This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") in the context of the provision of our services as well as within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Person responsible
OnDoc.ch
Bahnhofstrasse 100, 8001 Zürich
+41 44 310 50 00
contact@ondoc.ch

Types of data processed
- Existing data (e.g., personal master data, names or addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).

Categories of affected persons
Visitors and users of the online offer (hereinafter, we also refer to the affected persons collectively as "users").

Purpose of the processing
- Making the online offer, its functions and content available.
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing.

Terminology used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "affected person"); 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 (e.g. cookie) or to one or more specific characteristics that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.

"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific affected person without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

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

Relevant legal basis
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users from the jurisdiction of the General Data Protection Regulation (GDPR), i.e., the EU and the EEC, the following applies, unless the legal basis is mentioned in the privacy policy:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR.
The legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 (1) lit. b GDPR.
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c GDPR.
In the event that vital interests of the affected person or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR.
The processing of data for purposes other than those for which they were collected is determined by the requirements of Art. 6 (4) GDPR.
The processing of special categories of data (in accordance with Art. 9 (1) GDPR) is determined in accordance with the requirements of Art. 9 (2) GDPR.

Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, considering the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of affected persons' rights, deletion of data, and response to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis that complies with the legal requirements.

Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or do so in the context of using third-party services or disclosing, or transferring data to other persons or companies, this will only be done if it is necessary for the fulfillment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to explicit consent or contractually required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, which includes US processors certified under the "Privacy Shield" or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission).

Rights of the data subjects
You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about such data, as well as further information and a copy of the data, in accordance with the law.
You have the right, in accordance with the law, to request that the data about you be completed or that inaccurate data about you be corrected.
You have the right, in accordance with the legal requirements, to demand that data about you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
You have the right to demand that the data about you which you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other persons responsible.
You also have the right, in accordance with the law, to lodge a complaint with the competent supervisory authority.

Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.

Right of objection
You may object to the future processing of data relating to you at any time in accordance with the legal requirements. The objection can be made in particular against the processing for purposes of direct advertising.

Cookies and right to object in the case of direct advertising
"Cookies" are small files that are stored on users' computers. Various data can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if it is only their cookies are called "first-party cookies").
We may use temporary and permanent cookies and explain this in our privacy policy.
If we ask users to consent to the use of cookies (e.g., in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal cookies of the users are processed in accordance with the following explanations within the scope of this privacy policy on the basis of our legitimate interests (e.g., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), or insofar as the use of cookies is necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority, pursuant to Art. 6 para. 1 lit. e. GDPR, processed.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site https://www.aboutads.info/choices/ or the EU site https://www.youronlinechoices.com/ Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Comments and contributions
When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR are stored for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR, to process the information of the users for the purpose of spam detection.
On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.

Comment subscriptions
Follow-up comments can be subscribed to by users with their consent pursuant to Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving user consent, we store the time of subscription along with users' IP address and delete this information when users unsubscribe.
You can unsubscribe from receiving our subscription at any time, i.e., revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

Get in touch
When contacting us (e.g., by contact form, e-mail, telephone or via social media), the user's details are used to process the contact request and its handling pursuant to Art. 6 (1) lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) GDPR processed... The user's details may be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Newsletter - Mailchimp
The newsletter is sent using the dispatch service provider "MailChimp", a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the privacy policy of the shipping service provider here: https://mailchimp.com/legal/privacy/The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active)The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR and an order processing agreement pursuant to Art. 28 para. 3 p. 1 GDPR.
The dispatch service provider may use the data of the recipients in pseudonymous form, e.g., without assignment to a user, to optimize or improve its own services, e.g., to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

Google Analytics
We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
If we ask users for consent (e.g., in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the users' personal data is processed on the basis of our legitimate interests (e.g., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) are processed.
Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
For further information on data use by Google, setting and objection options, please refer to Google's privacy policy (https://policies.google.com/privacy) as well as the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or anonymized after 14 months.

Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. With regard to U.S. providers that are certified under the Privacy Shield, we point out that they commit themselves to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the computers of the users, in which the usage behavior and the interests of the users are collected. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the users' personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.
Also, in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Facebook, -pages, -groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) based on an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/ specifically, for pages:
https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads und https://www.youronlinechoices.com Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
- Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) - Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: https://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out:
https://about.pinterest.com/de/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy:
https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant? id=a2zt0000000L0UZAA0&status=Active.
- Xing (XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out:
https://privacy.xing.com/de/datenschutzerklaerung
- Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Policy/ Opt-Out: https://wakelet.com/privacy.html
- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy

Integration of third-party services and content
Within our online offer, we use content or service providers on the basis of our legitimate interests (e.g., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. GDPR) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content").
This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

Google Fonts
We integrate the fonts ("Google Fonts") of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform display and consideration of possible licensing restrictions for their integration. Privacy policy:
https://www.google.com/policies/privacy/.

Google ReCaptcha
We integrate the function for the recognition of bots, e.g., for entries in online forms ("ReCaptcha") of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Twitter
Within our online offer, functions, and contents of the service Twitter, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Twitter.
If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

Instagram
Within our online offer, functions, and content of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above-mentioned content and functions to the profiles of the users there. Privacy policy of Instagram:
https://instagram.com/about/legal/privacy/.

LinkedIn
Within our online offer, functions, and contents of the service LinkedIn, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above-mentioned content and functions to the users' profiles there. Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policyLinkedIn is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law
(https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.