Data Protection and Privacy Policy

With this data protection declaration we inform you which personal data we process in connection with our activities and operations, including our www.zimex.com , www.zimex.ch, www.zimex.at Website. In particular, we provide information on what personal data we process, for what purpose, how and where. 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 and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.

1. CONTACT ADDRESS

Responsibility for the processing of personal data:

Zimex Aviation Ltd

Cherstrasse 4

8152 Glattbrugg Switzerland

dataprotection@zimex.ch

We would like to point out if there might be other persons responsible for the processing of personal data depending on the individual cases.

Data Protection Officer or Data Protection Advisor

We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities with enquiries in connection with data protection:

Data Protection Officer

Zimex Aviation Ltd

Cherstrasse 4

8152 Glattbrugg Switzerland

dataprotection@zimex.ch

2. TERMS AND LEGAL BASIS

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 retrieving, matching, adapting, archiving, storing, reading, disclosing, procuring, recording, collecting, 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 Basis

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

We process personal data – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with at least one of the following legal bases:

  • Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of 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, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c DSGVO 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 necessary processing of personal data for the performance of a task that is in the public interest.
  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the person concerned.
  • Article 6 (1) (d) of the GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.

3. TYPE SCOPE AND PURPOSE

We process those personal data that are necessary to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular 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 period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer required 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.

As a matter of principle, we only process personal data with the consent of the persons concerned. If and insofar as the 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 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 letter, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information, for example, in an address book or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection with regard to 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 for legal reasons.

4. PERSONAL DATA ABROAD

We process personal data fundamentally in Switzerland and in 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 states 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 to the extent that the General Data Protection Regulation (GDPR) is applicable – adequate data protection 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 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 any guarantees on request.

5. RIGHTS OF DATA SUBJECTS

5.1 Data protection rights

We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:

  • 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 necessary to assert their data protection rights and to 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 have inaccurate personal data corrected, incomplete data completed and the processing of their data restricted.
  • Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
  • Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

We may suspend, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We can draw the attention of data subjects to 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. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.

We may exceptionally provide for costs for the exercise of rights. We inform data subjects in advance of any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

5.2 Right of appeal

Data subjects have the right to enforce their data protection rights by legal means or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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

6. DATA SECURITY

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

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

Our digital communication is subject – as is basically all digital communication – to mass surveillance without cause or suspicion and other monitoring 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 agencies and other security authorities.

7. USE OF THE WEBSITE

7.1 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. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online branding, 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.

In the case of cookies used for performance 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 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 called up including amount of data transferred, website last called up in the same browser window (refer or referrer).

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.

7.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files.

8. SOCIAL MEDIA

We are present on social media platforms and other online platforms in order to communicate with interested persons 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. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

9. SERVICES FROM THIRD PARTIES

We use services from specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.

For necessary security-related, 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.

In particular, we use:

9.1 Digital Infrastructure

We use services from specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

In particular, we use:

WordPress.com: blog hosting and website builder; providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; data protection information: privacy policy, cookie policy.

9.2 Social media functions and social media content

We use third party services and plugins to embed features and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.

In particular, we use:

LinkedIn Consumer Solutions Platform: embedding functions and content from LinkedIn, for example with plug-ins such as the “Share Plugin”; provider: Microsoft; LinkedIn-specific information: “Privacy”, privacy policy, cookie policy, cookie management / objection to email and SMS communications from LinkedIn, objection to interest-based advertising.

9.3 Map material

We use third party services to embed maps on our website.

In particular, we use:

Google Maps including Google Maps Platform: map service; provider: Google; Google Maps-specific claims: “How Google uses location information”.

9.4 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: data protection declaration, “Data protection”.

9.5 Documents

We use third party services to enable us to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents. We may use them to enable not only viewing, but also editing or commenting on such documents.We use in particular:

Microsoft 365 (also Microsoft Office 365): text documents as well as forms, presentations and tables; Provider: Microsoft; Microsoft 365-specific information: “Privacy and security with Microsoft 365″.

10. EXTENSIONS FOR THE WEBSITE

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

In particular, we use:

Jetpack: Various functions for the free blog software WordPress in the form of modules; provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among other countries; data protection information: Privacy Notice for Visitors to Our Users’ Sites, Privacy Policy (from Automattic), Jetpack Privacy Center, Cookie Policy (Jetpack), Cookie Policy (Automattic).

11. SUCCESS AND REACH MEASUREMENT

We try to determine how our online offer 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 offer 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 offer.

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 fundamentally shortened (“IP masking”) in order to follow the principle of data economy 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 services of third parties with which users are registered can, if necessary, allocate the use of our online offer to the user account or user profile with the respective service.

We use in particular:

12. COPYRIGHT AND FINAL PROVISIONS

12.1 Copyright

The copyright and all other rights to the content, images, photos or other files on the website belong exclusively to the owner of this site, or to the specifically named rights holders, or have been acquired and licensed for this purpose. The written consent of the copyright holders must be obtained in advance for the reproduction of any elements.

12.2 Final Provisions

We may adapt and supplement this data protection declaration at any time. We will inform about such adjustments and amendments in an appropriate form, in particular by publishing the respective current data protection statement on our website.