpose of customer acquisition;
  • Advertising and providing information about our services and offers (including conducting events and sending the annual report) if you have not refused permission for the use of your data (if we send you advertising as a current customer, you may refuse permission at any time and we will place you on a list to block the sending of further advertising);
  • Market surveys, opinion research, media monitoring;
  • Asserting and defending legal claims in the context of legal disputes and official procedures;
  • Preventing and investigating crimes and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
  • Safeguarding our operations, in particular our IT, our websites and other platforms;
  • IT, building and system security measures to protect our employees and other persons, as well as assets that belong to us or have been entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone records);

Our legal basis for collecting and using the Personal Data described in this Privacy Policy depends on the Personal Data we collect and the specific purposes for which we collect it.

Contract: To perform our contractual obligations or take steps linked to a contract with you.

  • To provide and protect our Website and services.
  • To administer, manage and develop our business and services.

Consent: We may rely on your freely given consent at the time you provided your Personal Data.

  • To provide you with news, special offers, newsletters, and general information about services which we offer (with your explicit consent).

Legitimate interests: We may rely on legitimate interests based on our evaluation that the processing is fair and reasonable.

  • To maintain and improve our Website and services.

Public interest: To meet regulatory and public interest obligations.

  • To comply with applicable regulation and legislation.

Data Retention

We retain your Personal Data only for as long as is necessary for the purposes set out in Section 3 of this Privacy Policy, and to the extent necessary to comply with our legal obligations, resolve potential disputes and enforce our legal agreements and policies.

Service Providers and Data Transfers

We may employ third party companies ("Service Providers") to facilitate the operation of our Website, assist us in analysing how our Website is used, or perform Website-related services, such as IT infrastructure services. These third parties have access to your Personal Data only and insofar as necessary to perform these tasks on our behalf and are required to safeguard it in accordance with our contractual obligations and applicable data protection legislation.

Such safeguards may include transfer to countries that have been deemed to provide an adequate level of protection; applying standard data protection model clauses, binding corporate rules or other standard contractual obligations which provide for appropriate protection of data.

In particular, to store and manage Personal Data of our clients, potential clients and any other interested parties, we use the Salesforce CRM (https://www.salesforce.com/company/privacy/). The Personal Data stored on and handled with Salesforce CRM includes email addresses and names, and may include, if provided, phone numbers, and addresses. Salesforce does not own, control or direct the use of any of the Personal Data stored or processed by us. Only thirty3 employees with specific access rights are entitled to access, retrieve, and direct the use of such Personal Data.

We may also use recruiting websites such as LinkedIn and JobCloud to connect with job candidates. If you apply for a job using a third-party website, please observe that website's privacy policy prior to submitting your data.

Data Disclosure

We may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation (i.e. if required by law or in response to valid requests by public authorities, such as a court or government agency);
  • To protect the security of the Website and defend our rights or property;
  • To prevent or investigate possible wrongdoing in connection with our company;
  • To protect ourselves against legal liability.

Data Security

We take reasonable technical and organizational security measures that we deem appropriate in order to protect your data against manipulation, loss, or unauthorized third-party access. Our security measures are continually adapted to technological developments.

We also take internal data privacy very seriously. Our employees and the Service Providers that we retain are required to maintain secrecy and to comply with applicable data protection legislation. In addition, they are granted access to Personal Data only insofar as this is necessary for them to carry out their respective tasks or mandate.

The security of your Personal Data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We recommend that you use antivirus software, a firewall, and other similar software to protect your system.

Data Protection Rights

You have the below data protection rights on the basis of applicable data protection laws. Please note that we may ask you to verify your identity (e.g. with a copy of an ID card, if your identity cannot otherwise be clearly identified) before responding to such requests.

  • Right of access: You have a right to request a copy of your Personal Data, which we will provide to you in an electronic form.
  • Right to amendment: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.
  • Right to withdraw consent: If you have provided your consent to the processing of your Personal Data, you have the right to withdraw your consent. This includes cases where you wish to opt out from marketing communications. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal basis for processing. To stop receiving emails from us, please click on the 'unsubscribe' link in the email you received.
  • Right to erasure: You have the right to request that we delete your Personal Data when it is no longer necessary for the purposes for which it was collected, or when it was unlawfully processed.
  • Right to restriction of processing: You have the right to request the restriction of our processing of your Personal Data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it.
  • Right to portability: You have the right to request that we transmit your Personal Data to another data controller in a common format such as Excel, where this is data which you have provided to us and where we are processing it on the legal basis of your consent or in order to perform our contractual obligations.
  • Right to object to processing: Where the legal basis for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have a compelling legal basis for the processing which overrides your interests, or if we need to continue to process the Personal Data for the exercise or defence of a legal claim.
  • Right to lodge a complaint with a supervisory authority: You have the right of appeal to a data protection supervisory authority if you believe that the processing of your Personal Data violates data protection law. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch/edoeb/en/home.html).

Our Website may contain links to websites or apps that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site or app.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Cookies

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer's hard drive.

Please refer to our Cookie Policy for a full list of the cookies that we use, their function, and your choices.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We therefore encourage you to review this page periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

thirty3 GmbH
Nordstrasse 198
8037 Zurich

mike@thirty3.ch

At https://thirty3.ch/ ("We", "us", "our"), we strive to honour the privacy and security of any data we collect from visitors using our website, whilst we act as a personal data Controller under relevant data protection rules and regulations. Our website uses cookies, in combination with pixels, local storage objects, and similar devices (collectively, “cookies” unless otherwise noted) to distinguish you from other users of the website. This helps us provide you with a good experience, improve our service, and to personalize ads and content to you while you use the website.

This cookie policy (“Cookie Policy”) describes the types of the cookies we use on the website and our purposes for using them.

If you have questions about this Cookie Notice, please contact us at legal@thirty3.ch. For a more complete description and list of the cookies that we currently use on the website, please review our Cookie List found in section 5 of this document. For more information about our privacy practices, please review our privacy policy: https://thirty3.ch/privacy. If you have any questions or comments regarding this notice or data privacy, please contact us at legal@thirty3.ch.

Please read this Cookie Notice carefully for details about why we use cookies and the information they collect from and about you.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device, which is like computer memory.

First and third-party cookies: whether a cookie is 'first' or 'third' party refers to the domain placing the cookie.

  • First-party cookies are those set by a website that is being visited by the user at the time (e.g. cookies placed by our website domain).
  • Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies: these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

What Cookies Do We Use and Why?

Generally, the website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve it. The cookies we may use on the website may be categorized as follows:

  • Strictly necessary
  • Performance
  • Functionality
  • Targeting

Some cookies may fulfil more than one of these purposes.

'Strictly Necessary' cookies let you move around the website and use essential features like secure areas. Without these cookies, we cannot provide the requested services.

We use these Strictly Necessary cookies to:

  • Identify you as being logged in to the website and to authenticate you
  • Make sure you connect to the right service on the website when we make any changes to the way it works
  • For security purposes
  • Make sure you connect to the right service on the website when we make any changes to the way it works

If you prevent these cookies, we can't guarantee how the website or the security on the website will perform during your visit.

'Performance' cookies collect information about how you use the website, e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and are only used to help us improve how the website works, understand the interests of our users and measure the effectiveness of our advertising.

We use performance cookies to:

  • Carry out web analytics: Provide statistics on how the website is used
  • Perform affiliate tracking: Provide feedback to affiliated entities that one of our visitors also visited their site
  • Obtain data on the number of users of the website that have viewed a product or service
  • Help us improve the website by measuring any errors that occur
  • Test different designs for the website

Some of our performance cookies are managed for us by third parties.

'Functionality' cookies are used to provide services or to remember settings to improve your visit.

We use 'Functionality' cookies for such purposes as:

  • Remember settings you've applied such as layout, text size, preferences and colors
  • Remember if we've already asked you if you want to fill in a survey
  • Remember if you have engaged with a specific component or list on the website so that it won’t repeat
  • Show you when you're logged in to the website
  • To provide and show embedded video content

Some of these cookies are managed for us by third parties

‘Targeting’ cookies are used to track your visit to the website, as well other websites, apps and online services, including the pages you have visited and the links you have followed, which allows us to display targeted ads to you on the website.

We may use targeting cookies to:

  • Display targeted ads within the website.
  • To improve how we deliver personalized ads and content, and to measure the success of ad campaigns on the website.

All cookies require your consent.

We request your consent before placing them on your device. You can give your consent by clicking on the appropriate button on the banner displayed to you. If you do not wish to give consent or wish to withdraw your consent to any cookies at any time, you will need to delete, and block or disable cookies via your browser settings; see below for more information on how to do this. Please note that disabling these cookies will affect the functionality of the website, and may prevent you from being able to access certain features on the website.

How to Delete and Block our Cookies

Most web browsers allow some control of most cookies through the browser settings. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of the website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the website.

The browser settings for changing your cookies settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the 'Help' option in your internet browser for more details.

  • Cookie settings in Internet Explorer
  • Cookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari

More information To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

Contact us

For any questions feel free to contact us at: legal@thirty3.ch.