1. Contact address
Responsibility for the processing of personal data:
Cross-Link GmbH
Bachgasse 33
6073 Flüeli-Ranft
We point out if there are other controllers for the processing of personal data in individual cases.
2. 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, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, arranging, organizing, storing, modifying, disseminating, linking, destroying and using 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, DAP) and the Ordinance on data protection (Data Protection Regulation, DPR).
3. Type, extent 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 the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymized 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, specialized 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 subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations or to protect overriding interests.
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 for legal reasons.
4. Personal data abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it or have it processed there.
We can transfer personal data to all States and teritories of the World and elsewhere in the Universe provided that the law of the country in question ensures adequate data protection according to Decision of the Swiss Federal Council.
We may disclose personal data to countries whose laws do not guarantee adequate data protection, provided that suitable data protection is guaranteed for other reasons. Appropriate data protection can be ensured, for example, by means of corresponding contractual agreements, 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 execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of guarantees.
5. Rights of data subjects
5.1 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.
- Cancellation and objection: Data subjects can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data output and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.
We may defer, 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 data subjects 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.
5.2 Right to complain
Data subjects have the right to enforce their data protection claims through legal channels 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).
6. Data security
We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication – like all digital communication in general – 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.
7. Use of the website
7.1 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 recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
Cookies can be completely 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.
For cookies that are used to measure success and reach or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
7.2 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, 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 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.
7.3 Tracking pixel
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. Notifications and messages
We send notifications and messages by e-mail and via other communication channels such as instant messaging or SMS.
8.1 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 personal 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.
8.2 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 unauthorized third parties can occur. We may log such consents, including the IP address, 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.w
9. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.
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 on the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
10. Third party services
We use services from specialized 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 IP addresses of 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, anonymized or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Data protection and security principles”, Privacy Policy, “Google is committed to complying with applicable data protection laws”, “Guide to data protection in Google products”, How we use data from websites or apps on or in which our services are used” (information from Google), Types of cookies and other technologies used by Google, Personalized advertising” (activation / deactivation / settings).
- Microsoft services: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection:Data protection at Microsoft, Data protection and privacy (Trust Center), Privacy Policy, Data protection dashboard (data and privacy settings).
10.1 Digital infrastructure
We use the services of specialized 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:
- Infomaniak: Hosting; Service provider: INFOMANIAK NETWORK SA (Switzerland); Privacy policy: Infomaniak and the protection of your personal data, Privacy Policy, Cookie Policy, Certifications and labels.
- METANET: Hosting; Service provider: METANET AG (Switzerland); Privacy policy: Privacy Policy, Technical and organizational measures.
- StackPath CDN: Content Delivery Network (CDN); Service provider: StackPath LLC (USA) / Highwinds Network Group Inc (USA); Privacy Policy: Privacy Policy.
10.2 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.
We use in particular:
- Freshworks: Customer relationship management (CRM) and customer service; Service provider: Freshworks Inc. (USA); Privacy Policy: Privacy Policy.
10.3 Audio and video conferences
We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating 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 and blurring the background or displaying a virtual background when participating in audio or video conferences.
We use in particular:
- Google Meet: Video conferencing; Service provider: Google; Google Meet-specific information: Google Meet – Security and data protection for users.
- Microsoft Teams: Platform for audio and video conferencing, among other things; Service provider: Microsoft; Teams-specific information: Data protection and Microsoft Teams.
- Skype: Audio and video conferencing; Skype-specific providers: Skype Communications SARL (Luxembourg) / Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; data protection information: Legal information about Skype, «Data protection and security».
- Zoom: Video conferencing; Service provider: Zoom Video Communications Inc. (USA); Privacy Policy: Privacy Policy, Data protection at Zoom, Legal Compliance Center.
10.4 Online collaboration
We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy policies, also apply.
We use in particular:
- Miro: Whiteboard platform; Service provider: RealtimeBoard Inc. (USA); Privacy Policy: Privacy Policy, Miro Trust Center.
- MURAL: Whiteboard platform; Service provider: Tactivos Inc. (USA); Privacy Policy: Privacy Policy, Security & Compliance.
- Notion: Platform for team collaboration; Service provider: Notion Labs Inc. (USA); Privacy Policy: Privacy Policy, Security & Privacy, Cookie Policy.
10.5 Map material
We use third-party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Service provider: Google; Google Maps-specific information: How Google uses location information.
10.6 Digital audio and video content
We use services from specialized third parties to enable the direct playback of digital audio and video content such as music or podcasts.
We use in particular:nd video content
- Vimeo: Video platform; Service provider: Vimeo Inc. (USA); Privacy Policy: Privacy Policy, Video Privacy.
- YouTube: Video platform; Service provider: Google; YouTube-specific information: Data protection and security center, My data on YouTube.
10.7 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Adobe Fonts: Fonts; Service provider: Adobe Inc. (USA) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Data protection information: Adobe Privacy Center, Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), Questions about data protection?, Adobe privacy settings.
11. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use
- Google reCAPTCHA: Spam protection (distinction between desired comments from humans and unwanted comments from bots and spam); Provider: Google; Google reCAPTCHA-specific information: What is reCAPTCHA?.
- jQuery (OpenJS Foundation):Free JavaScript library; Service provider: OpenJS Foundation (USA) with use of StackPath CDN; Privacy policy: Privacy Policy (OpenJS Foundation), Cookie Policy (OpenJS Foundation).
- jQuery (Google Hosted Libraries): Free JavaScript library; Service provider: Google; Google Hosted Libraries-specific information: What does using the Google Hosted Libraries mean for the privacy of my users?.
- Smush: Image optimization; Service provider: Incsub LLC (USA); Privacy policy: Privacy Policy.
12. Success and reach measurement
We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering are used (“A/B test” method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offering.
In most cases, the IP addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are generally shortened (“IP masking”) in order to comply with the principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service.
We use in particular:
- Google Analytics: Performance and reach measurement; Service provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (Cross-Device Tracking) and with pseudonymized IP addresses, which are only transmitted in full to Google in the USA in exceptional cases, Data protection, Browser add-on to deactivate Google Analytics.
- Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; Service provider: Google; Google Tag Manager-specific information: Data collected with Google Tag Manager; Further information on data protection can be found in the individual integrated and managed services.
13. 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.