Private policy
1) Introduction and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about the handling of your personal data when using our website. Personal data are all data with which you can be personally identified.
1.2 The controller responsible for data processing on this website within the meaning of the Swiss Data Protection Act (DSG) is subtel GmbH, Mainzer Str. 3, 10247 Berlin, Germany, Tel.: 044 5830 881, Email: info@subtel.ch. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
2) Data Collection When Visiting Our Website
2.1 When using our website purely for informational purposes, i.e., if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you access our website, we collect the following data, which are technically necessary for us to display the website to you:
Our visited website
Date and time at the time of access
Amount of data sent in bytes
Source/reference from which you reached the page
Browser used
Operating system used
IP address used (if applicable: in anonymized form)
No disclosure or other use of the data takes place. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.
2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller). You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.
3) Hosting & Content Delivery Network
Cloudinary
We use a Content Delivery Network from the following provider: Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA
This service allows us to deliver large media files such as graphics, page content, or scripts more quickly via a network of regionally distributed servers. The processing is carried out to safeguard our legitimate interest in improving the stability and functionality of our website. We have concluded an order processing contract with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
For data transfer to the USA, the provider relies on standard contractual clauses of the Federal Data Protection and Information Commissioner (FDPIC), which are intended to ensure compliance with the Swiss data protection level.
4) Cookies
To make the visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files stored on your device. Some of the cookies we use are deleted after the browser session ends, i.e., after you close your browser (so-called session cookies). Other cookies remain on your device and allow us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). When cookies are set, they collect and process specific user information such as browser and location data as well as IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.
Partially, the cookies serve to simplify the ordering process by storing settings (e.g., remembering the contents of a virtual shopping cart for a later visit to the website).
We may work with advertising partners who help us make our internet offering more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). If we cooperate with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following paragraphs.
Please note that you can set your browser to inform you about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. Each browser differs in how it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:
Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/temporarily-allow-cookies-and-website-data-in-microsoft-edge-597f04f2-c0ce-f08c-7c2b-541086362bd2
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Chrome: https://support.google.com/chrome/answer/95647
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that if you do not accept cookies, the functionality of our website may be limited.
5) Contacting Us
When contacting us (e.g., via contact form or email), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. Your data will be deleted after the final processing of your inquiry. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided there are no statutory retention obligations to the contrary.
6) Data Processing When Opening a Customer Account and for Contract Execution
Personal data is collected and processed when you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to our address. We store and use the data you provide for contract processing. After deletion of your customer account, your data will be blocked with regard to tax and commercial retention periods and deleted after these periods have expired, unless we can demonstrate an overriding interest in further processing within the meaning of Art. 31 para. 2 DSG or a legal justification.
7) Use of Single Sign-On Procedures
Google Sign-In
On our website, you can register to create a customer account or register via the "Google Sign-In" service of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google") within the framework of the so-called Single Sign-On technology, if you have a Google profile. You can recognize the Google login function on our website by the button "Sign in with Google" or "Use your Google account".
When you call up a page of our website that contains a Google login function, your browser establishes a direct connection to Google's servers. The content of the login button is transmitted by Google directly to your browser and integrated into the page. Through this integration, Google receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Google profile or are not currently logged into Google.
This information (including your IP address) is transmitted by your browser directly to a Google server and stored there; this may also involve transmission to the servers of Google LLC. in the USA.
These data processing operations are carried out on the basis of Google's legitimate interest in the insertion of personalized advertising based on browsing behavior.
By using the Google login button on our website, you also have the option to log in or register on our website using your Google user data.
Only if you give your express consent before the login process on the basis of a corresponding notice about the exchange of data with Google, will we receive information from Google when using the Google button, depending on your personally set privacy settings at Google, the general and publicly accessible information stored in their profile. This information includes the user ID, name, profile picture, age, and gender.
We point out that after changes to Google's privacy conditions and terms of use, your profile pictures, the user IDs of your friends, and your friends list may also be transmitted if they have been marked as "public" in your privacy settings at Google. The data transmitted by Google will be stored and processed by us to create a user account with the necessary data (salutation, first name, last name, address data, country, email address, date of birth), if these have been released by you at Google. Conversely, data (e.g., information on your surfing or purchasing behavior) may be transferred from us to your Google profile on the basis of your consent.
The consent given can be revoked at any time by sending a message to the controller mentioned at the beginning of this privacy policy.
The purpose and scope of data collection and the further processing and use of the data by Google, as well as your rights in this regard and settings options for protecting your privacy, can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en&gl=en
You can view the terms of use for "Google Sign-In" here: https://policies.google.com/terms
If you do not want Google to associate the data collected via our website directly with your Google profile, you must log out of Google before visiting our website. You can also completely prevent the loading of Google plugins with add-ons for your browser, e.g., with "Adblock Plus" (https://adblockplus.org/en/).
For data transfer to the USA, the provider relies on standard contractual clauses of the Federal Data Protection and Information Commissioner (FDPIC), which are intended to ensure compliance with the Swiss data protection level.
8) Data Processing for Order Handling
8.1 The personal data collected by us will be passed on to the transport company commissioned with the delivery within the framework of contract processing, insofar as this is necessary for the delivery of the goods. Your payment data will be passed on to the credit institution commissioned with the payment processing, insofar as this is necessary for the payment processing. If special service providers are used for order processing, we will explicitly inform you about this below.
8.2 Passing on Personal Data to Shipping Service Providers
- Post CH
If the delivery of the goods is carried out by the transport service provider Post CH (Swiss Post Ltd, Switzerland, Wankdorfallee 4, 3030 Bern), we will pass on your email address to Post CH prior to the delivery of the goods for the purpose of coordinating a delivery date or for delivery notification, provided that you have given your express consent to this during the ordering process. Otherwise, we will only pass on the name of the recipient and the delivery address to Post CH for the purpose of delivery. The transfer takes place only insofar as it is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with Post CH or the transmission of status information of the shipment delivery is not possible.
The consent can be revoked at any time with effect for the future to the controller named above or to the transport service provider Post CH.
8.3 Use of Payment Service Providers (Payment Services)
- Adyen
One or more online payment methods from the following provider are available on this website: Adyen, Simon Carmiggeltstraat 6 - 50, 1011 DJ Amsterdam, Netherlands
If you choose a payment method from the provider where you make a payment in advance (e.g., credit card payment), your payment data communicated during the order process (including name, address, bank and card information, currency, and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 para. 1 lit. b GDPR. The transfer of your data takes place in this case exclusively for the purpose of payment processing with the provider and only insofar as it is necessary for this purpose.
- Apple Pay
If you choose the "Apple Pay" payment method of Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment processing is carried out via the "Apple Pay" function of your device running iOS, watchOS, or macOS by charging a payment card stored in "Apple Pay". Apple Pay uses security features integrated into your device's hardware and software to protect your transactions. To authorize a payment, it is therefore necessary to enter a code you have previously set and to verify it using the "Face ID" or "Touch ID" function of your device.
For the purpose of payment processing, the information provided during the ordering process, along with information about your order, is transmitted to Apple in encrypted form. Apple then re-encrypts this data with a developer-specific key before transmitting the data to the payment service provider of the payment card stored in Apple Pay to perform the payment. Encryption ensures that only the website through which the purchase was made can access the payment data. After the payment has been made, Apple sends your device account number and a transaction-specific dynamic security code to the originating website to confirm the success of the payment.
If personal data is processed in the described transmissions, the processing is carried out exclusively for the purpose of payment processing.
Apple retains anonymized transaction data, including the approximate purchase amount, the approximate date and time, and whether the transaction was successfully completed. Through anonymization, a personal reference is completely excluded. Apple uses the anonymized data to improve "Apple Pay" and other Apple products and services.
If you use Apple Pay on your iPhone or Apple Watch to complete a purchase made via Safari on your Mac, the Mac and the authorization device communicate via an encrypted channel on Apple's servers. Apple does not process or store any of this information in a format that can identify you personally. You can disable the ability to use Apple Pay on your Mac in your iPhone settings. Go to "Wallet & Apple Pay" and disable "Allow Payments on Mac".
Further information on data protection with Apple Pay can be found at the following internet address: https://support.apple.com/en-us/HT203027
- Google Pay
If you choose the "Google Pay" payment method of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), the payment processing is carried out via the "Google Pay" application of your mobile device running at least Android 4.4 ("KitKat") and equipped with an NFC function, by charging a payment card stored in Google Pay or a payment system verified there (e.g., PayPal). To authorize a payment over €25 via Google Pay, you must unlock your mobile device beforehand using the verification measure set up (e.g., facial recognition, password, fingerprint, or pattern).
For the purpose of payment processing, the information provided during the ordering process, along with information about your order, is transmitted to Google. Google then transmits your payment information stored in Google Pay in the form of a uniquely assigned transaction number to the originating website, which is used to verify a completed payment. This transaction number does not contain any information about your actual payment data stored in Google Pay but is created and transmitted as a one-time numerical token. For all transactions via Google Pay, Google acts only as an intermediary for processing the payment. The transaction is carried out exclusively in the relationship between the user and the originating website by debiting the payment method stored in Google Pay.
If personal data is processed in the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR.
Google reserves the right to collect, store, and evaluate certain transaction-specific information for each transaction made via Google Pay. This includes the date, time, and amount of the transaction, merchant location and description, a description provided by the merchant of the goods or services purchased, photos you have attached to the transaction, the names and email addresses of the seller and buyer or sender and recipient, the payment method used, your description of the reason for the transaction, and, if applicable, the offer associated with the transaction.
According to Google, this processing is carried out exclusively in accordance with Art. 6 para.1 lit. f GDPR on the basis of the legitimate interest in proper accounting, verification of transaction data, and optimization and maintenance of the functionality of the Google Pay service.
Google also reserves the right to combine the processed transaction data with other information collected and stored by Google when using other Google services.
The terms of use for Google Pay can be found here:
https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=googlepaytos&ldl=en
Further information on data protection with Google Pay can be found at the following internet address:
https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
- PayPal
When paying via PayPal, credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal, we pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"), within the framework of payment processing. The transfer takes place only insofar as it is necessary for the payment processing.
PayPal reserves the right to carry out a credit check for the payment methods credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency. The result of the credit check in relation to the statistical probability of default is used by PayPal for the purpose of deciding on the provision of the respective payment method. The credit check may contain probability values (so-called score values). Insofar as score values are included in the result of the credit check, they are based on a scientifically recognized mathematical-statistical procedure. Among other things, but not exclusively, address data is included in the calculation of the score values. Further data protection information, including information on the credit agencies used, can be found in PayPal's privacy policy: https://www.paypal.com/en/webapps/mpp/ua/privacy-full
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
- TWINT
If you choose a payment method of the payment service provider "TWINT", the payment processing is carried out via the payment service provider TWINT AG (Stauffacherstrasse 31, CH-8004 Zurich, hereinafter "TWINT"), to whom we pass on your information provided during the ordering process, along with information about your order (name, address, account number, bank code, possibly credit card number, invoice amount, currency, and transaction number). The transfer of your data takes place exclusively for the purpose of payment processing with the payment service provider TWINT and only insofar as it is necessary for this purpose.
9) Contacting for Review Reminder
Review Reminder by Trustpilot
If you have given us your express consent to do so during or after your order, we will transmit your email address to the review platform Trustpilot of Trustpilot A/S, Pilestræde 58, 1112 Copenhagen K, Denmark (www.trustpilot.com), so that they can send you a review reminder by email.
You can revoke your consent at any time by sending a message to us or to the review platform.
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
10) Use of Social Media: Videos
Use of YouTube Videos
This website uses the YouTube embedding function for displaying and playing videos from the provider "YouTube", which belongs to Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
The extended data protection mode is used here, which, according to the provider, only starts storing user information when the video(s) is/are played. When playback of embedded YouTube videos is started, the provider "YouTube" uses cookies to collect information about user behavior. According to "YouTube", these serve, among other things, to collect video statistics, improve user-friendliness, and prevent abusive behavior. If you are logged into Google, your data will be directly associated with your account when you click on a video. If you do not wish the association with your YouTube profile, you must log out before activating the button. Google stores your data (even for users not logged in) as usage profiles and evaluates them. You have a right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right. In the course of using YouTube, personal data may also be transmitted to the servers of Google LLC. in the USA.
Regardless of any playback of embedded videos, a connection to the Google network is established each time this website is called up, which can trigger further data processing operations without our influence.
Further information on data protection at "YouTube" can be found in the provider's privacy policy at: https://www.google.com/policies/privacy
For data transfer to the USA, the provider relies on standard contractual clauses of the Federal Data Protection and Information Commissioner (FDPIC), which are intended to ensure compliance with the Swiss data protection level.
11) Online Marketing
Use of Google Ads Conversion Tracking
This website uses the online advertising program "Google Ads" and, within the framework of Google Ads, conversion tracking from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). We use the offer of Google Ads to draw attention to our attractive offers with the help of advertising materials (so-called Google Adwords) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. We pursue the interest of showing you advertising that is of interest to you, making our website more interesting for you, and achieving a fair calculation of advertising costs.
The conversion tracking cookie is set when a user clicks on a Google Ads ad. Cookies are small text files stored on your computer system. These cookies generally lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot, therefore, be tracked across the websites of Google Ads customers. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. 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 information that personally identifies users. If you do not wish to participate in tracking, you can block this use by disabling the Google Conversion Tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics. In the course of using Google Ads, personal data may also be transmitted to the servers of Google LLC. in the USA.
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
For data transfer to the USA, the provider relies on standard contractual clauses of the Federal Data Protection and Information Commissioner (FDPIC), which are intended to ensure compliance with the Swiss data protection level.
You can find more information about Google's privacy policy at the following internet address: https://www.google.com/policies/privacy/
You can permanently disable cookies for advertising preferences by setting your browser software accordingly or by downloading and installing the browser plugin available at the following link:
https://www.google.com/settings/ads/plugin?hl=en
Please note that certain functions of this website may not be available or may be limited if you have disabled the use of cookies.
12) Web Analytics Services
12.1 Google Analytics 4
This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which enables an analysis of your use of our website.
By default, when visiting the website, Google Analytics 4 sets cookies that are small text snippets stored on your device and that collect certain information. This includes your IP address, which, however, is truncated by Google to exclude a direct personal reference.
The information is transmitted to Google's servers and further processed there. Transfers to Google LLC based in the USA are also possible.
Google uses the information collected on our behalf to evaluate your use of the website, compile reports on website activity for us, and provide other services related to website and internet usage. The IP address transmitted by your browser as part of Google Analytics and truncated is not merged with other Google data. The data collected as part of the use of Google Analytics 4 is stored for a period of two months and then deleted.
All the processing described above, in particular the setting of cookies on the device used, is carried out only if you have given us your express consent.
Without your consent, Google Analytics 4 will not be used during your site visit. You can revoke your consent at any time with effect for the future. To exercise your right of revocation, please deactivate this service via the "Cookie Consent Tool" provided on the website.
We have concluded a data processing agreement with Google, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
Further legal information on Google Analytics 4 can be found at https://policies.google.com/privacy?hl=en and at https://policies.google.com/technologies/partner-sites
Demographic Characteristics
Google Analytics 4 uses the special function "demographic characteristics" and can create statistics that contain statements about the age, gender, and interests of site visitors. This is done by analyzing advertising and information from third parties. This allows target groups for marketing activities to be identified. However, the collected data cannot be assigned to a specific person and will be deleted after a storage period of two months.
Google Signals
As an extension to Google Analytics 4, Google Signals can be used on this website to create cross-device reports. If you have activated personalized ads and linked your devices to your Google account, Google can, subject to your consent to the use of Google Analytics, analyze your usage behavior across devices and create database models, including cross-device conversions. We do not receive any personal data from Google, only statistics. If you want to stop cross-device analysis, you can deactivate the "Personalized Advertising" function in the settings of your Google account. Follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=en For more information on Google Signals, visit the following link: https://support.google.com/analytics/answer/7532985?hl=en
User IDs
As an extension to Google Analytics 4, the "User IDs" function can be used on this website. If you have consented to the use of Google Analytics 4, created an account on this website, and log in with this account on different devices, your activities, including conversions, can be analyzed across devices.
For data transfer to the USA, the provider relies on standard contractual clauses of the Federal Data Protection and Information Commissioner (FDPIC), which are intended to ensure compliance with the Swiss data protection level.
12.2 Hotjar (Hotjar Ltd.)
This website uses the web analytics service Hotjar from Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta).
With this tool, movements on the websites where Hotjar is used can be traced (so-called heatmaps). For example, you can see how far users scroll and which buttons they click and how often. The tool also makes it possible to collect feedback directly from website users. This provides us with valuable information to make our websites faster and more user-friendly. When using this tool, we pay special attention to the protection of your personal data. Thus, we can only track which buttons you click and how far you scroll. Areas of the websites where personal data about you or third parties are displayed are automatically hidden by Hotjar and are therefore never traceable.
Hotjar offers every user the option of using a "Do Not Track header" to prevent the use of the Hotjar tool, so that no data about the visit to the respective website is recorded. This is a setting that all common browsers support in current versions. To do this, your browser sends a request to Hotjar with the instruction to deactivate tracking of the respective user.
If you use our website with different browsers/computers, you must set up the "Do Not Track header" separately for each of these browsers/computers.
Detailed instructions with information about your browser can be found at: https://www.hotjar.com/opt-out
For more information about Hotjar Ltd. and the Hotjar tool, visit: https://www.hotjar.com
The privacy policy of Hotjar Ltd. can be found at: https://www.hotjar.com/privacy
We have concluded an order processing contract with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
13) Rights of the Data Subject
The applicable data protection law grants you the following data subject rights with respect to the controller regarding the processing of your personal data (rights of access and intervention), whereby reference is made to the legal basis cited for the respective exercise conditions:
Right of access according to Art. 25 DSG
Right to data delivery or transfer according to Art. 28 DSG
Right to rectification according to Art. 32 para. 1 DSG
14) Duration of Storage of Personal Data
The duration of the storage of personal data is determined based on the respective legal basis, the processing purpose, and—if relevant—additionally based on the respective statutory retention period (e.g., retention periods under the law of obligations).
When processing personal data based on explicit consent, the data concerned is stored until you revoke your consent.
If statutory retention periods exist for data, this data is stored for the statutory retention period.
Otherwise, personal data is processed as long as you do not expressly prohibit processing, unless we can demonstrate an overriding interest in further processing within the meaning of Art. 31 para. 2 DSG or a legal justification.