Logo HOMM interactive GmbH

Privacy policy

In this privacy policy, we provide information on which personal data we process in connection with our activities and operations, including our www.wicato.ch-Website. 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.

Further data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply to individual or additional activities and operations.

We are subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law guarantees adequate data protection.

1. Contact addresses

Responsibility for the processing of personal data:

HOMM interactive GmbH
HOMM interactive GmbH
Winkelriedstrasse 35
6003 Lucerne

mail@homm.ch

We would like to point out if there are other controllers for the processing of personal data in individual cases.

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
Hamburg, Germany

info@datenschutzpartner.eu

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 in connection with the GDPR.

2. Terms and legal bases

2.1 Definitions

Personal data means any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, 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. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal bases

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

If and insofar as the 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 GD PR 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 protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply 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 under any applicable law of member states in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary 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.

3. Type, scope and purpose

We process the personal data required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.

We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.

We only process personal data with the consent of the data subjects . If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example by post, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information in an address book, in a customer relationship management system (CRM system) or with comparable tools, for example. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection for these persons and to ensure the accuracy of this 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, if and to the extent that such processing is permitted by law.

4. Job applications

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent performance 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 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.

5. 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 may export personal data to all countries and territories on earth and elsewhere in the universe, provided that the local law 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 - 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 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 on request.

6. Rights of data subjects

6.1 Claims under data protection law

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

  • Information: Data subjects may 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.
  • 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 surrender 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 business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects 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 co-operate.

6.2 Right to lodge a complaint

Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent 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 ).

Data subjects have the right - if and insofar as the General Data Protection Regulation (GDPR) is applicable - to lodge a complaint with a competent European data protection supervisory authority.

7. Data security

We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication - like all digital communication - is subject to mass surveillance without cause or suspicion and other surveillance 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.

8. Use of the website

8.1 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. 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.

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), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Server log files

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: 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, last website accessed in the same browser window (referrer or referrers).

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

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

9. Notifications and messages

We send notifications and messages by email and via other communication channels such as instant messaging or SMS.

9.1 Measuring success and reach

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages effectively and in a user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

9.2 Consent and objection

You must always expressly consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the "double opt-in" procedure to obtain consent, i.e. you will receive an email with a web link that you must click on to confirm, so that no misuse by unauthorised third parties can occur. We may log such consents, including the Internet Protocol (IP) address, date and time, for reasons of proof and security.

In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.

9.3 Service providers for notifications and messages

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

We use in particular:

10. Social media

We are present on social media platforms and other online platforms in order to communicate with interested parties and to 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 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 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".

11. Services from third parties

We use the services of specialised third parties in order to be able to carry out our activities and operations in a permanent, 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 Internet Protocol (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:

11.1 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. This includes, for example, hosting and storage services from selected providers.

We use in particular:

11.2 Contact options

We use services from selected providers in order to be able to communicate better with third parties such as potential and existing customers.

We use in particular:

11.3 Audio and video conferencing

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

Depending on your life situation, we recommend muting the microphone by default and blurring the background or displaying a virtual background when participating in audio or video conferences.

We use in particular:

11.4 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.

11.5 Map material

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

We use in particular:

11.6 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:

11.7 Advertising

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

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 corresponding - 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 where you are logged in as a user may be able to assign the use of our online offering to your profile there.

In particular, we use

12. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

In particular, we use

13. Measuring success and reach

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offering 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 to our online offering.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for the purpose of measuring 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 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 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.

In particular, we use

  • Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross-device tracking) and 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: Integration and management of other services for measuring success and reach 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 in the individual integrated and managed services.

14. Final provisions

We have created this privacy policy using the privacy policy generator from Datenschutzpartner.

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and additions in an appropriate form, in particular by publishing the current privacy policy on our website.