In the following text, the term “we” refers to Say Hello GmbH, which is wholly owned by Mark Howells-Mead.
Our own privacy policy
This privacy policy informs you about which personal data we process in connection with our activities and operations, including our sayhello.ch website. In particular, we inform you about the purpose, how, and where we process personal data provided by clients and site visitors. We also want to inform you about the rights of individuals whose data we process.
For individual or additional activities and operations, additional privacy policies and other legal documents such as general terms and conditions (T+C), terms of use, or conditions of participation may apply.
1. Contact address
Responsible for the processing of personal data:
Say Hello GmbH
Mark Howells-Mead
Thunstrasse 4
3700 Spiez
Switzerland
We will point out if there are other persons responsible for processing personal data in individual cases.
2. Terms and legal bases
2.1 Terms
Personal data is 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, retrieving, disclosing, obtaining, recording, collecting, deleting, disclosing, structuring, organising, storing, altering, disseminating, linking, destroying, and using personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).
Type, scope and purpose
We process the personal data necessary to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data can, in particular, fall into the categories of inventory and contact data, browser and device data, content data, metadata or peripheral data and usage data, location data, sales data, and contract and payment data.
We process personal data for the period required for the respective purpose(s) or as required by law. Personal data whose processing is no longer necessary is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties include, in particular, specialised providers whose services we utilise. We also guarantee data protection for such third parties.
We generally only process personal data with the consent of the data subjects. If and to the extent that processing is permissible for other legal reasons, we may waive the requirement to obtain consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations, or to protect overriding interests.
We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect in the course of our activities, provided and to the extent that such processing is permitted by law.
4. Communication
We process data to enable us to communicate with third parties. In this context, we particularly process data that a data subject transmits when contacting us, for example, by letter or email. We may store such data in an address book or using similar tools.
Third parties who transmit data about other individuals are obligated to ensure data protection for such data subjects. This includes ensuring, among other things, the accuracy of the personal data transmitted.
5. Data security
We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. With our measures, we specifically guarantee the confidentiality, availability, traceability, and integrity of the personal data processed, but cannot guarantee absolute data security.
Access to our website and our other online presence is via transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.
Our digital communications – like all digital communications – are 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 have no direct influence on the corresponding processing of personal data by secret services, police authorities, and other security authorities. We also cannot rule out the possibility that individual data subjects may be specifically monitored.
6. Personal data abroad
We generally process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it or have it processed there.
We may disclose personal data to all countries and territories on Earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with a decision of the Swiss Federal Council.
We may disclose personal data to countries whose law does not guarantee adequate data protection, provided that appropriate data protection is guaranteed for other reasons. Suitable data protection can be ensured, for example, through appropriate contractual agreements, on the basis of standard data protection clauses, or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or suitable data protection if the specific data protection 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 about any guarantees or a copy of the guarantees upon request.
7. Rights of data subjects
7.1 Data protection claims
We grant data subjects all rights under applicable data protection law. Data subjects have, in particular, the following rights:
- Information: Data subjects can request information about whether we process personal data about them, and if so, which personal data this is. Data subjects will also receive the information necessary to assert their data protection rights and 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 can correct inaccurate personal data, complete incomplete data and have the processing of their data restricted.
- Deletion and objection: Data subjects can have their personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects can request the disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict, or refuse the exercise of data subjects’ rights within the legally permissible framework. We may inform data subjects of any conditions that may need to be met to exercise their data protection rights. For example, we may refuse to provide information in whole or in part, citing trade secrets or the protection of other individuals. We may also refuse to delete personal data in whole or in part, citing statutory retention periods.
In exceptional cases, we may charge fees for exercising these rights. We will inform data subjects in advance of any costs involved.
We are obligated to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obligated to cooperate.
7.2 Legal protection
Data subjects have the right to enforce their data protection rights through legal recourse or to file a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for complaints filed by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
8. Using our website
8.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.
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 defined storage duration. Cookies enable us, in particular, to recognize a browser on its next visit to our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing purposes.
Cookies can be deactivated or deleted entirely or partially at any time in the browser settings. Without cookies, our website may not be fully available. We actively request your explicit consent to the use of cookies – at least insofar as and to the extent necessary.
For cookies used for performance and reach measurement or for advertising, a general opt-out is available for many 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 Logging
We may log at least the following information for every access to our website and other online presence, provided that this information is transmitted to our digital infrastructure during such access: 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 sub-page of our website accessed including the amount of data transferred, and the last website accessed in the same browser window (referrer).
We log such information, which may also constitute personal data, in log files. This information is necessary to ensure the continuous, user-friendly, and reliable provision of our online presence. This information is also necessary to guarantee data security – including through or with the help of third parties.
9. Notifications and messages
We send notifications and messages via email and other communication channels such as instant messaging or SMS.
9.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links were clicked. Such web links and tracking pixels can also record the use of notifications and messages on a personalized basis. We require this statistical tracking of usage for measuring success and reach in order to send notifications and messages effectively and user-friendly, as well as reliably and securely, based on the needs and reading habits of the recipients.
9.2 Consent and objection
You must explicitly consent to the use of your email address and other contact details, unless their use is permitted for other legal reasons. For any consent, we will, where possible, use the “double opt-in” procedure, meaning you will receive an email with a web link that you must click to confirm your consent, thus preventing misuse by unauthorized third parties. We may log such consents, including your IP address, as well as the date and time, for evidentiary and security purposes.
You can generally object to receiving notifications and communications, such as newsletters, at any time. By objecting in this way, you can also simultaneously object to the statistical recording of your usage for the purpose of measuring success and reach. This does not affect necessary notifications and communications related to our activities and operations.
10. Social Media
We maintain a presence on social media and other online platforms to communicate with interested individuals and to provide information about our activities and services. In connection with these platforms, personal data may also be processed outside of Switzerland.
The general terms and conditions, terms of use, privacy policies, and other provisions of the respective platform operators also apply. These provisions, in particular, inform individuals about their rights directly with regard to the respective platform, including, for example, the right to access their data.
11. Third-party services
We use services from specialized third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed functions and content into our website. When such content is embedded, the services used collect the IP addresses of users, at least temporarily, for technically necessary reasons.
For essential 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 form. This includes, for example, performance or usage data necessary to provide the respective service.
We use in particular:
- Google Services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Principles of Data Protection and Security,” Privacy Policy, “Google is committed to complying with applicable data protection laws“, “Guide to Data Protection in Google Products”, “How we use data from websites or apps that use our services” (information from Google), “Types of cookies and other technologies used by Google,” “Personalized advertising” (activation / deactivation / settings).
- Microsoft services: Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; General information on data protection: “Data protection at Microsoft“, “Data protection and privacy (Trust Center)“, Privacy Statement, Privacy Dashboard (Data and privacy settings).
11.1 Digital Infrastructure
We use services from specialized third parties to access the necessary digital infrastructure related to our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
- Cyon: Hosting; Provider: cyon GmbH (Switzerland); Information on data protection: “Data protection“, Privacy policy.
11.2 Appointment and task scheduling
We use services from specialized third parties to enable online appointment scheduling, for example for meetings. In addition to this privacy policy, any terms and conditions of the services used, such as terms of use or privacy policies, also apply.
We use in particular:
- Google Calendar: Online scheduling; Provider: Google; Google Calendar-specific information: “Scheduling with Google Calendar“, “Data protection in Google Calendar“.
11.3 Audio and video conferencing
We use specialized audio and video conferencing services to communicate online. This allows us to hold virtual meetings, conduct online classes, and host webinars, for example. When participating in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, also apply.
Depending on your personal circumstances, we recommend that you mute your microphone by default and blur your background or use a virtual background when participating in audio or video conferences.
We primarily use the following services:
- Google Meet: Video conferencing; Provider: Google; Google Meet-specific information: “Google Meet – Security and data protection for users“.
- Microsoft Teams: Platform for audio and video conferencing, among other things; Provider: Microsoft; Teams-specific information: “Data protection and Microsoft Teams“.
- Zoom: Video conferencing; Provider: Zoom Video Communications Inc. (USA); Information on data protection: Privacy Policy, “Privacy at Zoom“, “Legal Compliance Center“.
11.4 Online collaboration
We use third-party services to facilitate online collaboration. In addition to this privacy policy, any terms and conditions of the services used, such as terms of service or privacy policies, also apply.
In particular, we use:
- Google Drive — cloud storage for documents and files. Information on data protection is mentioned above.
11.5 Social media features 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 through other channels.
In particular, we use:
- Instagram platform: Embedding of Instagram content; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Privacy Policy (Instagram), Privacy Policy (Facebook).
11.6 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.
In particular, we use:
- Vimeo: Video platform; provider: Vimeo Inc. (USA); information on data protection: Privacy Policy, “Data Protection“.
- YouTube: Video platform; provider: Google; YouTube-specific information: “Privacy and Security Center“, “My data on YouTube“.
12. Extensions for the website
We use extensions for our website to be able to utilize additional functions. We can use selected services from suitable providers or run these extensions on our own server infrastructure.
13. Success and reach measurement
We strive to understand how our online services are used. This allows us to measure the success and reach of our activities and initiatives, as well as the impact of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online services are used (using the “A/B testing” method). Based on the results of this success and reach measurement, we can, in particular, correct errors, promote popular content, or make improvements to our online services.
For success and reach measurement, the IP addresses of individual users are usually stored. In this case, IP addresses are generally shortened (“IP masking”) to comply with the principle of data minimization through pseudonymization.
Cookies may be used for success and reach measurement, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the – at least approximate – location. As a rule, any user profiles are created exclusively in a pseudonymized form and are not used to identify individual users. Individual third-party services where users are logged in may potentially associate the use of our online services with the user account or user profile on the respective service.
We use in particular:
- Matomo: Success and reach measurement; Provider: Matomo (free open-source software); Data protection information: Used on our own server infrastructure and with pseudonymised IP addresses, “List of all Matomo features“.
14. Final provisions
We created parts of this privacy policy using the privacy policy generator from Datenschutzpartner and translated it using Google Translate.
We may amend and supplement this privacy policy at any time. We will inform you of any such amendments and additions in an appropriate manner, in particular by publishing the current version of the privacy policy on our website.
Imprint
Responsible for the website
Say Hello GmbH
(Mark Howells-Mead)
Thunstrasse 4
3700 Spiez
Switzerland
UID: CHE 361.678.546
Contact person for all enquiries
Mark Howells-Mead, hello@sayhello.ch
