Privacy

PRIVACY POLICY OF HIGHSTEP SYSTEMS AG

October 2021 version

In this privacy policy, based on the DSAT (Data Protection Self Assessment Tool), we, HighStep Systems AG (hereinafter HighStep Systems AG, we or us), explain how we collect and otherwise process personal data.
This is not an exhaustive description; If necessary, other data protection declarations or general terms and conditions, conditions of participation and similar documents regulate specific matters. Personal data refers to all information that relates to a specific or identifiable person. 

If you provide us with personal data about other people (e.g. family members, data from work colleagues), please make sure that these people are aware of our data protection declaration here and only provide us with their personal data if you are allowed to do so and if this personal data is correct . 

This data protection declaration is aligned with the EU General Data Protection Regulation (GDPR). Although the GDPR is a European Union regulation, it is important to us. The Swiss Data Protection Act (DSG) is heavily influenced by EU law and companies outside the European Union or EEA must comply with the GDPR under certain circumstances. 

1. RESPONSIBLE / DATA PROTECTION OFFICER / REPRESENTATIVE

HighStep Systems AG is responsible for the data processing that we describe here, unless otherwise stated in individual cases. If you have any data protection concerns, you can let us know at the following contact address:

HighStep Systems AG
Silbernstrasse 10
CH-8953 Dietikon

info@highstepsystems.com

2. COLLECTION AND PROCESSING OF PERSONAL DATA 

We primarily process the personal data that we receive from these and other people involved as part of our business relationship with our customers and other business partners or that we collect from their users when operating our websites, apps and other applications. 

To the extent permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, internet) or receive such data from other companies within partnerships, from authorities and other third parties (such as credit reporting agencies). In addition to the data about you that you give us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with their professional functions and activities (so that we can, for example, conclude and process business transactions with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (if we conduct business with you personally), information about you that we provide to us Your environment (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as anti-money laundering and export restrictions , information from banks, insurance companies, sales and other contractual partners of ours regarding the use or provision of services by you (e.g. payments made, purchases made), information from the media and the Internet about you (if this is appropriate in the specific case, e.g. in As part of an application, author list, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, browser type and version, cookies, date and time of visit, pages and content accessed, functions used, referring website, location information). 

3. PURPOSES OF DATA PROCESSING AND LEGAL BASIS

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of the editorial services provided, the processing of advertising orders with our customers and the purchase of products and services from our suppliers subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity.

In addition, we process personal data from you and other persons, to the extent permitted and deemed appropriate to us, also for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offer and further development of our offers, services and websites, apps and other platforms on which we are present;
• Communicating with third parties and processing their inquiries (e.g. applications, media inquiries);
• Examination and optimization of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition; 
• Advertising and marketing (including the organization of events), unless you have objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then put you on a blocking list against further advertising); 
• Market and opinion research, media monitoring; 
• Assertion of legal claims and defense in connection with legal disputes and governmental proceedings; 
• Preventing and solving crimes and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud); 
• Warranties of our operations, in particular IT, our websites, apps and other platforms; 
• Video surveillance to protect house rules and other measures for IT, building and system security and to protect our employees and other people and assets belonging to or entrusted to us (such as access controls, visitor lists, network and email scanners, telephone records); 
• Purchase and sale of business areas, companies or parts of companies and other corporate transactions and the associated transfer of personal data as well as measures for business management and to comply with legal and regulatory obligations as well as internal regulations of HighStep Systems AG.

If you have given us your consent to process your personal data for specific purposes (for example when you register to receive newsletters or carry out a background check), we will process your personal data within the framework and based on this consent, unless we have another legal basis and we need one. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place. 

4. COOKIES / TRACKING AND OTHER TECHNOLOGIES RELATED TO THE USE OF OUR WEBSITE 

We typically use “cookies” and similar technologies on our websites and apps that can identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you are using when you visit our website or install a corresponding app. This way, when you visit this website or use our app again, we can recognize you, even if we don't know who you are. In addition to cookies that are only used during a session and are deleted after you visit the website (“session cookies”), cookies can also be used to store user settings and other information over a certain period of time (e.g. two years) (“permanent cookies.” "). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them early. Most browsers are preset to accept cookies. We use persistent cookies to save user settings (e.g. language, autologin), so that we can better understand how you use our offers and content and so that we can show you information, offers and advertising tailored to you (which is also the case on websites of other companies can happen; however, they will not find out from us who you are, if we even know that ourselves, because they only see that the same user is on their website who was also on a specific page on our site). Some of the cookies are set by us, and some are also set by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, login) may no longer work. 

In some of our newsletters and other marketing emails, and where permitted, we also include visible and invisible image elements, by retrieving them from our servers we can determine whether and when you have opened the email, so that we can also measure here and better understand how to use our offerings and tailor them to you. You can block this in your email program; most are preset to allow you to do this.

By using our websites, apps and agreeing to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not want this, you must set your browser or email program accordingly.

We sometimes use Google Analytics or comparable services such as Matomo on our websites. This is a service provided by third parties who may be located in any country in the world (in the case of Google Analytics, it is Google LLC in the USA, www.google.com, in the case of Matomo it is Innocraft Ltd. in New Zealand, www.innocraft.com), with which we can measure and evaluate the use of the website (not personal). Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (nor does it retain IP addresses), but may track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by the service provider, and use these insights for your own purposes (e.g. control of advertising). If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection regulations. The service provider only tells us how our website is used (no information about you personally).

We also use so-called plug-ins from social networks such as Xing, Linkedin, Facebook, Twitter, YouTube, Vimeo, Google+, Pinterest or Instagram on our websites. This is clear to you in each case (typically via corresponding symbols). We have configured these elements to be disabled by default. If you activate it (by clicking on it), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection regulations. We do not receive any information about you from him. 

5. DATA TRANSFER AND DATA TRANSFER ABROAD 

As part of our business activities and the purposes set out in Section 3, we also disclose data to third parties, to the extent permitted and deemed appropriate to us, either because they process it for us or because they use it for their own purposes want. This particularly concerns the following positions:

• Our service providers (such as banks, insurance companies), including order processors (such as IT providers); 
• dealers, suppliers, subcontractors and other business partners; 
• Customers; 
• Domestic and foreign authorities, offices or courts; 
• Media; 
• the public, including visitors to websites and social media; 
• Competitors, industry organizations, associations, organizations and other committees; 
• Acquirers or interested parties in acquiring business areas, companies or other parts of HighStep Systems AG; 
• other parties in potential or actual legal proceedings; 
• Other partners or companies of HighStep Systems AG; 

all common recipients. 

These recipients are partly domestic, but can be anywhere on earth. In particular, you must expect your data to be transmitted to all countries in which HighStep Systems AG is represented by partners or other offices as well as to other countries in Europe and the USA where the service providers we use are located (such as: Adobe, Fonts.com, Microsoft, Nine, Typo3). If we transfer data to a country without adequate legal data protection, we will ensure this as required by law by using appropriate contracts (namely based on the so-called standard contractual clauses of the European Commission, which here, here and here are available) or so-called Binding Corporate Rules for an appropriate level of protection or rely on the legal exceptions of consent, contract execution, the determination, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the affected persons is necessary. You can obtain a copy of the contractual guarantees mentioned at any time from the contact person named in section 1, unless they are available at the link provided above. However, we reserve the right to black out copies or only provide extracts for data protection reasons or reasons of confidentiality. 

6. DURATION OF STORAGE OF PERSONAL DATA 

We process and store your personal data for as long as it is necessary to fulfill our contractual and legal obligations or for other purposes pursued by the processing, i.e. for example for the duration of the entire business relationship (from initiation, processing to termination of a contract) as well as in accordance with the legal retention and documentation obligations. It is possible that personal data will be retained for the period in which claims can be asserted against our company and to the extent that we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidentiary and documentation purposes). As soon as your personal data is no longer required for the purposes mentioned above, it will generally be deleted or anonymized as far as possible. For operational data (e.g. system logs, logs), shorter retention periods of twelve months or less apply. 

7. DATA SECURITY 

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, controls. 

8. OBLIGATION TO PROVIDE PERSONAL DATA

As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or process a contract with you (or the entity or person you represent). The website cannot be used if certain information to ensure data traffic (such as IP address) is not disclosed.

9. PROFILING

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to provide you with targeted information and advice about products. We use evaluation tools that enable us to communicate and advertise as needed, including market and opinion research. 

In principle, we do not use fully automated automatic decision-making (as regulated in Art. 22 GDPR) to establish and implement the business relationship or otherwise. If we use such procedures in individual cases, we will inform you about this separately, provided this is required by law and inform you about the associated rights.

10. RIGHTS OF THE DATA SUBJECT 

Within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, as well as to the release of certain personal data for the purpose of transfer to another location (so-called data portability). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (to the extent that we are entitled to rely on this) or use them for the assertion of requirements. If you incur any costs, we will inform you in advance. We have already provided information about the possibility of revoking your consent in Section 3. Please note that exercising these rights may conflict with contractual agreements and this may have consequences such as early termination of the contract or cost consequences. We will inform you in advance if this is not already contractually stipulated. 

The exercise of such rights generally requires that you provide clear proof of your identity (e.g. by providing a copy of your ID, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in Section 1.

Every data subject also has the right to enforce their claims in court or to file a complaint with the responsible data protection authority. The responsible data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. CHANGES 

We may amend this privacy (data protection) policy at any time without prior notice. The current version published on our website applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change by email or other suitable means in the event of an update.