Introduction
This Privacy Policy informs you about the processing of personal data in connection with the use of our website. The abbreviation GDPR stands for the EU General Data Protection Regulation and applies to persons in the EU who visit our website (hereinafter referred to as “persons from the EU”). The abbreviation FADP stands for the Swiss Federal Act on Data Protection and applies to persons in Switzerland who visit our websites (hereinafter referred to as “persons from Switzerland”).
Right to information
In accordance with Art. 25 FADP / Art. 15 GDPR, you have the right to obtain confirmation from us as to whether personal data concerning you are being processed. In the event of processing, you have the right to obtain information about these data and further information in accordance with Art. 25 FADP / Art. 15 GDPR.
Right to rectification
In accordance with Art. 6 FADP / Art. 16 GDPR, you have the right to obtain the immediate rectification of inaccurate personal data. You may also obtain the completion of any incomplete personal data.
Right to erasure
Persons from the EU have the right to obtain the erasure by us of their personal data immediately if the requirements of Article 17 GDPR are met. Persons from Switzerland also have the right to erasure in cases provided for by law, for example if data are no longer required or consent has been withdrawn.
Disclosure of data to third parties
We do not pass on any personal data provided to us to third parties, especially not for advertising purposes. However, when working with third parties to operate our websites or provide products/services, we take data protection measures and carefully select service providers.
Data processing in Switzerland / in the EU
We generally process data in Switzerland (data transmission upon conclusion of a contract, server log files, contact form, registration, cookies). The EU has determined that Switzerland has an adequate level of data protection. Some of the service providers whose plugins and tools we use process data outside the EU, which is disclosed in this Privacy Policy when explaining the plugins/tools used.
Right to restriction of processing
Under Art. 18 GDPR, persons from the EU have the right, under certain conditions, to obtain the restriction of the processing of their personal data.
Right to data portability
In accordance with Art. 20 GDPR, persons from the EU have the right to receive their personal data that they have provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller.
Right to object
According to Art. 21 GDPR, persons from the EU have the right to object to the processing of their personal data, in particular for direct marketing purposes.
Right to lodge a complaint with a supervisory authority
Persons from the EU have the right to lodge a complaint with the supervisory authority in accordance with Art. 77 GDPR. Persons from Switzerland may avail themselves of the legal remedies provided for in Art. 32 / 41 / 4 FADP.
Server log files
When you visit our website, the contracted company processes and stores technical information about your device and browser, as well as your IP address. These data are used for the technical accessibility and security of our website and are erased through anonymization when they are no longer needed to defend against attacks.
Data transfer upon conclusion of contract
For the conclusion and execution of a contract, we process the data you provide and transfer them to shipping and billing service providers to the extent necessary. Your data are processed for the purpose of fulfilling the contract and detecting fraud attempts.
Cookies and analytics tools
We use session cookies, small data files used by most websites. These cookies do not contain any personalized information, but only identification numbers that are meaningless outside our website. We also use Google Analytics to analyse user behaviour on our website. Google Analytics also uses so-called “cookies”. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. In addition to the standard functions, we also use integrated services on this website for which data are collected in Google Analytics for advertising purposes, including the collection of data via cookies for advertising preferences and anonymous identifiers. Alongside the data collected by the Google Analytics analysis tool, additional information is gathered via Google cookies for advertising preferences and anonymous identifiers relating to access. We use this information to improve our website.
These tools are used to ensure the security of our website and systems. Furthermore, the data are used to capture the usage behaviour of the users in order to improve our services and to conduct statistical evaluations. This allows us to tailor the content of our websites to the specific needs of visitors. All these uses are fully anonymous. We do not share this information with third parties unless required by the competent authorities.
We reserve the right to identify users, but only in cases of justified suspicion of misuse of the website and/or serious violation of the General Terms and Conditions.
You can naturally also use our web pages without cookies. You can refuse to accept cookies by adjusting your browser settings accordingly, either by deactivating the option to store cookies or by instructing your browser (usually under “Internet options” or “Settings”) to inform you each time a website attempts to install a cookie. If you wish, you can also opt out of Google Analytics by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Please note that if you disable cookies or Google Analytics, you may not be able to use all the features of our website.
Changes to this Privacy Policy
We reserve the right to revise, amend or otherwise supplement this Privacy Policy at any time. We will inform you of any changes, additions or revisions to our Privacy Policy with a corresponding notification the next time you log in.
Right to lodge a complaint with the supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the supervisory authority if you believe that the processing of personal data concerning you violates applicable data protection laws.
Swiss Federal Data Protection and Information Commissioner
Feldeggweg 1
CH – 3003 Bern
+41 (0)58 462 43 95
Who are we?
We are Hafner Urbach Attorneys at Law, Beethovenstrasse 1, 8002 Zurich and General-Wille-Strasse 10, 8002 Zurich. We are responsible for processing your personal data that we collect or receive in the course of our business activities and process for the purposes described in this Privacy Policy.
What data are collected?
In order to provide our services and conduct our business activities, we collect and process personal data from clients and potential clients, affiliated persons, counterparties, authorities, courts, third parties and other relevant persons, including their representatives, beneficial owners and (former) employees.
In addition, we collect and process personal data when you offer us services or products, when we review your products or services, or when you request information from us or send us information.
Finally, we collect and process personal data from applicants as part of the application process.
Where do we obtain your personal data?
We obtain personal data directly from you, our clients, as well as from other persons involved and their representatives or employees. In addition, we collect data from third parties, such as employers, organizations with which you are in contact, supervisory authorities, government agencies, courts, other law firms or other advisers. In addition, we obtain personal data from publicly accessible sources, such as commercial registers, debt collection registers, land registries, credit agencies or from contractual partners.
Purpose of processing
To provide our services and manage our business
We collect and process personal data in order to provide our services to you (e.g. conclusion, execution and administration of contracts), to manage our mandates and to run our company’s business (e.g. to carry out administrative and organizational processes, risk management).
To comply with statutory or regulatory obligations
We collect and process personal data to comply with applicable statutory requirements, for example to combat money laundering and to comply with tax or professional obligations. This also includes self-regulation, certification and internal and external investigations in which we are a party (to proceedings) – for example, by law enforcement agencies, supervisory authorities or commissioned private agencies. The processing of personal data for the purposes of (data) security also falls under this category.
To analyse the use of our website
We collect and process personal data to ensure the proper functioning and security of our website. We also use these data to continuously improve the website and analyse user behaviour.
To process applications
When you apply for a job, we require certain personal data from you. This information enables us to review your application – including references, background, identity, as well as credit and criminal record checks – in order to decide whether to invite you for an interview.
How long will personal data be stored?
We retain your personal data for as long as is necessary for the purposes for which they are processed. We also retain your personal data in order to comply with statutory and regulatory documentation and retention requirements, for as long as claims could be asserted against us, or insofar as this is necessary for legitimate interests, in particular the security of our data.
Personal data of applicants to whom we cannot offer a position will be erased no later than 12 months after rejection.
What are your rights?
You have certain rights in connection with the processing of your personal data. Under applicable law, you can in particular:
- obtain information about which of your personal data we are processing.
- obtain the rectification of inaccurate or incomplete personal data.
- obtain the erasure of your personal data.
- object to the processing of your personal data.
- obtain the release of specific personal data in a commonly used electronic format or the transfer of such data to other controllers.
- withdraw consent previously given for data processing in future, insofar as the processing is based on your consent.
Please note that certain conditions, exceptions or restrictions may apply to the exercise of these rights – for example, to protect third parties, to preserve business secrets or due to our professional confidentiality obligations. In such cases, we reserve the right to redact copies for reasons of data protection or confidentiality, or to provide only partial copies.
You will not normally have to pay a fee to exercise your rights. However, we may charge a fee if permitted by applicable data protection law, in which case we will inform you accordingly.
If you wish to exercise your rights, please contact us in writing by email or post at:
Hafner Urbach Attorneys at Law
+41 58 444 11 00
office@huplaw.ch
Beethovenstrasse 1
8002 Zurich
General-Wille-Strasse 10
8002 Zurich
If you believe that we are not processing your data in accordance with data protection law, you can contact the relevant supervisory authority; in Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC).
Are personal data transferred abroad?
We generally process data in Switzerland (data transmission upon conclusion of a contract, server log files, contact form, registration, cookies). The EU has determined that Switzerland has an adequate level of data protection. Some of the service providers whose plugins and tools we use process data outside the EU, which is disclosed in this Privacy Policy when explaining the plugins/tools used.
Do we use cookies on our website?
We use cookies on our website to achieve some of the above purposes. Further information about which cookies we use, for what purposes they are used and what rights you have in relation to these cookies can be found below:
Server log files
When you visit our website, the contracted company processes and stores technical information about your device and browser, as well as your IP address. This data are used for the technical accessibility and security of our website and are erased through anonymization when they are no longer needed to defend against attacks.
Cookies and analytics tools
We use session cookies, small data files used by most websites. These cookies do not contain any personalized information, but only identification numbers that are meaningless outside our website. We also use Google Analytics to analyse user behaviour on our website. Google Analytics also uses so-called “cookies”. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. In addition to the standard functions, we also use integrated services on this website for which data are collected in Google Analytics for advertising purposes, including the collection of data via cookies for advertising preferences and anonymous identifiers. Alongside the data collected by the Google Analytics analysis tool, additional information is gathered via Google cookies for advertising preferences and anonymous identifiers relating to access. We use this information to improve our website.
These tools are used to ensure the security of our website and systems. Furthermore, the data are used to capture the usage behaviour of the users in order to improve our services and to conduct statistical evaluations. This allows us to tailor the content of our websites to the specific needs of visitors. All these uses are fully anonymous. We do not share this information with third parties unless required by the competent authorities.
We reserve the right to identify users, but only in cases of justified suspicion of misuse of the website and/or serious violation of the General Terms and Conditions.
You can naturally also use our web pages without cookies. You can refuse to accept cookies by adjusting your browser settings accordingly, either by deactivating the option to store cookies or by instructing your browser (usually under “Internet options” or “Settings”) to inform you each time a website attempts to install a cookie. If you wish, you can also opt out of Google Analytics by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Please note that if you disable cookies or Google Analytics, you may not be able to use all the features of our website.
EU
The abbreviation GDPR stands for the EU General Data Protection Regulation and applies to persons in the EU who visit our website (hereinafter referred to as “persons from the EU”).
Where we process personal data of persons from the EU, this is done exclusively within the scope of the purposes of the GDPR and the data processing governed by it.
The processing of your personal data is based in particular on the following:
- It is necessary for the initiation and conclusion of contracts and their administration and enforcement (point (b) of Art. 6(1) GDPR);
- It is necessary to safeguard our legitimate interests or those of third parties, namely for communication with you or third parties, to operate our website, to improve our electronic content and to register for certain content and services, for security purposes, to comply with Swiss law and internal regulations, for our risk management and corporate governance, and for other purposes such as training and education, administration, evidence and quality assurance, organization, implementation and follow-up of events, as well as other legitimate interests (point (f) of Art. 6(1) GDPR);
- It is required or permitted by law under EEA law or the law of a Member State on the basis of our mandate or position (point (c) of Art. 6(1) GDPR) or is necessary to protect your vital interests or those of other natural persons (point (d) of Art. 6(1) GDPR);
- You have separately consented to the processing, e.g. by making a declaration to that effect on our website (point (a) of Art. 6(1) and point (a) of Art. 9(2) GDPR).
We only process your personal data for as long as is necessary for our processing purposes, statutory retention periods or our legitimate interests, in particular for documentation and evidence purposes.
Technical reasons, such as backups or document management systems, may also necessitate temporary storage. Unless required otherwise due to legal, contractual or technical reasons, we will erase or anonymize your data after the storage or processing period has expired as part of our normal procedures and in accordance with our retention policy.
If you are located in the EEA, you also have the right to complain to your country’s data protection supervisory authority. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Changes to this Privacy Policy
This Privacy Policy is not part of any contract with you. We reserve the right to revise, amend or otherwise supplement this Privacy Policy at any time. The current version published on our website is applicable.