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Privacy Policy


With this Privacy Policy we explain what personal data we collect in connection with our activities and operations including our www.laemmle-chemicals.ch website. In particular, we explain for what purposes, how and where we process which personal data. We also provide information on the rights of individuals whose data we process.

Further privacy policies and other legal documents, such as General Terms and Conditions (GTC), Terms of Use or Terms and Conditions of Participation, may apply to specific or additional activities and operations.

We are subject to Swiss data protection law and, where 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 ensures an adequate level of data protection.


1. Contact details

Responsibility for the processing of personal data:

LAEMMLE Chemicals AG
Bläsimühle 2-6
CH-8322 Madetswil
Switzerland

info@laemmle-ag.ch

In individual cases, there may be other data controllers responsible for the processing of personal data, or joint responsibility with at least one other data controller.

1.1 Data Protection Officer or Data Protection Adviser

We have appointed the following Data Protection Officer or Data Protection Adviser as the point of contact for data subjects and authorities regarding enquiries relating to data protection:

Stephan Keller
Frauenmünsterstrasse 17
8022 Zurich

s.a.keller@keller-law.ch

1.2 Data Protection Representative in the European Economic Area (EEA)

We have appointed the following data protection representative in accordance with Article 27 of the GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

The Data Protection Representative serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.

2. Definitions and Legal Basis

2.1 Definitions

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

Processing covers any processing of personal data, regardless of the means and methods used, for example, the retrieval, comparison, modification, archiving, storage, reading, disclosure, collection, recording, collection, erasure, disclosure, classification, organization, storage, alteration, 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 handling 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, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).

We process personal data – insofar as the General Data Protection Regulation (GDPR) applies – in accordance with at least one of the following legal bases:

  • Article 6(1)(b) of the GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
  • Article 6(1)(f) of the GDPR for the necessary processing of personal data to safeguard our legitimate interests or those of third parties, provided that the fundamental freedoms and rights, as well as the interests, of the data subject do not take precedence. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner and to communicate about them; ensuring information security; protecting against misuse; enforcing our own legal claims; and complying with Swiss law.
  • Article 6(1)(c) of the GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under the applicable law of Member States within the European Economic Area (EEA).
  • Article 6(1)(e) of the GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Article 6(1)(a) of the GDPR for the processing of personal data with the consent of the data subject.
  • Article 6(1)(d) of the GDPR for the processing of personal data necessary to protect the vital interests of the data subject or of another natural person.

3. Nature, scope and purpose

We process the personal data necessary to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such personal data may include, in particular, the following categories: customer and contact details, browser and device data, content data, meta or ancillary data and usage data, location data, sales data, and contractual and payment data.

We process personal data for as long as is necessary for the respective purpose(s) or as required by law. Personal data that is no longer required for processing will be 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, specialist providers whose services we use. We also ensure data protection in relation to such third parties.

We only process personal data as a general rule with the consent of the data subjects. Where and to the extent that processing is permitted on other legal grounds, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to safeguard overriding interests.

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, provided that such processing is permitted for legal reasons.

4. Communication

We process personal data in order to communicate with third parties. In this context, we process, in particular, data provided by a data subject when making contact, for example by post or email. We may store such data in an address book or using similar tools.

Third parties who transfer data relating to other individuals are obliged to ensure data protection for those data subjects. This requires, amongst other things, that the accuracy of the personal data transferred be guaranteed.

We use selected services from suitable providers to enable us to communicate more effectively with third parties.

In particular, we use:

5. Job applications

We process personal data relating to job applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent performance of an employment contract. The personal data required is derived in particular from the information requested, for example in the context of a job advertisement. We may publish job vacancies with the assistance of suitable third parties, for example in electronic and print media or on job portals and recruitment platforms.

We also process 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 personal data relating to applicants – insofar as the General Data Protection Regulation (GDPR) applies – in particular in accordance with Article 9(2)(b) of the GDPR.

6. Data security

We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk. Through these measures, we ensure, in particular, the confidentiality, availability, traceability and integrity of the personal data processed, without, however, being able to guarantee absolute data security.

Access to our website and our other online presence is secured using transport encryption (SSL / TLS, in particular the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock icon in the address bar.

Our digital communications – like all digital communications in general – are subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence over the processing of personal data by intelligence services, police forces and other security authorities. Nor can we rule out the possibility that individual data subjects may be subject to targeted surveillance.

7. Personal data abroad

We process personal data generally in Switzerland and within the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it there or have it processed there.

We may transfer personal data to any country or territory on Earth or elsewhere in the universe, provided that the law in that jurisdiction ensures an adequate level of data protection in accordance with a decision by the Swiss Federal Council and – where and to the extent that the General Data Protection Regulation (GDPR) applies – in accordance with a decision by the European Commission.

We may transfer personal data to countries whose laws do not guarantee an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. We are happy to provide data subjects, upon request, with information about any such safeguards or to supply a copy of them.

8. Rights of data subjects

8.1 Data protection rights

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

  • Information: Data subjects may request information as to whether we process personal data relating to them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data being processed as such, but also, amongst other things, details of the purpose of processing, the retention period, any disclosure or export of data to other countries, and the origin of the personal data.
  • Rectification and restriction: Data subjects may have inaccurate personal data rectified, incomplete data completed and the processing of their data restricted.
  • Deletion and objection: Data subjects may request the erasure of personal data (‘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 data controller.

We may defer, restrict or refuse the exercise of data subjects’ rights within the limits permitted by law. We may inform data subjects of any conditions that must be met in order for them to exercise their data protection rights. For example, we may refuse to provide information, in whole or in part, on the grounds of trade secrets or the protection of other individuals. We may also, for example, refuse to erase personal data, in whole or in part, on the grounds of statutory retention obligations.

We may charge a fee in exceptional cases for the exercise of these rights. We will inform data subjects in advance of any such costs.

We are obliged to take reasonable measures to identify data subjects who request information or wish to exercise other rights. Data subjects are obliged to cooperate.

8.2 Legal protection

Data subjects have the right to enforce their data protection rights through legal proceedings or to lodge a report or complaint with a competent data protection supervisory authority.

The supervisory authority for data protection in relation to complaints by data subjects against private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities responsible for handling complaints from data subjects – where and to the extent that the General Data Protection Regulation (GDPR) applies – are organised as members of the European Data Protection Board (EDPB). In some Member States of the European Economic Area (EEA), the data protection supervisory authorities have a federal structure, particularly in Germany.

9. Use of the website

9.1 Cookies

We may use cookies. Cookies – both our own (first-party cookies) and those from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional text-based cookies.

Cookies may be stored temporarily in the browser as ‘session cookies’ or for a specific period as so-called permanent cookies. ‘Session cookies’ are automatically deleted when the browser is closed. Persistent cookies have a specific storage period. In particular, cookies enable us to recognise a browser the next time it visits our website and thereby, for example, measure the reach of our website. However, persistent cookies can also be used for online marketing, for example.

Cookies can be disabled in full or in part, or deleted, at any time via your browser settings. Without cookies, our website may no longer be available in its entirety. We actively seek your explicit consent to the use of cookies – at least where and to the extent necessary.

For cookies used to measure performance and reach, or for advertising, a general opt-out is available 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) possible.

9.2 Logging

For every visit to our website and our other online presence, we may log at least the following information, provided that this is transmitted to our digital infrastructure during such visits: 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-pages of our website accessed, including the volume of data transferred; and the last webpage accessed in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our online presence is available on a permanent, user-friendly and reliable basis. The information is also required to ensure data security – including through third parties or with the assistance of third parties.

9.3 Web beacons

We may incorporate tracking pixels into our website. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or JavaScript scripts that are automatically retrieved when you access our website. Tracking pixels can be used to collect at least the same information as is recorded in log files.

10. Notifications and communications

We send notifications and communications by email and via other communication channels, such as instant messaging.

10.1 Performance and Reach Measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual message has been opened and which web links were clicked on. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We require this statistical tracking of usage to measure effectiveness and reach, so that we can send notifications and communications in a way that is effective and user-friendly, as well as sustainable, secure and reliable, based on the needs and reading habits of the recipients.

10.2 Consent and objection

You must, in principle, consent to the use of your email address and other contact details, unless such use is permitted on other legal grounds. We may use the ‘double opt-in’ procedure to obtain double-confirmed consent where necessary. In this case, you will receive a message containing instructions for double confirmation. We may log the consent obtained, including the IP address and timestamp for evidential and security purposes.

You may, in principle, object at any time to receiving notifications and communications such as newsletters. By doing so, you may also object to the statistical tracking of your usage for the purposes of measuring performance and reach. This is without prejudice to any necessary notifications and communications relating to our activities and operations.

10.3 Service providers for notifications and communications

We send notifications and communications with the help of specialist service providers.

In particular, we use:

11. Social Media

We are active 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).

The General Terms and Conditions (GTC) and Terms of Use, as well as the privacy policies and other provisions of the individual operators of such platforms, also apply in each case. These provisions provide information, in particular, on the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

For our social media presence on Facebook, including so-called Page Insights, we are jointly responsible – insofar as the General Data Protection Regulation (GDPR) applies – with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta group of companies (including those in the USA). Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to ensure that our social media presence on Facebook is effective and user-friendly.

Further information on the nature, scope and purpose of data processing, details of the rights of data subjects, and the contact details of Facebook and Facebook’s Data Protection Officer can be found in Facebook’s privacy policy. We have entered into the so-called “Addendum for Controllers” with Facebook and have thereby agreed, in particular, that Facebook is responsible for ensuring the rights of data subjects. For what are known as Page Insights, the relevant information can be found on the ‘Information on Page Insights’ page, including ‘Information on Page Insights Data’.

12. Third-party services

We use services provided by specialist third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. These services enable us, amongst other things, to embed functions and content into our website. When such embedding takes place, the services used collect users’ IP addresses at least temporarily, for technically necessary reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data relating to our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data required to provide the relevant service.

In particular, we use:

12.1 Digital infrastructure

We use services provided by specialist third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

12.2 Audio and video conferences

We use specialised audio and video conferencing services to enable online communication. This enables us, for example, to hold virtual meetings or conduct online lessons and webinars. Participation in audio and video conferences is also subject to the legal terms and conditions of the individual services, such as privacy policies and terms of use.

Depending on your circumstances, we recommend that you mute your microphone by default when taking part in audio or video conferences, and either blur your background or display a virtual background.

12.3 Online collaboration

We use third-party services to facilitate online collaboration. In addition to this privacy policy, any terms and conditions of the services used that are directly visible – such as terms of use or privacy policies – shall also apply.

In particular, we use:

12.4 Map data

We use third-party services to embed maps on our website.

In particular, we use:

12.5 Digital audio and video content

We use services provided by specialist third parties to enable the direct playback of digital audio and video content, such as music or podcasts.

In particular, we use:

12.6 Fonts

We use third-party services to embed selected fonts, icons, logos and symbols into our website.

In particular, we use:

12.7 E-commerce

We operate an e-commerce business and use third-party services to successfully offer services, content or goods.

In particular, we use:

  • Shopware: Open-commerce platform; provider: shopware AG (Germany); information on data protection: Privacy Policy.

12.8 Payments

We use specialist service providers to process our customers’ payments securely and reliably. The legal documents of the individual service providers, such as their General Terms and Conditions (GTC) or privacy policies, also apply to the processing of payments.

In particular, we use:

13. Website extensions

We use extensions on our website to enable additional functions. We may use selected services from suitable providers or run such extensions on our own server infrastructure.

In particular, we use:

  • Google reCAPTCHA: Spam protection (distinguishing between desired content from humans and undesired content from bots and spam); Provider: Google; Google reCAPTCHA-specific information: “What is reCAPTCHA?”.

14. Performance and Reach Measurement

We seek to analyse how our online services are used. In this context, we may, for example, measure the success and reach of our activities and operations, as well as the impact of third-party links on our website. However, we may also, for example, test and compare how different parts or versions of our online offering are used (the ‘A/B testing’ method). Based on the results of these success and reach measurements, we can, in particular, rectify errors, enhance 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. IP addresses are in this case always truncated (‘IP masking’) in order to comply with the principle of data minimisation through appropriate pseudonymisation.

Cookies may be used to measure performance and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, details of the size of the screen or browser window, and the user’s location (at least approximately). In principle, any user profiles created are exclusively pseudonymised and are not used to identify individual users. Certain third-party services with which users are registered may, where applicable, link the use of our online service to the user’s account or profile with the respective service.

In particular, we use:

15. Final provisions

We have created this privacy policy using the privacy policy generator from Datenschutzpartner.

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and additions in an appropriate manner, in particular by publishing the current version of the privacy policy on our website.

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