Privacy policy
This translation is provided for information. Only the German version is legally binding: Datenschutzerklärung.
1. Introduction
Below we inform you, among other things, about who is responsible for processing your data, which data we collect in connection with your visit to our website and the use of our services, for which purposes we process this data and to whom we may disclose it. We also inform you about how long your data is processed, the legal basis for the processing (where one is required) and the rights you have towards us with regard to the processing of your data. This privacy policy applies to all of your data that we already hold or will hold in the future. Please note that we may amend this privacy policy from time to time. The current version published on our website applies.
Personal data means all information relating to an identified or identifiable person (hereinafter “personal data”). This includes in particular information such as name, address, telephone number, email address and, in some circumstances, IP addresses and device IDs. In this privacy policy, the general term data covers, in addition to personal data, non-personal and anonymised data. Processing means any handling of data, irrespective of the means and procedures used, in particular the collection, storage, use, modification, disclosure, archiving or deletion of data (hereinafter “processing”).
If you provide us with personal data of other persons, please make sure that these persons are aware of this privacy policy, and only share their personal data with us if you are entitled to do so under applicable data protection law.
2. Name and address of the controller
The controller responsible for the data processing described in this privacy policy is:
Swiss Hair Life GmbH
Campingweg 13, 4665, Oftringen
3. Categories of data processed
We collect certain data when you visit our website, use our services and contact us. As a rule, we collect this data directly from you. The personal data we process may include the following:
- Data that is determined or disclosed when you visit our website or use our services. This includes, among other things, the IP and MAC address or device ID of the device used, cookies, pages you visit and search terms you enter, entries in dialogue fields, ratings, time and duration of visits, clicks, referrer/exit URL, information on the time of use, the browser and device type, the operating system and internet service provider used, and the amount of data transferred.
- Data exchanged in or in connection with contact with us, e.g. communication by letter, telephone, email, contact form, etc. (in particular name, contact details, gender, marital status, date of birth, job title, photo, employees, language, payment information).
- Data disclosed when subscribing to a newsletter or downloading files (e.g. software) (in particular email address and name).
- Data provided when creating a customer account for online shopping and in connection with orders placed (in particular user name, password, chosen payment method and delivery address).
- Data concerning offers and concluded contracts (e.g. contract date, type, content, product, parties, term, value, amendments, payment details, contact details, contact persons, billing and correspondence addresses, customer feedback, terminations, disputes, etc.).
- Data disclosed in the context of the comment function (in particular email address, the user name you choose unless you post anonymously, and your IP address).
- Data you disclose when taking part in competitions, surveys and the like.
The above data does not constitute personal data in every case. As a rule, we cannot attribute data arising from the use of our services without registration (e.g. for a newsletter or online shop) to an individual identified by name. In individual cases, however, this may be possible in combination with other data.
Please note that the information provided in connection with the use of the contact form or the comment function may include particularly sensitive data (such as health data) and that you provided it to us voluntarily.
4. Purposes of processing
To the extent permitted by applicable law, we will process personal data in particular for the following purposes:
- initiating, concluding, performing and administering contracts;
- offering, further developing and improving our offers, developing new services, operating, maintaining, optimising and ensuring the security of our services and infrastructure;
- managing the users of our services, identity checks, log-ins and other authentication;
- maintaining, administering and developing our customer relationships, communicating with customers and third parties, promotions, advertising and marketing, offering tailored services and relevant content;
- quality control, compiling statistics;
- compliance with legal and regulatory obligations and internal rules, enforcement of rights, civil, administrative and criminal proceedings, complaints, combating abuse, investigations and responding to enquiries from authorities and public offices.
Patient reviews and before/after images
When you submit a review on swisshairlife.ch, we process your first and last name, your email address if applicable, your star rating, your text, information on the treatment, location and time, and the photos you upload. Photos of the head and hair after a treatment may allow conclusions to be drawn about your health.
We use this data to check your review, to match it to a treatment with us and, with your express consent, to publish it on our website. Your first and last name, the rating, the treatment, the location, the time information and, with separate consent, the photos appear publicly. We never publish your email address or the original photo files.
You can withdraw your consent at any time with effect for the future, by email to info@swisshairlife.ch or via our contact form. We will then remove the review from the website without delay. We keep your consent and the time it was given for as long as we need it as evidence.
5. Legal basis
We use personal data for the above purposes on the basis of the following legal grounds, where such a basis is required under applicable data protection law:
- performance of a contract;
- compliance with legal obligations;
- consent given to us or to third parties;
- legitimate interests of ours and of third parties, in particular:
- offering and providing services;
- advertising and marketing;
- maintaining contacts and communicating with users;
- user management, identity checks, log-ins;
- compliance with legal and regulatory obligations, enforcement of rights, civil, administrative and criminal proceedings, complaints, investigations and responding to enquiries from authorities.
6. Publication and disclosure of data
We may publish and disclose data as follows:
Processors
We may engage third parties to provide certain services (e.g. in the areas of IT, operation of applications, administration, dispatch, etc.) and to process and store data (so-called “processors”). Processors may have access to personal data and process it on our behalf. We oblige processors to comply with data protection law and to process data only in the way we would do ourselves. Processors that may receive personal data may be located in any country, in particular in Switzerland, Germany, Israel and the USA.
Contractual partners
We may disclose data to contractual partners (for example sales partners, service providers, financial companies, etc.). This is done, for example, to fulfil contractual obligations, to offer certain services, for debt collection and marketing purposes, to analyse the use and operation of our services, systems and infrastructure, and for payment processing. Possible recipients may also include acquirers or prospective acquirers of business units, of the companies or of parts thereof. Contractual partners may obtain access to personal data and process it for their own purposes (for example to perform the contract or to comply with their own legal obligations). In doing so, they are themselves obliged to comply with applicable data protection laws. Contractual partners that may receive personal data may be located in any country, in particular in Switzerland, in countries of the EU and the EEA and in the USA.
For the digital creation, transmission, signing and processing of contracts, we may use
SmartDocs. In this case, in particular master and contact data, contract content, signature data, time stamps, IP addresses and technical log data may be processed by SmartDocs on our behalf. The data is processed for the purpose of initiating and concluding contracts, electronic signature, and documenting and administering the contractual relationship.
Disclosure to authorities
In certain situations, we may disclose data to authorities, public offices and other third parties. We do so where we are requested to do so by an authority or public office, or where we consider ourselves obliged to do so.
7. Retention period
We store personal data for as long as is necessary for the purpose for which we collected it. Certain personal data is also subject to legally binding retention obligations of ten years or more, which we take into account. We may also store personal data for at least the duration of the applicable limitation periods, which in many cases is five or ten years. Personal data arising in connection with the use of our services (e.g. records, logs, analyses, etc.) that is not subject to such retention or limitation periods is generally deleted earlier, as soon as we no longer have an interest in processing it. Data may also be kept longer in anonymised form. Subject to an express contractual agreement, we are not obliged to you to retain data for a specific period.
8. Data security
We apply appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.
9. Your rights (rights of data subjects)
Every data subject has the right to information about the personal data concerning them. They also have the right to request that we correct, delete and restrict personal data concerning them, and to object to such processing of personal data. Exercising these rights generally requires that the data subject can clearly prove their identity. If the processing of personal data is based on consent, the data subject can withdraw that consent at any time. In certain cases, the data subject has the right to receive the data generated through the use of online services in a structured, commonly used and machine-readable format that allows its further use and transfer. Requests relating to these rights should be sent to the address given above. We reserve the right to restrict the rights of the data subject within the scope of the applicable law and, for example, not to provide complete information or not to delete data. Please also note that deleting your personal data may mean that services are no longer available or can no longer be used, in whole or in part.
Every data subject has the right to lodge a complaint with the competent data protection authority. For a controller in Switzerland, this is the Federal Data Protection and Information Commissioner. For a controller in the Principality of Liechtenstein, it is the Liechtenstein Data Protection Authority.
10. Cookies, web analytics and tracking tools
We use various common technologies to collect, store and evaluate data when you visit our website and use our services.
These include in particular cookies, which can be used to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use. When you access a service again, it can recognise your browser or device by means of the cookie. Cookies can store user settings and other information. We use session cookies. These are necessary to perform the basic functions of the services and are automatically deleted after you have used our services. We also use temporary and permanent cookies, which remain stored on your computer or mobile device for longer. The information collected by means of cookies enables us to improve our website and services in line with customer wishes and to present you with offers tailored to you.
You can block the use of cookies in your browser settings or delete them there. Please note that if cookies are not permitted, it may not be possible to use all the functions of a service in full, and that deleting cookies also deletes any opt-out cookies you may have set. Such opt-out cookies would then have to be activated again on your next visit to the service concerned. Otherwise you will be recognised as a new user and your data will be collected again.
In addition to cookies, we use web analytics and tracking tools to measure and evaluate the use of our website and services, to personalise the services and to show you tailored offers and advertising. The data processing carried out by such tools, which are usually provided by third parties, is subject to the terms of use and privacy policies of those third parties.
11. Integration of third-party offers
We integrate services and content from third parties into our web pages that may allow you to interact with third parties (e.g. YouTube videos or online payment via a payment service provider). Any data provided is forwarded to these third parties for processing and performance of the service concerned, or processed directly by them.
Please note that the terms of use and privacy policies of these third parties apply to their data processing.
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