Privacy Policy
With this privacy policy we inform you which personal data we process in connection with our activities, including our www.fostrio.com website. In particular, we inform you for what purpose, how and where we process which personal data. We also inform you about the rights of the persons whose data we process.
For individual or additional activities and operations, further privacy policies as well as other legal documents such as terms and conditions (T&C), terms of use or participation terms may apply.
We are subject to Swiss data protection law and any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law provides an adequate level of data protection.
1. Contact details
Responsibility for the processing of personal data:
We will point out if there are other controllers responsible for the processing of personal data in individual cases.
Data protection officers or data protection advisors
We have the following data protection officer or data protection advisor as a point of contact for data subjects and authorities for inquiries related to data protection:
2. Terms and legal bases
2.1 Terms
Personal data is all information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing encompasses any handling of personal data, regardless of the means and procedures applied, for example querying, comparing, adapting, archiving, storing, reading out, disclosing, obtaining, collecting, gathering, deleting, making available, ordering, organizing, saving, modifying, distributing, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process personal data, where and to the extent that the General Data Protection Regulation (GDPR) is applicable, in accordance with at least one of the following legal bases:
Art. 6(1)(b) GDPR for the necessary processing of personal data to fulfil a contract with the data subject and to carry out pre-contractual measures.
Art. 6(1)(f) GDPR for the necessary processing of personal data to protect the legitimate interests of ours or of third parties, provided that the fundamental freedoms and rights and interests of the data subject do not override such interests. Legitimate interests include in particular our interest in exercising our activities and operations in a sustainable, user-friendly, secure and reliable manner and in communicating about them, ensuring information security, protecting against abuse, enforcing our own legal claims and complying with Swiss law.
Art. 6(1)(c) GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under applicable law of EEA member states.
Art. 6(1)(e) GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6(1)(d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process the personal data that is necessary to exercise our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such personal data may fall in particular into the categories of master and contact data, browser and device data, content data, meta or ancillary data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the period required for the respective purpose or purposes or as required by law. Personal data that is no longer needed for processing is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are in particular specialized providers whose services we use. We ensure data protection even with such third parties.
We generally process personal data only with the consent of the data subjects. Where and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. We may process personal data without consent, for example, to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject has voluntarily transmitted to us when making contact, for example by letter post, email, instant messaging, contact form, social media or telephone, or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management system (CRM system) or using comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection towards these persons and to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of exercising our activities and operations, provided and to the extent that such processing is permitted for legal reasons.
4. Applications
We process personal data about applicants insofar as it is necessary to assess their suitability for employment or for the subsequent execution of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process personal data about applicants, where and to the extent that the General Data Protection Regulation (GDPR) is applicable, in particular in accordance with Art. 9(2)(b) GDPR.
We may enable applicants to store their information in our talent pool so that they can be considered for future open positions. We may also use such information to maintain contact and share news. If we believe that an applicant may be a good fit for an open position based on the information provided, we may inform the applicant accordingly.
5. Personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transmit personal data to other countries, in particular to process it there or have it processed there.
We may export personal data to any country and territory on Earth and elsewhere in the universe, provided that the law there ensures an adequate level of data protection according to the decision of the Swiss Federal Council and, where and to the extent that the General Data Protection Regulation (GDPR) is applicable, according to the decision of the European Commission.
We may transmit personal data to countries whose law does not provide an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard contractual clauses or other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. We will be happy to provide data subjects with information about any safeguards upon request or provide a copy of any safeguards.
6. Rights of data subjects
6.1 Data protection claims
We grant data subjects all claims under the applicable data protection law. Data subjects have in particular the following rights:
Access:
Data subjects may request information about whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also, among other things, information about the purpose of processing, the retention period, any disclosure or export of data to other countries, and the origin of the personal data.
Rectification and restriction:
Data subjects may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
Erasure and objection:
Data subjects may request the deletion of personal data ("right to be forgotten") and object to the processing of their data with effect for the future.
Data disclosure and data transfer:
Data subjects may request the transfer of personal data or the transmission of their data to another controller.
We may delay, restrict or refuse the exercise of the rights of data subjects within the legally permissible framework. We may point out to data subjects any requirements that must be met for the exercise of their data protection claims. For example, we may refuse information wholly or partly with reference to trade secrets or the protection of other persons. We may also refuse the deletion of personal data wholly or partly with reference to statutory retention obligations.
We may exceptionally charge fees for the exercise of rights. We will inform data subjects in advance about any costs.
We are obliged to identify data subjects who request information or assert other rights by means of appropriate measures. Data subjects are obliged to cooperate.
6.2 Right to lodge a complaint
Data subjects have the right to enforce their data protection claims through the courts or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have the right, where and to the extent that the General Data Protection Regulation (GDPR) is applicable, to lodge a complaint with a competent European data protection supervisory authority.
7. Data security
We take appropriate technical and organizational measures to ensure a level of data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Access to our website is encrypted using transport layer security (SSL/TLS, in particular with Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock icon in the address bar.
Our digital communications are subject, like all digital communications in principle, to mass surveillance without cause or suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security agencies.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies, both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies), are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.
Cookies can be stored temporarily in the browser as "session cookies" or for a certain period as so-called permanent cookies. Session cookies are automatically deleted when the browser is closed. Permanent cookies have a specific storage duration. Cookies make it possible in particular to recognize a browser on the next visit to our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example.
Cookies can be deactivated partially or entirely and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request express consent to the use of cookies, at least where and to the extent required.
For cookies used for performance and reach measurement or for advertising, a general opt-out is available for many services via AdChoices (Digital Advertising Alliance of Canada), Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Server log files
We may record the following information for each access to our website, provided that this is transmitted by your browser to our server infrastructure or can be determined by our web server: date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website called up including amount of data transferred, last web page called up in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. This information is necessary to provide our website in a sustainable, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data, including through or with the help of third parties.
8.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels, including those from third parties whose services we use, are small, usually invisible images that are automatically loaded when visiting our website. Tracking pixels can be used to collect the same information as in server log files.
9. Notifications and communications
We send notifications and communications by email and via other communication channels such as instant messaging or SMS.
9.1 Performance and reach measurement
Notifications and communications may contain web links or tracking pixels that track whether an individual message has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal level. We need this statistical tracking for performance and reach measurement in order to send notifications and communications effectively and in a user-friendly as well as sustainable, secure and reliable manner, based on the needs and reading habits of the recipients.
9.2 Consent and objection
You must generally give express consent to the use of your email address and other contact details, unless the use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure where possible, meaning you receive an email with a web link that you must click to confirm, so that no abuse by unauthorized third parties can occur. We may log such consents including IP address as well as date and time for evidentiary and security reasons.
You may generally object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical tracking of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.
10. Social media
We are present on social media platforms and other online platforms to communicate with interested persons and to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).
The terms and conditions (T&C), terms of use, privacy policies and other provisions of the individual operators of such platforms also apply respectively. These provisions inform in particular about the rights of data subjects directly towards the respective platform, which include, for example, the right of access.
For our social media presence on Facebook, including the so-called Page Insights, we are jointly responsible with Meta Platforms Ireland Limited (Ireland), where and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta group of companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook effectively and in a user-friendly manner.
Further information on the type, scope and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook and its data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Controller Addendum" with Facebook, which in particular stipulates that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the "Page Insights Information" page, including "Information about Page Insights Data".
11. Third-party services
We use services from specialized third parties to exercise our activities and operations in a sustainable, user-friendly, secure and reliable manner. Such services allow us to embed functions and content into our website, among other things. When embedding such services, they necessarily collect at least temporarily the IP addresses of the users for technical reasons.
For necessary security-relevant, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymized or pseudonymized manner. This involves, for example, performance or usage data in order to be able to provide the respective service. We also pass data on to third parties so that they can determine ad measurement values on our behalf.
Google services:
Providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General privacy information: "Privacy and Security Principles", Privacy Policy, "Google's commitment to applicable privacy laws", "Privacy Guide for Google Products", "How we use data from websites or apps that use our services" (information from Google), "Types of cookies and similar technologies used by Google", "Personalized ads" (activation / deactivation / settings).
Microsoft services:
Providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Great Britain and Switzerland; General privacy information: "Privacy at Microsoft", "Privacy and Security (Trust Center)", Privacy Policy, Privacy Dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialized third parties to access the digital infrastructure needed in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
Cloudflare:
Content Delivery Network (CDN); Cloudflare Inc. (USA); Privacy information: "Privacy", Privacy Policy, Cookie Policy.
Google Cloud including Google Cloud Platform (GCP):
Storage space and other infrastructure; Google Cloud-specific providers: Google LLC (USA) for users including in the USA / Google Ireland Limited or Google Commerce Limited (each Ireland) for users including in the European Economic Area (EEA) and Switzerland; Google Cloud-specific information: "Privacy Resource Center", "Privacy", "Compliance Resource Center", "Trust and Security".
Infomaniak:
Hosting; Provider: INFOMANIAK NETWORK SA (Switzerland); Privacy information: "Infomaniak and the protection of your personal data", Privacy Policy, Cookie Policy, "Certifications and labels".
11.6 Map material
We use third-party services to embed maps into our website.
Google Maps:
Our website uses the Google Maps mapping service from Google LLC to display geographical information. When using Google Maps, user data is collected, processed and used by Google. Further information can be found in Google's privacy notice.
11.7 Fonts
We use third-party services to embed selected fonts as well as icons, logos and symbols on our website.
Google Fonts:
Fonts; Provider: Google; Google Fonts-specific information: "Privacy and Google Fonts", "Privacy and data collection".
11.8 Advertising
We use the option to display targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
We would like to use such advertising to reach in particular people who are already interested or might be interested in our activities and operations (remarketing and targeting). For this purpose, we may transmit corresponding information, which may also be personal, to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties where we advertise and where you are logged in as a user may be able to associate the use of our website with your profile there.
Facebook advertising (Facebook Ads):
Social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy information: remarketing and targeting in particular with the Facebook Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy, "Ad preferences" (login as user required).
Google Ads:
Search engine advertising; Provider: Google; Google Ads-specific information: advertising based on search queries, using various domain names, in particular doubleclick.net, googleadservices.com and googlesyndication.com, for Google Ads, "Ads" (Google), "Why am I seeing a particular ad?".
Instagram Ads:
Social media advertising; Providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Privacy information: remarketing and targeting in particular with Facebook Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), "Ad preferences" (Instagram) (login as user required), "Ad preferences" (Facebook) (login as user required).
12. Website extensions
We use website extensions to provide additional functionality.
13. Performance and reach measurement
We try to determine how our online offering is used. In this context, we can measure, for example, the success and reach of our activities and operations as well as the impact of links from third parties to our website. However, we can also try out and compare how different parts or versions of our online offering are used ("A/B test" method). Based on the results of the performance and reach measurement, we can in particular fix errors, strengthen popular content or make improvements to our online offering.
For performance and reach measurement, the IP addresses of individual users are stored in most cases. In this case, IP addresses are generally truncated ("IP masking") to comply with the principle of data minimisation through the corresponding pseudonymization.
Cookies may be used for performance and reach measurement, and user profiles may be created. Any such user profiles may include, for example, the individual pages visited or content viewed on our website, information about screen or browser window size, and the approximate location. As a rule, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services where users are logged in may be able to associate the use of our online offering with the user account or profile at the respective service.
Google Analytics:
Performance and reach measurement; Provider: Google; Google Analytics-specific information: measurement across different browsers and devices (cross-device tracking) with pseudonymized IP addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy", "Browser add-on to deactivate Google Analytics".
Use of Google Signals in Google Analytics 4 (GA4):
We use Google Analytics 4 (GA4), a web analytics service from Google LLC, to analyze and improve the use of our website. As part of using GA4, we also enable Google Signals. Google Signals is a feature of GA4 that allows us to collect aggregated and anonymized information about our website users. This information includes demographic data, interests and activities of users. Google Signals uses information from users who are logged into Google services and can aggregate this information to give us insights into the behavior of our website visitors.
Privacy and opt-out: Although Google Signals anonymizes and aggregates the information, we would like to inform you that Google Signals is enabled on our website. We respect your privacy and offer you the option to object to ad personalization. If you would like to disable the use of your data for personalized advertising by Google, you can do so via the Google ad settings.
Further information: For more information about how Google collects and uses data, we refer you to Google's privacy policy at Google Privacy Policy. Please note that we have no control over Google's privacy policies and that these may change.
Google Tag Manager:
Integration and management of other services for performance and reach measurement as well as other Google and third-party services; Provider: Google; Google Tag Manager-specific information: "Data collected by Google Tag Manager"; further privacy information can be found with the individual integrated and managed services.
14. Final provisions
We may amend and supplement this privacy policy at any time. We will inform you about such amendments and additions in an appropriate manner, in particular by publishing the respective current privacy policy on our website.