All your data from application documents, contact data and other information (from here on called your data), which you send us via twincapfirst.ch or by mail or via a service, will be stored by us until revoked. We treat your data confidentially and do not pass it on to third parties, neither for advertising purposes nor for any other reason. We take careful precautions to ensure that your data cannot be accessed by unauthorized persons. If necessary, we use your contact address to inform you about news or to make new inquiries.
TABLE OF CONTENTS
- Objective and responsible body
- Basic information on data processing
- Processing of personal data
- Collection of access data
- Cookies & range measurement
- Google Analytics
- Google Re/Marketing Services
- Facebook Social Plugins
- Facebook Remarketing
- Integration of third-party services and content
- User rights and deletion
1. OBJECTIVE AND RESPONSIBLE BODY
The provider of the online offer and the entity responsible for data protection is TwinCap First AG, Favreweg 1, 8304 Walilsellen (hereinafter referred to as «provider», «we» or «us»). For contact options, please refer to our imprint. The term «user» includes all customers and visitors of our online offer or our software services. The terms used, such as «user» are to be understood as gender-neutral.
2. BASIC INFORMATION ON DATA PROCESSING
We process personal data of users only in compliance with the relevant data protection provisions in accordance with the principles of data economy and data avoidance. This means that the user’s data will only be processed if a legal permission exists, in particular if the data is necessary for the provision of our contractual services and online services, or is required by law, or if consent has been given.
We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
If content, tools or other means from other providers (hereinafter collectively referred to as «third party providers») are used within the scope of this data protection declaration and their named registered office is abroad, it is to be assumed that a transfer of data to the countries in which the third party providers are based takes place. The transfer of data to third countries takes place either on the basis of a legal permission, user consent or special contractual clauses that guarantee a legally required security of the data.
3. PROCESSING OF PERSONAL DATA
- Providing, executing, maintaining, optimizing and securing our services, service and user performance;
- The provision of effective customer service and technical support.
We transmit the users› data to third parties only if this is necessary for billing purposes (e.g. to a payment service provider) or for other purposes if these are necessary to fulfill our contractual obligations to the users (e.g. address communication to suppliers).
When contacting us (via contact form or email), the user’s details are stored for the purpose of processing the request and in case follow-up questions arise.
Personal data is deleted if it has fulfilled its intended purpose and there are no storage obligations that prevent its deletion.
4. COLLECTION OF ACCESS DATA
We collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
We use the log data without attribution to the person of the user or other profiling in accordance with legal requirements only for statistical analysis for the purpose of operation, security and optimization of our online offer. However, we reserve the right to check the log data retrospectively if there is a justified suspicion of unlawful use based on concrete indications.
5. COOKIES & REACH MEASUREMENT
The viewing of this online offer is also possible under exclusion of cookies. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
It is possible to manage many online ad cookies from companies through the US site or the EU site to manage.
6. GOOGLE ANALYTICS
Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the IP address of the user 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.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available under the following link:
You can find out more information about the use of data for advertising purposes by Google, and about setting and objection options on the Google website:
Polcies of partners Google
Technology Policies for Ads
Define your Google Ad settings
Define your Ad preferences
We may use the marketing and remarketing services (Google Marketing Services for short) of Google Ireland Ltd, Gordon House, 4 Barrow St,Dublin, D04 E5W5, Ireland, («Google»).
The Google Marketing Services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. For example, if users are shown ads for products in which they have expressed interest on other websites, this is referred to as «remarketing». For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as «web beacons») are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (similar technologies can be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offerings. This aforementioned information may also be combined with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
The user’s data is processed pseudonymously as part of Google’s marketing services. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data on a cookie basis within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by «DoubleClick» about users is transmitted to Google and stored on Google’s servers in the USA.
The Google marketing services we use include the online advertising program «Google AdWords». In the case of Google AdWords, each AdWords customer receives a different «conversion cookie». Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.
Another Google marketing service used by us is the «Google Tag Manager», with the help of which further Google analysis and marketing services can be integrated into our website (e.g. «AdWords», «DoubleClick» or «Google Analytics»).
If you wish to object to the collection by Google marketing services, you can use the settings and opt-out options provided by Google:
8. FACEBOOK SOCIAL PLUGINS
Our online offer may use social plugins («plugins») of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland («Facebook»). The plugins are recognizable by one of the Facebook logos (white «f» on blue tile, the terms «Like», «Like» or a «thumbs up» sign) or are marked with the addition «Facebook Social Plugin». The list and appearance of Facebook social Plug-Ins can be viewed here.
When a user calls up a function of this online offering that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the latter. In the process, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored with Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook Profile settings or via the US American Site oor the EU Site. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
9. FACEBOOK REMARKETING
Within our online offer, so-called «Facebook pixels» of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland («Facebook»), may be used. With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our offer as a target group for the display of advertisements, so-called «Facebook Ads». Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our Internet offer. This means that with the help of the Facebook pixel, we want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad.
The Facebook pixel is directly integrated by Facebook when our websites are called up and can save a so-called cookie, i.e. a small file, on your device. If you subsequently log in to Facebook or visit Facebook while logged in, the visit to our offer will be noted in your profile. The data collected about you is anonymous for us, so it does not offer us any conclusions about the identity of the user. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible. The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, you can find more information on how the remarketing pixel works and generally on the display of Facebook ads, in Facebook’s data usage policy.
You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions there regarding the settings for usage-based advertising: usage-based advertising or the opposition via the U.S. Site or the EU Site. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
Content of the newsletter: We may send newsletters, e-mails and other electronic notifications with promotional information (hereinafter «newsletter») only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain the following information: our products, offers, promotions and our company.
Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address.
The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, may be stored on the servers of the shipping service provider. The shipping service provider uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, the dispatch service provider may use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for economic purposes to determine from which countries the recipients come. However, the dispatch service provider does not use the data of our newsletter recipients to address them itself or to pass them on to third parties.
Registration data: To sign up for the newsletter, it is sufficient to provide your email address.
Statistical collection and analyses – The newsletters may contain a so-called «web beacon», i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. This will simultaneously terminate your consents to its dispatch by the dispatch service provider and the statistical analyses. A separate cancellation of the dispatch by the dispatch service provider or the statistical analysis is unfortunately not possible. You will find a link to cancel the newsletter at the end of each newsletter.
11. INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT
It may happen that content or services from third-party providers, such as city maps or fonts from other websites, are integrated within our online offer. The integration of content from third-party providers always requires that the third-party providers perceive the IP address of the user, since without the IP address they could not send the content to the user’s browser. The IP address is thus required for the display of this content. Furthermore, the providers of the third-party content can set their own cookies and process the users› data for their own purposes. In doing so, user profiles can be created from the processed data. We will use this content in a data-saving and data-avoiding manner as far as possible and select reliable third-party providers with regard to data security.
The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, in part already mentioned here, opt-out options:
12. USER RIGHTS AND DELETION OF DATA
Users have the right to receive, upon request and free of charge, information about the personal data that we have stored about them.
In addition, users have the right to correct inaccurate data, revoke consent, block and delete their personal data, as well as the right to file a complaint with the competent supervisory authority in the event that unlawful data processing is assumed.
The data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.
Users are requested to inform themselves regularly about the content of the data protection declaration.