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Privacy Statement for Kalaidos University of Applied Sciences and STI – Schweizerisches Treuhand-Institut FH

28.07.2023

This privacy policy providers information about which personal data we process in connection with our activities and operations, including our www.kalaidos-fh.ch website. In particular, we provide information about why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.

Individual or additional activities and operations may be subject to additional privacy policies as well as other legal documents such as General Terms and Conditions (GTCs), Terms of Use or Conditions of Participation.

1. Contact addresses

Responsibility for the processing of personal data:

Kalaidos University of Applied Sciences
Sabine Eichert-Breuer
Jungholzstrasse 43
8050 Zürich
Switzerland

datenschutz@kalaidos-fh.ch

STI Schweizerisches Treuhand-Institut FH AG
Raphael Cabrera
Josefstrasse 53
8005 Zürich
Schweiz

raphael.cabrera@treuhandinstitut.ch

We will point out if there are other data controllers responsible for the processing of personal data in individual cases.

2. Terms and legal basis

2.1 Terms

Personal data is any information that relates 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, the retrieval, matching, adaptation, archiving, storage, reading, disclosure, procurement, recording, collection, erasure, disclosure, classification, organisation, storage, modification, dissemination, linking, destruction and use of personal data.

2.2 Legal bases

We process personal data in accordance with Swiss data protection law such as, in particular, the Swiss Federal Data Protection Act (Datenschutzgesetz, DSG) and the Swiss Data Protection Ordinance (Datenschutzverordnung, DSV).

3. Nature, scope and purpose

We process personal data that is necessary for us to carry out our activities and operations in a long term, user-friendly, safe 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, in particular.

We process personal data for the duration that is necessary for the respective purpose(s) or required by law. Personal data whose processing is no longer necessary 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 ensure data protection with such third parties. In particular, this concerns the following:

  • our service providers (within the Kalaidos Education Group and externally, such as banks, insurance companies), including processors (such as IT providers);
  • purchasers or those interested in acquiring business areas, companies or other parts of the Kalaidos Education Group;
  • other companies of the Kalaidos Education Group;

We process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after acquiring prior information.

In this context, we process in particular data that a data subject voluntarily provides to us when contacting us - for example, by mail, email, instant messaging, contact form, social media or telephone - or when registering for a user account. For example, we may store such information in an address book, in a customer relationship management (CRM) system, or with similar tools. If we receive data about other persons, the persons transmitting the data are obliged to ensure data protection towards these persons as well as to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, or receive from other companies within the Kalaidos Education Group, if and to the extent that such processing is permitted for legal reasons.

4. Applications

We process personal data about applicants to the extent that it is necessary for assessing their suitability for employment or for the subsequent execution of an employment contract. The personal data required depends in particular on the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, resumes and other application documents, as well as online profiles.

We use third-party services to post jobs via E-recruiting and to enable and manage applications.

In particular, we use:

5. Personal data abroad

In general we process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it or have it processed there.

We may disclose personal data to all states and territories on Earth as well as elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with a decision of the Swiss Federal Council.

We may disclose personal data to countries whose laws do not ensure adequate data protection, provided that adequate data protection is ensured in other ways. Appropriate data protection can be ensured, for example, through corresponding contractual agreements, on the basis of standard data protection clauses, or with other suitable guarantees. By way of exception, 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 provide a copy of any guarantees upon request.

6. Rights of data subjects

6.1 Claims under data protection law

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

  • Information: Data subjects may request to be informed as to whether we process personal data about them, and if so, what personal data. Data subjects also receive the information required to assert their claims in accordance with Swiss data protection law. This includes, among others, the processed personal data as such. This also includes, 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 may have incorrect personal data corrected and have the processing of their data restricted.
  • Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data.
  • Disclosure of data and data portability: Data subjects may request the disclosure of personal data or the transfer of their data to another data controller.

We may suspend, limit or deny the exercise of data subjects' rights to the extent permitted by law. We can point out to data subjects any requirements they may have to meet in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part on the grounds of trade secrets or the protection of others. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.

We may, by way of exception, cover costs required to exercise the rights. We shall inform data subjects in advance about any costs.

We are required to take reasonable steps to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

6.2 Right to lodge a complaint

Data subjects have the right to enforce their data protection claims through legal channels 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 Swiss Federal Data Protection and Information Commissioner (EDÖB).

7. Data security

We take suitable technical and organisational measures to ensure data security that is appropriate to the respective risk. 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 to HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

Our digital communications - basically all digital communications - are subject 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.

8. Use of the website

8.1 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 is stored in the browser. Such stored data does not need to 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. In particular, cookies make it possible to recognise a browser the next time it visits 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 completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request - at least if and to the extent necessary - express consent for the use of cookies.

For cookies used to measure performance 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).

8.2 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 (referrer).

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, reliably and in a user-friendly as well as to ensure data security and thus in particular the protection of personal data, including by third parties or with the help of third parties.

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - including 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 capture the same information as server log files.

9. Notifications and messages

We send notifications and messages via email and other communication channels, such as instant messaging or SMS.

9.1 Performance and reach measurement

Notifications and messages may contain web links or tracking pixels that capture 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 messages on a personal basis. We need this statistical recording of usage to measure performance and reach in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.

9.2 Consent and objection

Fundamentally, you must expressly consent to the use of your email address and other contact addresses, unless their use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure whenever possible, which means that you will receive an email with a web link that you must click to confirm, so that there can be no misuse by unauthorised third parties. We may log such consents including internet protocol (IP) address, date and time for evidential and security purposes.

Fundamentally, you can object to receiving notifications and messages such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for measuring performance and reach. This is subject to any required notifications and messages in connection with our activities and operations.

9.3 Service provider for notifications and messages

We send notifications and messages with the help of specialised service providers.

In particular, we use:

10. Social Media

We are present on social media platforms and other online platforms in order to be able to communicate with interested persons as well as to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland.

The General Terms and Conditions (GTCs) and Terms of Use as well as privacy policies and other provisions of the individual operators of such platforms shall also apply in each case. These provisions provide information in particular about the rights of data subjects directly against the respective platform, which includes, for example, the right to be informed.

11. Third party services

We use the services of specialised third parties in order to carry out our activities and operations in a sustainable, 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 mandatory reasons.

For necessary security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymised or pseudonymised manner. This is, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

11.1 Digital infrastructure

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

In particular, we use:

11.2 Audio and video conferences

We use specialised audio and video conferencing services to communicate online. We can use it, for example, to hold virtual meetings or to conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy policies and terms of use apply in addition.

Depending on the situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background superimposed.

In particular, we use:

11.3 Online collaboration

We use third party services to enable online collaboration. In addition to this data protection declaration, any directly visible conditions of the services used, such as terms of use or data protection declarations, also apply.

In particular, we use:

11.4 Social media functions and social media content

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

In particular, we use:

11.5 Map material

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

In particular, we use:

11.6 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

In particular, we use:

11.7 Advertising

We use the option of displaying targeted advertisements for our activities and operations with third parties such as social media platforms and search engines.

With such advertising, we particularly want to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding - possibly also personal - information to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our online services to your profile there.

In particular, we use:

12. Extensions for the website

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

In particular, we use:

  • Google reCAPTCHA: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA-specific information: ("What is reCAPTCHA?").

13. Performance and reach measurement

We use services and programmes to determine how our online offering is used. Within this framework, 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. However, we can also, for example, try out and compare how different versions of our online offer or parts of our online offer are used ("A/B test" method). Based on the results of the performance and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offer.

When using services and programmes for performance and reach measurement, the internet protocol (IP) addresses of individual users must be stored. IP addresses are always shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation and thus to improve the data protection of users.

When using services and programmes for performance and reach measurement, cookies may be used and user profiles may be created. 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 (at least approximate) location. Fundamentally, user profiles are only created pseudonymously. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, at most, assign the use of our online offer to the user account or user profile with the respective service.

In particular, we use:

14. Final provisions

We have created this privacy policy using the Data Protection Generator by Datenschutzpartner.

We can amend and add to this privacy policy at any time. We will provide information about such amendments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.

Kalaidos University of Applied Sciences

Jungholzstrasse 43
8050 Zurich
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