Privacy Statement

This privacy statement provides information about the personal data we process in connection with our activities and operations, including our sentience.ch website. In particular, we provide information on what personal data we process, for what purpose, how and where. We also provide information about the rights of individuals whose data we process.

We may publish further privacy policies or other information regarding data protection for specific or additional activities and services.

We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). In its Decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. In its Report of 15 January 2024, the European Commission confirmed this adequacy decision.

1. Contact addresses

Responsible for the processing of personal data:

Sentience
4000 Basel

vasb@fragvrapr.pu

In individual cases, third parties may be responsible for the processing of personal data, or joint responsibility with third parties may exist. Upon request, we will be happy to provide data subjects with information about the respective responsibility.

2. Definitions and legal basis

2.1 Definitions

Data subject: A natural person whose personal data we process.

Personal data: Any information relating to an identified or identifiable natural person.

Sensitive personal data: Data concerning trade union, political, religious or philosophical views and activities; data concerning health, intimate sphere, or affiliation with an ethnicity or race; genetic data; biometric data that uniquely identify a natural person; data relating to criminal or administrative sanctions or proceedings; and data relating to social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as retrieving, matching, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, deleting, providing, arranging, organising, storing, modifying, disseminating, linking, destroying and using personal data.

The European Economic Area (EEA) comprises the Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.

2.2 Legal basis

 

We process personal data in accordance with Swiss  law, in particular the Federal Data Protection Act (FADP) and the Ordinance on Data Protection (FADP).

Where and to the extent that the European General Data Protection Regulation (GDPR) applies, we process personal data on the basis of at least one of the following legal bases:

  • Art. 6 Paragraph 1 Letter b GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for carrying out pre-contractual measures.
  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests – including the legitimate interests of third parties – provided that the fundamental freedoms and fundamental rights, as well as the interests of the data subject, do not override those interests. Such interests include, in particular, the long-term, human-centered, secure and reliable conduct of our activities, ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law..
  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data[1]  for the fulfilment of a legal obligation to which may be subject to the 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 that is in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
  • Article 6(1)(d) of the GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.
  • Article 9(2) et seq[2] . of the GDPR regarding the processing of special categories of personal data, in particular with the consent of the data subjects.

 

The European General Data Protection Regulation (GDPR) defines the handling of personal data as the processing of personal data and the handling of sensitive personal data as the processing of special categories of personal data (Article 9 GDPR).

3. Nature, scope and purpose of the processing of personal data

We process the personal data necessary to carry out our activities and operations in a long-term, human-centred, secure and reliable manner. The personal data processed may, in particular, fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data, including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of carrying out our activities and operations, insofar as such processing is permitted.

We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example in order to comply with legal obligations or to safeguard overriding legitimate interests. We may also request the consent of data subjects even where such consent is not required.

We process personal data for as long as is necessary for the respective purpose. In particular, we anonymise or delete personal data depending on applicable statutory retention and limitation periods

4. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, include specialised service providers whose services we use. These third parties may in turn disclose personal data to other third parties.

As part of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, public authorities, educational and research institutions, consultants and legal advisors, accounting and fiduciary service providers, debt collection agencies, interest groups, IT service providers, cooperation partners, credit reference and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurance providers, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, as well as with public authorities, organisations and companies. In doing so, we process, in particular, data that a data subject provides to us when contacting us, for example by post or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data relating to other individuals are legally obliged to ensure the data protection of those data subjects themselves. In particular, they must ensure that they are authorised to provide such data and must also guarantee the accuracy of the data provided.

We use selected services from suitable providers to facilitate and improve communication with individuals and other communication partners. We may also use such services to manage and otherwise process the data of data subjects beyond the scope of direct communication, for example in connection with orders, services, projects and resource planning.

In particular, we use:

bexio: Customer Relationship Management (CRM); Provider: bexio AG (Switzerland); Information on data protection:

Privacy Policy, ‘Cloud and Data Security’, ‘Data Security – Definition and Measures for Businesses’ .

6. Job applications

We process personal data about applicants to the extent that it is necessary for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular in accordance with Art. 9 Paragraph 2 Letter b GDPR.

7. Data Security

We take appropriate technical and organizational measures to ensure data security that is appropriate to the respective risk. In particular, our measures ensure the confidentiality, availability, traceability and integrity of the personal data processed, although we cannot guarantee absolute data security.

Access to our website and other digital presence is protected by transport encryption (SSL / TLS, in particular via the Hypertext Transfer Protocol Secure, HTTPS). Most browsers warn users when a website is accessed without transport encryption.

Like all digital communication, our digital communication may be subject to mass surveillance without cause or suspicion by security authorities in Switzerland, other European countries, the United States of America (USA), and other countries. We have no direct influence on the processing of personal data by intelligence services, police authorities, or other security agencies. We also cannot exclude the possibility that an individual may be specifically monitored.

8. Personal data abroad

We process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.

We may export personal data to all States and territories on earth as well as elsewhere in the universe provided that the law there ensures adequate data protection in accordance with the Decision of the Swiss Federal Council – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with the  Decision of the European Commission.

We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular by way of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection law requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information on any guarantees or a copy of any guarantees on request.

9. Rights of data subjects

9.1 Data Protection Claims

We grant data subjects all claims in accordance with applicable data protection law. Data subjects have the following rights in particular:

Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Affected persons also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the processed personal data as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
Correction and limitation: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.

Opportunity to express one’s own point of view and to obtain human review: Data subjects may, in the case of decisions based solely on automated processing of personal data that produce legal effects concerning them or similarly significantly affect them (automated individual decision-making), express their point of view and request a review by a human.

Deletion and objection: Affected persons can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
Data release and data transmission: Affected persons can request the release of personal data or the transfer of their data to another person responsible.
We may suspend, restrict or refuse to exercise the rights of data subjects to the extent permitted by law. We can inform affected persons of any requirements that need to be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part with reference to trade secrets or the protection of other persons. For example, we can also refuse to delete personal data in whole or in part with reference to legal retention requirements and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.

Correction and restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed and the processing of their data restricted.

Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.

Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

We may suspend, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can inform data subjects of any requirements they must meet in order to exercise their rights under data protection law. For example, we may refuse to provide the information in whole or in part on the grounds of confidentiality obligations, overriding interests or the protection of other individuals.

We may exceptionally provide for costs for the exercise of rights. We inform data subjects in advance of any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

9.2 Right of appeal

Affected persons have the right to enforce their data protection claims through legal action or to lodge a complaint with a responsible data protection supervisory authority. The data protection supervisory authority for private parties responsible and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, affected persons have the right to lodge a complaint with a responsible European data protection supervisory authority.

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB).

In some Member States of the European Economic Area (EEA), supervisory authorities are structured on a federal basis, in particular in Germany.

10. Use of the Website

10.1 Cookies

We may use cookies. Cookies – our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that are stored in the browser. Such stored data need not be limited to traditional text-based cookies.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies – at least if and to the extent necessary.

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 AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

10.2 Server log files

We may log at least the following information for every visit to our website and other digital platforms, provided that this information is automatically generated or transmitted to our digital infrastructure during such visits:

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 log such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence remains available on a permanent, user-friendly and reliable basis. It is also necessary to ensure data security – including through third parties or with the assistance of third parties.

 

10.3 Tracking pixelsWe may integrate tracking pixels into our digital presence. .

Tracking pixels are also referred to as web beacons. Tracking pixels—including those from third parties whose services we use—are typically small invisible images or JavaScript-based scripts that are automatically retrieved when accessing our digital presence.

Tracking pixels can be used to collect at least the same information as is recorded in log files

10.4 Comments

We enable you to post comments on our website. In this context, we process in particular the information that a commenting person voluntarily submits to us, as well as the IP address used and the date and time. This information is required to enable the publication of comments and to ensure protection against misuse, which constitutes our overriding legitimate interest.

To enable you to publish comments, we use in particular:

●      Disqus: Discussion platform for websites; provider: Disqus Inc. (USA); data protection information:

Disqus Privacy Policy | Disqus

Disqus Data Sharing Settings privacy policy, opt-out of interest-based and personalised advertising (“Data Sharing Settings”)

Privacy FAQ

11. Notifications and Messages

11.1 Performance and reach measurement

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

11.2 Consent and Objection

In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons.

We may use the ‘double opt-in’ procedure to obtain double-confirmed consent where necessary. In this case, you will receive a message containing instructions for double confirmation.

We may log obtained consents, including IP address and timestamp, for evidentiary and security purposes.

In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is without prejudice to necessary notifications and communications in connection with our activities and operations.

11.3 Service providers for notifications and communications

We send notifications and communications with the help of specialised service providers.

In particular, we use:

  • Brevo (formerly Sendinblue): Platform for email marketing, SMS distribution, and CRM services. Provider: Sendinblue SAS, 7 rue de Madrid, 75008 Paris, France. Data protection information: Privacy policy, information on data retention and GDPR compliance, data processing within the EU.
  • SendGrid: Platform for transactional emails (“emailing made easy”); Providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland); Data protection information: Privacy policy.

12. Social media

We are present on social media platforms and other online platforms in order to be able to communicate with interested persons and to inform them about our activities and operations. In connection with such platforms 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 platforms also apply in each case. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are – if and insofar as the General Data Protection Regulation (GDPR) is applicable – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provides information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook, as well as Facebooks’s data protection officer, can be found in the Facebook privacy policy. With the so-called “Responsible Party Addendum” with Facebook and in particular agreed that Facebook is responsible for ensuring the rights of data subjects. For the so-called page insights, the relevant information can be found on the page «Page Insights Information» including «Page Insights Data Information».

13. Third-party services

We use the services of specialised third parties in order to carry out our activities and operations in a sustainable, human-centered, secure and reliable manner. Such services allow us to, among other things, embed features and content on our website. As a result of such embedding, the services used record the users’ Internet Protocol (IP) addresses for technically necessary purposes at least temporarily.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.

We use in particular:

13.1 Digital infrastructure

We use the services of specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

13.2 Automation and integration of apps and services

We use specialised platforms to integrate and connect existing third-party apps and services. We may use such “no-code” platforms to We also automate processes and activities with third-party apps and services.

In particular, we use:

13.3 Audio and Video Conferencing

We use specialised audio and video conferencing services to communicate online. For example, we can hold virtual meetings or conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services such as data protection declarations and terms of use apply in addition.

Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences as well as blurring the background or having a virtual background superimposed.

We use in particular:

13.5 Online collaboration

We use the services of third parties to enable online collaboration. In addition to this privacy statement, any directly visible terms and conditions of the services used, such as terms of use or privacy statements, also apply.

We use in particular:

13.6 Digital audio and video content

We use services provided by specialised third parties to embed digital content into our website. Digital content includes, in particular, images and video material, music, and podcasts.

In particular, we use:

13.7 Payments

We use specialised service providers to process payments from our customers securely and reliably. The legal texts of the individual service providers, such as the General Terms and Conditions (GTC) or data protection declarations, also apply to the processing of payments.

We use in particular:

13.8 Advertising

We use the option of displaying targeted advertising for our activities and operations via third parties such as social media platforms and search engines.

With such advertising, we would like to reach in particular people who are already interested in our activities and operations or who might be interested in them (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 online offer to your profile there.

We use in particular:

  • Google Ads: Google Ads: Search engine advertising; Provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, using different domain names – in particular, doubleclick.net, googleadservices.com and googlesyndication.com – for Google Ads, “Advertising” (Google), “Advertising” (Google), “Why do I see a particular advertisement?”.
  • Meta advertising (Meta Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Meta pixel as well as Custom Audiences including Lookalike Audiences, Data protection, “Advertising preferences” (Registration as a user required).

14. Website Extensions

We use extensions to our website to enable us to use additional features. We may use selected services provided by suitable providers or deploy such extensions on our own digital infrastructure.

In particular, we use:

15. Success and reach measurement

We aim to measure the success and reach of our activities and operations.In this context, we may also measure the effectiveness of references from third parties or analyse how different sections or versions of our digital presence are used (“A/B testing” method). Based on the results of success and reach measurement, we may in particular correct errors, strengthen popular content, or implement improvements.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and reach measurement. In this case, IP addresses are always shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymisation.

Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.

 

We use in particular:

  • AWStats: Performance and reach measurement; Developer: (free open source software); Data protection information: Analysis of server log files on our own server infrastructure, «What is AWStats / Features Overview».
  • Google Marketing Platform:  Measurement of performance and reach, particularly using; Google Analytics-specific: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, Data protection”, “Browser add-on to deactivate Google Analytics”.
  • Google Tag Manager: Google Tag Manager: Integration and management of other services for performance and reach measurement as well as other services from Google and third parties; provider: Google; Google Tag Manager-specific information: Data collected with Google Tag Manager further information on data protection can be found with the individual integrated and managed services.

14. Final provisions

We may update this data protection policy at any time. We will notify you of any updates in an appropriate manner, in particular by publishing the latest version of the privacy policy on our website.

“This Privacy Policy is an unofficial translation from the original German language version.”