Privacy policy

This privacy policy provides information about the personal data we process in connection with our activities and operations, including our website orphis.ch. In particular, we provide information about why, how, and where we process personal data. We also provide information about the rights of individuals whose data we process.

Additional privacy policies 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, 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.

1. Contact addresses

Responsibility for processing personal data:

Orphis AG
Bleichestrasse 9
9000 St. Gallen

We will indicate if there are other parties responsible for processing personal data in individual cases.

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, for example, querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, storing, modifying, distributing, 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 bases

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

Where and to the extent that the General Data Protection Regulation (GDPR) applies, we process personal data in accordance with at least one of the following legal bases:

3. Type, scope, and purpose

We process the personal data that is necessary to enable us to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. Such personal data may 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, and contract and payment data.

We process personal data for the duration required for the respective purpose or purposes or as required by law. Personal data that no longer needs to be processed is anonymized 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, specialized providers whose services we use. We also guarantee data protection with such third parties.

We only process personal data with the consent of the persons concerned. If and to the extent that processing is permissible for other legal reasons, we may refrain from obtaining 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.

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 in an address book or similar tools, for example. If we receive data about other persons, the persons transmitting the data are obliged to guarantee data protection for 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, provided that such processing is permissible for legal reasons.

4. Personal data abroad

We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for processing or to have it processed there.

We may export personal data to all countries and territories on Earth and elsewhere in the universe, provided that the local law guarantees adequate data protection in accordance with a decision by the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) applies, in accordance with a decision by the European Commission.

We may transfer personal data to countries whose laws do 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 other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate 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 execution of a contract. Upon request, we will gladly provide data subjects with information about any guarantees or provide a copy of any guarantees.

5. Rights of data subjects

5.1 Data protection claims

We grant data subjects all rights in accordance with applicable data protection law. Data subjects have the following rights in particular:

We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any conditions that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part on the grounds of business secrets or the protection of other persons. We may also refuse to delete personal data in whole or in part on the grounds of statutory retention obligations.

In exceptional cases, we may charge a fee for exercising these rights. We will 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 to lodge a complaint

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

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

Data subjects have the right to lodge a complaint with a competent European data protection supervisory authority, provided that the General Data Protection Regulation (GDPR) applies.

6. Data security

We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. However, we cannot guarantee absolute data security.

Access to our website is secured by 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.

Like all digital communication, our digital communication is subject to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the 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—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data that are stored in the browser. Such stored data are not necessarily limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a specific 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 enable, in particular, a browser to be recognized the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

Cookies can be disabled or deleted in whole or in part at any time in your 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 where and to the extent necessary.

For cookies used to measure success and reach 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 collect the following information for each access to our website, provided that it 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 subpages of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to ensure that our website is permanently available, user-friendly, and reliable, and to ensure data security and, in particular, the protection of personal data—including 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 known as web beacons. Tracking pixels—including those from third parties whose services we use—are small, usually invisible images that are automatically retrieved when you visit our website. Tracking pixels can be used to collect the same information as server log files.

8. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities. 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 privacy policies and other provisions of the individual operators of such platforms, also apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis 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, including the so-called Page Insights, insofar as the General Data Protection Regulation (GDPR) applies. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook 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 Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called «Supplement for Controllers» with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the «Information about Page Insights» page, including «Information about Page Insights data.».

9. Third-party services

We use specialized third-party services to ensure that our activities and operations are sustainable, user-friendly, secure, and reliable. These services enable us to embed functions and content into our website, among other things. When embedding such content, the services used collect the Internet Protocol (IP) addresses of users, at least temporarily, for technical reasons.

For necessary 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 in order to be able to offer the respective service.

In particular, we use:

9.1 Digital infrastructure

We use the services of specialized third parties in order to be able to utilize the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

10. Measuring success and reach

We try to determine how our online offering is used. In this context, we can, for example, measure the success and reach of our activities and the impact of third-party links on our website. However, we can also test and compare how different parts or versions of our online offering are used (A/B testing 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 offering.

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 always shortened («IP masking») in order to comply with the principle of data minimization through appropriate pseudonymization.

Cookies may be used to measure success and reach, 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 location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.

We use the following in particular:

11. Final provisions

We have created this privacy policy using the privacy policy generator from Datenschutzpartner.

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.