Last updated: July 2022Privacy Statement
This Privacy Statement explains how we handle your personal data, i.e. what we do with your data, and how and why we do it. It applies to all users of our websites, portals, mobile applications and social media platforms (hereinafter also “digital offerings”). TX Group Ltd maintains a range of data offerings for the benefit of the group companies of the TX Group and other affiliated companies (hereinafter “TX data offerings”).
1. What is this Privacy Statement about?
When our digital offerings are utilised, personal data are also processed in connection with the TX data offerings. Please refer to the Privacy Notice regarding the TX Data Offerings.
This Privacy Statement provides you with information particularly regarding:
the personal data we collect and process;
the purposes for which we use your personal data;
who has access to your personal data;
how you benefit from our data processing;
how long we process your personal data;
the rights you have in relation to your personal data; and
how you can contact us.
The processing of personal data is complex, particularly if companies such as us collaborate based on the division of labour in the digital sector. Our goal is to explain as easily as possible in this Privacy Statement what we do with your data and how and why we do it. Nevertheless, if you have any further questions about our data processing, please do not hesitate to contact us (Section 14).
Incidentally, we have aligned the content of this Privacy Statement not only with the Swiss Data Protection Act (FADP), but also with the European General Data Protection Regulation (GDPR), which sets standards for strong data protection worldwide. However, whether and to what extent the GDPR is applicable will depend on the individual case.
2. Who is responsible for the data processing?
For every data processing operation, there is a “controller”, i.e. a company that is primarily responsible for compliance with data protection law in the event of processing. In each instance, it is the company that determines that processing takes place at all, what purposes it serves and how it is structured. Several companies may also be jointly responsible for processing. Most companies indicate on their websites the processing for which they are responsible.
As a general rule, one of the following companies (“we” or “us”) is responsible under data protection law for data processing in accordance with this Privacy Statement. Normally, this is the company that has referred you to this Privacy Statement on its website, in an app, in contractual provisions or elsewhere:
Berner Oberland Medien AG BOM
Tamedia Basler Zeitung AG
Tamedia Espace Ltd
Tamedia Publications Deutschschweiz AG
Tamedia Publications romandes SA
Tamedia Verlag Finanz und Wirtschaft AG
Tamedia ZRZ AG
TX Group Ltd (with its offerings, 20minuten.ch and lematin.ch)
Please note that any third-party offerings that can be reached through our digital offerings are not subject to this Privacy Statement. We assume no responsibility and shall not be held liable for third-party websites’ compliance with data protection law. We also advise you to consult the privacy statements of those third-party websites.
3. What personal data do we process?
As "personal data", the Act covers all information relating to a specific person or which can be associated with a specific person. Below you will find information on the most important categories of personal data that we process. You will find out more about the origin of this data in Section 4 and in Section 5 regarding the purposes for which we process this data.
However, we may also have or wish to process additional personal data depending on the individual case. We will always inform you accordingly, e.g. in declarations of consent or in further privacy statements, if this is required by law. You will also find additional details in the information on cookies and similar technologies.
3.1. Master data
Master data is basic data, e.g. your name, contact details or date of birth. We collect master data particularly when you register for a digital offering, e.g. because you wish to use personalised services, visit restricted areas or manage subscriptions. However, we also collect master data if you enter into a contract with us, participate in a contest or sweepstakes or sign up for a newsletter. Certain information is frequently marked or technically designed as mandatory, but you may often voluntarily enter further personal data in addition to this information.
Depending on the case, the master data includes e.g.
first and last name;
address, e-mail address, telephone number and other contact details;
date of birth and gender;
education, occupation;
username and profile picture;
details about the use of digital offerings and subscriptions;
information on linked websites, social media profiles, etc.;
information on preferences and interests, language preferences, etc.;
settings concerning the receipt of advertising, subscribed newsletters, etc.;
Information about your status with us (inactivity or blocking of a user account, etc.);
details regarding your participation in contests and sweepstakes;
date and time of registrations.
Under certain circumstances, you may use the login of a third-party provider (e.g. Apple, Google or Facebook) to log in to individual digital offerings. In this case, we will receive access to certain data stored with the relevant provider, e.g. your username, profile picture, date of birth, gender and other information. Normally, information about the data provided to us can be found directly during the login process and also in the privacy statement of the relevant provider.
3.2. Contract data
Contract data is personal data that arises in connection with the conclusion or implementation of a contract (e.g. when concluding an online subscription). This includes e.g. information on the conclusion of the contract, on contractual services, on claims and receivables or on customer satisfaction.
Depending on the circumstances, the contract data may include, e.g. information
regarding the initiation and conclusion of contracts, e.g. information about the subscription in question (e.g. type and duration);
regarding the processing and management of contracts, e.g. contact details and means of payment information, although in the case of online payment options such as credit card or PayPal, payment is made directly via the online payment system of the respective provider, and we do not collect or store your payment data (please always consult the privacy policy of the respective provider of the online payment system);
on the current contracts we have concluded with you;
in relation to customer service and technical support;
regarding defects and complaints;
about customer satisfaction that we may collect through surveys;
on financial matters, such as determining creditworthiness (i.e. information that allows us to infer the likelihood of receivables being settled), reminders, collection and enforcement of receivables.
3.3. Communication data
If we are in contact with you, e.g. if you contact our customer service department, we process the exchanged communication content and details about the type, time and place of communication. In certain situations, we may also ask you to provide proof of your identity for identification purposes, e.g. if you exercise your rights as a data subject (Section 13).
If you make posts via our digital offerings (comments, photos, videos, etc.) and share them with other users, we may publish your username and these posts and, depending on their functionality, we may also make them available to the general public. Such data may remain available if it is published on the Internet even if we have deleted this information and content from our systems.
Depending on the circumstances, communication data may include e.g.
name and contact details, e.g. postal address, e-mail address and telephone number;
content of emails, written correspondence, chat messages, social media posts, comments on a website, telephone conversations, etc.;
information you have posted on our digital offerings;
responding to customer and satisfaction surveys;
information on the type, time and, where applicable, place of communication;
proof of identity, such as copies of official identity documents;
communication metadata.
Telephone conversations with us may be recorded for educational and training purposes; however, we will inform you of this at the beginning of every conversation. If you do not want us to record such conversations, you can always cancel the conversation and contact us in another way (e.g. via email).
1.1. Behavioural and transaction data
If you use our digital offerings or receive newsletters, we collect data about the relevant use and generally about your interaction with our digital offerings. Further information can be found in the Privacy Notice regarding the TX Data Offerings.
Depending on the circumstances, behavioural and transaction data includes e.g. the following information, insofar as it is available to us in relation to a person:
regarding your behaviour on websites;
regarding the installation and use of mobile apps;
about your participation in contests, sweepstakes and similar events;
about your use of electronic messages (e.g. whether and when you opened an email or clicked on a link).
If you have a user account, behavioural and transaction data may also be assigned to your profile if you are not logged when you use the digital offering.
3.5. Preference data
We want to best orient the content and presentation of our digital offerings and the advertising on them to our customers. We therefore also process data concerning your interests and preferences. For this purpose, we may e.g. analyse behavioural and transaction data on a personal and non-personal basis, including in conjunction with other data. This enables us to draw conclusions about characteristics, preferences and expected behaviour, e.g. which media and advertising content are of particular interest to you. Further information on profiling in this regard can be found in Section 9. Further information can also be found in the Privacy Notice regarding the TX Data Offerings.
We may analyse behavioural and transaction data and may also combine it with other information for evaluation purposes, e.g. master data, contract data, technical data and non-personal statistical data, in order to derive information about your characteristics, preferences and expected behaviour. Preference data may be used on a personal basis, e.g. to display media and advertising content tailored to you, but also on a non-personal basis (e.g. for market research or product development).
3.6. Technical data
When you use our digital offerings, we collect certain technical data, such as your IP address or a device ID. Technical data also includes the logs in which we record the use of our systems (log data). We may also assign a unique identification number to your end device (tablet, PC, smartphone, etc.), e.g. by using cookies and similar technologies, so that we can recognise your device at a later date. You can find further details in our information on cookies and similar technologies.
We may also collect behavioural data based on technical data (see Section 3.4). However, as a rule, we cannot infer who you are from technical data unless you have registered with us. In this case, we may combine technical data with master data – and thus with you personally.
Depending on the circumstances, technical data may include, e.g.
the IP address of your device and other device IDs (e.g. MAC address);
Identification numbers assigned to your device by cookies and similar technologies (e.g. pixel tags);
Information about your device and its configuration, e.g. operating system or language settings;
Information about the browser you use to access the offering and its configuration;
information about your movements and activity on our websites and in our apps;
information about your internet provider;
your approximate location and the time of use;
system-generated records of accesses and other processes, e.g. which digital offerings were called up from us, reference/exit pages, the time and duration of the visit (log data).
4. Where does the personal data come from?
We often receive personal data directly from you, e.g. when you transmit data to us or communicate with us. Most of all, we receive master data, contract data and communication data from you.
For example, you provide us with personal data in the following cases:
you register for one of our digital offerings;
you participate in a sweepstakes or contest;
you contact our customer service department;
The provision of personal data is generally voluntary, i.e. you are usually not obligated to disclose personal data to us. However, we must collect and process personal data that is necessary or prescribed by law for the performance of a contractual relationship and for the fulfilment of associated obligations, e.g. mandatory master and contract data. Without such data, we will not be able to conclude or continue the contract or subscription.
If you provide us with data about other persons, we assume you have the right to do so and that the data is correct. Please also ensure that these other persons have been informed of this Privacy Statement.
We may also collect personal data about you directly or automatically. In many cases, this is behavioural and transaction data, (see Section 3.4) as well as technical data (see Section 3.6).
For example, we collect personal data about you in the following cases:
you visit one of our websites or use one of our apps;
you click on a link in one of our newsletters or otherwise interact with one of our electronic marketing communications.
However, we may also derive personal data from existing personal data, e.g. by evaluating behavioural and transaction data. Such derived personal data is often preference data.
We may, for example, analyse behaviour and transaction data and make assumptions on this basis about your personal interests, preferences, likes and habits. This enables us, for example, to tailor our offers and information to your individual needs and interests. So, for example, instead of just showing you just any advertising on our website, we may show you advertising that might actually be of interest to you. You will find further information on behavioural and transaction data in Section 3.4 and on profiling in this regard in Section 9.
We may also receive personal data from other companies of the TX Group. You will find further information in this regard in Section 7. However, we may also receive information about you from other third parties, e.g. companies with which we work, people who communicate with us, or public sources.
We may, for example, receive information about you from the following third parties:
from credit reporting agencies, e.g. when we obtain credit information;
from banks, insurance companies, distribution partners and other contractual partners in relation to payments;
providers of online services, e.g. providers of internet analysis services;
authorities, parties and other third parties in connection with official and court proceedings;
from public registers, such as the debt collection or commercial register, from public bodies, such as the Federal Statistical Office, from the media or from the internet.
5. For what purposes do we process personal data?
We process personal data for one or more purposes. These are, in particular, the purposes explained below.
5.1. Communication
We would like to stay in touch with you and respond to your concerns. We therefore process personal data for the purpose of communicating with you, e.g. responding to enquiries and providing customer service. For this purpose, we process mainly communication and master data and, where the communication relates to a contract or subscription, contract data, as well. We may also personalise the content and timing of messages based on behavioural, transaction, preference and other data.
The purpose of the communication includes but is not limited to:
answering enquiries;
contacting you in case of questions;
customer service and customer care;
the authentication;
quality assurance and training;
all other processing purposes, insofar as we communicate with you for this purpose (e.g. contractual performance, providing information and direct marketing).
5.2. Implementation of the contract
We want to provide you with offerings and the best possible service. We therefore process personal data in connection with the initiation, management and implementation of contractual relationships, e.g. in connection with your use of digital offerings or participation in events such as a sweepstakes. The implementation of the contract also includes any agreed personalisation of services. For this purpose, we mainly use master data, contract data, communication data, behavioural and transaction data, as well as preference data.
The purpose of implementing the contract generally includes everything that is necessary or expedient in order to prepare, conclude, perform and, if necessary, enforce a contract. This may also include the involvement of other companies of the TX Group, as well as third parties.
This includes, e.g. processing:
to decide whether and how (e.g. with which payment options) we enter into a contract with you (including the credit check);
to provide contractually agreed services, e.g. to provide services and functions (including personalised service components);
to ascertain customer satisfaction;
to identify, notify and, where appropriate, announce the winners of contests and sweepstakes;
to bill for our services and in general for accounting;
to prepare and process corporate transactions, e.g. corporate acquisitions, sales and mergers;
to enforce legal claims arising from contracts (collection, court proceedings, etc.);
to administer and manage our IT and other resources;
to store data as part of our retention obligations;
to cancel and terminate contracts.
5.3. Registering and managing a user account
For personalised services or restricted areas, or to process requests and administer your subscriptions, you may need to register and create a user account. For this purpose, we use “OneLog”, a registration and log-in service that is operated and offered by OneLog Ltd, Dufourstrasse 23, 8008 Zurich. If you register with us in this way and create a user account, you must enter certain personal data.
This may include, for example,
your email address, which may also serve as your username,
password
and, depending on the context and offering, additional details, such as
first and last name
nickname
address (complete postal address, postcode, city/town)
telephone number
date of birth
gender
information about subscribed newsletters or other advertising
language preferences
Apart from the details labelled as mandatory for taking advantage of a particular digital offering, you can also voluntarily enter and store additional personal data.
We use such data for processing and administering our digital offerings, verifying the plausibility of the data entered, i.e. establishing, designing the content of, processing and amending the contracts concluded with you via your user account and, in case of fee-based services, proper invoicing.
By your confirmation upon completing the registration for collecting and changing your details for the user account, you guarantee that the information collected from you is accurate.
In OneLog’s Privacy Policy, you will find additional information on the registration and log-in service and specifically on the question of which personal data are processed by you and in what manner by OneLog Ltd as a service provider.
5.4. Information and marketing
We would like to make you attractive offers. We therefore process personal data for relationship maintenance and marketing purposes, e.g. to send you written and electronic communications and advertising and to display them on our digital offerings. These may be our own offers or offers from other companies of the TX Group or from advertising partners. Messages and advertisements may also be personalised in order to provide you, where possible, with only information that is likely to be of interest to you. For this purpose, we mainly use master, contract, communication, behaviour and transaction data, as well as preference data.
These may include, e.g. the following communications and offerings:
newsletters, promotional emails, in-app messages, instant messaging and other electronic messages;
digital banners
digital promotional videos
newspapers, magazines and other printed matter;
delivery of coupons;
invitations to sweepstakes and contests.
Unless we separately request your consent to contact you for marketing purposes, you can refuse such contact at any time (see Section 13). For newsletters and other electronic communications, you can usually unsubscribe from the relevant service directly by using an unsubscribe link integrated into the message.
5.5. Market research and development of offerings
We want to improve our offerings and make them more attractive to you, and develop new ones, as well. We therefore process personal data for market research and product development. For this purpose, we process primarily master, behaviour, transaction and preference data, but also communication data and information from user surveys and other information, e.g. from the media, the Internet and other public sources. If you have given your consent, you may also be contacted by other TX Group companies in order, for example, to participate in other user surveys. To the extent possible, we use pseudonymised or anonymised information for these purposes.
Market research and the development of offerings include, but are not limited to:
conducting user surveys and studies;
the further development of our offerings (e.g. design of media content, etc.);
evaluating and improving the acceptance of our offerings and our communication in relation to offerings;
optimising and improving the usability of websites and apps;
the development and testing of new offerings;
reviewing and improving our internal processes;
the basic and advanced education and training of our employees;
statistical evaluations, e.g. in order to evaluate on a non-personal basis information about the interactions of our customers with us;
market monitoring, e.g. to understand and respond to current developments and trends.
5.6. Safety and prevention
We want to ensure your security and ours and to prevent misuse. We therefore also process personal data for security purposes, to guarantee IT security, to prevent fraud and misuse and for evidentiary purposes. This may affect all categories of personal data referred to in Section 3, including but not limited to behavioural and transaction data.
The purpose of safety and prevention includes, for example:
the analysis of behavioural and transaction data for the purpose of detecting suspicious patterns of behaviour and fraudulent activities;
the evaluation of system-generated records of the use of our systems (log data);
preventing, defending against and investigating cyberattacks and malware attacks;
analyses and tests of our networks and IT infrastructures, as well as system and error tests;
control of accesses to electronic systems (e.g. logins to user accounts);
documentation purposes and creation of backup copies.
5.7. Compliance with legal requirements
We want to and must comply with legal requirements. We therefore also process personal data in order to comply with legal obligations and to prevent, detect and, where necessary, prosecute violations. These include, e.g. the receipt and processing of complaints and other reports, compliance with orders of a court or other authority, as well as measures to detect and investigate misuse. This may affect all categories of personal data referred to in Section 4.
Compliance with legal requirements includes but is not limited to:
receiving and processing complaints and other reports;
ensuring compliance and risk management;
disclosing information and documents to the relevant authorities if we have an objective reason to do so or are legally obligated to do so;
participating in external investigations, e.g. by a law enforcement or supervisory authority;
ensuring data security as required by law;
fulfilling access, information or reporting obligations, e.g. in relation to supervisory and tax obligations, e.g. archiving obligations and to prevent, detect and investigate criminal offences and other infringements;
combatting money laundering and the financing of terrorism as regulated by law.
In all cases, the regulations in question may be Swiss legislation, but also foreign regulations to which we are subject, as well as self-regulation, industry and other standards, our own corporate governance or official instructions.
5.8. Safeguarding our interests
We have the right to enforce claims and defend ourselves against third-party claims. We therefore also process personal data to protect our interests, e.g. in order to enforce claims prior to litigation, in court and out of court, before authorities in Switzerland and abroad, or to defend ourselves against claims. Depending on the situation, we process different personal data, e.g. contact data and information about processes that gave rise or could give rise to a dispute.
The purpose of safeguarding our interests includes but is not limited to:
investigating and enforcing our claims, which may include claims of companies affiliated with us and of our contractual and business partners;
defending against claims brought against us, our employees, companies affiliated with us and against our contractual and business partners;
clarifying litigation prospects and other legal, financial and other issues;
participating in proceedings before courts and other authorities in Switzerland and abroad. For example, we can secure evidence, have the prospects of litigation clarified or submit documents to an authority. Authorities may also ask us to disclose documents and data carriers containing personal data.
5.9. Intragroup administration and support
We want to make our internal processes as efficient as possible. We therefore process personal data for our intragroup administration. For this purpose, we may process all of the data specified in Section 3.
intragroup support and administration includes but is not limited to:
the use of the TX data offerings (please refer to the further privacy notices);
the sharing of content, e.g. if content that you have published on our digital offerings is published in an adapted form in other offerings of the TX Group;
the central storage and management of data used by multiple TX Group companies;
the management of IT;
the archiving of data and the management of our archives;
training and education, e.g. when evaluating telephone recordings or other communications;
the review or execution of corporate transactions, such as corporate acquisitions, sales and mergers;
forwarding enquiries to the competent authorities, e.g. if you address an enquiry to a company of the TX Group concerning another company;
In general, reviewing and improving our internal processes.
6. What are the legal bases for our processing of personal data?
The GDPR only permits the processing of personal data if it relies on one or more legal bases. Depending on the purpose of the data processing, our processing of personal data relies on several different legal bases.
Insofar as the GDPR applies to our processing of personal data, these legal bases can be found in Articles 6 and 9 GDPR, particularly Article 6 (1) (a) and Article 9 (2) (a) (consent), Article 6 (1) (b) (performance of a contract or the taking of pre-contractual steps), Article 6 (1) (c) (compliance with a legal obligation) and Art. 6 (1) (f) (safeguarding of legitimate interests).
In particular, we may process personal data if the processing:
is necessary for the performance of a contract (e.g. a subscription) with the data subject or for pre-contractual measures;
is necessary to safeguard legitimate interests;
We have a legitimate interest particularly in processing data for the purposes described in Section 5 above and in disclosing data in accordance with Section 8 and the associated purposes in each case. Legitimate interests include our own interests and those of third parties.
These legitimate interests include, for example, our interest
in continuously improving our offerings, adapting them to your needs, displaying advertising to you and thereby (co-)financing our offerings;
in providing good customer service, maintaining contacts and communicating with clients, even outside of a contract;
in the intra-group administration and intra-group transactions that are necessary in a group with a division of labour;
in mutually supporting the activities and objectives of our group companies;
in combatting fraud and preventing and investigating offences;
in the protection of clients, employees and other persons and data, secrets and assets of the TX Group;
in ensuring IT security;
in ensuring and organising the business operations, including the operation and further development of websites and other systems;
in corporate governance and development;
in the sale or purchase of companies, parts of companies and other assets;
in enforcing or defending legal claims;
in complying with Swiss and foreign law, as well as our internal rules and regulations.
is based on consent;
Consent may be revoked prospectively at any time. However, this shall not affect the lawfulness of the data processing prior to revocation.
is necessary to comply with domestic or foreign legislation.
7. To whom do we disclose personal data?
We may disclose personal data (Section 3) to other companies of the TX Group, for example, for the purpose of intra-group administration or to support the relevant TX Group companies. Disclosure to companies of the TX Group and other affiliated companies may also take place if, in the context of the TX data offerings, we support the personalisation of marketing activities, the development and improvement of offerings, or efforts to prevent fraud and misuse. Please also refer to the Privacy Notice regarding the TX Data Offerings.
Like any association of companies, the TX Group also has an overall interest in the successful business activities of its group companies. Our group companies in turn have an interest in their own activities and their own processing purposes (Section 5). In order to support these activities and purposes, the personal data required for this purpose may be disclosed to group companies. These group companies may then compare this data and link it with their existing personal data.
We may also disclose your personal data to companies within and outside the TX Group if we utilise their services. These service providers generally process personal data on our behalf as “processors”. Processors are obligated to process personal data exclusively in accordance with our instructions and to take appropriate data security measures. Certain service providers are also responsible jointly with us or independently (e.g. debt collection companies). By selecting service providers and making appropriate contractual agreements, we ensure that data protection is guaranteed throughout the entire processing of your personal data.
This concerns, e.g. services in the following areas:
advertising and marketing services, e.g. for sending messages and information;
corporate management, e.g. accounting or asset management;
payment services;
credit information, e.g. if you wish to make a purchase on account;
debt collection services;
IT services, e.g. services in the areas of data storage (hosting), cloud services, dispatch of email newsletters, data analysis and refinement, etc.;
advisory services, e.g. services of tax advisors, attorneys or business consultants
In individual cases, we may also disclose personal data to other third parties even for their own purposes, e.g. if you have consented to the relevant disclosure and processing or if we are legally obligated or entitled to disclose such data.
Such cases include, for example, the following:
the transfer of receivables to other companies, such as debt collection companies;
the review or execution of corporate transactions, such as corporate acquisitions, sales and mergers;
the disclosure of personal data to courts and other authorities in Switzerland and abroad, e.g. to law enforcement authorities where criminal acts are suspected;
the processing of personal data to comply with a court order or to assert or defend against legal claims or if we deem it necessary for other legal reasons. At the same time, we may also disclose personal data to other parties to the proceedings.
In such cases, the recipient of the data is its own controller under data protection law, who normally informs you of its own privacy statement. Please also note our information on cookies and similar technologies for independent data collection by third-party providers, whose cookies and similar technologies we have incorporated into our digital offerings.
8. How do we disclose personal data abroad?
The recipients of your personal data mentioned in Section 7 may also be located abroad, including outside the European Economic Area (EEA). Not all of these countries have laws that protect personal data to the same extent as in Switzerland or the EEA. If we transfer your personal data to such a country, we ensure that it is protected in an appropriate manner.
One means of ensuring adequate data protection is, e.g. by concluding data transfer agreements with recipients or your personal data in third countries that ensure the necessary data protection. This includes contracts that have been approved, issued or recognised by the European Commission and the Federal Data Protection and Information Commissioner; these are referred to as standard contractual clauses. An example of the data transfer agreements we generally use can be found here. Please note that such pre-contractual steps compensate in part for legal protection that is deficient or lacking, but they may not entirely exclude all risks (e.g. from government access abroad). In exceptional circumstances, data transfers to countries lacking adequate protection may also be permitted in other cases, e.g. based on consent, in relation to legal proceedings abroad, or if the transfer is necessary for the performance of a contract.
9. How do we use profiling?
“Profiling” means the automated processing of personal data in order to analyse personal aspects or make forecasts, e.g. the analysis of personal interests, preferences, affinities and habits or the forecast of prospective behaviour. In particular, profiling may be used to derive preference data (for additional information, see Section 3.5).
Profiling is a frequent operation, e.g. in the case of the automated processing
of master data and contract data in relation to the purchase of subscriptions;
of behavioural and transaction data, as well as technical data as regards our websites and apps;
of information relating to participation in contests and sweepstakes;
of communication data, e.g. your response to advertising and other messages;
other behavioural and transaction data.
At the same time, profiling helps us, e.g. to
continuously improve our offerings and better tailor them to your individual needs;
present our content and offerings to you according to your needs;
if possible, only provide you with advertising and offerings that are likely to be relevant to you;
better support you when providing customer service;
to decide on the basis of a credit check which payment options are available.
In order to improve the quality of our analyses and forecasts, we may also combine personal data from various sources as a basis for profiling, e.g. data collected via several of our digital offerings or received from companies affiliated to the TX data offerings. Please also refer to the Privacy Notice regarding the TX Data Offerings.
You can opt out of profiling in certain cases, as described in Section 13.
10. Do we make automated individual decisions?
“Automated individual decision-making” refers to decisions made through the fully automated processing of personal data without the involvement of a person, and which have legal consequences for, or otherwise significantly affect, the specific data subject. As a rule, we do not make decisions automatically, but inform you separately if we use automated individual decisions concerning you in individual cases. In such cases, you have the right to have the decision reviewed if you disagree with it.
11. How do we protect personal data?
We take appropriate technical and organisational security measures to maintain the security of your personal data, to adequately protect it against unauthorised or unlawful processing and to counteract the risk of loss, accidental alteration, unwanted disclosure or unauthorised access. Our security measures are continuously adapted and improved in line with technological developments. Like all companies, however, we cannot completely rule out data security breaches; certain residual risks are unavoidable.
We only grant our employees access your personal data if this is necessary for the activities of the employees concerned. This may also include employees in support areas, such as IT. They are however bound by our instructions and are obligated to maintain confidentiality when handling your personal data.
Security measures of a technical nature include, e.g. password-protected areas, encryption and pseudonymisation of data, logging, access restrictions and the storage of backup copies. Security measures of an organisational nature include, e.g. instructions to our employees, non-disclosure agreements and audits. We also require our processors to take appropriate technical and organisational security measures.
12. How long do we process personal data?
We process and store your personal data for at least as long as necessary for the purpose of the processing or for purposes compatible therewith, and in the case of contracts, normally at least for the duration of the contractual relationship. In general, we also store personal data for as long as we have a legitimate interest in storing it. This may be the case, in particular, if we need personal data in order to enforce or defend against claims, for archiving purposes and to guarantee IT security. And we store personal data for as long as it is subject to a statutory retention obligation. For example, certain data is subject to a ten-year retention period. For other data, shorter retention periods apply, e.g. for records of certain processes on the Internet (log data). Once these periods have expired, we will erase or anonymise your personal data.
13. What rights do you have as regards the processing of your personal data?
You have the right to opt out of data processing, particularly if we process your personal data based on a legitimate interest and the other applicable requirements are met. Furthermore, you may opt out of data processing in relation to direct marketing (e.g. advertising emails) at any time. This also applies to profiling insofar as it relates to such direct marketing.
Provided that the relevant applicable prerequisites are met, and no statutory exceptions apply, you also have the right to information, rectification, erasure, restriction of data processing, and the right to receive the personal data provided by you in a commonly used format. Moreover, you have the right to revoke prospectively any consent you have given to us.
Right to information: You have the right to be informed as to how we process your personal data and as to your rights in relation to the processing of your personal data. We fulfil this obligation by publishing this Privacy Statement. If you would like further information, please do not hesitate to contact us.
Right of access: You have the right to request access to your personal data stored by us at any time. This gives you the opportunity to check which personal data we process about you. In individual cases, the right of access may be restricted or excluded, particularly if there are doubts as to the identity concerned or if this is necessary for protecting other persons.
Right to rectification: You have the right to have incorrect or incomplete personal data rectified or completed, or to have it supplemented with a note about the objection, and to be informed of the rectification.
Right to erasure: You have the right to request the erasure of your personal data if the personal data is no longer necessary for the purposes pursued, you have validly revoked your consent or have validly opted out of the processing, or if the personal data is being processed unlawfully. The right to erasure may be excluded in individual cases, particularly if the processing is required in order to exercise the right of free expression or to enforce legal claims: We may also anonymise personal data so that it is no longer available. Please note that, even after you have requested the erasure of your personal data, we must retain it in some instances in accordance with our statutory or contractual retention duties. In such cases, we will only block your personal data to the extent required for this purpose. Furthermore, an erasure of your personal data may mean that you can no longer obtain or use the services registered by you.
Right to restrict processing: Under certain conditions, you have the right to request that the processing of your personal data be restricted. This may mean, for instance, that the processing of personal data is (temporarily) discontinued or that published personal data is (temporarily) removed from a website.
Right to the surrender or transfer of data: You have the right to obtain from us the personal data that you have provided to us in a structured, commonly used and machine-readable format if the specific data processing is based on your consent or is necessary for the performance of the contract and the processing is performed through automated processes.
Right to revoke consent: If we process your personal data based on consent, you have the right to revoke your consent at any time. The revocation shall apply only for the future; However, past processing activities based on your consent are not rendered unlawful by your revocation. We reserve the right to continue to process personal data on a different basis in the event of a revocation of consent.
You may contact us as described in Section 14 if you wish to exercise one of your rights or if you have any questions about the processing of your personal data. You can also unsubscribe from newsletters and other promotional emails by clicking on the relevant link at the end of the email. Learn how to disable cookies and similar technologies.
You can manage your privacy settings via a link in the User Cockpit. In order to deactivate the processing of your data by the TX Group Data Offerings and other technologies , you can deactivate all processing purposes listed in the Cookie Preference Center for which data processing by the TX Group data services is to be prevented. In addition, you have the option to deactivate TX Group AG in the list of vendors in the Cookie Preference Center. You can find detailed information about the processing purposes in the Cookie Preference Center. As a result, a cookie will be stored in your browser or on your end device. If you change browsers, use another device or delete your cookies, you must perform the deactivation process again. Alternatively, on the websites of the affiliated companies, you have the option to activate and deactivate certain categories of cookies and similar technologies, including the technology of the TX Group Ltd, via a Cookie Preference Center.
You are also free to lodge a complaint with the appropriate supervisory authority if you have any concerns as to whether the processing of your personal data is legally compliant.
The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
14. How can you contact us?
If you have any questions about this Privacy Statement or our processing of your personal data, or if you wish to assert rights under Section 13, please use the «Exercise Your Rights» button below.
For requests from the EU countries, you can contact our representative (Art. 27 GDPR):
ePrivacy GmbH
Grosse Bleichen 21
D-20354 Hamburg
Germany
https://www.eprivacy.eu/en
15. Changes to this Privacy Statement
This Privacy Statement may be amended over time, in particular if we further develop our website, implement new technologies, or if new legislation becomes applicable. We actively inform persons registered with us about significant changes, either through the email address provided in the registration process or via a similar notice posted in a suitable location, provided this is possible without unreasonable effort. As a general rule, data processing is subject to the version of the privacy statement in effect at the start of the relevant processing.
The original privacy statement is in German. The translated versions are for ease of comprehensibility only. In the event of discrepancies, the German text shall prevail.
Last updated: July 2022
