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Privacy Policy and Imprint

This privacy policy describes how Zwiss Avenue handles personal data and applies to all data processing that takes place in the context of using our digital offerings, contacting us or using our services.

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1. Preamble

Scope 

This privacy policy describes how Zwiss Avenue handles personal data and applies to all data processing that takes place in the context of using our digital offerings, contacting us or using our services. It is addressed to all persons whose data is processed by us, regardless of whether they visit our website, fill in a form, communicate with us or have a project or order-related relationship with Zwiss Avenue. 

The Notice applies to both national and international data processing operations, insofar as they are related to our activities. This includes, in particular, the processing of personal information through integrated digital systems, communication interfaces and analysis platforms that are used by Zwiss Avenue to provide, optimize and further develop our services. 

Zwiss Avenue is currently not a registered legal entity, but an organization in the process of being established with digital offerings and international activities. Nevertheless, we are fully aware of our responsibility under data protection law and are committed to processing personal data in accordance with applicable laws and the principles of transparency, purpose limitation, data minimisation and security 

Objective and responsible body 

The aim of this privacy policy is to explain to users in a transparent, understandable and structured form what personal data Zwiss Avenue collects, to what extent it is processed, for what purposes this is done and on what legal basis the processing takes place. At the same time, this statement provides information about the existing rights of data subjects and how these rights can be asserted. 

Zwiss Avenue attaches great importance to data protection and is committed to processing all personal data with the utmost care and in compliance with applicable data protection laws. These include, in particular, the Swiss Data Protection Act (revFADP), the EU General Data Protection Regulation (GDPR), the data protection law of the United Kingdom, the California Data Protection Regulations (CCPA) and, where relevant, the regulations of the United Arab Emirates. 

The data controller within the meaning of the applicable data protection laws is Zwiss Avenue. Although Zwiss Avenue is not currently registered as a legal entity in the commercial register, the operational management of the organization assumes all obligations arising from its responsibility under data protection law. Responsibility, administration and provision of information are carried out via the primary location in Switzerland. Requests for data protection can be directed at any time to the central contact address of Zwiss Avenue listed at the end of this statement. 

2. Applicable law

European Union General Data Protection Regulation (GDPR) 

The processing of personal data by Zwiss Avenue is subject to, among other things, the General Data Protection Regulation of the European Union (GDPR), provided that the data subjects are resident in the European Economic Area (EEA) or the data processing is related to the targeted approach of such persons. This applies in particular to cases where Zwiss Avenue advertises and provides its services within the EU or collects and processes personal data of European users, for example via forms, tracking technologies or digital communication channels. 

According to Article 3 (2) GDPR, the Regulation also applies if Zwiss Avenue, as an organisation not established in the EU, offers services to data subjects within the EU or observes their behaviour – for example through analysis and retargeting technologies on the website. For this reason, we are committed to complying with the requirements of the GDPR in all cases where its provisions apply to our activities. 

In collecting, processing and storing personal data, Zwiss Avenue is guided by the principles of lawfulness, purpose limitation, data minimization, transparency, integrity and confidentiality in accordance with Article 5 GDPR. The processing is carried out on the basis of clearly defined legal bases, such as in particular consent (Art. 6 (1) (a) GDPR), the implementation of pre-contractual measures or contractual obligations (Art. 6 (1) (b) GDPR), legal obligations (Art. 6 (1) (c) GDPR) and legitimate interests (Art. 6 (1) (f) GDPR), insofar as these interests do not outweigh the fundamental rights of the data subjects. 

In addition, the GDPR grants data subjects extensive rights, including the right to information, correction, deletion, restriction of processing, objection and data portability. Zwiss Avenue undertakes to guarantee these rights and to deal with such requests without undue delay. 

Swiss Data Protection Act (revFADP) 

In addition to the European Union’s General Data Protection Regulation, the revised Swiss Data Protection Act (revFADP), which has been in force since 1 September 2023, is relevant for Zwiss Avenue. This law applies to all data processing that takes place in Switzerland or is carried out by an entity based in Switzerland. The revFADP also applies if the data processing has an impact on persons in Switzerland, even if Zwiss Avenue is not listed as a registered legal entity. 

Zwiss Avenue is committed to complying with the basic principles of the revFADP, in particular to the processing of personal data in good faith, purpose limitation, transparency and proportionality. We ensure that only the data that is necessary to fulfil the purposes pursued is processed and that it is protected in a manner that meets the requirements of current Swiss data protection law. 

In the course of our activities – in particular in connection with digital forms, contract processing, communication and advertising technologies – we observe the specific requirements for the duty to provide information (Art. 19 et seq. revFADP), data security (Art. 8 revFADP), as well as the rights of data subjects (Art. 25 et seq. revFADP), which include, among others, the right to information, the right to data disclosure and the right to rectification. 

Since Zwiss Avenue was founded in Switzerland and operates from here, the provisions of the revFADP are binding for all relevant processing activities. We ensure that all data processing is carried out in accordance with Swiss standards, even in an international context, or – where necessary – is secured with additional protective measures such as standard contractual clauses. 

UK Data Protection Act 

In the event that Zwiss Avenue processes personal data of individuals located in the United Kingdom or provides targeted services there or analyzes their behavior in the context of the use of digital channels, the UK Data Protection Framework will also apply. Following the United Kingdom’s withdrawal from the European Union, data protection law in the United Kingdom is governed by the UK Data Protection Act 2018 (DPA 2018) as well as the supplementary UK General Data Protection Regulation (UK GDPR).  

Zwiss Avenue is committed to complying with data protection regulations in the United Kingdom, insofar as these apply to a specific processing activity. This applies in particular to cases where we target UK users through our website, generate leads, process digital forms or target audiences in the UK via third-party platforms such as Meta or Google. 

In accordance with the DPA 2018, Zwiss Avenue undertakes to process personal data lawfully, fairly and transparently, to ensure data security and to fully guarantee the rights of data subjects. These include, but are not limited to, the right to information, correction, restriction of processing, objection and, in certain cases, the right to data portability or deletion. 

To the extent that personal data is transferred from the UK to other countries, Zwiss Avenue will ensure that appropriate security measures are in place. These include, but are not limited to, the use of recognised standard contractual clauses or, where available, adequacy decisions by UK data protection authorities. 

UAE Data Protection Law (Federal Decree Law No. 45 of 2021) 

To the extent that Zwiss Avenue processes personal data of individuals located in the United Arab Emirates (UAE) or specifically directs marketing and service offers to natural persons residing in this jurisdiction, Federal Law No. 45 of 2021 on the Protection of Personal Data shall  apply. 

This law represents the first comprehensive data protection law at the federal level in the UAE and is structurally aligned with international data protection standards, in particular the GDPR. Among other things, it regulates the obligation to consent for the processing of personal data, the purpose limitation, the information obligations towards data subjects and their rights in connection with the processing of their data. 

Zwiss Avenue undertakes to respect the data protection requirements of Decree No. 45/2021 in the context of commercial activities related to the United Arab Emirates. This includes, in particular, the collection and processing of personal data on a clear legal basis, the transparent information of the data subjects about the purpose of use of the data, as well as the implementation of suitable organizational and technical measures to protect this data. 

If personal data is transferred from the UAE to other countries – for example in the context of the use of international software solutions – Zwiss Avenue ensures that this is only done in compliance with the conditions provided for by law. These include, in particular, appropriate safeguards for the protection of data in the third country as well as contractual safeguards that are comparable to international standards. 

California Consumer Privacy Act (CCPA) 

To the extent that Zwiss Avenue processes personal information of individuals who reside in the State of California or otherwise directs products, services, or marketing to California consumers, the terms of the California Consumer Privacy Act (CCPA), as amended, will apply. 

The CCPA provides California residents with specific privacy rights, including the right to request access to the personal information collected and processed, the right to have that information deleted, and the right to object to the “sale” of personal information to third parties. Although Zwiss Avenue does not currently sell personal information to third parties for commercial purposes, California data subjects will be notified of their right to object in this regard. 

Zwiss Avenue fully recognizes the principles of the CCPA and strives to comply with all requirements of the law to the extent that they apply due to the nature of the data processing. This applies in particular to the transparent presentation of the categories of collected data, the disclosure of the purposes of data processing and the possibility of asserting the rights of data subjects in a clearly structured and barrier-free form. 

Requests under the CCPA, such as access, deletion, or restriction of use of personal information, may be made at any time using the contact details provided at the end of this Privacy Statement. Zwiss Avenue undertakes to process such requests in accordance with the statutory response times and requirements. 

3. Definitions

For the purposes of this Privacy Policy, the following terms shall apply with the meanings described herein. These definitions are for the sake of clarity and refer to both national and international data protection regulations, in particular the GDPR, the revFADP and similar regulations. 

Personal data 

Personal data is any information relating to an identified or identifiable natural person. A person is considered identifiable if he or she 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. This includes, among other things, information such as first and last name, e-mail address, telephone number, IP address, user behavior or even content from completed forms. 

Controller and processor 

A controller within the meaning of data protection law 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. In the context of this statement, Zwiss Avenue is considered the controller for all data processing initiated via its own digital offerings or in the context of customer relationships. 

A processor, on the other hand, is a body – such as a technical service provider or a platform provider – that processes personal data on behalf of and under the instructions of the controller. Zwiss Avenue uses such processors in certain cases, in particular in connection with hosting, communication services, booking tools, analytics platforms or cloud-based data processing. These service providers are contractually obliged to comply with the applicable data protection regulations. 

Services, tools and user groups 

For the purposes of this Statement, the terms “Services” and “Tools” refer to the digital platforms, interfaces and software solutions that Zwiss Avenue uses to provide, optimise and automate its services. These include Microsoft 365, Zapier, Calendly, Google Analytics, Meta Ads, LinkedIn, Wise, OpenAI and UBS Online Services. These systems are used for the purpose of data processing, communication, appointment management, billing or online marketing. 

User groups are all natural persons whose data are processed in the course of Zwiss Avenue’s activities. This includes, in particular, interested parties, website visitors, contact persons with business customers, persons who fill out a form on the website, as well as project partners or consultants with whom communication or cooperation is carried out in the context of the provision of services. 

4. Categories of Data Subjects

The processing operations described in this Privacy Policy concern different groups of natural persons whose data is processed in different ways by Zwiss Avenue. The classification of these data subjects is based on the type of interaction with our digital offerings, the form of contact and the respective context of the cooperation. 

Data subjects include, among others, all persons who visit our website and transmit information to our servers via their browser or device. These people interact with our website either in an informative or active way, for example by filling out a form or booking an appointment. Technical access data, such as IP addresses, browser types used or access times, also fall into this context. 

In addition, personal data of natural persons who have a contractual or pre-contractual relationship with Zwiss Avenue will be processed. This includes both individuals who use our services as end users and representatives of companies with whom Zwiss Avenue enters into a B2B customer relationship. The data concerned results in particular from the bidding phase, project management, correspondence and billing. 

Finally, we also process personal data of persons who provide us with their data as part of a voluntary contact without a contractual relationship already existing. This applies in particular to leads generated via marketing campaigns, applicants who contact Zwiss Avenue via digital channels, and general interested parties who request information about our service portfolio. In these cases, too, data processing will be carried out in compliance with the applicable data protection regulations and only within the scope of the intended purposes. 

5. Types of data processed

The type of personal data processed by Zwiss Avenue depends on the context in which the data is transferred and the underlying purpose. Only those data are collected and used that are necessary for the performance of the respective task or may be processed on the basis of valid consent. 

In the context of making contact, customer relationships or submitting forms, we process so-called master data and contact data. This includes, but is not limited to, full name, email address, telephone number, country, address, or organization information if there is a business connection. This data forms the basis for communication and contract processing with our prospects, customers or partners. 

In addition to the classic contact details, we also collect communication data that is generated in the course of the exchange with Zwiss Avenue. This applies in particular to content from messages, support requests, feedback or appointment requests, regardless of whether they are made by e-mail, via a contact form, a booking tool or via social media. This information is stored for the purpose of response, documentation and traceability. 

In addition, when using our digital offerings, technical and behavioral data is also collected, which falls under the term usage data. This includes, for example, IP addresses, timestamps of access, browser types used, screen resolutions, language settings, and information about pages visited or interactions with certain website content. This data is usually collected automatically by the analysis and tracking tools used and is used to optimise our website and to analyse our reach. 

A special aspect is the processing of so-called profile data, which is generated in the context of personalized advertising and retargeting. Zwiss Avenue uses third-party services such as Meta Ads, Google Ads or LinkedIn Campaign Manager to analyze anonymized or pseudonymized user data for marketing purposes and to define target groups. This data is based on previous user behaviour, interactions with advertising materials or visited content and is processed exclusively within the framework of the applicable data protection laws. 

If users voluntarily provide additional information – for example through free text fields in forms or application documents – this content will also be collected, stored and processed within the scope of the legitimate purposes. 

6. Purposes of data processing

The processing of personal data by Zwiss Avenue is carried out exclusively for legitimate and traceable purposes that are directly related to the provision, development and marketing of our services. The specific objective of the respective data processing results from the context of the data collection and the relationship between Zwiss Avenue and the data subject. 

A key purpose of the processing is the preparation, execution and performance of contracts with our customers and partners. This includes, among other things, the processing of inquiries, the preparation of offers, the implementation of projects, communication with contact persons, the documentation of services and invoicing. In this context, personal data is used for identification, coordination and the legally secure processing of all contractual obligations. 

In addition, Zwiss Avenue processes personal data for the purpose of lead generation, market approach and data-based analysis of user behaviour. Through targeted advertising measures in digital channels – such as social media, search engine marketing or e-mail campaigns – potential interested parties are addressed and encouraged to contact or interact with our offers. In doing so, we collect certain data to measure the effectiveness of these measures, segment target groups and continuously optimize the relevance of our content. 

Another central purpose of processing is the provision of professional customer support as well as individual advice in the context of enquiries or existing projects. In order to be able to respond efficiently to concerns, we store and process information on previous communication processes, project statuses or technical requirements. 

Last but not least, Zwiss Avenue uses personal data to carry out retargeting measures in which people who have already interacted with our digital content are retargeted. This type of processing is carried out in compliance with the applicable regulations on consent and serves the purpose of displaying interest-based content and consistently developing the user experience. 

7. Legal basis for processing

The processing of personal data by Zwiss Avenue is always carried out in accordance with the relevant legal requirements and is based on clearly defined legal bases. Depending on the type of data processing and the underlying purpose, we refer to different legal permission requirements that ensure that all data processing is lawful, purpose-bound and proportionate. 

In many cases, the processing of personal data is carried out on the basis of freely given consent by the data subject. This applies in particular to the use of forms, the registration for newsletter services, the participation in marketing campaigns or the use of analysis and tracking technologies on our website. The consent can be withdrawn at any time without affecting the lawfulness of the processing carried out before the withdrawal. 

Another essential legal reason is the necessity of data processing for the initiation and execution of a contract or for the implementation of pre-contractual measures. When interested parties contact Zwiss Avenue, request a quote or contract services, the collection and processing of certain personal data is necessary in order to be able to fulfil contractual obligations or to properly implement a project. 

In addition, in certain cases we invoke a legitimate interest in the processing of personal data. This is particularly the case when it comes to optimising our website, improving our internal processes, carrying out targeted marketing measures or ensuring IT security. In these cases, a careful balancing of interests is carried out in advance, in which the interests of the data subject worthy of protection are weighed against our own interest in the processing. 

Last but not least, data processing may also take place on the basis of legal obligations to which Zwiss Avenue is subject. These include, but are not limited to, tax, commercial or regulatory regulations that oblige us to store, document or disclose certain information. Processing of personal data may also be required by law in the context of inquiries by authorities or in connection with legal disputes. 

8. Third-Party Providers and Platforms

To provide, improve and automate our digital services, Zwiss Avenue uses various external services and cloud-based systems operated by third-party providers. These platforms support us in communication, appointment scheduling, analysis, data transfer, payment processing, document creation and the technical infrastructure of our company. The integration of these tools is carried out exclusively for functional and operational purposes and in compliance with the care required by data protection law. 

In this context, Zwiss Avenue works with the following external systems, among others: Microsoft 365 (including Outlook, Teams, SharePoint), Google Analytics and Google Tag Manager, Meta Ads (including Facebook and Instagram), Zapier, Calendly, OpenAI, UBS E-Banking, Wise (for international payment processing) and LinkedIn Campaign Manager. These services are used to optimize communication processes, evaluate user behavior, implement retargeting campaigns, carry out financial transactions or automatically control processes in the company. 

In this context, it is important for us to clearly distinguish it from the presentation of these providers on our website. Zwiss Avenue is not in any economic partnership with the companies mentioned. The logos and brands embedded on our website serve exclusively to provide transparent information about the systems we work with in the context of the provision of services. The mere mention or presentation of these services does not imply any contractual cooperation or special business relationship in the legal sense. 

If personal data is processed or stored when using these platforms, this is generally done on the basis of order processing agreements, provided that these are provided for or available in the respective jurisdiction. In all cases where personal data is transferred to so-called third countries – i.e. outside Switzerland, the EU or the UK – Zwiss Avenue ensures that appropriate safeguards are in place to protect the data. These include, in particular, the conclusion of standard contractual clauses of the European Commission, participation in recognized data protection framework agreements or the implementation of additional technical protection measures such as encryption and access restriction. 

The tools used are selected with a view to security, reliability and legal compliance. We regularly check the data protection compliance of our service providers and, if necessary, adapt our system landscape to new legal requirements or contractual conditions. 

9. Forms and Consent to the Privacy Policy

Zwiss Avenue provides various digital forms on its website through which interested parties, customers or project partners can contact us. These forms serve different purposes – for example, requesting a quote, booking appointments, downloading information or contacting them in the context of a consultation. In this context, personal data is collected directly via input fields and transmitted digitally. 

The use of these forms implies that the data subject expressly confirms that he or she has read Zwiss Avenue’s privacy policy before submitting the data. For this purpose, all forms have a corresponding mandatory marking in the form of a checkbox, which must be actively selected by the user. Without this consent, the transmission of the form is technically not possible. This consent is an explicit prerequisite under data protection law for the processing of the data entered. 

The consent given refers to the processing of the transmitted data within the scope of the defined purpose, for example to process an enquiry or to contact us. Zwiss Avenue stores the submitted forms, including the consent given, in order to be able to provide documented proof of consent in accordance with the applicable data protection regulations if necessary. 

Data subjects have the right to revoke their consent at any time with effect for the future. The consequence of a revocation is that Zwiss Avenue will no longer process the data concerned from the time of the revocation – unless further processing is permissible on an alternative legal basis. The revocation can be made in any form via the contact channels given at the end of this data protection declaration. 

Zwiss Avenue ensures that the design of the forms and consent processes is transparent, understandable and in compliance with data protection regulations. Users are clearly informed about the purpose, scope and possible further processing of their data before they give their consent. 

10. Cookies and Tracking Technologies

The Zwiss Avenue website uses cookies and similar technologies to ensure the operation of the site, improve the user experience, provide functions and evaluate the effectiveness of our digital offerings. Cookies are small text files that are stored by the browser on the user’s end device and may contain certain information about behaviour, technical characteristics or preferences when visiting our website. 

From a legal point of view, a distinction must be made between technically necessary cookies and those that are used for statistical, analytical or advertising purposes. Technically necessary cookies are those that are absolutely necessary for the operation of the website – for example, to ensure that forms work, language settings are stored or security-relevant functions can be activated. These cookies may be set without prior consent and are automatically activated when you visit the site. 

All other cookies – in particular those used to track user behaviour, measure reach or personalised retargeting – may only be set after the user has given their active consent. For this purpose, Zwiss Avenue uses a data protection-compliant consent banner that is displayed when the website is visited for the first time. Users have the opportunity to decide individually whether they want to agree to the use of optional cookies or not. The selection can be adjusted or revoked at any time via a corresponding link on the website. 

The following types of cookies may be used on this website, among others: session cookies, which are deleted when the browser is closed; persistent cookies, which remain on the device for a longer period of time; as well as third-party cookies that come from external services such as Google Analytics or Meta Ads. The respective storage periods vary depending on the provider, purpose and configuration. Zwiss Avenue makes sure that all cookies used are configured in compliance with data protection regulations and that no excessive or unjustified storage periods are implemented. 

Insofar as personal data is processed by cookies – for example, when assigning an IP address or a pseudonymous user profile – this is done exclusively on the basis of a valid legal basis in accordance with the applicable data protection laws. 

11. Profiling and automated decision-making

As part of its digital marketing activities, Zwiss Avenue uses targeted procedures for segmentation and evaluation of users, which under certain conditions qualify as profiling within the meaning of data protection laws. Profiling refers to any form of automated processing of personal data in which it is used to assess certain personal aspects of a natural person – such as their interests, behaviour, location or economic situation. 

A central field of application of such technologies at Zwiss Avenue is the targeted approach of user groups through retargeting measures. Based on previous interactions with our website – such as page visits, click behaviour or completed forms – a system-supported re-engagement via external platforms such as Meta (Facebook, Instagram), Google Ads or LinkedIn is made possible. The underlying processing is carried out via third-party tools, in which pseudonymised or aggregated usage data is used to create target group profiles. These measures serve to display relevant content to our interested parties and to minimize the wastage of our advertising campaigns. 

In addition, certain data processing steps related to scoring leads can be automated. This applies in particular to so-called lead qualification, in which defined criteria – such as company size, geographical location or previous contact activity – are used to classify how likely a successful customer relationship is to be established. The resulting evaluations may influence the type and extent of further contact, but do not constitute a decision with legal effect. 

In the context of these proceedings, Zwiss Avenue does not make any fully automated decisions that would have a legal effect on data subjects or significantly impair them in a comparable way. All measures serve exclusively to increase efficiency, improve relevance and automate internal processes. Data subjects retain the right to object to such processing at any time or, if necessary, to request a manual check by a contact person of Zwiss Avenue. 

The procedures used take into account the principles of transparency, proportionality and data protection and, if necessary, are based on the prior consent of the data subject. 

12. Data transfer to third countries

In the context of the use of external platforms, technical infrastructures and cloud-based services, it may be necessary to transfer personal data to countries outside Switzerland, the European Economic Area (EEA) and the United Kingdom. In terms of data protection law, such countries are considered so-called third countries in which there is no level of data protection equivalent to Swiss or European standards. Potentially affected third countries include, in particular, the United States of America (USA), the United Kingdom (UK), the United Arab Emirates (UAE) and, where applicable, other countries in which the providers used by Zwiss Avenue operate. 

Such data transfer takes place, for example, in connection with the use of Microsoft 365, Google Analytics, Meta Ads, Calendly, Zapier, OpenAI or international payment platforms such as Wise or UBS. In all these cases, Zwiss Avenue ensures that the transfer of personal data only takes place if either an adequacy decision has been made by the competent data protection authorities or if appropriate contractual, technical or organisational safeguards are implemented. 

As a standard measure for the legal protection of such transfers, so-called Standard Contractual Clauses (SCCs) of the European Commission or the Swiss Data Protection Supervisory Authority are used. These regulate compliance with an adequate level of protection even in the case of data processing outside the jurisdiction of national or European data protection laws. 

In addition, Zwiss Avenue checks whether service providers participate in officially recognized data protection framework agreements – such as the EU-U.S. Data Privacy Framework – or whether additional measures such as encryption, access restriction or data minimization have been implemented. These supplementary safeguards ensure that the rights and freedoms of data subjects are safeguarded even in cases of cross-border data processing. 

In principle, the transfer of personal data to third countries only takes place if it is necessary for the performance of the contract, complies with a legal obligation or is based on the express consent of the data subject. 

13. Storage Period and Deletion

Zwiss Avenue will only retain personal data for as long as is necessary for the specific purposes for which it was collected or for as long as a legal basis requires it. The specific storage period depends on the type of data, the purpose of processing and any statutory retention periods. 

In the context of contractual relationships or project collaborations, we generally store personal data for the duration of the contract processing and beyond that for the period necessary to comply with legal obligations to provide evidence and retention. This concerns, among other things, tax or commercial law requirements, which may provide for storage for up to ten years after the conclusion of the respective business transaction. 

Data processed on the basis of consent – such as contact details from a form or in connection with a newsletter subscription – will be stored until the data subject withdraws his or her consent or the purpose of the processing no longer applies. After receipt of a revocation or a request for deletion, it is checked whether there are legal obligations to the contrary. If this is not the case, it will be deleted immediately and completely. 

Technical usage data that is automatically collected when you visit the website – such as IP addresses, access times or device types – is usually only stored for a short time, unless it is used for IT security, troubleshooting or reach analysis in individual cases. In such cases, the data is stored in pseudonymised or aggregated form in order to exclude the identifiability of the data subject. 

Zwiss Avenue uses suitable technical and organisational measures to ensure that personal data is automatically or manually deleted, anonymised or blocked after the defined storage period has expired. Permanent storage will only take place if this is expressly prescribed by law in the individual case or if the data subject has expressly consented to storage beyond this. 

14. Rights of data subjects

Zwiss Avenue takes the protection of personal data seriously and guarantees data subjects the exercise of their data protection rights in accordance with the applicable laws. Every person whose data is processed by us has the right to receive information about the type, scope and purpose of the processing and to demand corrections or deletions of their data – provided that this does not conflict with a legal obligation to continue storage. 

The right of access includes the possibility of obtaining confirmation as to whether and which personal data is being processed by Zwiss Avenue. As part of this information, we provide, among other things, information on the categories of data, the purpose of processing, the recipients or categories of recipients and the storage period. 

In addition, there is the right to rectification of inaccurate or incomplete personal data. As soon as we receive a corresponding notification, incorrect information will be updated promptly. Data subjects also have the right to erasure (“right to be forgotten”) if the data is no longer necessary for the original purposes, consent has been revoked or there is no other legal basis for the processing. 

Furthermore, every data subject has the right to object to the further processing of his or her data under certain conditions – in particular if this is carried out on the basis of a legitimate interest or in connection with direct marketing. In the event of a permissible objection, data processing will be discontinued, unless compelling reasons worthy of protection prevail. 

Within the scope of the legal possibilities, there is also the right to restriction of processing and data portability. The latter makes it possible to receive personal data in a structured, commonly used and machine-readable format and – as far as technically feasible – to have it transmitted directly to another controller. 

Persons who believe that Zwiss Avenue is in breach of applicable data protection law in the processing of their personal data have the right to lodge a complaint with a competent supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), in the EU the respective national data protection office of the country of residence, in the United Kingdom the Information Commissioner’s Office (ICO) and in California the California Privacy Protection Agency (CPPA). 

Zwiss Avenue actively supports data subjects in exercising these rights and ensures that such requests are answered in a timely, comprehensible and data protection compliant manner. Inquiries can be directed at any time to the contact address given in the imprint or at the end of this privacy policy. 

15. Technical and organisational measures (TOM)

Zwiss Avenue takes appropriate technical and organizational measures to ensure the security of personal data and to protect it from unauthorized access, loss, misuse or manipulation. The security measures are continuously adapted and improved, taking into account the state of the art, the risk to the rights and freedoms of the data subjects, and the nature and scope of the processing. 

The central measures include, in particular, access controls to personal data, to which only authorized persons have access. Data transmitted via our website is protected against spying and manipulation by means of transport encryption (TLS/SSL). In addition, Zwiss Avenue relies on the use of security-certified cloud platforms, regular system updates, logging of critical access and security mechanisms within Microsoft 365 to systematically minimize risks such as data loss or unauthorized access. 

16. Company sales and reorganization

In the event of a restructuring, acquisition, merger, sale of shares in the company or any other form of change in the legal or economic ownership of Zwiss Avenue, it may be necessary to transfer personal data to a new controller. In such a case, Zwiss Avenue will ensure that the data subjects are informed of the transfer in a timely manner and that future processing of the data will continue to be carried out in compliance with applicable data protection laws. 

17. Data of minors

The digital offers and services of Zwiss Avenue are not aimed at children or young people under the age of 16. Persons below this age limit are not permitted to transmit personal data via our website without the prior express consent of the parent or guardian. If Zwiss Avenue becomes aware that personal data has been processed without the required consent, this information will be deleted immediately. Parents or guardians who suspect this are requested to contact us directly. 

18. Links to Third Party Sites

The Zwiss Avenue website may contain links to other, external websites over whose content or privacy practices we have no control. The respective operators are solely responsible for the content and data processing on these pages. Zwiss Avenue assumes no responsibility for the data protection measures or the handling of personal data on these third party sites. We therefore recommend that you always carefully check the privacy policies of the linked offers when leaving our website. 

19. Changes to this Privacy Policy

Zwiss Avenue reserves the right to update or supplement this privacy policy at any time, in particular in the event of legal changes, technical adjustments or further developments to our range of services. The current version will be published on our website and will be recognizable by the update date indicated above. Users will be informed in an appropriate manner in the event of significant changes. It is recommended to review the privacy policy regularly. 

20. Contact the Data Protection Office

If you have any questions about data protection, exercising the rights of data subjects or communication in connection with this statement, please contact Zwiss Avenue at the following contact address: 

Zwiss Avenue 

Eichiweg 8 

3267 Seedorf, Switzerland 

E-mail: [email protected] 

At present, there is no obligation to appoint an external data protection officer. All data protection inquiries are processed internally and answered within the legal deadlines. 

Imprint

Zwiss Avenue, Eichiweg 83267 Seedorf, Canton of Bern Switzerland 

E-mail: [email protected] 
Phone: +41 31 561 92 15 
Web: www.zwissavenue.com 

Responsible for the content of this website 

Arianit & Valmir(Co-Leader of Zwiss Avenue) 

Legal form 

Zwiss Avenue is currently not a company registered in the commercial register. It is a nascent organization that provides digital services in marketing, technology, and consulting. 

VAT number 

Non-existent – Zwiss Avenue is currently not subject to VAT. 

Disclaimer 

Despite careful control of the content, Zwiss Avenue assumes no liability for the content of external links. The operators of the linked pages are solely responsible for their content. The information on this website is updated regularly. However, liability for accuracy, completeness or up-to-dateness is excluded. 

Copyright 

The content and works created by Zwiss Avenue on this website are subject to Swiss copyright law. Third-party contributions are marked as such. Duplication, editing and any kind of exploitation outside the limits of copyright law require the written consent of Zwiss Avenue. 

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