With this data protection declaration we inform you which personal data we process for what, how and where, in particular in connection with our websites metagami.xyz and our other offers. With this privacy policy, we also inform you about the rights of persons whose data we process.

For individual or additional offers and services, special, supplementary or additional data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

Our offer is subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.

1. Contact Addresses

Responsibility for the processing of personal data:

Haip AG
Pilatusstrasse 18
6003 Lucerne
Switzerland

contact@metagami.xyz

We point out if there are other persons responsible for the processing of personal data in individual cases.

Data Protection Officer

We have the following data protection officer as a point of contact for data subjects and as a contact for supervisory authorities in the event of data protection inquiries:

Niklas Jung
c/o Haip AG
Pilatusstrasse 18
6003 Lucerne
Switzerland

hi@metagami.xyz

2. Processing of Personal Data

2.1 Terms

Personal data is any information that relates to an identified or identifiable individual. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.

The European Economic Area (EEA) comprises the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal Basis

We process personal data in accordance with Swiss data protection law, in particular the Swiss Federal Data Protection Act (DSG) and the Ordinance to the Swiss Federal Data Protection Act (VDSG).

We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to provide our offer permanently, in a user-friendly, secure and reliable manner and to be able to advertise for it as required, information security and protection against misuse and unauthorised use, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.

2.3 Nature, Scope and Purpose

We process those personal data that are necessary to provide our offer permanently, user-friendly, secure and reliable. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales, contract and payment data.

We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary is anonymised or deleted. Persons whose data we process generally have the right to have their data deleted.

We process personal data basically only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

In this context, we process in particular information that a data subject voluntarily and self-submits to us when contacting us – for example, by letter, email, contact form, social media or telephone – or when registering for a user account. For example, we may store such information in an address book, in a customer relationship management (CRM) system, or with similar tools. If you transmit data about other persons to us, you are obliged to ensure data protection with respect to such persons and to ensure the accuracy of such personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.

Personal data from applications are only processed insofar as they are necessary for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required to carry out an application procedure is derived from the information requested or provided, for example in the context of a job advertisement. Applicants have the option of voluntarily submitting additional information for their respective applications.

2.4 Processing of Personal Data by Third Parties, including abroad

We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties.

Such third parties are generally located in Switzerland and in the European Economic Area (EEA). However, such third parties may also be located in other states and territories on Earth as well as elsewhere in the universe, provided that their data protection laws are applicable under Assessment of the Federal Data Protection and Information Commissioner (FDPIC) and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to European Commission’s assessment ensures adequate data protection, or if adequate data protection is ensured for other reasons, such as through an appropriate contractual agreement, in particular on the basis of standard contractual clauses, or through an appropriate certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the conditions under data protection law, such as the explicit consent of the data subject, are met.

3. Rights of Data Subjects

Data subjects whose personal data we process have the rights under Swiss data protection law. This includes the right to information as well as the right to rectification, deletion or blocking of the processed personal data.

Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.

Data subjects whose personal data we process may – if and insofar as the GDPR applies – revoke consent given at any time with effect for the future and object to the processing of their personal data at any time.

Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

4. Data Security

We take appropriate and suitable technical and organisational measures to ensure data protection and in particular data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.

Access to our online offer takes place by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Access to our online offer is subject – as is any use of the Internet – to mass surveillance without cause and without suspicion, as well as other surveillance by security authorities in Switzerland, the European Union (EU), the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.

5. Use of the Website

5.1 Cookies

We may use cookies for our website. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in your browser. Such stored data need not be limited to traditional textual cookies. Cookies cannot execute programs or transmit malware such as Trojans and viruses.

Cookies can be stored temporarily in your browser as “session cookies” when you visit our website or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they enable us to recognise your browser the next time you visit our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

You can deactivate cookies in your browser settings at any time, in whole or in part, as well as delete them. Without cookies, our website may no longer be fully available. We actively seek your explicit consent for the use of cookies, if and when required.

In the case of cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

5.2 Server Log Files

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer permanently, user-friendly and reliably as well as to be able to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.

5.3 Tracking Pixel

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Counting pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.

6. Notifications and Messages

We send notifications and communications such as newsletters by email and through other communication channels such as instant messaging.

6.1 Success and Reach Measurement

Notifications and messages may contain web links or tracking pixels that track whether an individual message has been opened and which web links have been clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to offer notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.

6.2 Consent and Objection

In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent to receive e-mails, we use the “double opt-in” procedure where possible, i.e. you will receive an e-mail with a web link which you must click to confirm, so that no misuse by unauthorised third parties can take place. We may log such consents, including Internet Protocol (IP) address, date and time, for evidentiary and security purposes.

In principle, you can unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. This is subject to notifications and communications that are absolutely necessary for our offer.

6.3 Service Provider for Notifications and Messages

We send notifications and communications through third party services or with the help of service providers. Cookies may also be used in the process. We also ensure appropriate data protection for such services.

In particular, we use:

7. Social Media

We have a presence on social media platforms and other online platforms to communicate with interested individuals and provide information about our offerings. Personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions inform in particular about the rights of data subjects, which include in particular the right of access.

For our social media presence on Facebook, including the so-called Page Insights, we are, if and to the extent that the GDPR is applicable, jointly responsible with Facebook Ireland Limited in Ireland. Page insights provide information about how visitors interact with our Facebook presence. We use Page Insights to help us provide our social media presence on Facebook in an effective and user-friendly manner.

Further information on the nature, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook’s data protection officer can be found in Facebook’s privacy policy (“Data Policy”). We have entered into what is known as the “Responsible Party Addendum” with Facebook, specifically agreeing that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the pages “Information on Page Insights” including “Page Insights supplement regarding the responsible person” and “Information on Page Insights data” respectively of Facebook.

Users of social media platforms have the option of logging in or registering for our online offering with their corresponding user account (“social login”). The respective terms and conditions of the social media platforms concerned, such as general terms and conditions (GTC) and terms of use or data protection declarations, apply.

8. Success and Reach Measurement

We use services and programs to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our online offering as well as the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offer or parts of our online offer are used (“A/B test” method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen particularly popular content or make improvements to our online offering.

When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened in order to follow the principle of data economy through the corresponding pseudonymisation and to improve the data protection of visitors to our website (“IP masking”).

When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. As a matter of principle, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual visitors to our website. Individual services with which you are registered as a user may assign the use of our online services to your profile with the respective service, whereby you usually have to give your consent to this assignment in advance.

In particular, we use:

9. Services Provided by Third Parties

We use services of third parties in order to be able to provide our offer permanently, user-friendly, secure and reliable. Such services are also used to embed content into our website. Such services – for example, hosting and storage services, video services and payment services – require your Internet Protocol (IP) address, otherwise such services cannot deliver the relevant content. Such services may be located outside Switzerland and the European Economic Area (EEA), provided that adequate data protection is guaranteed.

For their own security, statistical and technical purposes, third parties whose services we use may also process data in connection with our offer and from other sources – including cookies, log files and counting pixels – in aggregated, anonymous or pseudonymous form.

9.1 Digital Infrastructure

We use services of third parties in order to be able to make use of the required digital infrastructure for our offer. These include, for example, hosting and storage services from specialist providers.

In particular, we use:

9.2 Contact Options

We use third party services to better communicate with you and others, such as customers. We also ensure appropriate data protection for such third parties.

In particular, we use:

9.3 Social Media Functions and Social Media Content

9.3.1 Facebook

We use social plugins from Facebook to embed Facebook functions and Facebook content on our website. Such functions are for example “Like” or “Share”. Cookies are also used in this process. For more information, please visit Facebook’s Social Plug-ins page.

The social plugins are an offer of Facebook Ireland Ltd. in Ireland or the American Facebook Inc. If you are logged in to Facebook as a user, Facebook can assign the use of our online offer to your profile. Further information on the type, scope and purpose of data processing can be found in Facebook’s privacy policy (“Data Policy”).

9.3.2 LinkedIn

For our website, we use the possibility of embedding functions and content from LinkedIn with the help of plugins. For example, we can use it to enable you to use LinkedIn’s “share” feature on our website. Cookies are also used in this process. For more information, see the LinkedIn plugins page.

The plugins are offered by LinkedIn Ireland Unlimited Company in Ireland or the American LinkedIn Corporation. If you are registered as a user with LinkedIn, LinkedIn can assign the use of our online offer to your profile. Further information on the type, scope and purpose of data processing can be found in the privacy policy, in the cookie policy and on the privacy portal of LinkedIn in each case. There is also the possibility to object to personalised advertising.

9.3.3 Pinterest

We use the possibility of embedding functions and content from Pinterest for our website. For example, we can use it to show you images or pins that have been published on Pinterest as part of our website. Cookies are also used in this process.

The offer originates from Pinterest Europe Ltd. in Ireland and the American Pinterest Inc. respectively. If you are logged in to Pinterest as a user, Pinterest can assign the use of our online service to your profile. Further information on the type, scope and purpose of data processing can be found on Pinterest’s “Data protection” page.

9.3.4 Twitter

For our website, we use the possibility of embedding functions and content from Twitter (“Twitter for Websites” or “Twitter for websites”). For example, we can use it to enable you to use Twitter’s “share” feature on our website or to display tweets to you within our website. Cookies are also used in this process.

Twitter for Websites” is an offer of the American Twitter Inc. Twitter International Company in Ireland is responsible for users in the European Economic Area (EEA), the United Kingdom and Switzerland. If you are registered as a user with Twitter, Twitter can assign the use of our online service to your profile. Further information on the type, scope and purpose of data processing can be found in the information on ads and data protection at Twitter for websites as well as in the privacy policy of Twitter in each case. In addition, Twitter informs about the use of cookies and similar technologies as well as about the personalization of advertisements both in connection with a possible Twitter account and based on the use of Twitter content on the Internet. Privacy settings – including opt-out options – are available for personalized ads.

9.4 Map Material

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

In particular, we use:

9.5 Audiovisual Media

We use third party services to enable the direct playback of audiovisual media such as music or videos on our website.

In particular, we use:

9.6 Fonts

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

In particular, we use:

9.7 Payments

We use payment service providers to process our customers’ payments securely and reliably. The terms and conditions of the respective payment service providers, such as general terms and conditions (GTC) or data protection declarations, apply to the processing in each case.

In particular, we use:

9.8 Advertising

We use the possibility of displaying targeted advertising for our offer on third parties such as social media platforms and search engines.

With such advertising, we would like to reach in particular people who are interested in our offer or who already use our offer(remarketing and targeting). For this purpose, we may transmit corresponding – possibly also personal – information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our offer to your profile there.

In particular, we use:

10. Extensions for the Website

We use extensions for our website in order to be able to use additional functions.

In particular, we use:

11. Final Provisions

We may amend and supplement this privacy policy at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.
This privacy policy is an unofficial translation from the German original. In case of doubt, the German version shall prevail.

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