Privacy policy

1. Controller

The controller within the definition set down in the General Data Protection Regulation (GDPR) is:

Ludwig Limbeck AG
Sinserstrasse 67
CH - 6330 Cham

Telephone	(+41) 043 456 27 57
	(+41) 041 780 31 06
Email	info@lliag.ch

2. Technology

2.1 SSL/TLS encryption

This website uses SSL or TLS encryption to guarantee security of data processing and to protect the transfer of confidential content such as contact requests, order inquiries or login data that you transmit to us as the operator of the website. You can tell that a connection is encrypted when ‘https://’ instead of ‘http://’ is displayed in the address bar of the browser and a padlock icon appears in the browser bar.

If SSL or TLS encryption is activated, the data that you transmit to us cannot be intercepted by third parties.

3. Collection and storage of personal data

3.1 Data collection on visiting the website

If our website is merely used for information purposes, i.e. if you do not register or otherwise transmit data to us, we only collect the data that your browser transmits to our server (in what are known as ‘server log files’). Our website records various general data and information every time a page is accessed by you or an automated system. This general data and information is stored in the server’s log files. The following may be collected:

1. browser types and versions used,
2. the operating system used on the accessing system,
3. the website that referred an accessing system to our website (known as referrer),
4. the web pages accessed on our website by an accessing system,
5. the date and time of an access to the website,
6. an internet protocol address (IP address),
7. the internet service provider of the accessing system.

This general data and information is not used to draw any conclusions about your person. Instead, it is used:

1. to accurately deliver the content of our website,
2. to optimise the content of our website and the advertising for the website,
3. to guarantee the permanent functionality of our IT systems and the technology used on our website and
4. to provide any necessary information to law enforcement agencies for the purposes of criminal prosecution in the event of a cyberattack.

For that reason, we analyse the collected data and information both statistically and also with the aim of increasing data protection and data security in our company with the ultimate goal of guaranteeing an optimum level of protection for the personal data we process. The data from the server log files is stored separately from any personal data provided by a data subject.

The legal basis for the data processing is Art. 6 (1) (1) (f) GDPR. Our legitimate interest follows from the data collection purposes listed below.

3.2 Data collection on contact initiation via email and on use of the contact form

Personal data is collected when you make contact with us (e.g. via a contact form or email). The data collected via a given contact form is evident from the contact form in question. The personal data entered into the input form helps safeguard our interests in terms of business secrecy and prevent a misuse of the contact form, in particular by establishing who is sending the request. This data is stored and used exclusively for the purpose of responding to your request or for making contact and associated technical administration purposes. The legal basis for the processing of the data is our legitimate interest in responding to your query in accordance with Art. 6 (1) (f) GDPR. If you contact us with the intention of entering into a contract, a further legal basis for the processing is Art. 6 (1) (b) GDPR. Once your query has been conclusively dealt with, the data will be deleted; this is the case if it is apparent from the circumstances that the matter at hand has been conclusively resolved and no statutory retention obligations preclude deletion.

3.3 Data collection in recruitment management

We collect and process the personal data of applicants for the purpose of managing the recruitment process. This processing may also be performed electronically. This is the case in particular where an applicant transmits corresponding application documents electronically, e.g. by email or via a web form on the website. If we enter into an employment contract with an applicant, the transmitted data will be stored for the purpose of managing the employment relationship in compliance with the statutory provisions. If we do not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided no other legitimate interests on our part preclude deletion. Another legitimate interest in this sense may include for instance the obligation to provide evidence in proceedings under the Swiss Gender Equality Act (GlG).

In this context, data processing takes place exclusively on the basis of our legitimate interest pursuant to Art. 6 (1) (f) GDPR.

4. Collection, processing, storage and forwarding of data

Your personal data will not be collected, processed, stored or forwarded to third parties for any purposes other than the following.

We will only forward your data to third parties if:

• you have provided your express consent pursuant to Art. 6 (1) (1) (a) GDPR,
• this is permissible by law and is necessary under Art. 6 (1) (1) (b) GDPR for the performance of a contract with you,
• a statutory obligation applies in respect of forwarding pursuant to Art. 6 (1) (1) (c) GDPR,
• the processing is necessary to protect the vital interests of the data subject or another natural person pursuant to Art. 6 (1) (1) (d) GDPR,
• the processing is necessary pursuant to Art. 6 (1) (1) (e) GDPR for the performance of a task carried out in the public interest or in the exercise of official authority vested in us,
• forwarding is necessary pursuant to Art. 6 (1) (1) (f) GDPR to assert, pursue or defend legal claims and there are no grounds to assume that you have an overriding legitimate interest in your data not being forwarded.

5. Google Analytics analysis tool

This website uses functions of the Google Analytics web analysis service. The provider is Google Inc. (‘Google’), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The ‘Universal Analytics’ mode is used. This enables data, sessions and interactions to be assigned to a pseudonymised user ID across multiple devices so that a user’s activities can be analysed across various devices.

Google Analytics uses what are known as ‘cookies’, text files 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 is usually transferred to one of Google’s servers in the USA and stored there. If IP anonymisation is activated on this website, your IP address will be shortened beforehand by Google within the member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to one of Google’s servers in the USA and shortened there. Note that IP anonymisation has been added to Google Analytics on this website to enable an anonymised recording of IP addresses (known as IP masking). The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google. Further information on terms of use and data protection can be found at https://marketingplatform.google.com/about/analytics/terms/us/ or https://policies.google.com/?hl=en.

5.1 Purposes of processing

Google uses this information on behalf of the operator of this website to analyse your usage of the website, to compile reports on your website activity and to provide further services connected to the use of the website and internet for the benefit of the website operator.

5.2 Legal basis

The legal basis for the use of Google Analytics is your consent pursuant to Art. 6 (1) (1) (a) GDPR.

5.3 Recipients/categories of recipients

The recipient of the collected data is Google.

5.4 Transmission to third countries

The personal data is transmitted to the USA under the EU-US Privacy Shield on the basis of the adequacy decision of the European Commission. You can access the certificate here.

5.5 Duration of data storage

The data transmitted by us that is linked to cookies, user identifier (e.g. user ID) or advertising IDs is automatically deleted after 14 months. Data whose retention period has expired is deleted automatically once a month.

5.6 Rights of data subjects

You can withdraw your consent at any time with future effect by preventing the storage of cookies via a corresponding setting in your browser software; however, note that in this case you may not be able to use the full functionality of this website.

5.7 Objection to data collection

Further, by downloading and installing the browser add-on you can prevent the information generated by the cookie about your use of the website (including your IP address) from being transmitted to and processed by Google. Opt-out cookies prevent your data from being collected when visiting the website in future. To prevent data collection across multiple devices by Universal Analytics, you need to perform the opt-out on all systems used. Click here to set the opt-out cookie: deactivate Google Analytics

6. Newsletter distribution

6.1 Newsletter distribution to existing customers

If you have provided us with your email address on purchasing goods or services, we reserve the right to regularly email you offers of goods or services from our range similar to those you have already purchased. We do not require any separate consent from you for this purpose pursuant to section 7 (3) of the Swiss Federal Act against Unfair Competition (UWG). Data processing for this purpose takes place exclusively on the basis of our legitimate interest in personalised direct advertising pursuant to Art. 6 (1) (f) GDPR. If you initially objected to your email address being used for this purpose, we will not send you any emails. You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with future effect by notifying the controller specified above. The use of your email address for advertising purposes will be immediately discontinued on receipt of your objection.

6.2 Advertising newsletter

On our website you have the option to subscribe to our company newsletter. You can see which personal data is transmitted to us on subscription to the newsletter from the input form.

We notify our customers and business partners about our offers via a newsletter sent at regular intervals. You can only receive our company newsletter if

1. you have a valid email address and
2. you have subscribed to the newsletter.

For legal reasons, as part of the double opt-in process a confirmation email is sent to the email address you initially supplied to receive the newsletter. The purpose of this confirmation email is to review whether you have authorised receipt of the newsletter as the owner of the email address.

When you subscribe to the newsletter we also store the IP address of the IT system you use at the point of subscription as issued by your internet service provider (ISP) as well as the date and time of subscription. We need to collect this data in order to track the (potential) abuse of your email address at a later point in time, which helps us comply with our legal obligations.

The personal data collected during the process of subscribing to the newsletter is used solely for the purpose of sending out our newsletter. Further, subscribers to the newsletter can be emailed information that is necessary for operating the newsletter service or newsletter subscription, as may be the case in the event of changes to the newsletter offering or the technical conditions. The personal data collected in the context of the newsletter service is not forwarded to third parties. You can terminate the subscription to our newsletter at any time. You may withdraw your consent to the storage of the personal data provided to us for the purpose of newsletter distribution at any time. Each newsletter contains a link enabling consent to be withdrawn.

The legal basis for the processing of data for newsletter distribution is Art. 6 (1) (a) GDPR.

6.3 Newsletter tracking

Our newsletters contain what are termed web beacons. A web beacon is a miniature graphic that is embedded in emails that are distributed in HTML format to enable log file recording and log file analysis. This enables a statistical evaluation of the success or otherwise of online marketing campaigns. The embedded web beacon enables the company to identify whether and when an email was opened by you and which links you clicked on in the email.

We store and analyse personal data collected via web beacon in the newsletters for the purpose of optimising newsletter distribution and ensuring that the content of future newsletters is tailored to your interests even better. This personal data is not passed to third parties. Data subjects are entitled to withdraw the separate declaration of consent granted via the double opt-in process for this purpose at any time. We delete this personal data when consent is withdrawn. If you unsubscribe from the newsletter, we automatically interpret this as a withdrawal of consent.

These analyses are performed in particular pursuant to Art. 6 (1) (f) GDPR on the basis of our legitimate interests in displaying personalised advertising, market research and/or demand-focused design of our website.

7. Your rights as a data subject

7.1 Right of confirmation

You have the right to request from us a confirmation of whether personal data concerning you is being processed.

7.2 Right of access – Art. 15 GDPR

You have the right at any time to request information from us at no charge about the stored personal data relating to you and you may obtain a copy of this data.

7.3 Right to rectification – Art. 16 GDPR

You have the right to obtain the rectification of any incorrect personal data concerning you. Further, the data subject is entitled to have incomplete personal data completed, taking account of the purposes of the processing.

7.4 Erasure – Art. 17 GDPR

You have the right to obtain from us erasure of the personal data concerning you without undue delay, on condition that one of the grounds provided for by law applies and to the extent that the processing is not necessary.

7.5 Restriction of processing – Art. 18 GDPR

You have the right to request that we restrict the processing of your personal data if one of the statutory conditions applies.

7.6 Data portability – Art. 20 GDPR

You have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance by us – to whom the personal data has been supplied – provided the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and the processing is performed with the aid of automated processes, provided the processing is not necessary for the performance of a task in the public interest or the exercise of official authority vested in us.

Further, in the exercise of your right to data portability under Art. 20 (1) GDPR you have the right to demand that your personal data be transmitted directly from one controller to another, provided that this is technically feasible and does not adversely affect the rights and freedoms of others.

7.7 Objection – Art. 21 GDPR

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) (e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) GDPR.

This also applies to profiling based on these provisions as defined in Art. 4 (4) GDPR.

If you make an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for the processing that override your interests, rights and freedoms, or the purpose of the processing is to assert, pursue or defend legal claims.

In individual cases we process personal data for the purpose of direct advertising. You can object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling where this is connected to such direct advertising. If you raise an objection with us to processing for the purpose of direct advertising, we will no longer process the personal data for these purposes.

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you performed by us for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

7.8 Withdrawal of consent to data processing

You have the right to withdraw your consent to the processing of personal data at any time with future effect.

7.9 Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint regarding our processing of personal data with a supervisory authority responsible for data protection.

8. Routine storage, deletion and blocking of personal data

We will only process and store your personal data for the period required to perform the purpose for which it is being stored or if this is required by the legal provisions to which our company is subject.

If the purpose for which the data is being stored lapses or a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

9. Duration of the storage of personal data

The criterion for the duration of the storage of personal data is the respective statutory retention period. On expiry of the period, the data in question will be routinely deleted, provided it is no longer needed for the performance or initiation of a contract.

10. Validity and amendment of the privacy policy

This privacy policy is currently valid and was last amended on 31 March 2020. It may need to be amended as our websites and product ranges evolve or as a result of changes to statutory or regulatory requirements. The current version of the privacy policy can be accessed and printed via our website at any time.