Data protection

This privacy policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name spp.ch. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

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We may publish further data protection declarations or other information on data protection for individual or additional activities and operations.

We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

In its decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures adequate data protection. The European Commission confirmed this adequacy decision in its report of 15 January 2024.

1. contact addresses

Responsible in the sense of data protection law:

Lawyer John Burns

Swiss Physio Partner AG
Haldenstrasse 5
6340 Baar

In individual cases, third parties may be responsible for the processing of personal data or there may be joint responsibility with third parties. We are happy to provide data subjects with information about the respective responsibility on request.

1.1 Data protection officer or data protection consultant

We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities for enquiries relating to data protection:

Lawyer John Burns
Burns Legal
Limmatquai 80
8001 Zurich

1.2 Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR:

VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg Germany

The Data Protection Representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.

2. terms and legal bases

2.1 Terms
Data subject: Natural person about whom we process personal data.

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

Particularly sensitive personal data: Data concerning trade union, political, religious or philosophical opinions and activities, data concerning health, privacy or ethnic or racial origin, genetic data, biometric data uniquely identifying a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, collection, deletion, disclosure, organisation, storage, modification, dissemination, linking, destruction and use of personal data.

European Economic Area (EEA): 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 Act on Data Protection (Data Protection Act, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).

If and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process 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 fulfilment of a contract with the data subject and for the implementation of 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 - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of 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 to fulfil a legal obligation to which we are subject in accordance with 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 GDPR 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 in order to protect the vital interests of the data subject or another natural person.
Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

The European General Data Protection Regulation (GDPR) characterises the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

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

We process the personal data required to carry out our activities and operations in a sustainable, humane, secure and reliable manner. The personal data processed may 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 particularly 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 our activities and operations, insofar as such processing is permitted.

Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example to fulfil legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

We process personal data for the duration required for the respective purpose. We anonymise or delete personal data in particular depending on statutory retention and limitation periods.

4. automation and artificial intelligence (AI)

We may process personal data automatically or use artificial intelligence to process personal data.

We may use profiling to automatically evaluate certain personal aspects relating to data subjects. Profiling is used, for example, to analyse or predict interests, behaviour or personal preferences.

In individual cases, we provide information about decisions that are based exclusively on the automated processing of personal data and that have legal consequences for the data subjects or significantly affect them (automated individual decisions).

5. 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 are, in particular, specialised providers whose services we use.

For example, we may disclose personal data to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.

6. communication

We process personal data in order to be able to communicate with individuals and with authorities, organisations and companies. In particular, we process data that a data subject transmits to us when contacting us, for example by post or e-mail. We may store such data in an address book or with comparable tools.

Third parties who transmit data about other persons to us are obliged to independently ensure the data protection of these data subjects. In particular, they must ensure that such data is correct and may be transmitted.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We can also use such services to manage and otherwise process the data of data subjects beyond direct communication.

We use in particular:

Microsoft Dynamics 365: Customer Relationship Management (CRM); Service provider: Microsoft; Microsoft Dynamics-specific information: "Data protection and personal data in Microsoft Dynamics 365".
Pipedrive: Customer Relationship Management (CRM); Provider: Pipedrive OÜ (Estonia); Data protection information: Privacy Policy, "Data Controller and Data Processor". 7 Applications We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms. We also process the 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. We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR. We may allow applicants to enter their details in our talent pool so that they can be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant is suitable for a vacancy based on the information provided, we may inform the applicant accordingly. We use selected services from suitable third parties to advertise vacancies via e-recruitment and to facilitate and manage applications.

8. data security

We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee in particular the confidentiality, availability, traceability and integrity of the processed personal data, without being able to guarantee absolute data security.

Access to our website and our other digital presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting a website without transport encryption.

Our digital communication - like all digital communication in general - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance.

9. personal data abroad

We generally process personal data in Switzerland and 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 can export personal data to all countries on earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission.

We may transfer personal data to countries whose laws do not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.

10 Rights of data subjects 10.1 Data protection claims

We grant data subjects all rights in accordance with the applicable law. In particular, data subjects have the following rights:

Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also 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 can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
Possibility for own point of view and human review: In the case of decisions that are based exclusively on automated processing of personal data and are associated with a legal consequence for them or significantly affect them (automated individual decisions), data subjects can present their own point of view and request a review by a human being.
Erasure and objection: Data subjects can have their personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller. We may defer, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance.

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

10.2 Legal protection

Data subjects have the right to enforce their data protection claims by taking legal action or to lodge a complaint with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are organised on a federal basis, particularly in Germany.

11. use of the website 11.1 Cookies

We may use cookies. Cookies - our own cookies (first-party cookies) as well as 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 cookies in text form.

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. In particular, cookies make it possible to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

Cookies can be fully or partially deactivated, restricted or deleted at any time in the browser settings. The browser settings often also allow automated deletion and other management of cookies. 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 required by applicable law.

For cookies that are used to measure success and reach 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), YourAd- Choices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

11.2 Logging

We may log at least the following information for each access to our website and our other digital presence, insofar as this information is transmitted to our digital infrastructure during such accesses: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual subpage of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).

We record such information, which may also constitute personal data, in log files. The information is required to provide our digital presence in a permanent, user-friendly and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties.

11.3 Tracking pixels

We can integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to record at least the same information as is recorded in log files.

12. social media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information 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. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide 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 way.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data".

13. services of third parties

We use services from specialised third parties in order to be able to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the IP addresses of users at least temporarily for technically compelling reasons.

For necessary security, 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:

Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and in Switzerland; General information on data protection: "Privacy and security principles", "More information on how Google uses personal data", Privacy policy, "Google is committed to complying with applicable data protection laws", "Guide to privacy in Google products", "How we use data from websites or apps on or in which our services are used", "Types of cookies and similar technologies used by Google", "Advertising" ("Personalised advertising"). where our services are used", "Types of cookies and similar technologies Google uses", "Advertising you can control" ("Personalised advertising").
Services from Microsoft: Provider: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: "Data protection at Microsoft", "Data protection and privacy", Privacy Policy, "Data and privacy settings".

13.1 Digital infrastructure

We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

We use in particular: Microsoft Azure: storage space and other infrastructure; Provider: Microsoft; Microsoft

Azure-specific information: "Data protection in Azure".

WordPress.com: Blog hosting and website builder; Service provider: Automattic Inc (USA) / Aut O'Mattic A8C Ireland Ltd (Ireland) for users in Europe and elsewhere; Privacy Policy: Privacy Policy, Cookie Policy.

13.2 Automation and integration of apps and services

We use specialised platforms to integrate and connect existing apps and services from third parties. We can also use such "no-code" platforms to automate processes and activities with third-party apps and services.

We use in particular:

Microsoft Power Automate including Microsoft Power Platform: Integrated application platform; Provider: Microsoft; Microsoft Power Platform-specific information on data protection: "Compatibility and data protection", "Data storage and governance", "Security".
n8n: Platform for the integration of apps and services; Service provider: n8n GmbH (Germany); Privacy Policy: Privacy Policy, "Data protection and security".

13.3 Online collaboration

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

We use in particular:

Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; Service provider: Microsoft; Teams-specific information: "Security and compliance in Microsoft Teams", in particular "Data protection".

13.4 Social media functions and social media content

We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

We use in particular:

Facebook (social plugins): Embedding Facebook functions and Facebook content, for example "Like" or "Share"; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy policy.
Instagram platform: Embedding Instagram content; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy Policy: Privacy Policy (Instagram), Privacy Policy (Facebook).
LinkedIn Consumer Solutions Platform: Embedding functions and content from LinkedIn, for example with plugins such as the "Share Plugin"; Provider: Microsoft; LinkedIn-specific information: "Privacy", privacy policy, cookie policy, cookie management / objection to e-mail and SMS communication from LinkedIn, objection to interest-based advertising.
TikTok for Developers: Embedding of functions and content from TikTok, for example "Share to TikTok"; Provider: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / TikTok Inc. (USA) for users in the USA / TikTok Pte. Ltd. (Singapore) for most users in the rest of the world; Data protection information: Privacy Policy, "Children's Privacy Policy", "Privacy Policy for TikTok Partners", Cookie Policy.

13.5 Card material

We use third-party services to embed maps in our website.

We use in particular:

Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: "How Google uses location information".

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

In particular, we would like to use such advertising to reach 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 relevant - possibly also personal - data 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 with whom you are registered as a user may be able to assign the use of our website to your profile there.

We use in particular:

Google Ads: Search engine advertising; Service provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, whereby various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - are used for Google Ads, privacy policy for advertising, "Manage displayed adverts directly via ads".
LinkedIn Ads: Social media advertising; Service provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Privacy Policy: Remarketing and targeting in particular with the LinkedIn Insight Tag, "Privacy Policy", Privacy Policy, Cookie Policy, Objection to personalised advertising.
Meta adverts (Meta Ads): Social media advertising on Facebook and Instagram; Service provider: Meta Platforms Ireland Limited (Ireland) and other meta companies (including in the USA); Data protection information: Targeting, including retargeting, in particular with the meta pixel and with custom audiences including lookalike audiences, privacy policy, "Advertising preferences" (user registration required).
TikTok Ads: Social media advertising; Service provider: TikTok Information Technologies UK Limited (United Kingdom) and TikTok Technology Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / TikTok Inc. (USA) for users in the USA / TikTok Pte. Ltd. (Singapore) for most users in the rest of the world; Data protection information: Remarketing and targeting in particular with the TikTok pixel, Privacy Policy, "Children's Privacy Policy", "Privacy Policy for TikTok Partners", Cookie Policy.

14. success and reach measurement

We endeavour to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our digital presence are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements.

In most cases, the IP addresses of individual users are recorded to measure success and reach. In this case, IP addresses are generally shortened ("IP masking") in order to comply with the principle of data minimisation 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 digital presence, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are only created in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile with the respective service.

We use in particular:

Google Marketing Platform: Performance and reach measurement, in particular with Google Analytics; Service provider: Google; Google Marketing Platform-specific information: Measurement also across different browsers and devices (cross-device tracking) with pseudonymised IP addresses, which are only transmitted in full to Google in the USA in exceptional cases, privacy policy for Google Analytics, "Browser add-on to deactivate Google Analytics".
Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring success and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the individual integrated and managed services. 15. final notes on the data protection declaration We have created this data protection declaration with the data protection generator from Datenschutzpartner.

We may update this privacy policy at any time. We will inform you about updates in an appropriate form, in particular by publishing the current privacy policy on our website.