General Contract and Travel Conditions
The General Terms and Conditions apply to all future services to be provided by CT for the benefit of legal or natural persons ("Customer [s]").
1. Contact Addresses
Responsibility for the processing of personal data:
We point out when there are other responsible parties for the processing of personal data in specific cases.
1.1 Data Protection Officer or Data Protection Advisor
We have the following Data Protection Officer or the following Data Protection Advisor as the contact point for affected individuals and authorities for inquiries related to data protection:
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
The Data Protection Representation serves as an additional contact point for affected individuals and authorities in the European Union (EU) and other parts of the European Economic Area (EEA) for inquiries related to the GDPR.
2. Definitions and Legal Bases
Personal data refers to all information relating to an identified or identifiable natural person. An affected person is a person whose personal data we process.
Processing includes every handling of personal data, regardless of the means and methods used, such as accessing, matching, adjusting, archiving, retaining, reading, disclosing, acquiring, recording, collecting, deleting, revealing, arranging, organizing, storing, changing, distributing, 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. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personally identifiable data.
2.2 Legal Bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (Datenschutzgesetz, DSG) and the Data Protection Ordinance (Datenschutzverordnung, DSV).
We process – if and to the extent the General Data Protection Regulation (GDPR) applies – personal data based on at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the affected person as well as for carrying out pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to protect our or third-party legitimate interests, unless the fundamental freedoms and rights and interests of the affected person prevail. Legitimate interests include our interest in carrying out our activities and operations sustainably, user-friendly, securely, and reliably and to communicate about them, ensuring information security, protection against misuse, enforcement of our legal claims, and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to comply with a legal obligation to which we may be subject according to the law of member states in the European Economic Area (EEA).
- Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data to perform a task in the public interest.
- Art. 6 para. 1 lit. a GDPR for processing personal data with the consent of the affected person.
- Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the affected person or another natural person.
3. Type, Scope and Purpose
We process those personal data that are essential to carry out our activities and tasks continuously, user-friendly, safely, and reliably. Such personal data can particularly be categorized into inventory and contact data, browser and device data, content data, meta or secondary data, usage data, location data, sales data, and contractual and payment data.
We process personal data for the duration required for the respective purpose or purposes or as mandated by law. Personal data that is no longer necessary for processing is anonymized or deleted.
We may have personal data processed by third parties. We can process personal data together with third parties or transfer it to third parties. Such third parties are especially specialized providers whose services we utilize. We also ensure data protection with such third parties.
We process personal data fundamentally only with the consent of the affected individuals. If and insofar as processing is permissible for other legal reasons, we may refrain from obtaining consent. We might, for instance, process personal data without consent to fulfill a contract, comply with legal obligations, or safeguard overriding interests.
In this context, we primarily process details voluntarily provided to us by an individual when establishing contact – for example, by postal mail, email, instant messaging, contact form, social media, or telephone – or when registering for a user account. We might store such details in an address book, a Customer-Relationship-Management system (CRM system), or with comparable tools. When we receive data about other individuals, the individuals providing the data are obliged to ensure data protection for these persons and to verify the accuracy of this personal data.
We also process personal data that we obtain from third parties, acquire from publicly accessible sources, or collect during our activities and tasks, provided and insofar as such processing is permitted for legal reasons.
4. Personal Data Abroad
We fundamentally process personal data in Switzerland and the European Economic Area (EEA). However, we can also export or transfer personal data to other countries, especially to process or have them processed there.
We can export personal data to all countries and territories on Earth and elsewhere in the universe, provided the law there ensures adequate data protection according to the decision of the Swiss Federal Council and – if and insofar as the General Data Protection Regulation (GDPR) applies – according to the decision of the European Commission.
We may transfer personal data to countries whose law does not ensure adequate data protection, as long as data protection is ensured for other reasons, especially based on standard data protection clauses or other appropriate guarantees. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the specific data protection legal prerequisites are met, for example, the express consent of the affected individuals or a direct relation to the conclusion or processing of a contract. We will gladly provide affected individuals with information about possible guarantees upon request or provide a copy of any such guarantees.
5. Rights of Affected Individuals
5.1 Data Protection Claims
We grant individuals all claims in accordance with applicable data protection law. Specifically, affected individuals have the following rights:
- Access: Affected individuals can request information on whether we process personal data about them, and if so, which personal data. Affected individuals also receive information necessary to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also details about the purpose of processing, the duration of storage, any potential disclosure or potential export of data to other countries, and the origin of the personal data.
- Correction and Restriction: Affected individuals can correct inaccurate personal data, complete incomplete data, and request the restriction of the processing of their data.
- Deletion and Objection: Affected individuals can request the deletion of personal data ("Right to be Forgotten") and object to the processing of their data, effective for the future.
- Data Release and Data Transfer: Affected individuals can request the release of personal data or the transfer of their data to another responsible entity.
We may postpone, limit, or deny the exercise of rights by affected individuals within the legally permissible framework. We may inform affected individuals about any prerequisites that must be met for them to exercise their data protection claims. For example, we may deny access referring to trade secrets or the protection of other persons. We may also deny the deletion of personal data, citing statutory retention obligations.
We may, exceptionally, charge fees for the exercise of rights. We will inform affected individuals in advance of any potential costs.
We are obliged to identify affected individuals who request information or assert other rights using appropriate measures. Affected individuals are obliged to cooperate.
5.2 Right to Complain
Individuals have the right to enforce their data protection claims through legal means or to file a complaint with a competent data protection supervisory authority.
The supervisory authority for private entities and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).
Individuals, where and when the General Data Protection Regulation (GDPR) applies, have the right to file a complaint with a competent European data protection supervisory authority.
6. Data Security
We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. However, we cannot guarantee absolute data security.
Access to our website is secured using transport encryption (SSL / TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subjected to – as is generally the case with all digital communication – mass surveillance without specific reason or suspicion and other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police agencies, and other security authorities.
7. Website Use
Cookies can be stored temporarily in the browser as "Session Cookies" or for a specific period as so-called permanent cookies. "Session Cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies particularly allow a browser to be recognized during a subsequent visit to our website, for instance, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
For cookies used for success 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).
7.2 Server Log Files
We may record the following details for each access to our website, provided they are transmitted from your browser to our server infrastructure or can be determined by our web server: 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, the specific sub-page of our website accessed including the amount of data transferred, and the last web page accessed in the same browser window (referer or referrer).
We store such details, which may also be personal data, in server log files. This information is necessary to ensure our website remains consistent, user-friendly, and reliable, and to ensure data security, especially the protection of personal data – even through third parties or with the help of third parties.
7.3 Tracking Pixels
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels - including those from third parties whose services we use - are small, typically invisible images that are automatically retrieved when visiting our website. The same details as in server log files can be captured with tracking pixels.
8. Notifications and Communications
We send notifications and messages via email and other communication channels, such as instant messaging or SMS.
8.1 Performance and Reach Measurement
Notifications and messages may contain web links or tracking pixels that record whether a single message was opened and which web links were clicked. Such web links and tracking pixels can also record the use of notifications and messages on an individual basis. We need this statistical recording of usage for performance and reach measurement, to send notifications and messages based on the needs and reading habits of the recipients in an effective, user-friendly, consistent, secure, and reliable manner.
8.2 Consent and Objection
You must generally expressly consent to the use of your email address and your other contact addresses, unless their use is permitted for other legal reasons. Where possible, we use the "double opt-in" method for consent, meaning you will receive an email with a web link that you must click to confirm, preventing misuse by unauthorized third parties. We can log such consents including the IP address as well as date and time for evidence and security reasons.
You can generally object to receiving notifications and messages, such as newsletters, at any time. With such an objection, you can also object to the statistical recording of usage for performance and reach measurement. Notifications and messages necessary in connection with our activities and operations remain reserved.
8.3 Service Providers for Notifications and Communications
We send notifications and messages with the help of specialized service providers.
Specifically, we use:
9. Social Media
We are present on social media platforms and other online platforms to communicate with interested individuals and to inform about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
For our social media presence on Facebook, including the so-called Page Insights, we are - where and when the General Data Protection Regulation (GDPR) applies - jointly responsible with Meta Platforms Ireland Limited (Ireland). The Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide insights into how visitors interact with our Facebook presence. We use Page Insights to effectively and user-friendly deliver our social media presence on Facebook.
10. Third-Party Services
We use services from specialized third parties to carry out our activities and operations continuously, user-friendly, securely, and reliably. With such services, we can, among other things, embed functions and content into our website. When embedding, for technical reasons, the used services capture at least temporarily the IP addresses of users.
For required security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized manner. This may include performance or usage data to offer the respective service.
We particularly use:
10.1 Digital Infrastructure
We use services from specialized third parties to access the required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We particularly use:
10.2 Contact Options
We use services from selected providers to better communicate with third parties such as potential and existing customers.
10.3 Online Collaboration
We use, in particular:
- Asana: Corporate collaboration platform; Provider: Asana Inc. (USA); Privacy details: "Trust at Asana", Privacy Statement, Bug-Bounty Program.
10.4 Map Material
We use third-party services to embed maps into our website.
We use, in particular:
- Outdooractive: Map service; Provider: Outdooractive AG (Germany); Privacy details: Privacy Statement.
10.5 Digital Audio and Video Content
We use services from specialized third parties to enable the direct playback of digital audio and video content, such as music or podcasts.
We use, in particular:
- YouTube: Video platform; Provider: Google; Specific YouTube details: "Privacy and Security Center", "My Data on YouTube".
We use third-party services to embed documents into our website. Such documents can include, for example, forms, PDF files, presentations, spreadsheets, and text documents. We can not only enable viewing but also editing or commenting on such documents.
We operate e-commerce and use third-party services to successfully offer services, content, or goods.
We use, in particular:
We use specialized service providers to securely and reliably process our customers' payments. Additional legal texts of individual service providers, such as Terms and Conditions (T&C) or privacy statements, apply for payment processing.
We use, in particular:
- TWINT: Payment processing in Switzerland; Provider: TWINT AG (Switzerland); Privacy details: Privacy Statement, "Security according to Swiss standards".
- Worldline: Payment processing, especially with mobile payment solutions; Providers: Worldline Financial Services (Europe) SA (France) and other Worldline companies; Privacy details: General Privacy Statement, Privacy Statement of Worldline Financial Services (Europe) SA, "Security in cashless payments".
We use the option to display advertisements for our activities and operations to third parties such as social media platforms and search engines.
With such advertising, we particularly aim to reach individuals who are already interested in our activities and operations or might be interested (Remarketing and Targeting). For this, we may transmit corresponding – possibly also personal – information to third parties enabling such advertising. We can also determine whether our advertising is effective, especially if it leads to visits to our website (Conversion Tracking).
Third parties where we advertise, and where you as a user are registered, may associate the use of our website with your respective profile there.
We particularly use:
- Google Ads: Search engine advertising; Provider: Google; Specific Google Ads information: advertising based on search queries, using various domain names – especially doubleclick.net, googleadservices.com, and googlesyndication.com for Google Ads, "Advertising" (Google), "Why am I seeing this ad?".
11. Success and Reach Measurement
We attempt to determine how our online offer is used. In this context, we can, for instance, measure the success and reach of our activities and operations and the impact of third-party links on our website. We might also experiment with and compare how different parts or versions of our online offer are used (the "A/B test" method). Based on the results of the success and reach measurement, we can particularly fix errors, reinforce popular content, or make improvements to our online offering.
In most cases, the IP addresses of individual users are stored for success and reach measurement. In this case, IP addresses are generally abbreviated ("IP-Masking") to follow the principle of data minimization.
For success and reach measurement, cookies may be used, and user profiles may be created. Any created user profiles typically include, for example, the individual pages visited or content viewed on our website, information about screen size or browser window, and the – at least approximate – location. Generally, potential user profiles are created in a pseudonymized form and are not used to identify individual users. Some third-party services, where users are registered, may associate the use of our online offer with the user's account or profile at the respective service.
We particularly use:
- Google Analytics: Success and reach measurement; Provider: Google; Specific Google Analytics information: measurement across different browsers and devices (Cross-Device Tracking), as well as with pseudonymized IP addresses, which are only exceptionally transmitted in full to Google in the US, "Privacy", "Browser Add-on to Deactivate Google Analytics".
- Google Tag Manager: Integration and management of other services for success and reach measurement as well as other Google services and third-party services; Provider: Google; Specific Google Tag Manager information: "Data Collected with Google Tag Manager"; further privacy information can be found in the individual integrated and managed services.
12. Video Surveillance
We use video surveillance for the prevention of criminal acts and for evidence collection in the event of crimes, as well as for exercising our property rights. This represents — if and when the General Data Protection Regulation (GDPR) is applicable — our predominant legitimate interests according to Art. 6 Para. 1 lit. f GDPR.
We store recordings from our video surveillance for as long as they are needed for evidence collection. Typically, the recordings are deleted or overwritten after 24 hours.
We may preserve recordings due to legal obligations, to assert our legal rights, and in suspicion of criminal acts, as well as transmit them to competent authorities, especially judicial or law enforcement agencies.
13. Final Provisions