Privacy Policy

Privacy Policy

Thank you very much for visiting our website or for contacting us in any other way. For us, the protection of personal data is of particularly high importance. In principle, it is possible to use the website without providing any personal data. However, if you wish to take advantage of an offer from our company online, the processing of personal data may become necessary.

If the processing of personal data is required and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the current Federal Data Protection Act (BDSG), the EU General Data Protection Regulation (GDPR) which became effective on 25 May 2018, and the TMG.

With this privacy policy, our company aims to inform you about the nature, scope and purpose of the personal data we process and to clarify the rights to which data subjects are entitled. Our company has implemented numerous technical and organizational measures to ensure the most complete protection possible of the personal data processed. Nevertheless, internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed.

I. Definitions

Our company’s privacy policy is based on the GDPR. Our privacy policy is intended to be easy to read and understand. To ensure this, we explain the terms used in advance:

Personal Data Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (Art. 4 para. 1 GDPR).

Data Subject A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Processing Processing is any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of Processing Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or Controller Responsible for the Processing The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processor Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient Recipient is a natural or legal person, public authority, agency or another body to which personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

Third Party Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data concerning him or her.

 

II. Name and Address of the Controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection provisions is:

Trojka Limousine Service Soldbachstrasse 1 8152 Glattbrugg Switzerland

Contact: Zürich +41 76 316 46 46 Basel +41 78 716 67 46 Geneva +41 79 682 81 87 E-Mail: info@trojka-limousine.ch

 

III. Name and Address of the Data Protection Officer

There is no obligation to appoint a data protection officer pursuant to Art. 37 GDPR and § 38 BDSG.

 

IV. General Information on Data Processing

  1. Scope of the Processing of Personal Data We generally collect and use personal data of our users only to the extent necessary to provide a functional website and our content and services. The collection and use of personal data of our users regularly occurs only with the user’s consent. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by statutory provisions.
  2. Legal Basis for the Processing of Personal Data Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis. For the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations necessary for the implementation of pre-contractual measures. Insofar as the processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.
  3. Data Erasure and Storage Period The personal data of the data subject will be erased or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

 

V. Provision of the Website and Creation of Log Files

  1. Description and Scope of Data Processing Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:
  • Information about the browser type and version used
  • The user’s operating system
  • The user’s internet service provider
  • The user’s IP address
  • Date and time of access
  • Websites from which the user’s system reaches our website

The data is also stored in our system’s log files. These data are not stored together with other personal data of the user.

  1. Legal Basis for Data Processing The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDPR.
  2. Purpose of Data Processing The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must be stored for the duration of the session. The storage in log files is carried out to ensure the functionality of the website. In addition, the data helps us to optimise the website and to ensure the security of our information technology systems. No evaluation of the data for marketing purposes takes place in this context. These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.
  3. Duration of Storage The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. In the case of storage of the data in log files, this is the case after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or anonymised so that an assignment of the calling client is no longer possible.
  4. Objection and Removal Option The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

 

VI. Cookies

  1. Description and Scope of Data Processing Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables unique identification of the browser when the website is called up again.

The following data is stored and transmitted in the cookies: – Session tracking / Session ID – Consent to cookie usage

In addition, we use cookies on our website that enable an analysis of the user’s surfing behaviour. The following data can be transmitted in this way: – Search terms entered – Frequency of page views – Use of website functions

  1. Legal Basis for Data Processing The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.
  2. Purpose of Data Processing The use of cookies serves to simplify the use of the website for our users. The use of analysis cookies is for the purpose of improving the quality of the website. Through the knowledge gained about the exact use of the website, we are able to continuously optimise our offering. This also constitutes our legitimate interest in the processing of personal data pursuant to Art. 6 lit. f GDPR.
  3. Objection and Removal Option Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

 

VII. Contact / Offer Form and Email Contact

  1. Description and Scope of Data Processing Our website has a contact form that can be used for electronic contact and requests for offers. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored. These data are: name, email address, address, telephone number and, where applicable, other order-related data for an offer. During the sending process, your consent is obtained and reference is made to this privacy policy. Alternatively, contact via the provided email address is possible. In this case, the personal data of the user transmitted with the email will be stored. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.
  2. Legal Basis for Data Processing If the user has given consent, the legal basis for processing the data is Art. 6 para. 1 lit. a GDPR or, in the case of a request for an offer, pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR. The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR. If the email contact is aimed at concluding a contract, an additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.
  3. Purpose of Data Processing The processing of the personal data from the input mask serves solely to process the contact or the request for an offer. In the case of contact by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
  4. Duration of Storage The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the contact form input mask and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is deemed ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. In the case of a request for an offer, deletion occurs after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion occurs after their expiry (end of commercial (6 years) and tax (10 years) retention periods). The additional personal data collected during the sending process is deleted after a period of seven days at the latest.
  5. Objection and Removal Option The user has the option to withdraw consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. In the event of revocation, please contact us by telephone or in writing using the contact details provided above. All personal data stored in the course of the contact will be deleted in this case.

 

VIII. Application Form for Translators

Description and Scope of Data Processing Our website has an application form that can be used for electronic applications as a translator. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored. These data are: name, email address, address, telephone number, language combinations, qualifications and specialist fields. During the sending process, your consent is obtained and reference is made to this privacy policy. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing your application.

Legal Basis for Data Processing If the user has given consent, the legal basis for processing the data is Art. 6 para. 1 lit. a GDPR and, pursuant to pre-contractual measures, Art. 6 para. 1 lit. b GDPR.

Purpose of Data Processing The processing of the personal data from the input mask serves solely to process the application. The other personal data processed during the sending process serve to prevent misuse of the form and to ensure the security of our information technology systems.

Duration of Storage The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the application form input mask, this is the case if the application does not lead to further cooperation. In the case of a contractual relationship, deletion occurs after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion occurs after their expiry (end of commercial (6 years) and tax (10 years) retention periods). The additional personal data collected during the sending process is deleted after a period of seven days at the latest.

Objection and Removal Option The user has the option to withdraw consent to the processing of personal data at any time. In the event of revocation, please contact us by telephone or in writing using the contact details provided above. All personal data stored in the course of the application will be deleted in accordance with the statutory retention periods.

 

IX. Google Analytics

Description and Scope of Data Processing This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google also uses cookies on our website. Google Analytics uses cookies that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website (including your IP address) is transmitted to and stored by Google on servers in the USA.

This website has been extended with the code “grt._anonymizeIP();” to ensure anonymised collection of IP addresses. By activating IP anonymisation on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to website and internet use. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google. Google will not, under any circumstances, link your IP address with other Google data. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Legal Basis for Data Processing The legal basis for the use of the web analytics service Google Analytics is Art. 6 para. 1 lit. f GDPR. The use of cookies by Google is permitted under Art. 6 para. 1 lit. f GDPR.

Purpose of Data Processing The purpose of using the web analytics services and Google’s cookies is to increase the efficiency of our website through a perfected analysis of user behaviour, in order to fully take into account the interests and needs of our users. This also constitutes our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.

Objection and Removal Option You can prevent the storage of cookies set by Google by selecting the appropriate settings in your browser software; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de

 

X. Google AdWords Conversion Tracking

We use the online advertising program “Google AdWords” on our website and, within this framework, conversion tracking (evaluation of visit actions). Google Conversion Tracking is an analysis service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). When you click on an advertisement placed by Google, a cookie for conversion tracking is placed on your computer. These cookies have a limited validity, do not contain any personal data and therefore do not serve for personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognise that you clicked on the advertisement and were redirected to this page. Each Google AdWords customer receives a different cookie. This means there is no possibility that cookies can be tracked across the websites of AdWords customers.

The information obtained using the conversion cookie is used to create conversion statistics. We learn the total number of users who clicked on one of our advertisements and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that allows users to be personally identified.

The processing is carried out on the basis of Art. 6 (1) lit. f GDPR due to the legitimate interest in targeted advertising and the analysis of the effectiveness and efficiency of this advertising.

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you that is based on Art. 6 (1) f GDPR.

You can prevent the storage of cookies by making the appropriate technical settings in your browser software. However, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You will then not be included in the conversion tracking statistics.

Furthermore, you can disable personalised advertising for you in Google’s advertising settings. You can find instructions for this at https://support.google.com/ads/answer/2662922?hl=de In addition, you can disable the use of cookies by third-party providers by visiting the Network Advertising Initiative deactivation page at https://www.networkadvertising.org/choices/ and implementing the opt-out information provided there.

Further information and Google’s privacy policy can be found at: https://www.google.de/policies/privacy/

 

XI. Rights of the Data Subject

If personal data concerning you is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

  1. Right of Access You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you may request information from the controller about the following: (1) the purposes for which the personal data are processed; (2) the categories of personal data concerned; (3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed; (4) the envisaged period for which the personal data concerning you will be stored, or, if specific information on this is not possible, the criteria used to determine that period; (5) the existence of the right to request rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing; (6) the existence of the right to lodge a complaint with a supervisory authority; (7) where the personal data are not collected from the data subject, any available information as to their source; (8) the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to be informed whether the personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer.

  1. Right to Rectification You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and, taking into account the purposes of the processing, to have incomplete personal data completed.
  2. Right to Restriction of Processing Under the following conditions, you may request the restriction of the processing of personal data concerning you: (1) if you contest the accuracy of the personal data concerning you, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (3) the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or (4) you have objected to processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

Where the processing of personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. If the restriction of processing has been obtained under the above conditions, you will be informed by the controller before the restriction is lifted.

  1. Right to Erasure A. Obligation to Erase You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (1) The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed. (2) You withdraw consent on which the processing is based according to Art. 6 (1) lit. a or Art. 9 (2) lit. a GDPR, and there is no other legal ground for the processing. (3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR. (4) The personal data concerning you have been unlawfully processed. (5) The personal data concerning you have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject. (6) The personal data concerning you have been collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR.

B. Information to Third Parties Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17 (1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

C. Exceptions The right to erasure shall not apply to the extent that processing is necessary: (1) for exercising the right of freedom of expression and information; (2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (3) for reasons of public interest in the area of public health in accordance with Art. 9 (2) lit. h and i as well as Art. 9 (3) GDPR; (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR in so far as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or (5) for the establishment, exercise or defence of legal claims.

  1. Right to be Informed If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed by the controller about these recipients.
  2. Right to Data Portability You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (1) the processing is based on consent pursuant to Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) lit. b GDPR; and (2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The exercise of this right shall not adversely affect the rights and freedoms of others.

  1. Right to Object You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes. You have the possibility, in the context of the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by automated means using technical specifications.
  2. Right to Withdraw Data Protection Consent You have the right to withdraw your data protection consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  3. Automated Individual Decision-Making, Including Profiling You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision: (1) is necessary for entering into, or performance of, a contract between you and the controller; (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (3) is based on your explicit consent.

However, such decisions shall not be based on special categories of personal data referred to in Art. 9 (1) GDPR, unless Art. 9 (2) lit. a or g applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place. In the cases referred to in (1) and (3), the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

  1. Right to Lodge a Complaint with a Supervisory Authority Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The supervisory authority with which the complaint has been lodged will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.