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Privacy Policy

We are delighted that you are interested in our company. Data protection is a particularly high priority for the management of Trans-In AG. It is generally possible to use the Trans-In AG website without providing any personal data. However, if a data subject wishes to use special services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal 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 General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Trans-In AG. Through this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects about their rights.

As the controller, Trans-In AG has implemented numerous technical and organisational measures to ensure the most complete protection possible for the personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, meaning that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The Trans-In AG privacy policy is based on the terminology used by European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this privacy policy:

a) personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’). A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

b) data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing means 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, distribution or other forms of provision, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

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

e) Profiling

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

f) 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 is not attributed to an identified or identifiable natural person.

g) Data controller or data processor

The controller or data controller 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processors

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

i) Recipient

Recipient means a natural or legal person, public authority, agency or another body, to which the 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.

j) Third party

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

k) Consent

Consent 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 relating to him or her.

2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Trans-In AG
Fraumünsterstrasse 17
8001 Zürich
Schweiz

Tel.: +41 44 281 33 88
E-Mail: info@trans-in.ch
Website: www.trans-in.ch

3. Cookies

The Trans-In AG website uses cookies. Cookies are text files that are stored on a computer system via an internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that can be used to assign websites and servers to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the person concerned from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID.

By using cookies, Trans-In AG can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies enable us to optimize the information and offers on our website for the benefit of the user. As already mentioned, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, users of a website that uses cookies do not have to re-enter their login details each time they visit the website, as this is done by the website and the cookie stored on the user’s computer system. Another example is the cookie used for a shopping basket in an online shop. The online shop uses a cookie to remember the items that a customer has placed in their virtual shopping basket.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programmes. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

4. Collection of general data and information

The Trans-In AG website collects a range of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serves to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Trans-In AG does not draw any conclusions about the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Trans-In AG for statistical purposes and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

5. Comment function in the blog on the website

Trans-In AG offers users the opportunity to leave individual comments on individual blog posts on a blog located on the website of the data controller. A blog is a portal on a website, usually publicly accessible, where one or more people, known as bloggers or web bloggers, can post articles or write down their thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.

If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, information about the time the comment was posted and the user name (pseudonym) chosen by the data subject will also be stored and published. Furthermore, the IP address assigned by the data subject’s Internet service provider (ISP) is also logged. This IP address is stored for security reasons and in the event that the data subject violates the rights of third parties or posts illegal content in a comment. The storage of this personal data is therefore in the interest of the controller, so that the controller can exculpate themselves in the event of a legal violation. This collected personal data will not be passed on to third parties unless such disclosure is required by law or serves the legal defence of the controller.

6. Routine deletion and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose or as provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose for storage no longer applies or if a storage period prescribed by European directives and regulations or other competent legislators expires, personal data is routinely blocked or deleted in accordance with legal requirements.

7. Rights of the data subject

a) Right to confirmation

Every data subject has the right, granted by European directives and regulations, to request confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact an employee of the controller at any time.

b) Right of information

Every person affected by the processing of personal data has the right, granted by European directives and regulations, to obtain from the controller, at any time and free of charge, information about the personal data stored about them and a copy of this information. Furthermore, European directives and regulations grant the data subject the right to obtain the following information:

  • the processing purposes
  • the categories of personal data that are processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing
  • the existence of a right of appeal to a supervisory authority
  • if the personal data is not collected from the data subject: all available information on the source of the data
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information about whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right to information, they may contact an employee of the controller at any time.

c) Right to rectification

Any person affected by the processing of personal data has the right, granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing.

If a data subject wishes to exercise this right of rectification, they may contact an employee of the controller at any time.

d) Right to erasure (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by European directives and regulations, to request that the controller delete personal data concerning them without delay, provided that one of the following reasons applies and insofar as the processing is not necessary:

  • The personal data was collected for purposes or processed in other ways for which it is no longer necessary.
  • The data subject withdraws their consent on which the processing was based in accordance with Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data was processed unlawfully.
  • The erasure of personal data is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.
  • Personal data was collected in relation to the services offered by the information society in accordance with Article 8(1) of the GDPR.

If one of the above reasons applies and a data subject wishes to have personal data stored by Trans-In AG deleted, they may contact an employee of the controller at any time. The Trans-In AG employee will ensure that the deletion request is complied with immediately.

If the personal data has been made public by Trans-In AG and our company is obliged to delete the personal data as the controller pursuant to Art. 17(1) GDPR, Trans-In AG shall take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform other controllers who process the published personal data that the data subject has requested these other data controllers to delete all links to this personal data or copies or replications of this personal data, unless processing is necessary. The Trans-In AG employee will take the necessary steps in each individual case.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right, granted by European directives and regulations, to request that the controller restrict processing if one of the following conditions is met:

  • The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, the data subject refuses to have the personal data deleted and instead requests the restriction of the use of the personal data.
  • The controller no longer needs the personal data for the purposes of processing, but the data subject needs it to assert, exercise or defend legal claims.
  • The data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Trans-In AG, they may contact an employee of the controller at any time. The Trans-In AG employee will arrange for the processing to be restricted.

f) Right to data portability

Every person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that 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 carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To exercise their right to data portability, data subjects may contact a Trans-In AG employee at any time.

g) Right to object

Every person affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

Trans-In AG will no longer process personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If Trans-In AG processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Trans-In AG processing their data for direct marketing purposes, Trans-In AG will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them carried out by Trans-In AG for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact any employee of Trans-In AG or another employee directly. Furthermore, the data subject is free to exercise their right to object in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

h) Automated individual decision-making, including profiling

Any person affected by the processing of personal data has the right granted by European legislators and regulators not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided that the decision (1) is not necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is it made with the explicit consent of the data subject, Trans-In AG shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

If the data subject wishes to exercise their rights in relation to automated decisions, they may contact an employee of the controller at any time.

i) Right to withdraw consent under data protection law

Every person affected by the processing of personal data has the right, granted by European directives and regulations, to withdraw their consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

8. Data protection in applications and during the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits the relevant application documents to the controller electronically, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller prevent deletion. Other legitimate interests in this sense include, for example, the burden of proof in proceedings under the General Equal Treatment Act (AGG).

9. Data protection provisions regarding the use of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component (with anonymisation function) into this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behaviour of visitors to websites. A web analytics service collects, among other things, data about which website a data subject came to a website from (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analytics is mainly used to optimise a website and for cost-benefit analysis of internet advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The controller uses the suffix ‘_gat._anonymizeIp’ for web analysis via Google Analytics. This suffix is used by Google to shorten and anonymise the IP address of the data subject’s Internet connection when accessing our website from a Member State of the European Union or from another State party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By placing the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently to enable commission settlements.

The cookie stores personal information, such as the time of access, the location from which access originated and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

As described above, the data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting in the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programmes.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information relating to visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the data subject’s information technology system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable data protection provisions can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

10. Legal basis for processing

rt. 6 I lit. a GDPR serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were to be injured and their name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. This legal basis applies to processing operations that are not covered by any of the above legal bases if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override these interests. Such processing operations are permitted in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 of the GDPR).

11. Legitimate interests in processing pursued by the controller or a third party

If the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the performance of our business activities for the benefit of all our employees and shareholders.

12. Duration for which personal data is stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of a contract.

13. Legal or contractual requirements for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is in some cases required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we must then process. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of not providing the personal data would be.

14. Existence of automated decision-making

As a responsible company, we refrain from automated decision-making or profiling.

This privacy policy was created using the privacy policy generator provided by DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer in Munich, in cooperation with Christian Solmecke, a solicitor specialising in data protection law.