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Privacy Policy

With this Privacy Policy, we inform you about the nature, scope and purpose of the collection and use of personal data on our website goclark.ch.

For individual or additional offers and services, specific, supplementary or additional privacy policies as well as other legal documents such as General Terms and Conditions, Terms of Use or participation conditions may apply.

1. Data Controller

The controller responsible for data processing on this website and the contact for data protection matters is:

2media GmbH
Hagenholzstrasse 81A
8050 Zurich
Switzerland

Email: support@2media.ch

2. Processing of Personal Data

2.1 Definitions

Personal data refers to all information relating to an identified or identifiable natural person. A data subject is a person whose personal data is processed.

Processing includes any handling of personal data, regardless of the means and procedures used, in particular the collection, acquisition, storage, disclosure, use, modification, deletion or destruction 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 (FADP) and the Data Protection Ordinance (DPO).

2.3 Nature, Scope and Purpose of Data Processing

We process personal data that is necessary to provide our online offering on a continuous, user-friendly, secure and reliable basis. Such personal data may fall into the categories of master and contact data, content data, usage data and metadata, as well as contractual and payment data.

Personal data is processed only for as long as required for the respective purpose or as required by law. Personal data that is no longer required is anonymised or deleted.

As a rule, we process personal data only with the consent of the data subject, unless processing is permitted on other legal grounds, such as for the performance of a contract with the data subject, for pre-contractual measures, to safeguard our overriding legitimate interests, where the processing is evident from the circumstances, or after prior information has been provided.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us (e.g. by postal mail, email, contact form, social media or telephone) or when registering for a user account. Such information may be stored, for example, in an address book, a customer relationship management (CRM) system or comparable tools.

If you transmit personal data of third parties to us, you are obliged to ensure compliance with data protection requirements in relation to such third parties and to ensure the accuracy of such personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of providing our online offering, insofar and as long as such processing is legally permitted.

2.4 Data Security

We implement appropriate technical and organisational measures to ensure data protection and, in particular, data security. However, despite such measures, data processing on the internet may still involve security vulnerabilities. Therefore, we cannot guarantee absolute data security.

Access to our online offering is encrypted using transport encryption (SSL/TLS with HTTPS).

2.5 Processing of Personal Data by Third Parties

We may have personal data processed by third parties, in particular processors, or process personal data jointly with or with the assistance of third parties, or transfer personal data to third parties. Such third parties are, in particular, service providers whose services we use. We ensure an adequate level of data protection with respect to such third parties as well.

Such third parties are generally located in Switzerland or in the European Economic Area (EEA), including the European Union (EU), but may also be located in third countries, provided that their data protection laws ensure an adequate level of protection according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC), or where adequate protection is ensured by other means, such as contractual arrangements (in particular standard contractual clauses) or appropriate certification.

For third parties located in the United States of America (USA), certification under the Data Privacy Framework may ensure an adequate level of data protection. In exceptional cases, such third parties may be located in countries without an adequate level of data protection, provided that the applicable legal requirements are met, such as the explicit consent of the data subject.

2.5.1 Service Providers

Some processing of personal data may also be carried out by service providers engaged by us. In addition to the service providers explicitly mentioned in this Privacy Policy, these may include in particular data centres and cloud service providers hosting our website and databases, IT service providers (especially cloud, software and hosting providers), consulting firms, and other service providers to whom we outsource individual tasks.

Where we transfer personal data to such service providers, they process the data exclusively within the scope of the purposes and tasks specified by us and are subject to corresponding contractual data protection obligations.

3. Data Collection on This Website

Below, we explain how we collect and use information to provide you with a better user experience. The collected data helps us better understand your needs and interests and to tailor our content accordingly. We place great importance on protecting your privacy and inform you transparently about our data collection methods.

We use various third-party services on our website. Below we describe in detail which services are used, for what purpose, and which data is collected.

3.1 Log Files

For each access to our website, we may collect the following data if transmitted by your browser to our server infrastructure or 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 pages accessed, volume of data transferred, and the previously visited website (referrer).

Our website is hosted by WPEngine (50044 Lavaca St, Austin, TX 78701). For data collection and storage, we use web tools hosted via the Swiss service provider nine (Badenerstrasse 47, 8004 Zurich). This data is collected and stored in order to optimise processes and workflows, in particular in connection with the use of our website and the security and stability of the system.

We store such information, which may also constitute personal data, in log files. This data is required to ensure the continuous, user-friendly and reliable provision of our online offering and to ensure data security, in particular the protection of personal data, including with the assistance of third parties.

3.2 Newsletter

3.2.1 Newsletter Distribution and Reach Measurement

Your data is used in connection with any newsletter distribution. You may object to such contact at any time by sending an email to support@2media.ch.

Notifications and messages may contain links or tracking pixels that record whether a message has been opened and which links were clicked (performance measurement). Such links and tracking pixels may also record the use of notifications and messages. This statistical analysis, including performance and reach measurement, is necessary in order to provide notifications and messages effectively, user-friendly, and in a secure and reliable manner, based on the needs and reading habits of recipients.

3.2.2 Disclosure of Your Data

In addition, the data is used to enable contact by us or by third parties regarding similar offers or tax services, as well as advice and brokerage in connection with financial and insurance products. You may object to such contact at any time.

Third parties to whom we transfer your personal data include Clark Switzerland AG, Frikartstrasse 5, 4800 Zofingen, Switzerland.

3.3 Cookies and Similar Technologies

We use cookies and similar technologies (e.g. tracking pixels / web beacons) on our website. Cookies are small files stored on your device and saved by your browser. Cookies cannot execute programs or transmit malware such as trojans or viruses.

Tracking pixels, also referred to as web beacons, are small images retrieved when visiting our website. Tracking pixels can collect the same information as server log files.

Cookies may be stored in your browser temporarily (“session cookies”) or for a specified period (“persistent cookies”). Session cookies are automatically deleted when you close your browser. Persistent cookies enable, in particular, recognition of your browser on subsequent visits and may be used, for example, to measure the reach of our website. Persistent cookies may also be used for online marketing purposes.

You can disable or delete cookies at any time in your browser settings. Without cookies, our online offering may not be fully available.

For cookies used for performance and reach measurement or advertising purposes, many services offer a general opt-out via the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

3.3.1 Google

3.3.1.1 Google Analytics

We use Google Analytics to analyse how our website is used, including measuring the reach of our website and the success of third-party links to our website. Google Analytics is a service provided by Google LLC (USA); for users in the EEA and Switzerland, the responsible entity is Google Ireland Limited.

Google may attempt to recognise individual visitors even when they use different browsers or devices (cross-device tracking). Cookies are also used for this purpose. Google Analytics requires your IP address, which is not merged with other Google data.

Further information on the nature, scope and purpose of data processing can be found in Google’s privacy and security principles, Google’s privacy policy, the guide to data protection in Google products (including Google Analytics), information on how Google uses data from websites that use Google services, and Google’s information on cookies. You may also use the Google Analytics opt-out browser add-on and object to personalised advertising.

We use Google Tag Manager to integrate and manage analytics and advertising services from Google and third parties on our website. Google Tag Manager itself does not use cookies, although cookies may be used by the services integrated and managed through it. Information on the processing of personal data by such services is provided in this Privacy Policy.

3.3.1.2 Google Ads

We use Google Ads (formerly AdWords) to advertise our online offering on Google search and elsewhere on the internet, for example on other websites, including based on search queries. Google Ads is a service of Google LLC (USA); for users in the EEA and Switzerland, the responsible entity is Google Ireland Limited. Cookies are also used in connection with Google Ads. Google uses various domain names, including doubleclick.net, googleadservices.com and googlesyndication.com.

Through such advertising, we aim in particular to reach persons who are interested in our online offering or who already use it. For this purpose, we transmit corresponding data—potentially including personal data—to Google (remarketing). We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

Further information can be found in Google’s privacy and security principles, Google’s privacy policy, information on how Google uses data from websites that use Google services, and Google’s information on cookies. You may also object to personalised advertising.

3.3.2 Bing Ads

We use Bing Ads to advertise our online offering on the Bing search engine based on search queries. Bing Ads is a service provided by Microsoft Ireland Operations Limited (Ireland) or Microsoft Corporation (USA). Cookies are also used in connection with Bing Ads.

We aim in particular to reach persons who are interested in our online offering or who already use it. For this purpose, we transmit corresponding data—potentially including personal data—to Bing (remarketing). We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

Further information can be found in Microsoft’s privacy policy. You may also object to personalised advertising.

3.3.3 Facebook (Ads)

We use Facebook Ads to advertise our online offering on Facebook. Facebook Ads is a service provided by Facebook Ireland Ltd. (Ireland) or Facebook Inc. (USA). Cookies are also used in connection with Facebook Ads.

Through such advertising, we aim in particular to reach persons who are interested in our online offering or who already use it. For this purpose, we transmit corresponding data—potentially including personal data—particularly via the Facebook Pixel, to Facebook (custom audiences including lookalike audiences). We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

Further information on the nature, scope and purpose of data processing can be found in Facebook’s data policy. Facebook users can also influence which advertisements they see via their advertising preferences.

3.4 Other Third-Party Services

We may use additional third-party services to provide our online offering on a continuous, user-friendly, secure and reliable basis. Such services may also be used to embed content in our online offering. These services—such as hosting and storage services, video services or payment services—require your IP address in order to transmit their content.

Such services may be located outside Switzerland and the EEA, including the EU, provided that an adequate level of data protection is ensured.

For their own security-related, statistical and technical purposes, third-party services may process data relating to our online offering as well as data from other sources in aggregated, anonymised or pseudonymised form, including through the use of cookies, log files and tracking pixels. Such data is not used to directly identify data subjects in connection with our online offering.

4. Data Retention Period

Your personal data is stored only for as long as necessary for the respective purpose. Thereafter, it is routinely deleted, unless a statutory retention obligation applies (for example for the performance or initiation of a contract).

Our website contains links to third-party websites. We are not responsible for the content or data protection practices of external websites that can be accessed via such links. Please consult the respective privacy policies of those websites.

6. Social Media

We maintain presences on social media platforms and other online platforms in order to communicate with interested persons and provide information about our online offering. The terms and conditions, privacy policies and other provisions of the respective platform operators apply.

7. Your Rights

If we process your personal data, you have rights under Swiss data protection law. In particular, you have the right to obtain, free of charge, information about the personal data relating to you that is stored, its origin and the purpose of processing. Subject to the statutory requirements, you also have the right to rectification, deletion, restriction of processing, or to object to processing.

You may withdraw any consent you have given at any time with effect for the future by informal notice via email.

Please note that the above rights are subject to statutory limitations and may, in certain cases, impair or prevent the provision of our services.

You are entitled to enforce your rights through legal proceedings or to lodge a complaint with the competent data protection authority. In Switzerland, the competent authority is the Swiss Federal Data Protection and Information Commissioner (FDPIC).

8. Final Provisions

We may amend or supplement this Privacy Policy at any time. We will inform you of such changes by publishing the current version of the Privacy Policy on our website.