Privacy Policy
By using our Website, you confirm you have read, understood, and agree to the collection and use of your Personal Data as outlined in this Privacy Policy.
Effective Date: 01.01.2025
Swiss Subnet AG (hereinafter "we," "us," "our" or the "Company") respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Policy explains how we collect, use, disclose, and safeguard your Personal Data when you visit our website https://www.subnet.ch (“Website”) or otherwise interact with us as described below.
This Privacy Policy is designed to be in compliance with:
- The Swiss Federal Act on Data Protection (FADP)
- The EU General Data Protection Regulation (GDPR).
- The California Consumer Privacy Act (CCPA) and its amendments, as well as the California Online Privacy Protection Act (CalOPPA).
- Other relevant global privacy laws and regulations to the extent applicable.
By accessing or using our Website, you acknowledge you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Website.
1. Who We Are & Contact Details
Data Controller:
Swiss Subnet AG
https://www.subnet.ch
Email: team@subnet.ch
For any questions regarding this Privacy Policy or to exercise any of your statutory rights, please contact us at the above email address.
2. Scope & Eligibility
Scope
This Privacy Policy applies to Personal Data collected through:
- Your use of our Website.
- Your subscription to our newsletter or other forms of communication.
- Email inquiries to team@subnet.ch; and
- Any related online or offline interactions in connection with the Website.
Children’s Privacy
Our Website is not directed to children under the age of 13. We do not knowingly collect or process Personal Data from anyone under 13. If you become aware that a child under 13 has provided us with Personal Data, please contact us immediately so we may delete such information.
3. Personal Data We Collect
3.1 Personal Data You Provide Directly
- Contact Information: Name, email address (for newsletter subscriptions, inquiries, or other communication).
- Communication Data: Any additional information you choose to include when emailing us at team@subnet.ch or filling out any contact or feedback forms.
3.2 Geolocation Data
We may process geolocation information to provide certain features or personalize our services. You can typically disable geolocation tracking in your device or browser settings, but doing so may limit some functionalities of our Website.
3.3 Automatically Collected Data
When you visit or interact with our Website, we automatically collect certain technical data:
- Device & Usage Data: IP address, device type, browser type, operating system, referring URLs, pages viewed, time spent on pages, and date/time of visits.
- Cookies & Similar Technologies: We use cookies, web beacons (e.g., pixel tags), and other tracking technologies to improve functionality, analyze traffic, and tailor your experience.
- Cookies: Small text files placed on your device to track usage and preferences.
- Web Beacons (Pixel Tags): Small pieces of code embedded in webpages or emails that monitor user activity.
3.4 Third-Party Tracking & Pixels
We use third-party technologies, including Google, Facebook Pixel, Twitter, and LinkedIn, to measure the effectiveness of our marketing campaigns and to display tailored advertisements. These third parties may collect or receive information about your use of our Website and elsewhere on the internet in accordance with their own privacy policies.
4. How We Use Your Personal Data
We process Personal Data for the following purposes and in accordance with applicable legal bases (GDPR Art. 6, FADP Art. 4 et seq.):
- Provision & Maintenance of Our Website
- To provide, maintain, and secure our website, including monitoring usage and resolving technical issues.
- Legal Basis: Our legitimate interest in ensuring the functionality and security of our Website (GDPR Art. 6(1)(f)).
- Newsletters & Direct Marketing
- To send newsletters and promotional materials, where you have subscribed or otherwise provided consent.
- Legal Basis: Consent (GDPR Art. 6(1)(a)), or our legitimate interest in direct marketing if consent is not mandatory under local law (GDPR Art. 6(1)(f)).
- Communication & Customer Support
- To respond to your inquiries, requests, and provide customer service.
- Legal Basis: Our legitimate interests in responding to user queries (GDPR Art. 6(1)(f)) or consent where required.
- Analytics & Performance
- To analyze usage trends, measure campaign effectiveness, and improve our content and offerings.
- Legal Basis: Our legitimate interest in analyzing our website performance and user engagement (GDPR Art. 6(1)(f)).
- Legal & Compliance
- To comply with legal obligations, respond to lawful requests by public authorities, and protect our rights.
- Legal Basis: Compliance with legal obligations (GDPR Art. 6(1)(c)) or legitimate interest (GDPR Art. 6(1)(f)) where the legal obligation is not strictly EU/Swiss-based.
5. Disclosure of Personal Data
We may share or disclose your Personal Data under the following circumstances:
- Service Providers
We allow third-party companies and individuals to facilitate our services (e.g., newsletter distribution). Analytics providers parties that have access to your Personal Data to perform tasks on our behalf contractually obligate not to disclose or use it for any other purpose. - Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your Personal Data may be part of the transferred assets. - Legal Obligations & Rights
We may disclose Personal Data if required by law or in good faith that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users or the public.
We do not sell Personal Data for monetary consideration. If we engage in practices that are considered a “sale” under certain jurisdictions (such as the “sale” definition under the CCPA), we may provide an opportunity to opt out.
6. International Data Transfers
Your Personal Data may be transferred to, and stored at, a destination outside of your country of residence, including countries that may not offer the same level of data protection as your home jurisdiction. In such cases, we ensure appropriate safeguards (e.g., Standard Contractual Clauses approved by the European Commission, compliance with the revised FADP international transfer provisions) to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable law.
7. Retention of Personal Data
We retain Personal Data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We may also retain certain information for legitimate business purposes (e.g., record-keeping, compliance with our legal obligations, dispute resolution, and enforcement of agreements).
8. Your Rights & Choices
8.1 Rights of Swiss & EEA Residents (FADP/GDPR)
If you are located in Switzerland or the European Economic Area, you may have the following rights (subject to legal limitations):
- Right to Access: Obtain confirmation as to whether we process your Personal Data, receive a copy of your Personal Data, and obtain information about how it is processed.
- Right to Rectification: Request correction of any inaccurate or incomplete Personal Data.
- Right to Erasure: Under certain circumstances, request deletion of your Personal Data (“right to be forgotten”).
- Right to Restrict Processing: Under certain circumstances, restrict or object to the processing of your Personal Data.
- Right to Data Portability: Receive your Personal Data in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller.
- Right to Object: Object to processing based on our legitimate interests, and to direct marketing.
- Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact us at team@subnet.ch. We may need to verify your identity before processing your request. You also have the right to lodge a complaint with your local data protection authority (in Switzerland, the Federal Data Protection and Information Commissioner; in the EEA, your local supervisory authority).
8.2 Rights of California Residents (CCPA & CalOPPA)
If you are a California resident, you may have certain rights regarding your Personal Data:
- Right to Know: Request disclosure of the categories of Personal Data we collect, the purposes for which the information is used, and any third parties with whom we share it.
- Right to Delete: Request deletion of Personal Data we have collected about you, subject to certain exceptions.
- Right to Opt-Out of Sale/Sharing: Direct us not to sell or share your Personal Data, if applicable.
- Right to Non-Discrimination: You have the right to be free from discrimination for exercising any of the above rights.
To exercise your rights, please contact us at team@subnet.ch. We may need to verify your identity before processing your request. Under CalOPPA, we may also inform you that we do not track users over time and across third-party websites for targeted advertising beyond the third-party technologies described herein. However, third parties (such as advertising networks) may engage in such tracking; their practices are governed by their own privacy policies.
9. Security Measures
We implement appropriate technical and organizational measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. Despite our efforts, no security measures are perfect or impenetrable. We cannot guarantee the absolute security of your Personal Data. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities where required by law.
10. Third-Party Websites & Services
Our Website may contain links to third-party websites, plug-ins, or services that are not operated by us. This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies and practices of any third-party site or service before providing any Personal Data to them. We are not responsible for their privacy practices or content.
11. No Online Payments
We do not collect or process online payments through our Website. Accordingly, we do not request or store payment card details or related financial information.
12. Updates to This Privacy Policy
We reserve the right to modify or update this Privacy Policy at any time to reflect changes in our data processing practices or to comply with new legal requirements. When we do, we will revise the “Effective Date” at the top of this page and, if the changes are material, we may provide a more prominent notice on our Website. Your continued use of our Website after the effective date constitutes acceptance of the updated Privacy Policy.
13. Contact Us
For any questions, concerns, or comments regarding this Privacy Policy or our data handling practices, please contact us at:
Swiss Subnet AG
https://www.subnet.ch
Email: team@subnet.ch
We will strive to address your inquiry promptly and work with you to find a satisfactory resolution to any concerns you may have.
By using our Website, you confirm you have read, understood, and agree to the collection and use of your Personal Data as outlined in this Privacy Policy.
