Privacy policy
This privacy policy provides information about the processing of personal data in
connection with our activities and operations including our Website under
the domain
name imorana.com. In particular, we provide information on why, how and where
we process
which personal data. We also provide information about the rights of persons whose data
we process.
For individual or additional activities and operations, we may publish further data
protection
declarations or other information on data protection.
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 European General Data Protection
Regulation (GDPR).
In its decision of 26 July 2000, the European Commission
recognized that Swiss data protection
law guarantees adequate data protection. In a report dated
January 15, 2024 the European Commission confirmed this adequacy decision.
1. Contact addresses
Responsibility for the processing of personal data:
Astra Group GmbH
Zugerstrasse 76B
6340 Baar
Schweiz
In individual cases, third parties may be responsible for the processing of personal data or
there
may be joint responsibility with third parties.
Data protection representation in the European Economic Area (EEA)
We have the following data protection representation in accordance with Art. 27 DSGVO:
The Data Protection Representation serves data subjects and authorities in the European
Union
(EU) and the rest of the European Economic Area (EEA) as an additional point of
contact for
inquiries in connection with the GDPR.
2. Definitions and legal bases
2.1 Terms
Data subjects: Natural person about whom we process personal data.
Personal subjects: Any information relating to an identified or identifiable natural person.
Particularly sensitive personal data: Data concerning trade union, political,
religious or
philosophical opinions and activities, data concerning health, privacy or racial or ethnic
origin,
genetic data, biometric data uniquely identifying a natural person, data concerning criminal
or
administrative sanctions or prosecutions, and data concerning social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, disclosure, procurement, collection, deletion, organization, modification, dissemination, linking, destruction and use of personal data.
European Economic Area (EEA): Member States of the European Union (EU) as well
as the
Principality of Liechtenstein, Iceland and Norway.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection
Act, DPA) and the Ordinance on
Data Protection (Data Protection Ordinance, DPO).
If and to the extent that the European General Data Protection Regulation (GDPR) is
applicable,
we process personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are, in particular, the permanent, humane, secure and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
- Art. 6 para. 1 lit. 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 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
- Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of personal
data as the processing of personal data and the processing of particularly sensitive
personal data
as the processing of special categories of personal data (Art. 9 DSGVO)
3. Type, scope and purpose of the processing of personal data
We process the personal data required to carry out our activities and operations in a
permanent,
humane, secure and reliable manner. The processed personal data may fall into the categories
of
browser and device data, content data, communication data, metadata, usage data, master data
including inventory and contact data, location data, transaction data, contract data and
payment
data.
We also process personal data that we receive from third parties, obtain from publicly
accessible sources or collect in the course of our activities and operations, insofar as
such
processing is permitted for legal reasons.
Where necessary, we process personal data with the consent of the data subjects. In many
cases,
we may process personal data without consent, for example to fulfill legal obligations or to
protect overriding interests. We may also ask data subjects for their consent if their
consent is
not required.
We process personal data for the duration necessary for the respective purpose. We anonymize or
delete
personal data in particular depending on statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have it processed by third
parties or process it
jointly with third parties. Such third parties are, in particular, specialized providers
whose
services we use.
For example, we may disclose personal data to banks and other financial service providers,
public authorities, educational and research institutions, consultants and lawyers, interest
groups, IT service providers, cooperation partners, credit and credit agencies, logistics
and
shipping companies, marketing and advertising agencies, media, organizations and
associations,
social institutions, telecommunications companies and insurance companies.
5. Communication
We process personal data in order to be able to communicate with individuals as well as with
authorities, organizations and companies. In particular, we process data that a data subject
sends
us when contacting us, for example by post or e-mail. We may store such data in an address
book or with comparable tools.
Third parties who transmit data about other persons to us are obliged to independently
ensure
the data protection of the persons concerned. In particular, they must ensure that such data
is
correct and may be transmitted.
6. Data security
We take suitable technical and organizational measures to ensure data security appropriate
to the
respective risk. With our measures, we ensure in particular the confidentiality,
availability,
traceability and integrity of the personal data processed, without being able to guarantee
absolute data security.
Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to
HTTPS). Most browsers warn against visiting websites without transport encryption.
Our digital communication - like all digital communication in general - is subject to
mass
surveillance without cause or suspicion by security authorities in Switzerland, the rest of
Europe, the United States of America (USA) and other countries. We cannot directly influence
the corresponding processing of personal data by secret services, police forces and other
security
authorities. Nor can we rule out the possibility that a data subject may be subject to
targeted
surveillance.
7. Personal data abroad
We generally process personal data in Switzerland and the European Economic
Area (EEA). However, we may also export or transfer personal data to other countries, in
particular in
order to process it or have it processed there.
We can export personal data to all countries on earth and elsewhere in the universe, provided that the law there guarantees
adequate data protection in accordance with the decision of the Swiss Federal Council and - if
and insofar as the General Data Protection
Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission.
We may transfer personal data to countries whose laws do not guarantee adequate data
protection, provided that data protection is guaranteed for other reasons, in particular on
the
basis of standard data protection clauses or with other suitable guarantees. Exceptionally,
we
may export personal data to countries without adequate or appropriate data protection if the
special requirements under data protection law are met, for example the express consent of
the
data subjects or a direct connection with the conclusion or execution of a contract. On
request,
we will be happy to provide data subjects with information about any guarantees or provide a
copy of any guarantees.
8. Rights of affected persons
8.1 Data protection claims
We grant data subjects all rights in accordance with the applicable data protection law.
Data
subjects have the following rights in particular:
- Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of the processing, the duration of retention, any disclosure or export data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects can have their personal data deleted ("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 disclosure of personal data or the transfer of their data to another controller.
We may postpone, restrict or refuse the exercise of the rights of data subjects within the
legally
permissible framework. We can inform data subjects of any requirements that must be met in
order to exercise their rights under data protection law. For example, we may refuse to
provide
information in whole or in part with reference to confidentiality obligations, overriding
interests
or the protection of other persons. We may also, for example, refuse to delete personal data
in
whole or in part, in particular with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of
rights. We will inform affected
persons of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request
information
or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal protection
Data subjects have the right to enforce their data protection claims by legal means or to
lodge a
complaint with a 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).
European data protection supervisory authorities are organized as members of the European
Data Protection Board (EDPB) . In some Member States in the European Economic Area
(EEA),
the data protection supervisory authorities are federally structured, particularly in Germany.
9. Use of the website
9.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from
third parties whose services we use (third-party cookies) - are data files stored in the
browser. Such stored data need not be limited to traditional cookies in text form.
Cookies can stored in the browser temporarily as "session cookies" or for a certain period
of time as so-called permanent cookies. "Session cookies" are automatically deleted when
the browser closed. Permanent cookies have a specific storage period. In particular, cookies
make it possible to recognize a browser the next time it visits our website and thus, for
example, to measure the reach of our website. However, permanent cookies can also be
used for online marketing, for example.
Cookies can be completely or partially deactivated and deleted at any time in the browser
settings. Without cookies, our website may no longer be fully available. We actively request
- at
least if and insofar as necessary - to express consent to the use of cookies.
For cookies that are used to measure success and reach or for advertising, a general
objection
("opt-out") is possible for numerous services via AdChoices
(Digital Advertising Alliance of Canada), the Network
Advertising Initiative (NAI), YourAd-Choices (Digital Advertising
Alliance) or Your Online
Choices (European Interactive Digital Advertising Alliance, EDAA).
9.2 Logging
We may log at least the following information for each access to our website and our other
online presence, insofar as this information is transmitted to our digital infrastructure
during
such access: 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 accessed including amount of data transferred, last
website
accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. The
information is required to provide our online presence in a permanent, user-friendly and
reliable
manner. The information is also required to ensure data security - also by third parties or
with
the help of third parties.
9.3 Tracking pixel
We can integrate tracking pixels into our online presence. Tracking pixels are also known as
web beacons. Tracking pixels - including those from third parties whose services we use -
are
usually small, invisible images or scripts written in JavaScript that are automatically
retrieved
when our online presence is accessed. Tracking pixels can be used to collect at least the
same
information as log files.
10. Notifications and messages
10.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that record whether an
individual message has been opened and which web links have been clicked on. Such web links
and tracking pixels can also record the use of notifications and messages on a personal
basis.
We require this statistical recording of usage to measure success and reach in order to be
able to
send notifications and messages effectively and in a human-friendly, permanent, secure and
reliable manner based on the needs and reading habits of the recipients.
10.2 Consent and objection
You must always consent to the use of your e-mail address and your other contact
addresses,
unless the use is permitted for other legal reasons. We may use the "double opt-in"
procedure to
obtain double confirmation of your consent. In this case, you will receive a message with
instructions for double confirmation. We may log the consent obtained, including the IP address
and time stamp, for reasons of proof and
security.
You can object to receiving notifications and communications such as newsletters at any
time.
With such an objection, you can at the same time object to the statistical recording of
usage for
measuring success and reach. Necessary notifications and communications in connection with
our activities and operations remain reserved.
10.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
11. Social Media
We are present on social media platforms and other online platforms in order to communicate
with interested persons and to information 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 general terms and conditions (GTC) and terms of use as well as data protection
declarations
and other provisions of the individual operators of such platforms also apply. These
provisions
provide information in particular about the rights of data subjects directly vis-à-vis the
respective platform, including, for example, the right to information.
12. Third party services
We use the services of specialized third parties in order to be able to carry out our
activities and
operations in a permanent, user-friendly, secure and reliable manner. Among other things, we
can use such services to embed functions and content in our website. In the case of such
embedding, the services used record the IP addresses of
users least temporarily for technically
compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we
use
may process data in connection with our activities and operations in aggregated, anonymized
or
pseudonymized form. This is, for example, performance or usage data in order to be able to
offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) partly for users in the European Economic Area (EEA) and Switzerland; General information on data protection: «Privacy and principles», «Information on how Google uses personal data", Privacy policy», Privacy policy, «Google is committed to complying with applicable data protection laws», «Privacy policy for Google products», «How we process data from websites or apps», «How we use data from websites or apps», «How we process data from websites or apps).
12.1 Digital infrastructure
We use the services of specialized third parties in order to make use of the necessary digital
infrastructure in connection with our activities and operations. These include, for example,
hosting and storage services from selected providers.
We use in particular:
- Amazon Web Services (AWS) including Amazon CloudFront: Storage space, Content Delivery Network (CDN) and other infrastructure; Provider: Amazon Web Services Inc. (USA) for users in Switzerland / Amazon Web Services EMEA SARL (Luxembourg) for users in the European Economic Area (EEA); Privacy Policy, «Privacy Center», «Frequently Asked Questions about Data Protection», «General Data Protection Regulation (GDPR) Center».
- Infomaniak: Hosting; Service provider: INFOMANIAK NETWORK SA (Switzerland);Information on Data protection: "Infomaniak and the protection of your personal data", Privacy policy, Cookie policy, "Certifications and labels".
12.2 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Google Fonts: Fonts; Service provider: Google; Google Fonts-specific information : >, "Your Privacy and Google Fonts", "Privacy and data collection" (for Google Fonts).
12.3 Payments
We use specialized service providers to process payments securely and reliably. The legal texts
of the individual service providers,such as general terms and condition (GTC) or data protection
declarations, also apply to the processing of payments.
We use in particular:
- : Mollie: Processing of payments; Service provider: Mollie B.V. (Netherlands); Privacy Policy: Privacy Policy, «Security».
13. Success and reach measurement
We try to measure the success and reach of our activities and operations. In this context, we can
also measure the effect of third-party references or check how different parts or versions of our
online offering are used ("A/B test" method). Based on the results of the success and reach
measurement, we can in particular correct errors, strengthen popular content or make
improvements.
In most cases, the IP addresses of individual users are recorded to measure success and reach. In
this case, IP addresses are generally shortened ("IP masking") in order to comply with the
principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach and user profiles may be created. Any user
profiles created include, for example, the individual pages visited or content viewed on our
website, information on the size of the screen or browser window and the - at least approximate - location. In principle, any user profiles are created exclusively in pseudonymized form and are
not used to identify individual users. Individual third-party services with which users are
registered may be able to assign the use of our online offer to the user account or user profile of
the respective service.
14. Final notes on the privacy policy
We have created this data protection declaration with the data protection generator from Datenschutzpartner
We may update this privacy policy at any time. We will inform you about updates in a suitable
form, in particular by publishing the current privacy policy on our website.