Imprint and privacy policy

Imprint

Mint Consulting GmbH
Bahnhofstrasse 12
CH-5400 Baden

CHE-116.336.073

Phone: +41 79 372 08 27

EMail: ahummler@mint-consulting.ch

Privacy policy

In this privacy policy, we provide information about which personal data we process in connection with our activities and operations, including our website. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

For individual or additional activities and operations, further data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

We are subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law guarantees adequate data protection.

 

  1. Contact addresses

Responsibility for the processing of personal data:

MINT Consulting GmbH, Bahnhofstrasse 12, CH-5400 Baden, Switzerland

ahummler@mint-consulting.ch

We would like to point out if there are other controllers for the processing of personal data in individual cases.

 

  1. Terms and legal bases

2.1 Terms

Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, for example the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, recording, deletion, disclosure, organisation, storage, modification, dissemination, linking, destruction and use of personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as 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.

2.2 Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

If and insofar as the General Data Protection Regulation (GDPR) is applicable, we process 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 fulfilment of a contract with the data subject and 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 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 in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.

Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil 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 carried out 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 in order to protect the vital interests of the data subject or another natural person.

 

  1. 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 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 as well as contract and payment data.

We process personal data for as long as is necessary for the respective purpose(s) or required by law. Personal data that no longer needs to be processed is anonymised 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, specialised providers whose services we use. We also guarantee data protection for such third parties.

We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permitted, for example, for the fulfilment of a contract with the data subject and for corresponding pre-contractual measures in order to protect our overriding legitimate interests, because the processing is evident from the circumstances or following prior information.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example by post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such data in an address book, in a customer relationship management system (CRM system) or with comparable tools, for example. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection for these persons and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.

 

  1. Applications

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

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 para. 2 lit. b GDPR.

 

  1. Personal data abroad

We generally process personal data in Switzerland and 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 and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and – if and insofar as the General Data Protection Regulation (GDPR) is applicable – in accordance with the decision of the European Commission.

We may transfer personal data to countries whose laws do 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 suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.

 

  1. Rights of data subjects

6.1 Data protection claims

We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:

Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.

Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.

Erasure and objection: Data subjects can have their personal data erased (“right to be forgotten”) and object to the processing of their data with effect for the future.

Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

6.2 Right to lodge a complaint

Data subjects have the right to enforce their data protection claims by legal means or to lodge a complaint with a competent 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).

Data subjects have the right – if and insofar as the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European data protection supervisory authority.

 

  1. Data security

We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

Our digital communication – like all digital communication – is subject to mass surveillance without cause or suspicion and 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 forces and other security authorities.

 

  1. Use of the website

8.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) as well as 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. In particular, cookies make it possible to recognise 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 fully 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 your express consent to the use of cookies – at least if and to the extent necessary.

8.2 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, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. The information is required in order to provide our website in a permanent, 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.

8.3 Tracking pixels

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. Tracking pixels can be used to collect the same information as server log files.

8.4 Comments

We enable you to publish comments on our website. In this context, we process in particular the information that a commenting person transmits to us themselves, but also the Internet Protocol (IP) address used as well as the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which is in our overriding legitimate interest.

 

  1. Notifications and messages

We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.

9.1 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 can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage to measure success and reach in order to be able to send notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

9.2 Consent and objection

You must always expressly consent to the use of your e-mail address and your other contact addresses, unless such use is permitted for other legal reasons. Wherever possible, we use the “double opt-in” procedure to obtain consent, i.e. you will receive an e-mail with a web link that you must click on to confirm, so that no misuse by unauthorised third parties can occur. We may log such consents, including the Internet Protocol (IP) address and the date and time, for reasons of proof and security.

You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.

9.3 Service provider for notifications and messages

We send notifications and messages with the help of specialised service providers.

We use in particular:

Microsoft 365: Exchange system from Microsoft 365 provider:

Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.

The data is hosted in Switzerland.

You can view Microsoft’s privacy policy at Privacy with Microsoft Privacy Principles | Microsoft Trust Centre.

 

  1. Social media

We are present on social media platforms and other online platforms in order to communicate with interested parties 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).

We use Linkedin as social media. The privacy policy of linkedin.com can be found at: LinkedIn Privacy Policy.

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. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

 

  1. Services of third parties

We use services from specialised third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in 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 in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.

11.1 Digital infrastructure

We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

We use in particular:

Microsoft 365: One Drive and Share Point. Provider:

Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.

The data is hosted in Switzerland.

You can view Microsoft’s privacy policy at Privacy with Microsoft Privacy Principles | Microsoft Trust Centre.

We also use the services of Bexio AG for accounting purposes. You can find Bexio AG’s privacy policy at: The privacy policy of bexio.

11.2 Contact options

We use services from selected providers in order to be able to communicate better with third parties such as potential and existing customers.

11.3 Audio and video conferences

We use specialised audio and video conferencing services to communicate online. For example, we can 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, also apply.

Depending on your life situation, we recommend muting the microphone by default when taking part in audio or video conferences and blurring the background or displaying a virtual background.

We use in particular:

Microsoft 365, Teams. The data is hosted in Switzerland.

11.4 Digital audio and video content

We do not use the services of specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

 

  1. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

We use in particular:

Antispam Bee: Privacy-friendly, yet efficient and reliable spam protection (distinguishes between wanted comments from humans and unwanted comments from bots and spam); Developer: Pluginkollektiv (Germany and the rest of Europe): Pluginkollektiv (in Germany and the rest of Europe); Privacy Policy: Use on own server infrastructure and without cookies, Documentation (Pluginkollektiv), Documentation (GitHub).

 

  1. Final provisions

We may amend and supplement this privacy policy at any time. We will inform you of such amendments and additions in an appropriate form, in particular by publishing the current data protection declaration on our website.

References