Privacy Policy

This English version of our privacy policy is a translation provided for your convenience only. The binding version is the German original, which can be found at jenewein.ch/datenschutz. In case of any discrepancies between the two language versions, the German version shall prevail.

1. PRIVACY AT A GLANCE

GENERAL INFORMATION

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on data protection, please refer to our privacy policy set out below this text.

DATA COLLECTION ON THIS WEBSITE

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. Their contact details can be found in the section «Information on the controller» of this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may, for example, be data you enter into a contact form.

Other data is collected automatically, or with your consent, by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page access). Such data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the website is provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the data transmitted is also processed for contract offers, orders or other order-related enquiries.

What rights do you have regarding your data?

You have the right at any time to receive free information about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or deletion of this data. If you have given your consent to data processing, you can withdraw this consent at any time with future effect. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. In addition, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

ANALYSIS TOOLS AND THIRD-PARTY TOOLS

When visiting this website, your browsing behaviour may be statistically analysed. This is done primarily through so-called analysis programmes.

Detailed information on these analysis programmes can be found in the privacy policy below.

2. HOSTING AND CONTENT DELIVERY NETWORKS (CDN)

We host the content of our website with the following provider:

EXTERNAL HOSTING

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact enquiries, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

External hosting is carried out for the purpose of contract performance vis-à-vis our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of TDDDG. Consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil their service obligations and will follow our instructions regarding this data.

We use the following host(s):

Hostpoint AG Neue Jonastrasse 60 8640 Rapperswil-Jona Switzerland

Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

CLOUDFLARE

We use the service «Cloudflare». The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter «Cloudflare»).

Cloudflare provides a globally distributed Content Delivery Network with DNS. Technically, the transfer of information between your browser and our website is routed via the Cloudflare network. This enables Cloudflare to analyse the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious data traffic from the internet. Cloudflare may also use cookies or other technologies to recognise internet users, although these are used solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our website as error-free and securely as possible (Art. 6(1)(f) GDPR).

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find further details and information on security and data protection at Cloudflare here: https://www.cloudflare.com/privacypolicy/ .

The company is certified under the «EU-US Data Privacy Framework» (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to uphold these data protection standards. You can find more information from the provider at the following link: https://www.dataprivacyframework.gov/participant/5666.

3. GENERAL INFORMATION AND MANDATORY DISCLOSURES

DATA PROTECTION

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various items of personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains which data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

INFORMATION ON THE CONTROLLER

The controller responsible for data processing on this website is:

JENEWEIN AG Seeweg 16 8593 Kesswil Switzerland

VAT ID: CHE-114.001.621 Email: info@jenewein.ch

The controller is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses or similar).

STORAGE PERIOD

Unless a more specific storage period is mentioned in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, provided we have no other legally permissible grounds for storing your personal data (e.g. tax or commercial retention periods); in the latter case, deletion will take place once these reasons no longer apply.

GENERAL INFORMATION ON THE LEGAL BASIS FOR DATA PROCESSING ON THIS WEBSITE

Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, in case special categories of data within the meaning of Art. 9(1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing also takes place on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your terminal device (e.g. via device fingerprinting), data processing additionally takes place on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. Where your data is required for the performance of a contract or for pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data where this is necessary for compliance with a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The legal bases relevant in each individual case are set out in the following paragraphs of this privacy policy.

RECIPIENTS OF PERSONAL DATA

In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties where this is necessary in the context of contract performance, where we are legally obliged to do so (e.g. passing on data to tax authorities), where we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits the data disclosure. When using processors, we only pass on personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

WITHDRAWAL OF YOUR CONSENT TO DATA PROCESSING

Many data processing operations are only possible with your express consent. You can revoke consent that you have already given at any time. The lawfulness of the data processing carried out up to the point of revocation remains unaffected by the revocation.

RIGHT TO OBJECT TO DATA COLLECTION IN SPECIAL CASES AND TO DIRECT MARKETING (ART. 21 GDPR)

If data processing is carried out on the basis of Art. 6(1)(e) or (f) GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (objection pursuant to Art. 21(1) GDPR).

If your personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will no longer be used for the purposes of direct marketing (objection pursuant to Art. 21(2) GDPR).

RIGHT TO LODGE A COMPLAINT WITH THE COMPETENT SUPERVISORY AUTHORITY

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy.

RIGHT TO DATA PORTABILITY

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

INFORMATION, RECTIFICATION AND DELETION

Within the framework of applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, where applicable, a right to rectification or deletion of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

RIGHT TO RESTRICTION OF PROCESSING

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you contest the accuracy of your personal data stored with us, we generally need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data has taken place or is taking place unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you require it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing must take place between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a Member State.

SSL/TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content such as orders or enquiries that you send to us as the site operator, this page uses SSL/TLS encryption. You can recognise an encrypted connection by the fact that the browser’s address line changes from «http://» to «https://» and by the lock symbol in your browser bar.

When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. DATA COLLECTION ON THIS WEBSITE

COOKIES

Our web pages use so-called «cookies». Cookies are small data packets and do no harm to your terminal device. They are stored on your terminal device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable certain services from third-party companies to be integrated within websites (e.g. cookies for processing payment services).

Cookies have different functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping basket function), or to optimise the website (e.g. cookies for measuring the web audience) – so-called necessary cookies – are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be revoked at any time.

You can configure your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

CONSENT WITH BORLABS COOKIE

Our website uses the consent technology of Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies, and to document this in a data-protection-compliant manner. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser in which the consent you have given, or the withdrawal of this consent, is stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected is stored until you request us to delete it, you delete the Borlabs cookie yourself, or the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected. You can find details on the data processing by Borlabs Cookie at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/ .

The use of Borlabs Cookie consent technology takes place in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

ENQUIRY BY EMAIL OR TELEPHONE

When you contact us by email or telephone your enquiry, including all personal data arising from it (name, enquiry), is stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, provided your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR), or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact enquiries remains with us until you ask us to delete it, you revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

HUBSPOT CRM

We use Hubspot CRM on this website. The provider is Hubspot Inc., 25 Street, Cambridge, MA 02141, USA (hereinafter Hubspot CRM).

Hubspot CRM enables us, among other things, to manage existing and potential customers as well as customer contacts. With the help of Hubspot CRM, we are able to capture, sort and analyse customer interactions via email, social media or telephone across various channels. The personal data collected in this way can be evaluated and used for communication with the potential customer or for marketing measures (e.g. newsletter mailings). With Hubspot CRM, we are also able to capture and analyse the user behaviour of our contacts on our website.

The use of Hubspot CRM is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the most efficient customer management and customer communication possible. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of TDDDG. Consent can be revoked at any time.

For details, please refer to the privacy policy of Hubspot: https://legal.hubspot.com/de/privacy-policy .

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find details here: https://www.hubspot.de/data-privacy/privacy-shield .

5. SOCIAL MEDIA

INSTAGRAM

Functions of the Instagram service are integrated on this website. These functions are offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

When the social media element is active, a direct connection is established between your terminal device and the Instagram server. Instagram thereby receives information about your visit to this website.

If you are logged into your Instagram account, you can link the contents of this website with your Instagram profile by clicking the Instagram button. This enables Instagram to associate your visit to this website with your user account. Please note that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram.

The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be revoked at any time.

Insofar as personal data is collected on our website using the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). This joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook or Instagram. The processing subsequently carried out by Facebook or Instagram is not part of the joint responsibility. The obligations jointly incumbent on us have been set out in a joint processing agreement. You can find the wording of the agreement at: https://www.facebook.com/legal/controller_addendum . According to this agreement, we are responsible for providing the data protection information when using the Facebook or Instagram tool, and for the data-protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert data subject rights with us, we are obliged to forward them to Facebook.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum , https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381 .

Further information on this can be found in Instagram’s privacy policy: https://privacycenter.instagram.com/policy/ .

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Each time a page of this website that contains LinkedIn elements is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click LinkedIn’s «Recommend button» and are logged into your LinkedIn account, LinkedIn is able to associate your visit to this website with you and your user account. Please note that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find details here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de

Further information on this can be found in LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy .

6. ANALYSIS TOOLS AND ADVERTISING

GOOGLE TAG MANAGER

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create user profiles, store cookies or carry out any independent analyses. It serves solely to manage and deploy the tools integrated through it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The use of Google Tag Manager is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the fast and straightforward integration and management of various tools on its website. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of TDDDG. Consent can be revoked at any time.

GOOGLE ANALYTICS

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on site, operating systems used and origin of the user. This data is summarised in a user ID and assigned to the respective terminal device of the website visitor.

Google Analytics uses technologies that enable the user to be recognised for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to a Google server in the USA and stored there.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/ .

IP Anonymisation

Google Analytics IP anonymisation is activated. As a result, your IP address is shortened by Google within Member States of the European Union or in other Contracting States to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services to the website operator relating to website use and internet use. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.

Browser Plug-in

You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en .

Further information on the handling of user data in Google Analytics can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en .

Demographic features in Google Analytics

This website uses the «demographic features» function of Google Analytics in order to be able to show website visitors suitable advertisements within the Google advertising network. This makes it possible to create reports containing statements about the age, gender and interests of site visitors. This data comes from interest-based advertising by Google as well as from visitor data from third-party providers. This data cannot be attributed to a specific person. You can deactivate this function at any time via the ad settings in your Google account, or generally prohibit the collection of your data by Google Analytics, as described under «Objection to data collection».

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

MATOMO

This website uses the open source web analytics service Matomo.

With the help of Matomo, we are able to collect and analyse data on the use of our website by website visitors. This enables us, among other things, to find out when which page views took place and from which region they came. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors carry out certain actions (e.g. clicks, purchases and the like).

The use of this analytics tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its online offering and its advertising. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of TDDDG. Consent can be revoked at any time.

IP anonymisation

When analysing with Matomo, we use IP anonymisation. Your IP address is shortened before analysis, so that it can no longer be clearly attributed to you.

Cookieless analytics

We have configured Matomo so that it does not store any cookies in your browser.

Hosting

We host Matomo exclusively on our own servers, so that all analytics data remains with us and is not passed on.

PLAUSIBLE ANALYTICS

We use Plausible Analytics on our website. The provider is Plausible Insights OÜ, Västriku tn 2, 50403, Tartu, Estonia.

Plausible Analytics enables us to analyse the behaviour of our website visitors. For this purpose, the following data is primarily collected: page URL, HTTP request, HTTP referrer, browser, operating system, device type and IP address. HTTP request and IP address are stored in a hash for 24 hours; within this period, a user can be recognised if they return to the website. Identification of the person is not possible.

Where consent has been obtained, the use of the above-mentioned service takes place exclusively on the basis of Art. 6(1)(a) GDPR and Section 25 TDDDG. Consent can be revoked at any time. Where no consent has been obtained, the use of this service takes place on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the most meaningful possible analysis of the user behaviour of our website visitors.

GOOGLE ADS

The website operator uses Google Ads. Google Ads is an online advertising programme of Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Targeted advertisements can also be displayed on the basis of user data available at Google (e.g. location data and interests) (audience targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to the display of our advertisements and how many ads led to corresponding clicks.

Data transfers to the USA are based on the Standard Contractual Clauses of the EU Commission. You can find details here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.

7. PLUG-INS AND TOOLS

GOOGLE FONTS (LOCAL HOSTING)

This site uses so-called Google Fonts, provided by Google, for the consistent display of fonts. The Google Fonts are installed locally. No connection to Google servers takes place.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en .