Privacy Policy

The Summa Verwaltung AG (hereinafter “SV”) takes your privacy very seriously and adheres strictly to legal regulations. We are committed to your privacy and protecting the confidentiality of your data. The following statement gives an overview this protection and what kind of data is collected for what purpose.

Security and Protection of Your Personal Data

We consider it our primary task to maintain the confidentiality of the personal data you provide us and protect it from unauthorized access. That is why we take the greatest care and use the most up-to-date security standards to guarantee the maximal protection of your personal data.

As a private-law company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the regulations of the Swiss Federal Data Protection Act (Datenschutzgesetz DSG or DSG). We have taken technical and organizational measures to ensure that we and our external service providers respect the regulations regarding data protection.

Notice of Data Controller

The controller for the data processing of this website is

Summa Verwaltung AG
Sterenweg 7
6300 Zug, Switzerland
Telephone: +41 41 508 74 73
info@summaverwaltung.ch

“Controller” means the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data (for example, names, email addresses, or similar).

I. Definitions

We are required by law to process personal data lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”). To ensure that this is the case, we are providing you with information about the individual legal definitions that are also being used in this privacy policy:

  1. Personal Data

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Processing

“Processing” means every operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. Restriction of Processing

“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.

4. Profiling

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

5. Pseudonymization

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

6. Filing System

“Filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.

7. Controller

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

8. Processor

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

9. Recipient

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

10. Third Party

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

11. Consent

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

II. Lawfulness of Processing

Processing shall be lawful only if and to the extent that there is a legal basis for the processing. In accordance with point (a) of Article 6(1) GDPR, a legal basis for processing can be, specifically:

  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
  • 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;
  • processing is necessary for compliance with a legal obligation to which the controller is subject;
  • processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • 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, in particular where the data subject is a child.

1 Information About the Collection of Personal Data

(1) In the following, we provide information about the collection of personal data upon the use of our website. Personal data include all data that can be personally referenced to you such as name, address, email address, user behavior.

(2) Legally Mandated Data Protection Officer

We have appointed a Data Protection Officer for our company.

Summa Verwaltung AG
Data Protection Department
Sterenweg 7
6300 Zug, Switzerland
Telephone: +41 41 508 74 73
info@summaverwaltung.ch

(3) Upon contacting us via email or a contact form, we will store the data you share with us (your email address and, if applicable, your name and telephone number) in order to answer your question. We will delete the data collected in this context after the purpose is no longer necessary or will limit their processing if legal retention requirements apply. The processing of this data is necessary to process your request and any subsequent order. The data processing shall be carried out in accordance with Article 6 (1) (a) of the GDPR.

(4) If we make use of contracted providers to carry out individual features of our offering or would like to use your data for advertising purposes, we will inform you in detail about the respective activities below. This will include specifying the established criteria for determining how long we will store your data.

2 Your Rights

(1) You have the followings rights in relation to us regarding the personal data concerning you:

–     The right to access

–     The right to rectification or erasure

–     The right to restriction of processing

–     The right to object to processing

–     The right to data portability

(2) You additionally have the right to lodge a complaint with a supervisory authority for data protection about our processing of your personal data.

3 Collection of Personal Data During Visits to Our Website

(1) If you visit our website for purely informational purposes, meaning you do not register or provide other information to us, we collect only the personal data transmitted to our server by your browser. If you would like to view our website, we collect the following data which are technically necessary for us to display our website and to ensure its stability and security (legal basis is sentence 1 point [f] of Article 6[1] GDPR):

  • IP address
  • Date and time of request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Respective volume of data transferred
  • The website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of browser software

(2) In addition to the data named above, we store cookies on your computer when you use our website. Cookies are small text files that are stored on your hard drive and attributed to the browser you are using and that transmit certain information to the site that places the cookie (in this case, us). Cookies cannot run programs or infect your computer with viruses. They serve to make our Internet offering more user friendly and effective overall.

(3) The use of cookies:

a) This website uses the following types of cookies, the scope and functionality of which are explained in the following:

  • transient cookies (see b)
  • persistent cookies (see c)

b) Transient cookies are automatically deleted when you close your browser. They include, in particular, session cookies. Session cookies store a so-called session ID that allows different requests from your browser to be attributed to the same session. This makes it possible to recognize your browser if you return to our website. Session cookies are deleted when you log out or close your browser.

c) Persistent cookies are automatically deleted after a preset period of time, which can differ from cookie to cookie. You can delete the cookies at any time in the security settings of your browser.

d) You may configure your browser settings as you like to, for example, block third party cookies or all cookies. We advise you that you may not be able to use all features of this website if you block cookies.

e) We use cookies to be able to identify you on subsequent visits if you have an account with us. Otherwise, you must log in again each time you visit our website.

f) We use cookies to determine if you have come to our website from a specific partner retailer and to then make it easier for you to return to that retailer.

g) The Flash cookies that we use are not captured by your browser but rather by your Flash plugin. We also use HTML5 storage objects that are saved on your end device. These objects store the required data independently of the browser you are using and have no automatic expiry date. If you do not wish for any Flash cookies to be processed, you must install a corresponding add-on, for example, “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the “Adobe Flash Killer Cookie” for Google Chrome. You may prevent the use of HTML5 storage objects by selecting the private mode in your browser. We additionally recommend regularly deleting your cookies and browsing history manually.

(4) Use of Google Analytics:

a) This website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses so-called “cookies,” text files that are stored on your computer and make it possible to analyze your use of the website. The information generated by the cookie pertaining to your use of this website is usually transmitted to and saved on a server operated by Google that is located within the United States. If IP anonymization has been activated on this website, your IP address will nevertheless first be truncated within Member States of the European Union or in other contract states to the agreement on the European Economic Area. Only in exceptional cases is your complete IP address transmitted to a Google server in the United States, where it is then truncated. On behalf of the operator of this website, Google will use this information to analyze your use of this website, prepare reports about activities on the website and to provide further services to the website operator connected to the use of the website and of the Internet.

b) The IP address transmitted by your browser in the framework of Google Analytics will not be linked to other Google data.

c) You can prevent cookies from being saved to your device by using the corresponding setting in your browser software; we would like to explicitly state, however, that you may not be able to completely use all of this website’s features if you deactivate cookies. You may further prevent the data that is generated by the cookie and the data relating to your use of the website (including your IP address) from being collected or processed by Google by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout.

d) This website uses Google Analytics with the extension “_anonymizeIp.” This extension truncates IP addresses before they are further processed, preventing data from being linked to a specific person. Insofar as the data gathered from you can be linked to a specific person, this link is immediately removed and the personal data thus quickly deleted.

e) We use Google Analytics in order to analyze and regularly improve the use of our website. The statistics we gain help us to improve our offering and make it more interesting for you as a user. For cases of exception in which personal data is transmitted into the United States, Google has agreed to be subject to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is sentence 1 point (f) Article 6(1)  of the GDPR.

f) Information about the Third Party Provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User conditions: www.google.com/analytics/terms/de.html, Overview of data protection: www.google.com/intl/de/analytics/learn/privacy.html and Privacy policy: www.google.de/intl/de/policies/privacy.

g) You may also deactivate the use of Google Analytics for this browser on this website by clicking this link. This will save an opt-out cookie in your browser. If you delete the cookies in this browser, you must click the link again.

(5) Use of Google Tag Manager

a) We use Google Tag Manager to manage our advertising. The Tag Manager collects personal data on your end device and directly passes these on to other marketing providers connected to your end device, who process this data in accordance with this privacy policy. The TAG Manager does not itself thereby store or transmit these data. Depending on the circumstances, cookies may be set to ensure functionality. The TAG Manager is also responsible for your opt-out with individual marketing providers.

b) Information about the Third Party Provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Privacy Policy: www.google.de/intl/de/policies/privacy.

c) The legal basis for the use of Google Analytics is sentence 1 point (b) Article 6(1)   of the GDPR. The Tag Manager is necessary for this page to function.

(6) Integration of Google Maps

a) On this website, we use services provided by Google Maps. This allows us to display interactive maps directly in our website and makes it possible for you to easily use the map function.

b) Your visit to our website informs Google that you have accessed the corresponding subpage of our website. In addition, the data named in Section 3 of this Privacy Policy are also transmitted to the provider. This occurs independently of whether you have a user account with Google with which you are logged in, or you have no user account. If you are logged in with Google, your data is directly attributed to your account. If you do not want your data to be attributed to your Google profile, you must log out before activating the button. Google stores your data as user profiles and uses them for purposes of advertising, market research and/or to design the website according to the usability needs of individual users. Such an analysis is carried out in particular (even for users who are not logged in) in order to provide advertising according to users’ accessibility needs and to give other users of the social network information about your activities on our website. You have the right to object to the establishment of these user profiles, although you must contact Google to exercise this right.

c) You will find further information about the purpose and scope of the data collection and its processing by the plug-in provider in the Privacy Statements of the provider. In these statements, you will also find further information about your rights in this regard and settings options you may choose to protect your privacy: www.google.de/intl/de/policies/privacy. Google processes your personal data in the United States, among other locations, and has agreed to be subject to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

(7) Google Remarketing

a) We use the remarketing function of Google Inc. (“Google”). This function serves to present interest-related advertising to visitors to the website in the framework of the Google advertising network. The browser of the visitor to th website stores so-called “cookies,” text files that are stored on your computer and make it possible to recognize the visitor when the visitor accesses websites belonging to the advertising network of Google. On these pages, it is then possible to present advertisements to the visitor that relates to content the visitor previously accessed on websites that use Google’s remarketing function. According to information given by Google, Google does not collect any personal data in this process. Should you however not wish to allow the function “Remarketing by Google,” you may entirely deactivate it by changing the corresponding settings in Google at www.facebook.com/settings/ads. Alternately, you may deactivate the use of cookies for interest-related advertising via the Network Advertising Initiative by following the instructions at www.networkadvertising.org/managing/opt_out.asp.

b) You may also deactivate the use of Google Remarketing for this browser on this website by clicking this link . This will save an opt-out cookie in your browser. If you delete the cookies in this browser, you must click the link again.

c) Information about the Third Party Provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Privacy Policy: www.google.de/intl/de/policies/privacy.

d) The legal basis for the use of Google Remarketing is sentence 1 point (f) Article 6(1)   of the GDPR.

(8) Facebook Remarketing:

a) We use the remarketing function of Facebook Inc. (“Facebook”). This function serves to present interest-related advertising to visitors to the website in the framework of the Facebook advertising network. The browser of the visitor to th website stores so-called “cookies,” text files that are stored on your computer and make it possible to recognize the visitor when they access websites belonging to the advertising network of Facebook. On these pages, it is then possible to present advertisements to the visitor that relates to content the visitor previously accessed on websites that use Facebook’s remarketing function. According to information given by Facebook, Facebook does not collect any personal data in this process. Should you however not wish to allow the function “Remarketing by Facebook,” you may entirely deactivate it by changing the corresponding settings in Facebook at www.facebook.com/settings/ads. Alternately, you may deactivate the use of cookies for interest-related advertising via the Network Advertising Initiative by following the instructions at www.networkadvertising.org/managing/opt_out.asp.

b) You may also deactivate the use of Google Analytics for this browser on this website by clicking this link. This will save an opt-out cookie in your browser. If you delete the cookies in this browser, you must click the link again.

c) Information about the Third Party Provider: Facebook Ireland Ltd, 4 Grand Canal Square,  Dublin 2, Ireland. Settings: www.facebook.com/settings/ads

d) The legal basis for the use of Facebook Remarketing is sentence 1 point (f) Article 6(1)  of the GDPR.

use of Matelso in the browser you are using whilst on the website by clicking the relevant link. In this instance, an opt-out cookie is stored in your browser. If you delete your cookies in the same browser, you will need to click the link again.

(14) Utilization of Google Optimize:

1. This website utilizes Google Optimize, an analysis service provided by Google Inc. Optimize enables us to test new modifications to the website on a selection of users and thus contribute to the improvement of our offer.

2. Google Optimize utilizes cookies that make it possible to recognize users and display consistent versions of the website on return visits. The data are communicated to Google Analytics (see section on Google Analytics) and processed there for subsequent analysis. The reports themselves do not contain any personal data.

3. The data are communicated to Google Servers in the USA. The basis is Google Privacy Shield certification https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI

4. You can disable Google Optimize on this device and for this website by clicking on this link. You may have to repeat this action on other devices. You can prevent cookies from being saved to your device by using the corresponding setting in your browser software. Deactivating cookies may, however, prevent the use of several features of this (and other) websites.

5 Processor

Our service providers (processors) include agencies, printing companies, letter shops, call centers, logistics companies and data centers, as well as providers of advertising, IT and analysis. Our providers are prohibited from processing your data for any purpose other than that which we have agreed. We have concluded agreements with these providers regarding the processing of data on our behalf (Article 28 GDPR).

6 Objection to or Withdrawal of Consent for the Processing of Your Data

(1) If you have given consent for your data to be processed, you may withdraw that consent at any time. Such a withdrawal of consent affects the permissibility of processing your personal data after you have communicated it to us.

(2) To the extent that the processing of your personal data is supported by a balancing of interests, you may object to the processing of your data. This is the case where the processing is, in particular, not necessary for the performance of a contract with you, which we will indicate in each of the respective descriptions of functions. In making such an objection, we ask you to explain the reasons why we should not process your personal data the way we did. In the case you submit a reasoned objection, we will examine the facts and either stop processing/adjust how we process your data or present compelling legitimate grounds for why we may continue to process your data.

(3) Obviously you may object at any time to the processing of your personal data for purposes of advertising and data analysis. You may informs us about your objection via the following contact information:

Summa Verwaltung AG
Sterenweg 7
6300 Zug, Switzerland
Telephone: +41 41 508 74 73
info@summaverwaltung.ch

The Privacy Policy is based on the current legal basis and was prepared to the best of our knowledge. From time to time it is necessary to adjust the content of this notice regarding data protection to account for data collected in the future and, if applicable, for changes in law. We thus reserve the right to change this notice at any time. We will likewise publish the changed version of the data protection notice at this site. If you visit us again, you should therefore read the notice on data protection once more.