Privacy Policy

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the provision of our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as "online offer").

The terms used are not gender-specific.

Date: July 29, 2021

Table of Contents

Responsible

Manfred Jurgovsky
Waidstrasse 21
CH 8037 Zürich

Email address: jurgovsky@minima.media.

Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g., names, addresses).
  • Content data (e.g., entries in online forms).
  • Contact data (e.g., email, telephone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g., websites visited, interest in content, access times).

Categories of data subjects

  • Communication partners.
  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Provision of our online offer and user-friendliness.
  • Content Delivery Network (CDN).
  • Direct marketing (e.g., by email or postal).
  • Contact inquiries and communication.
  • Profiles with user-related information (creating user profiles).
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Provision of contractual services and customer service.

Relevant legal bases

In the following, we provide an overview of the legal bases of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence may apply. If, in individual cases, more specific legal bases are relevant, we will inform you about them in the privacy policy.

  • Consent (Article 6 (1) a. GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Contract performance and pre-contractual inquiries (Article 6 (1) b. GDPR) - The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Article 6 (1) f. GDPR) - The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Switzerland: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Switzerland. This includes in particular the Federal Act on Data Protection (FADP). The FADP applies in particular if no EU/EEA citizens are affected and for example, only data of Swiss citizens are processed.

Security measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

Among the measures are in particular the securing of the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, deletion of data, and reaction to data compromise. Moreover, we consider the protection of personal data already in the development or selection of hardware, software, and processes, according to the principle of privacy by design and privacy by default.

Transmission of personal data

As part of our processing of personal data, it may happen that the data is transferred to other entities, companies, legally independent organizational units, or persons, or that it is disclosed to them. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content that are embedded in a website. In such case, we comply with legal requirements and conclude in particular corresponding contracts or agreements, which serve the protection of your data, with the recipients of your data.

Processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons, entities, or companies, this only occurs in accordance with legal requirements.

Subject to express consent or transfer required by contract or law, we process or let the data be processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Deletion of data

The data processed by us is deleted in accordance with legal requirements as soon as the consents allowed for processing are revoked or other permissions no longer apply (e.g., if the purpose of processing this data no longer applies or if it is not necessary for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.

Use of cookies

Cookies are text files that contain data from visited websites or domains and are saved by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his or her visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart, or the location where a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs")

The following types and functions of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly if the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g., to save logins or other user inputs or for reasons of security).
  • Statistics, marketing, and personalization cookies: Furthermore, cookies are generally also used in the context of reach measurement as well as when a user's interests or behavior (e.g., viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles serve to display to users e.g., content that corresponds to their potential interests. This procedure is also referred to as "tracking", i.e., following the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies are processed on the basis of our legitimate interests (e.g., in a business operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

Storage duration: Unless we provide you with explicit information about the storage duration of permanent cookies (e.g., as part of a cookie consent), please assume that the storage duration can be up to two years.

General information on withdrawal and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively referred to as "Opt-Out"). You can initially declare your objection via the settings of your browser, e.g., by disabling the use of cookies (which may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices within the scope of the information on the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure, within the framework of which the consents of the users to the use of cookies, or the procedures and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by the users. The declaration of consent is stored in order not to have to repeat the query of consents and to be able to prove the consent according to the legal obligation. The storage can take place server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user, or his device. Subject to individual information on the providers of cookie management services, the following applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is then formed and stored with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and used device.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), Meta-/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Consent (Article 6 (1) a. GDPR), Legitimate interests (Article 6 (1) f. GDPR).

Provision of the online offer and web hosting

To be able to provide our online offer safely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security services and technical maintenance services.

The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer collected during use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders as well as further information concerning the email sending (e.g., the participating providers) as well as the contents of the respective emails are processed. These data may also be processed for the purpose of detecting SPAM. We kindly ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore assume any responsibility for the transmission path of the emails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files can include the address and name of the retrieved websites and files, the date and time of the retrieval, transferred data volumes, notification of successful retrieval, browser type plus version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can, on the one hand, be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.

Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service with the help of which contents of our online offer, especially large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed and connected servers via the Internet.

Cloudflare:

  • Types of data processed: Content data (e.g., entries in online forms), Usage data (e.g., websites visited, interest in content, access times), Meta-/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, Content Delivery Network (CDN).
  • Legal bases: Legitimate interests (Article 6 (1) f. GDPR).

Contact and request management

When contacting us (e.g., via contact form, email, telephone, or social media), the information provided by the person making the request is processed to the extent necessary to answer the contact inquiries and any requested measures.

The response to the contact inquiries within the framework of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in responding to the inquiries.

  • Types of data processed: Inventory data (e.g., names, addresses), Contact data (e.g., email, telephone numbers), Content data (e.g., entries in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact inquiries and communication.
  • Legal bases: Contract performance and pre-contractual inquiries (Article 6 (1) b. GDPR), Legitimate interests (Article 6 (1) f. GDPR).

Web analysis, monitoring, and optimization

Web analysis (also referred to as "reach measurement") is used to evaluate the visitor traffic of our online offer and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognize at what time our online offer or its functions or contents are most frequently used or invite for reuse. Likewise, we can understand which areas need optimization.

In addition to web analysis, we can also use testing procedures, for example, to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, viewed content, visited websites, and there used elements and technical information, such as the browser used, the computer system used as well as information on usage times. If users have consented to the collection of their location data, depending on the provider, these can also be processed.

The IP addresses of the users are also stored. However, we use IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing, and optimization, no clear data of the users (such as email addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis of the processing is consent. Otherwise, the users' data are processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), Meta-/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors), Profiles with user-related information (creating user profiles).
  • Security measures: IP masking (Pseudonymization of the IP address).
  • Legal bases: Consent (Article 6 (1) a. GDPR), Legitimate interests (Article 6 (1) f. GDPR).

Services used and service providers:

  • Matomo: The information generated by the cookie about your use of this website is stored only on our server and not shared with third parties; Service provider: Web analysis/reach measurement in self-hosting; Website: https://matomo.org/; Deletion of data: The cookies have a maximum storage duration of 13 months.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). This can include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").

The integration always presupposes that the third-party providers of this content process the IP address of the users since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We strive to use only the content whose respective providers use the IP address only for the delivery of the content. Third-party providers can also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offer, as well as be linked to such information from other sources.

Notes on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis of the processing of data is consent. Otherwise, the users' data are processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times), Meta-/communication data (e.g., device information, IP addresses), Inventory data (e.g., names, addresses), Contact data (e.g., email, telephone numbers), Content data (e.g., entries in online forms).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, Contract performance and customer service, Profiles with user-related information (creating user profiles).
  • Legal bases: Legitimate interests (Article 6 (1) f. GDPR), Consent (Article 6 (1) a. GDPR), Contract performance and pre-contractual inquiries (Article 6 (1) b. GDPR).

Services used and service providers:

  • Font Awesome: Display of fonts and symbols; Service provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy policy: https://fontawesome.com/privacy.
  • Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, where the data of the users are used solely for the purpose of the display of the fonts in the users' browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform display, and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-Out possibility (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video content; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Opt-Out possibility (Opt-Out): We point out that Vimeo can use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google-Analytics (https://tools.google.com/dlpage/gaoptout?hl=en) or Google's settings for data use for marketing purposes (https://adssettings.google.com/).

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adjust the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require action on your part (e.g., consent) or another individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6 (1) e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct marketing.
  • Right to withdraw consents: You have the right to withdraw consents at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to request the completion of the data concerning you or the correction of the incorrect data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be erased immediately, or alternatively, to demand a restriction of the processing of the data in accordance with legal requirements.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common, and machine-readable format in accordance with legal requirements, or to request its transfer to another controller.
  • Complaint to the supervisory authority: You also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended mainly for comprehension.

  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with the help of which contents of our online offer, especially large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed and connected servers via the Internet.
  • IP masking: "IP masking" is a method in which the last octet, i.e., the last two numbers of an IP address, are deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • Personal data: "Personal data" are all information that relates to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more special features, which are an expression of the physical, physiological, genetic, psychological, economic, cultural, or social identity of this natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any form of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information regarding age, gender, location and movement data, interaction with websites and their content, etc.) for purposes such as analyzing or predicting preferences, interests, behavior, location, or movement. Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, website owners can recognize, for example, at what time visitors visit their website and what content they are interested in. This allows them to optimize the content of the website for the needs of their visitors. For reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Responsible: The "responsible" is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
  • Processing: "Processing" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, whether it be collecting, evaluating, storing, transmitting, or deleting.

Created with free Datenschutz-Generator.de by Dr. Thomas Schwenke