Bases

Based on Article 13 of the Swiss Federal Constitution and the data-protection provisions of the Swiss Confederation (new Federal Act on Data Protection, nFADP) as well as the data-protection policy pursuant to Articles 13, 21 of Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR), every physical person is entitled to protection of their privacy and to protection against misuse of their personal data.  Personal data is treated confidentially at Complementa AG (hereinafter referred to as “Complementa”) and is neither sold nor passed on to third parties.

This Privacy Policy informs you of our commitment to protect your personal data and of your rights and explains whether and how Complementa collects, uses and discloses personal data when you visit this website.

We work in close cooperation with our hosting providers to protect the databases as well as possible from external access, losses, misuse or falsification.

This website may contain hyperlinks to other websites that are not operated or controlled by Complementa. Complementa is not responsible for the content of those websites or for their privacy policies.

Complementa reserves the right to amend the terms and conditions of this Privacy Policy at any time. The amendments shall take effect immediately when the amended content is posted on this website. By using said website, you agree to access and review the Privacy Policy regularly in order to inform yourself of any amendments of this nature. Your continued use of the website following the posting of modified terms and conditions shall be deemed to be implicit acceptance of the amended Privacy Policy.  If you do not agree to the amendments, the sole and exclusive remedy at your disposal is to immediately discontinue using this website. This Privacy Policy was last updated on September 1, 2023.

Transmission of data to Complementa and cross-border data flow

Please note that the Internet is generally not considered to be a secure environment and data transmitted via the Internet may be accessible to unauthorized third parties, which may lead to disclosure of this data, modification of the information content or to technical malfunctions.

Data transmitted via the Internet may be sent across national borders even if the sender and recipient are located in the same country. It is therefore possible that your data may be forwarded to a country with a lower level of data protection than your country of domicile.

Complementa accepts no responsibility or liability whatsoever for the security of your data while they are being transmitted to us via the Internet. We would like to draw your attention to the fact that in cases in which you consider this to be appropriate, you may communicate with us by other means for privacy-related reasons.

Cookies

This website uses cookies so as to enable us to tailor the services of complementa.ch more to your individual needs. Cookies are text files that are stored in your computer’s browser and make it possible to analyse how you use complementa.ch.

The data subject can prevent the placement of cookies by our website at any time by appropriately setting the web browser used and by thus permanently objecting to the placement of cookies. Furthermore, cookies that have already been placed can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject deactivates the placement of cookies in the web browser used, not all the functions of our website may be fully usable. You, as the user, therefore have full control over the use of cookies in any event. The information collected by means of cookies is stored only for a certain period of time. Generally, a distinction is drawn between mandatory cookies and optional cookies.

Mandatory cookies

These cookies are necessary for our website to function and cannot be switched off in our systems.  As a rule, they are placed only in response to actions that you take and that amount to a service request, such as setting your privacy preferences, logging on or filling out forms. You can set your browser in such a way as to block, or warn you about, these cookies, but then some parts of the website may not work. These cookies do not store any information that allows you to be personally identified.

Complementa uses the following three mandatory cookies:

• Borlabs cookie: stores the settings of the categories selected by the visitor in the cookie box
• WPML: stores the current language
• WordPress: a test cookie to check whether the user’s browser supports cookies.

The processing of your data is based on Art. 6 para. 1 b) GDPR.

Optional cookies

Our cookies banner is set in such a way that optional cookies are disabled by default. Due to informational self-determination, you must actively agree to the use of optional cookies.  Should you wish not to accept any cookies, you can control this via the cookies banner or in your web browser. Please note that not all functions of our website may then be fully usable.

We use a web analytics tool that gives us an insight into the way in which you use our websites.  This data includes, for example, which pages and links you have visited or clicked on, or how much time you spent on a page.  We use this data to understand better how users use our website and to ensure that it functions properly. This data is not used for marketing or advertising purposes and is not passed on to third parties either. The following cookie is used:

• Google Analytics: a cookie for website analytics, which generates statistical data on how the visitor uses the website.

The processing of your data is based on Art. 6 para. 1 a) GDPR.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files that are saved on your computer and make it possible to analyse how users use the website. The information generated by the cookie on how you use this website is, as a rule, transferred to a Google server and stored there.  IP anonymization is activated on our website. Your complete IP address is thus anonymized in such a way that it is no longer possible to restore the original IP address.

The now-abbreviated IP address is transferred to a Google server. Google will use this information to evaluate your use of the website, compile reports on website activity for the website operators and to provide further services relating to usage of the website and the Internet. Google may, if necessary, also transfer this information to third parties when required to do so by law, or when such third parties process this data on Google’s behalf.  The IP address transferred by your browser as part of Google Analytics will not be merged with other data by Google.

Further information and Google’s applicable privacy policy provisions can be found at https://policies.google.com/privacy?hl=en&gl=de.

Please note that currently, according to the European Parliament’s Committee on Civil Liberties, Justice and Home Affairs, the USA does not provide any guarantees that your data will be protected with a level of protection comparable to that in the EU (“EU-U.S. Data Privacy Framework”).

Social Media plugins – LinkedIn

A “LinkedIn button” is integrated into our website. The operator of LinkedIn is LinkedIn Ireland Unlimited Company. LinkedIn is a social network that enables users to network with existing business contacts and to make new business contacts. Users or companies can create a profile of themselves; companies can post job offers here.

As soon as a website with an integrated LinkedIn button is accessed, the browser used by the user downloads components from LinkedIn. This enables LinkedIn to obtain information about the user, such as sub-pages he/she has visited. This data cannot be assigned to a specific person and users are therefore not identifiable. However, if you are already logged in to LinkedIn when you access the Complementa website, it is technically possible for LinkedIn to assign and store the pages accessed with the LinkedIn button and the data collected in doing so to your LinkedIn account. If you do not want this information to be transmitted to LinkedIn, this transfer can be prevented by logging out of your LinkedIn account before accessing our website.

The privacy policy provisions applicable to LinkedIn and your rights can be accessed at https://linkedin.com/legal/privacy-policy .

WordPress Plugin – Gravity Forms

The forms on our website are based on the Gravity Forms service. This service is provided by Rocketgenius Inc., Virginia Beach, USA.  The data you provide will be used for the purpose of processing your enquiries and will be sent by e-mail to recipients of the website operator (Complementa AG) and to the e-mail address entered, as well as being stored on the WordPress content management system at our web hoster. The data is not passed on to third parties. It is confirmed in the documentation section of the Gravity Forms corporate website that the plugin is GDPR-compliant: https://docs.gravityforms.com/wordpress-gravity-forms-and-gdpr-compliance/. No data is stored or passed on by Rocketgenius, Inc. or the Gravity Forms website.

You can find further information about Gravity Forms’ privacy policy here: https://www.gravityforms.com/privacy/.

Google reCAPTCHA

Our website uses the Google reCAPTCHA service, which is provided by Google Ireland. The purpose of reCAPTCHA is to verify whether data entered on the website is entered by a human being or an automated program. To do so, reCAPTCHA analyses the website user’s behaviour on the basis of various characteristics.

Collection and use of personal data

Complementa collects personal data transparently and in compliance with the principles of proportionality and limitation of use to a specific purpose. The data is only processed to the extent and for as long as is necessary for our tasks and obligations.

We are particularly cautious about collecting, storing and processing data relating to our customers, suppliers, contact details, prospects or other interested parties. In principle, only the data necessary for the relationship in question is collected.  Due to our business model, our customer relationships are almost exclusively with legal entities. Although when collecting their data, personal contact data may also be collected, this is limited mainly to general basic data and contact data, for example, on:

• name, first name
• business address, place of business
• business phone number and
• business e-mail address.

Complementa does not specifically collect personal data via its websites. The following data is stored in log files when our website is accessed (without registration): IP address, date, time, browser request and general information transferred about the operating system or browser. This usage data forms the basis for statistical, anonymous evaluations, so that trends can be recognized which will help us to improve our websites accordingly. When using this general data, which remains stored in the log files for no longer than 7 days, we cannot draw any conclusions about the person concerned.

Apart from the data described above, we do not collect any personal data when you visit our website unless you provide it directly when you contact us by e-mail or a contact form, if you have a customer login or if you register, for example, to take part in surveys or competitions. Personal data provided in this way will be used to process your enquiry and, if necessary, for response purposes. By contacting us in this way, you consent to the collection and use of your personal data to respond to your enquiry. If you transfer personal data by e-mail to apply for employment or other work with Complementa, you consent to the collection, use and storage of your personal data for a reasonable period of time as long as we deem it necessary for possible current or future employment or other work, or as required of us by the statutory retention period. Your personal application data will be collected to the extent necessary in each case and be stored in a separate database accessible only to the HR department.

Storage and protection of personal data

Information from customers, suppliers, contact details, prospects or other interested parties will only be stored for the desired purpose and to the extent necessary for this purpose, as explained under “Collection and use of personal data”.  As soon as the purpose ceases to apply, all data will, if possible, be deleted in accordance with Complementa’s internal guidelines or after expiry of the statutory retention period.

We use all necessary technical and organizational measures to ensure the confidentiality and security of the data and to protect it from theft or unlawful usage or other unauthorized means of access.

In the section “Transmission of data to Complementa and cross-border data flow”, we point out that the transmission of data via the Internet or other electronic means involves certain risks, so that we cannot guarantee the security of information transmitted to us in this way.

Access to, and disclosure of, personal data

Within Complementa, employees are only given access to data to the extent that this is necessary for the performance of their work duties and for the provision of the service. All employees are trained in the handling and protection of personal data and are obliged to maintain confidentiality.

Complementa may pass on data to other units within the company, and if necessary, also abroad. Those units use and protect the data in accordance with the same guidelines and requirements of this Privacy Policy or, as applicable, with the Swiss Federal Act on Data Protection and the GDPR.

Complementa may pass on data to external service providers, if necessary also abroad, if this is required to provide the service and if use of the data is guaranteed pursuant to the Swiss Federal Act on Data Protection and the GDPR or an equivalent regulation and if data privacy is ensured.

Complementa may pass on data if this is necessary to comply with the applicable laws and regulations, in the event of judicial proceedings, at the request of the competent courts and authorities or on account of other legal obligations.

Your rights to your personal data

You have the right at any time to request information about your data that is processed by us. You also have the right to request that your data be deleted if further storage is no longer necessary due to contractual or legal requirements. Please use the address indicated at the end of this Privacy Policy to contact us.

Contact details

Complementa AG
Data protection officer
Gaiserwaldstrasse 14
CH-9015 St. Gallen
Phone: +41 71 313 84 84
E-mail: info@complementa.ch