Privacy Policy
With this privacy policy, we inform you which personal data we have in connection with our activities on https://www.chiaro-zurich.com/en/ and how it is used. In particular, we provide information about why, how and where we process personal data. We also provide information about the rights of people 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.
We are subject to Swiss data protection law and any applicable foreign data protection law, such as that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission acknowledges that Swiss data protection law guarantees adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
RGP beauty & cosmetics ag
Talacker 41
8001 Zurich
Switzerland
info@rgp-ag.ch
We would like to point out persons responsible for the processing of personal data in individual cases.
Data Protection Officer
We have the following data protection officer as a point of contact for data subjects and as a contact for supervisory authorities for data protection inquiries:
RGP beauty & cosmetics ag Talacker 41
8001 Zurich Switzerland
info@rgp-ag.ch
- Terms and Legal Bases
2.1 Terms
Personal data is all information that relates to a specific or identifiable person. The affected person is a person about whom personal data is processed.
To edit includes every handling of personal data, independently of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises of the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) describes the processing of personal data as the editing of personal data.
2.2 Legal Bases
We process personal data in accordance with Swiss data protection law, in particular, the Federal law on data protection (DSG) and the Ordinance to the Federal Law on Data Protection (VDSG).
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Article 6 paragraph 1 letter b GDPR for the necessary processing of personal data to fulfil a contract with the person concerned and to carry out pre-contractual measures.
- Art. 6 (1) (f) GDPR for the necessary processing of personal data in order to protect our legitimate interests or those of third parties, provided that the fundamental freedoms, rights and interests of the person concerned do not prevail. In particular, our legitimate interest in being able to carry out our activities in an ongoing, user-friendly, safe and reliable manner and to be able to communicate about them, guarantee information security, protect against misuse, enforce legal claims and comply with Swiss law.
- Art. 6 (1) (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).
- Article 6 paragraph 1 lit. e GDPR for the necessary processing of personal data to perform a task which is in the public’s interest.
- Art. 6 (1) (a) GDPR for the processing of personal data with the consent of the data subject.
- Article 6 paragraph 1 letter d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Nature, Scope and Purpose
We process personal data that is necessary to be able to carry out our ongoing activities in a way which is user-friendly, safe and reliable. Such personal data may fall under the categories of inventory and contact data, browser and device data, content data, meta or edge data, usage data, location data, sales data as well as contract and payment data.
We process personal data during this duration, which is required for the respective purpose or by law. Personal data that no longer needs to be processed will remain anonymous or deleted.
We may edit personal data through third parties. We may process personal data together with third parties or transfer them to third parties. Such third parties are specialized providers whose services we use. We also guarantee data protection with such third parties.
We process personal data primarily with the consent of the person concerned, unless the processing is permissible for other legal reasons, for example, to fulfil a contract with the person concerned and for corresponding pre-contractual measures to protect our overriding legitimate interests when the processing is evident from the circumstances or by prior information.
In this context, we process particular information that a person submits when contacting us – for example by letter post, e-mail, instant messaging, contact form, social media or telephone – or when voluntarily registering for a user account. We may store such information in an address book or with comparable tools. If you transmit personal data to us via third parties, you are obliged to ensure data protection against such third parties and to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, procure from publicly accessible sources or collect amid our activities, if and to the extent that such processing is permitted by law.
- Personal Data Abroad
We process personal data primarily in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries for processing either by us or a third party.
We can store personal data in all States and Territories on Earth as well as elsewhere in the universe, if and to the extent that the General Data Protection Regulation (GDPR) is applicable – and in accordance with the Decision of the European Commission to ensure adequate data protection.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other suitable guarantees. In exceptional cases, we may export personal data to countries without adequate or suitable data protection if the special data protection requirements are met, for example, the express consent of the person concerned or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide affected persons with copies of information relating to any guarantees.
- Rights of Data Subjects
Affected persons whose personal data we process have rights under Swiss data protection law. This includes the rights to information as well as the rights to correction, deletion or blocking of the processed personal data.
Affected persons whose personal data we process can – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – receive confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, restrict the processing of their personal data, exercise their right to data transferability and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.
Affected persons whose personal data we process can – if and to the extent that the GDPR is applicable – revoke a given consent at any time with immediate effect and object to the processing of their personal data at any time.
Affected persons whose personal data we process have the right to appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is Federal Data Protection and Information Commissioner (FDPIC).
- Data Security
We take appropriate technical and organizational measures to ensure data security is appropriate to the risk in question. Unfortunately, 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 mark transport encryption with a padlock in the address bar.
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 have no direct influence on the corresponding processing of personal data by secret services, police forces and other security authorities.
- Use of the Website
7.1 Cookies
We make use of cookies in the form of data that is stored in your browser. These may be from us or from third parties whose services we use. Such stored data need not be limited to traditional text-form cookies. Cookies cannot run programs or transmit malware such as Trojans and viruses.
Cookies can be stored temporarily as “session cookies” or for a certain period of time as permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a certain storage period. Cookies make it possible to recognize your browser the next time you visit our website to help us measure organic reach. However, permanent cookies may also be used on occasion for other purposes such as online marketing.
You may completely or partially deactivate or delete cookies in your browser settings at any time. Without cookies, our website may no longer be fully functional. If and to the extent necessary, we always ask for your express consent regarding the use of cookies.
In the case of cookies that are used to measure success and reach or for advertising, a general objection (“opt-out”) is required for the following services Ad Choices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), Your Ad Choices (Digital Advertising Alliance) or Your Online Choices(European Interactive Digital Advertising Alliance, EDAA).
7.2 Server Log Files
We may record the following information for each access to our website, provided that this is transmitted from 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), type of operating system including user interface and version, browser including language and version, individual sub-pages of our website visited including the amount of data transferred, and website last called up within the same browser window (referrer).
We store such information, which may also represent personal data, in server log files. This information is required in order to provide our website in a stable, user-friendly and reliable manner and to be able to ensure data security, particularly with regards to the protection of personal data – either by third parties or with the help of third parties.
7.3 Web Beacons
We may use web beacons on our website. These web beacons (or tracking pixels) may also be from third parties whose services we use, and are small, typically invisible images that are automatically retrieved when you visit our website. The same information may be recorded with tracking pixels as is with server log files.
- Notifications and Messages
We send notifications and communications via email and other communication channels such as instant messaging or SMS.
8.1 Success and Reach Measurement
Notifications and communications may contain web links or web beacons that record whether an individual communication was opened, and which specific web links were clicked on. Such web links and tracking pixels can also record the use of notifications and communications on a personal basis. We need these statistical recordings of usage to measure success and reach and to send ongoing notifications and messages in an effective, user-friendly, secure, and reliable way based on the needs and reading habits of the recipients.
8.2 Consent and Objection
You must expressly agree to the use of your email address and any other contact information unless the use is permitted for other legal reasons. If possible, we use the “double opt-in” procedure for any consent, i.e., you will receive an e-mail with a web link that you must click to confirm so that no misuse by unauthorized third parties may take place. We may log such consents, including Internet Protocol (IP) address and date and time for evidentiary and security reasons.
You may object to the receipt of notifications and communications such as newsletters at any time. With such an objection, you may also object to the statistical recording of use for measuring success and reach. Necessary notifications and notifications in connection with our activities remain reserved.
8.3 Notification and Communication Service Providers
We send notifications and communications using specialized service providers.
In particular, we use:
- Mailchimp: communication platform; Provider: The Rocket Science Group LLC d/b/a Mailchimp (USA) as subsidiary Intuit Inc. (USA); Information on data protection: Data protection (Intuit) including “Country and Region-Specific Terms”, Cookie Policy, “Privacy Rights Requests”, «Mailchimp and European Data Transfers»(«Mailchimp and European Data Transfers»), “Security”.
- Social Media
We make use of social media and other online platforms as a way to communicate with interested persons and to provide information about our activities. In connection with such platforms, personal data may sometimes be processed outside of Switzerland and the European Economic Area (EEA).
General terms and conditions (GTC), terms of use, data protection declarations and other provisions belonging to the individual operators of such platforms still apply. In particular, these provisions provide information about the rights of data subjects directly relating to 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 and its Page Insights, if and to the extent that the GDPR is applicable. Meta Platforms Ireland Limited is part of the Meta company (among others in the USA). These Page Insights provide information on how visitors interact with our Facebook presence. We use Page Insights to ensure our social media presence is effective and user-friendly.
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 its data protection officer can be found within Facebook’s Privacy Policy. We abide by Facebook’s “Supplement for responsible persons”, which states that Facebook is responsible for guaranteeing the rights of data subjects. Further information on page insights may be found on the page “Information on Page Insights” including “About Page Insights Data”.
- Third Party Services
We use third-party services to carry out our activities in a durable, user-friendly, safe and reliable manner. Such services may also be used to embed content on our website. Such services require your Internet Protocol (IP) address, otherwise, the relevant content cannot be transmitted.
For their own security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities in an aggregated, anonymous or pseudonymised manner. An example could include performance or usage data.
In particular, we use:
- 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”, Data protection, «Google is committed to compliance with applicable data protection laws», «Guide to data protection in Google products», “How we use data from websites or apps on which our services are used” (information from Google), “Types of cookies and other technologies used by Google“, “Personalized advertising” (activation/deactivation/settings).
10.1 Digital Infrastructure
We use third-party services to be able to use the digital infrastructure required in connection with our activities. These include hosting and storage services from specialized providers.
In particular, we use:
- Hostpoint: hosting; Provider: Hostpoint AG (Switzerland); Information on data protection: Data protection, «Frequently asked questions about the GDPR».
- WordPress.com: blog hosting and website builder; Providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; Information on data protection: Data protection, «Automattic and the General Data Protection Regulation (GDPR)», Cookie Policy.
10.2 Social Media Features and Content
We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and other sources.
In particular, we use:
- Facebook (social plugins): Embedding of Facebook functions and Facebook content, for example, “Like” or “Share”; Providers: Meta Platforms Ireland Limited (Ireland) and other meta companies (among others in the USA); Information on data protection: Data protection.
- Instagram platform: embedding Instagram content; Providers: Meta Platforms Ireland Limited (Ireland) and other meta companies (among others in the USA); Information on data protection: Privacy Policy (Instagram), Privacy Policy (Facebook).
10.3 Audio Visual Media
We use third-party services to enable the direct playback of audio/visual media such as music and videos on our website.
In particular, we use:
- Vimeo: videos; Provider: Vimeo Inc.(USA); Information on data protection: “Privacy”, Data protection.
10.4 Payments
We use payment service providers to be able to process payments from our customers securely and reliably. The terms and conditions of the relevant payment service provider, such as General Terms and Conditions (GTC) or data protection declarations, will also apply to this payment processing.
In particular, we use:
- PayPal (including Braintree): processing of payments; Providers: PayPal (Europe) S.à rl et Cie, SCA (Luxembourg) / PayPal Pte. ltd (Singapore); Information on data protection: Data protection, “Cookies and Tracking Technologies Statement“.
- Stripe: processing of payments; Providers: Stripe Inc. (USA) / Stripe Payments Europe Limited (SPEL, Ireland) for users in the European Economic Area (EEA) and in Switzerland and partly in Great Britain / Stripe Payments UK Limited (Great Britain) and Stripe Capital Europe Limited ( Ireland) partly for users in Great Britain; Information on data protection: “Stripe Privacy Center” (“Stripe Privacy Center”), Data protection, Cookie Policy.
10.5 Advertising
We possess the right to advertise our activities and for these operations to be displayed 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 or who may be interested in our activities (remarketing and targeting). For this purpose, we may transmit personal information to third parties who make such advertising possible. We can also determine whether our advertising is successful, i.e., whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are registered as a user can, if necessary, assign the use of our online offer to your user profile.
In particular, we use:
- Facebook advertising (Facebook Ads): social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other meta companies (among others in the USA); Information on data protection: remarketing and targeting, in particular with the Facebook pixel such as Custom Audiences including lookalike audiences, Data protection, “Advertising Preferences” (Registration as a user required).
- Google Ads: search engine advertising; Google Ads-specific information on data protection: Advertising, among other things, based on search queries, whereby different domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – are used for Google Ads, “Advertising” (Google), «Why am I seeing a certain advertisement?».
- Instagram ads: social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other meta companies (among others in the USA); Information on data protection: Remarketing and targeting in particular with Facebook pixel such as Custom Audiences including lookalike audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), «Advertising preferences» (Instagram) (Registration as a user required), «Advertising preferences» (Facebook) (Registration as a user required).
- Enhancements to the Website
We use extensions on our website to be able to use additional functions.
In particular, we use:
- Google reCAPTCHA: spam protection (distinguishing between legitimate human comments and unwanted comments from bots and spam); Google reCAPTCHA- specific data protection information: «What is reCAPTCHA?».
- Success and Reach Measurement
We use dedicated services and programs to help measure the success of our online activities. This can include measuring the effect of third-party links on our website.
However, we may also test and compare different versions of our online offering (“A/B test” method). Based on the results of the success and range measurement, we may correct errors, strengthen popular content, or make improvements to our online offering.
When using services and programs to measure success and reach, the Internet Protocol (IP) addresses of individual users must be saved. IP addresses will be shortened (“IP masking”) to follow the principle of data economy through the corresponding pseudonymization and thus improve the data protection of the users.
It may be necessary to use cookies or perhaps create user profiles when using services and programs for success and range measurement. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and the approximate location of the user. User profiles are primarily created exclusively pseudonymized. We do not use user profiles to identify individual users. Individual third-party services with which users are registered may assign the use of our online offering to the user account or user profile on their respective service.
In particular, we use:
- Google Analytics: success and reach measurement; Google Analytics-specific information on data protection: Measurement also across different browsers and devices (Cross Device Tracking) as well as with pseudonymized Internet Protocol (IP) addresses that only exceptionally be transferred in full to Google in the USA, “Privacy“, «Browser add-on to deactivate Google Analytics».
- Google Tag Manager: Integration and management of other services for success and range measurement as well as other services from Google and third parties; Google Tag Manager- specific data protection information: «Data collected with Google Tag Manager»; Further information on data protection can be found in the individual integrated and managed services.
- Final Provisions
We created this privacy policy with the Privacy Generator from Privacy Partner.
We may adapt and supplement this data protection declaration at any time. We will inform you about such adjustments and additions in a suitable form, including email and by publishing the current data protection declaration on our website.