DATA PRIVACY POLICY

With this privacy policy, we inform you which personal data we process, how, where and for what purpose, in particular in connection with our SHUBiDU app and our other services, including our SHUBiDU website. With this privacy policy, we also inform about the rights of persons whose data we process.

 

For individual or additional offers and services, special, supplementary or further data protection declarations as well as other legal documents such as our terms of use in particular may apply.

Our offer is subject to Swiss data protection law as well as 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 recognizes that Swiss data protection law ensures adequate data protection.

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1. Contact addresses

Responsibility for the processing of personal data:

 

Shubidu Inc.

Wengisteinstrasse 3b

4500 Solothurn

Switzerland

 

feedback@shubidu.com

 

We point out if there are other persons responsible 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 pursuant to Art. 27 GDPR in the European Economic Area (EEA) as an additional point of contact for supervisory authorities and data subjects for inquiries related to the General Data Protection Regulation (GDPR):

 

VGS Data Protection Partner UG

Am Kaiserkai 69

20457 Hamburg

Germany

 

info@datenschutzpartner.eu

 

2. Processing of Personal Data

 

2.1 Terms

 

Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing includes any handling of personal data, regardless 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 the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as 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 (FADP) and the Ordinance to the Federal Data Protection Act (FDPA).

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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:

 

• Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the fulfillment 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 provide our offer permanently, in a user-friendly, secure and reliable manner and to be able to advertise for it as required, information security as well as protection against misuse and unauthorized use, 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 comply with 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 DSGVO 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 DSGVO for the processing of personal data with the consent of the data subject.

• Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.

 

2.3 Nature, scope and purpose

 

We process the personal data that is necessary to provide our services, including the SHUBiDU app, in a permanent, user-friendly, secure and reliable manner. Such personal data can fall into the categories of inventory and contact data, browser and device data, content data, calendar data, meta or marginal data and usage data, location data, sales, contract and payment data.

 

For some functions, access to the address book, photos and location data on the smartphone of the individual user is particularly useful. Such access only takes place with the consent of the respective users. Depending on the operating system used, the individual users may have to explicitly confirm such access on their smartphone or can explicitly block access.

 

• Contacts from the address book: The phone numbers of your contacts are always transmitted one-way encrypted ("hashed") to our servers to match them with existing SHUBiDU users with whom you can share your events and groups. These hashes are deleted immediately after this matching and are not stored on our servers. When you add a family member, by accessing your address book, the phone number, name and profile picture of the person to be invited will be displayed, the phone number and name will be included in the family invitation and transmitted to our servers to create a profile for that person.

• Photos and Camera: Access to the camera or media library is required to upload family profile photos, attach photos to individual appointments or scan entire appointment slips, which you can then store on our servers.

• Location: Your location is used to find addresses when you collect locations for events, groups, or user profiles. We do not transmit it to our servers.

 

We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required will be anonymized or deleted. Persons whose data we process generally have a right to deletion.

 

As a matter of principle, we process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

 

In this context, we process in particular information that a data subject voluntarily and self-submits to us when contacting us - for example, by letter, email, contact form, social media or telephone - when registering for a user account or when using our SHUBiDU app. We may process and store such information, for example, in an address book, in a customer relationship management system (CRM system) or with comparable tools. If you transmit personal data to us via third parties, you are obligated to ensure data protection vis-à-vis such third parties and to ensure the accuracy of such personal data.

 

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.

Personal data from applications are only processed insofar as they are required for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required for the application process is derived from the information requested or provided, for example in the context of a job description. Applicants have the option of voluntarily providing further information for their respective applications.

 

2.4 Processing of personal data by third parties, also abroad

 

We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties.

 

Such third parties are generally located in Switzerland and in the European Economic Area (EEA). However, such third parties may also be located in other states and territories on earth as well as elsewhere in the universe, provided that their data protection law ensures adequate data protection according to the assessment of the Swiss Federal Data Protection and Information Commissioner (FDPIC) and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - according to the assessment of the European Commission, or if adequate data protection is ensured for other reasons, such as by a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or by a corresponding certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the data protection requirements for this, such as the express consent of the data subject, are met.

 

3. Rights of Data Subjects

Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the processed personal data.

Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request 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, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.

 

Data subjects whose personal data we process may - if and insofar as the GDPR applies - revoke any consent they have given at any time with effect for the future and object to the processing of their personal data at any time.

 

Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

 

4. Data Security

We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.

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Access to our online offer takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

 

Access to our online offering is subject - as is basically any use of the Internet - to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the European Union (EU), 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.

 

5. Use of the Website

 

5.1 Cookies

 

We may use cookies for our website. Cookies - both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) - are data in text form that are stored in your browser. Cookies cannot execute programs or transmit malware such as Trojans and viruses.

 

Cookies can be stored temporarily in your browser as "session cookies" when you visit our website or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when you close your browser. Permanent cookies make it possible in particular to recognize your browser the next time you visit our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.

 

You can disable cookies in your browser settings at any time in whole or in part, as well as delete them. Without cookies, our website may no longer be fully available. We ask you - if and to the extent necessary - actively for your express consent for the use of cookies.

 

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 the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

 

5.2 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, website last accessed in the same browser window (referer or referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer permanently, user-friendly and reliably 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.

 

5.3 Tracking pixels

 

We may use tracking pixels on our website. Tracking pixels are also known 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.

 

6. Notifications and Messages

We send notifications and communications such as newsletters by email and through other communication channels such as instant messaging.

 

6.1 Conversion measurement and reach

 

Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to offer notifications and communications effectively and in a user-friendly manner based on the needs and reading habits of the recipients, as well as permanently, securely and reliably.

 

6.2 Consent and objection

 

As a matter of principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure where possible, 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 can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.

 

In principle, you can unsubscribe from notifications and communications such as newsletters at any time. This is subject to notifications and communications that are absolutely necessary for our offer. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement.

 

6.3 Service provider for personalization, notifications and messages

 

We send notifications and messages via third-party services or with the help of service providers. Cookies may also be used in the process. We ensure appropriate data protection for such services as well.

 

6.3.1 We use customer.io in particular to analyze the behavior of users, to communicate with them in a segmented and targeted manner in connection with our SHUBiDU app and our other offerings, and to improve our products. customer.io is a service of the American Peaberry Software Inc. Information about the type, scope and purpose of data processing can be found in the customer.io privacy policy and on the page about customer.io and the General Data Protection Regulation (GDPR).

 

6.3.2 In particular, we use Segment.io, a service of the American Segment.io Inc. We use the service to be able to integrate usage data of our app and website with other services (in particular customer.io). Based on the corresponding usage profiles, we can improve our offer. Cookies may also be used in the process. Further information on the type, scope and purpose of data processing can be found in the Segment.io privacy policy.

 

6.3.3 We use MOBILEtechnics in particular to automate and simplify communication via SMS with our users and with interested persons. This is a service of the Swiss company MOBILEtechnics AG. Information about the type, scope and purpose of data processing can be found on the "Security & Datacenter" page of MOBILEtechnics.

 

6.3.4 We also use Twilio SMS to automate and simplify communication via SMS with our users and interested persons. This is a service of the American Twilio Inc. Information about the type, scope and purpose of data processing can be found in the Twilio privacy policy.

 

6.3.5 We use MailChimp in particular to send and manage newsletters. MailChimp is a service of the American The Rocket Science Group LLC. Information about the nature, scope and purpose of data processing can be found in the privacy policy of MailChimp and on the page about MailChimp and European data transfers.

 

 

7. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our offer. In doing so, personal data may also be processed outside of 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 online platforms also apply in each case. These provisions inform in particular about the rights of data subjects, which include in particular the right to information.

 

For our social media presence on Facebook, if and to the extent that the GDPR is applicable, we are jointly responsible with Facebook for the so-called Page Insights. 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. Facebook has published information about Page Insights data and an addendum regarding responsibility for Page Insights.

 

We use the Facebook Software Development Kit (SDK) to embed and use Facebook features and content in our service. This also includes the possibility to specifically advertise our offer on Facebook, among others to users of our SHUBiDU app. You can find more information, among other things, on the page about Facebook "social plug-ins".

 

The social plugins are an offer of Facebook Ireland Ltd. in Ireland and the American Facebook Inc. If you are logged in as a user on Facebook, Facebook can assign the use of our online offer to your profile. Further information about the type, scope and purpose of data processing can be found in the Facebook data policy.

 

Users of social media platforms have the option of logging in or registering for our online offering with their corresponding user account ("social login"). The respective terms and conditions of the social media platforms concerned apply, such as the General Terms and Conditions (GTC) and Terms of Use or data protection declarations.

 

8. Third-Party Services

We use third-party services to provide our offer permanently, user-friendly, secure and reliable. Such services are also used to embed content on our website. Such services - for example, hosting and storage services, video services and payment services - require your Internet Protocol (IP) address, as such services cannot otherwise transmit the corresponding content. Such services may be located outside of Switzerland and the European Economic Area (EEA), provided that adequate data protection is guaranteed.

 

In particular, we use the data (bank), hosting and storage services of the American Wix.com Inc. (privacy policy) and the American Google LLC (BigQuery, Data Studi, Firebase and web hosting with use of the Swiss Google Cloud; privacy policy). For users in the European Economic Area (EEA) and Switzerland, the Irish Google Ireland Limited is responsible.

 

For their own security, statistical and technical purposes, third parties whose services we use may also process data related to our offer as well as from other sources - including cookies, log files and counting pixels - in aggregated, anonymized or pseudonymized form.

 

 

8.1 Contact options

 

We use third-party services to better communicate with you and others, such as customers. We also ensure appropriate data protection with such third parties.

 

8.2 Entertainment

 

We use YouTube to embed videos on our website. YouTube is a service of the American Google LLC. For users in the European Economic Area (EEA) and Switzerland, the Irish Google Ireland Limited is responsible. Information on the nature, scope and purpose of data processing can be found in Google's privacy and security policy and data protection statement in each case, in the guide to data protection in Google products (including YouTube), in the information on how Google uses data from websites on which Google services are used and in the information on cookies at Google. In addition, there is the possibility to object to personalized advertising.

 

8.3 Fonts

 

8.3.1 We use Font Awesome to embed selected icons on our website. Cookies are also used in the process. This is a service provided by the American company Fonticons Inc. which, according to its own information, respects European data protection law. Further information about the nature, scope and purpose of data processing can be found in the privacy policy of Font Awesome.

 

8.3.2 We use Google Fonts to embed selected fonts on our website. No cookies are used in the process. This is a service of the American Google LLC, which is offered independently of other Google services. For users in the European Economic Area (EEA) and Switzerland, the Irish company Google Ireland Limited is responsible. Further information about the nature, scope and purpose of data processing can be found in the Privacy and Security Policy and in Google's privacy policy.

 

8.4 Payments

 

We use payment service providers to process our customers' payments securely and reliably. We only use payment service providers that guarantee appropriate data protection. The terms and conditions of the respective payment service providers, such as general terms and conditions (GTC) or data protection declarations, apply to the processing in each case.

 

8.5 Success and reach measurement

 

8.5.1 Google Analytics

 

We use Google Analytics to analyze how our website is used, including, for example, measuring the reach of our website and the success of third-party links to our website. This is a service of the American Google LLC. For users in the European Economic Area (EEA) and Switzerland, the Irish company Google Ireland Limited is responsible.

 

Google also attempts to track individual visitors to our website when they use different browsers or devices (cross-device tracking). Google Analytics requires your Internet Protocol (IP) address, but this is not merged with other Google data.

 

In any case, we have your Internet Protocol (IP) address anonymized before analysis by Google. As a result, your full IP address is generally not transmitted to Google in the USA.

 

Further information on the nature, scope and purpose of data processing can be found in Google's Privacy and Security Policy and Privacy Statement in each case, in the Guide to Privacy in Google Products (including Google Analytics), in the information on how Google uses data from websites on which Google services are used and in the information on cookies at Google. In addition, it is possible to use the "Browser Add-on to deactivate Google Analytics" as well as to object to personalized advertising.

 

8.5.2 Google Tag Manager

 

We use Google Tag Manager to integrate and manage services for analytics or advertising from Google as well as from third parties on our website. This is a service of the American Google LLC. For users in the European Economic Area (EEA) and Switzerland, the Irish Google Ireland Limited is responsible. No cookies are used, but cookies may be used as part of the services integrated and managed with it. We provide information about the processing of personal data by such services in this privacy policy.

 

 

8.6 Advertising

 

8.6.1 Google Ads

 

We use Google Ads (formerly AdWords) in order to be able to advertise our offer on the Google search engine and elsewhere on the Internet, for example on other websites, based on search queries, among other things. Google Ads is an offer of the American Google LLC. For users in the European Economic Area (EEA) and in Switzerland, the Irish company Google Ireland Limited is responsible. Google uses various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads.

 

With such advertising, we would like to reach in particular people who are interested in our online offer or who already use our online offer. For this purpose, we transmit corresponding - possibly also personal - information to Google (remarketing). We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

 

8.6.2 Facebook Ads

 

We use Facebook Ads in order to be able to advertise our offer on Facebook and elsewhere on the Internet, for example on other websites in the Facebook advertising network, based on interests, among other things. Facebook Ads is an offer of Facebook Ireland Ltd. in Ireland or the American Facebook Inc. If you are logged in as a user on Facebook, Facebook can assign the use of our online offer to your profile. Further information about the type, scope and purpose of data processing can be found in the Facebook data policy.

 

With such advertising, we would like to reach in particular people who are interested in our online offer or who already use our online offer. For this purpose, we transmit corresponding - possibly also personal - information to Facebook (remarketing). We can also determine whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

 

8.6.3 Google AdMob

 

In order to be able to display advertising in our SHUBiDU app, we also use the Google service AdMob. For this purpose, Google processes various personal data in order to be able to display personalized and otherwise relevant advertising.

Further information on the nature, scope and purpose of data processing can be found in the privacy and security policy and the privacy policy of Google in each case, in the information on how Google uses data from websites on which Google services are used and in the information on cookies at Google. In addition, there is the possibility to object to personalized advertising.

 

9. Website Extensions

We use jQuery, a free JavaScript library from the JS Foundation. We integrate the library with the help of jQuery.com so that we can improve the speed of our website. jQuery is delivered in this context via the Content Delivery Network (CDN) StackPath, a service of the American StackPath LLC. Further information about the type, scope and purpose of data processing can be found in the StackPath privacy policy.

 

 

10. Final Provisions

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

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