JUWELIS Data Protection Declaration

This data protection declaration explains how JUWELIS Asset Management GmbH collects and processes personal data on the website www.juwelis.digital. Under personal data, all information relates to an identified or identifiable person.

This data protection declaration takes into account both the EU General Data Protection Regulation (GDPR) and the Swiss data protection legislation (Data Protection Act (DSG)).

We emphasize on great importance to data protection. The collection and processing of your personal data is done in compliance with applicable data protection regulations, in particular to the Privacy Regulation (DSGVO) and the Swiss Data Protection Law (DSG).

1 Responsibility / Representation

1.1 Responsibility 

Responsible for the collection and processing of personal data is JUWELIS Asset Management GmbH, Firststrasse 6, 8835 Feusisberg, Switzerland, phone +41 (0)55 511 0228, e-mail: [email protected]

1.2 Representation

The representative of the EU in accordance with Article 27 DSGVO is JUWELIS Germany Management GmbH, Hegenheimer Strasse 18, DE-79576 Weil am Rhein, Germany, email: [email protected].

2 General Purposes of Processing

We use personal data for the purpose of operating the website, for processing contracts in our online shop and for membership in the JUWELIS Human Care Association.

3 What Data we Use and Why 

3.1 Hosting

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating the website.

We and our hosting provider process inventory data, contact information, content data, contract data, usage data, meta and communication data from customers, prospects and visitors of this site for our legitimate interests in providing an efficient and safe website based on Art. 6 Abs. 1 S. 1 f) DSGVO i.V.m. Art. 28 DSGVO and Art. 13 DSG.

3.2 Access Data

We collect information about you when you use this website. We automatically collect information about your usage behavior and your interaction with us and register data about your computer or mobile device. We collect, store and use data on each access to our site (so-called server log files). The access data include:

−Name and URL of the file accessed 
−Date and time of access 
−Amount of data transferred
−Notification of successful response (HTTP response code)
-Type and version of browser
−Operating system
−Referrer URL (e.g. the previously visited page)
−Websites that are accessed by the user’s system via our website
−User’s Internet service provider 
−IP address and the requesting provider

We use this log information without assigning any personal or other profiling for statistical analysis for the purpose of operation, security and optimizing our site, but also to the anonymous recording the number of visitors to our website (traffic) as well as the scope and type of use of our website and services, also for billing purposes, to measure the number of clicks received from cooperation partners. Based on this information, we can provide personalized and location-related content and analyze traffic, find and fix errors and improve our services.

This is also our, justifying interest in accordance with Art 6 Abs. 1 S. 1 f) DSGVO und Art. 13 DSG.

We reserve the right to check the log data retrospectively if there are reasonable grounds to suspect illegal use. We store IP addresses in the log files for a limited period of time if this is necessary for security purposes or for the provision of services or billing of a specific service, e.g. when you use one of our offered products or services. After termination of the operation of your order or after receipt of payment, we will delete the IP address if they are no longer needed for security purposes. We also save IP addresses if we have a specific suspicion of a crime in connection with the use of our website. Additionally, we store as part of your account, the date of your last visit (e.g registration, login, click on links, etc.).

3.3 Cookies

We use session cookies to optimize our website. A session cookie is a small text file that is sent by the respective server when you visit a website and is temporarily stored on your hard drive. As such, this file contains a so-called session ID, with which various requests from your browser can be assigned to the common session. As a result, your computer will be recognized when you return to our site. These cookies are deleted after you close your browser. They serve for example that you can use the shopping cart function across several pages.

We also use persistent cookies to a small extent (also small text files that are stored on your device), which remain on your device and enable us to recognize your browser the next time you visit. These cookies are stored on your hard drive and delete themselves after the specified time. Their lifespan is 1 month to 10 years. This way we are able to present our offer to you in a more user-friendly, effective and secure manner and, for example, show you information on the page that is tailored to your interests.

The following data and information are stored in the cookies:

– Log-in information 

– Language settings 

– search terms entered 

– Information about the number of visits to our website and the use of individual functions on our website. 

When the cookie is activated, it is assigned an identification number, but your personal data is not assigned to this identification number. Your name, IP address or similar information that would allow your allocation of the cookie will not be inserted into the cookie. Based on the cookie technology, we only receive pseudonymized information, for example about which pages of our shop were visited, which products were viewed, etc.

As far as it is technically necessary cookies of legitimate interest allow us the use of cookies according to Art 6 Abs. 1 S. 1 f) DSGVO und Art. 13 DSG for the purpose to present you a functional website.

If cookies are not technically necessary (for example, cookies for the purpose of analysis or tracking), we only save the cookie on your end device based on your prior consent by “opt-in”. We will then explain the respective purpose of storing the cookie to you separately as part of the respective service that stores the cookie on your device.

A consent to the storage of cookies can be revoked at any time cookie settings.

You can also set your browser so that you are informed about the setting of cookies in advance and can decide in individual cases whether you exclude the acceptance of cookies for certain cases or in general, or that cookies are completely prevented. However, this functionality results and a restricted site.

3.4 Data to Fulfill our Contractual Duties

We process personal data that we need to fulfill our contractual obligations, such as name, address, email address, ordered products, billing and payment data. The collection of this data is necessary for the closing of the contract.

The data will be deleted after the warranty periods and statutory retention periods have expired. Data that is linked to a user account (see below) is retained in any case for the time that this account is maintained.

The legal basis for the processing of this data is Art. 6 Abs. 1 S. 1 b) DSGVO and Art. 13 DSG, because this data is required so that we can fulfill our contractual obligations towards you.

3.5 User Account

You can create a user account on our website. If you wish this, we need the personal data requested when you log in. When logging in later, only your email or username and the password you have selected are required.

For the new registration we collect master data (e.g. name, address), communication data (e.g. email address) and payment data (bank details) as well as access data (username and password).

In order to ensure your proper registration and to prevent unauthorized registrations by third parties, you will receive an activation link by email after registration to activate your account. Only after the registration has been made will we permanently save the data you have provided in our system.

You can request to delete a created user account at any time without incurring any costs other than the transmission costs according to the basic tariffs. A message in text form to the contact details mentioned in section 1 (e.g. email, fax, letter) is sufficient for this. We will then delete your stored personal data if we do not have to save it to process orders or due to legal retention requirements.

The legal basis for the processing of this data is your consent Art. 6 Abs. 1 S. 1 a) DSGVO und Art. 13 DSG.

3.6 Newsletter

The data requested during the registration process is required to register for the newsletter. The registration for the newsletter is logged. After registration, you will receive a message at the email address provided asking you to confirm your registration (“Double Opt-in”). This is necessary so that third parties cannot register with their email address.

You can revoke your consent to receive the newsletter at any time and thus unsubscribe from the newsletter.

We save the registration data as long as they are required for sending the newsletter. We save the logging of the registration and the shipping address as long as there was an interest in proving the originally given consent, as a rule these are the limitation periods for civil law claims, i.e. a maximum of three years. 

The legal basis for sending the newsletter is our legitimate interest in direct advertising in accordance with Art. 6 Abs. 1 S. 1 f) 47 S. 7 DSGVO in in connection with your consent and Art. 13 DSG and Art. 13 GDPR.

You can cancel your registration at any time without incurring any costs other than the transmission costs according to the basic tariffs. A message in text form to the contact details mentioned in section 1 (e.g. email, fax, letter) is sufficient for this. Of course, you will also find an unsubscribe link in every newsletter.

3.7 Product Recommendations

Independently from our newsletter we will send product recommendations via e-mail. In this way, we send you information about products from our store that you may be interested in based on your recent purchases of goods or services from us. We strictly follow the legal obligations. You can object to this at any time without incurring any costs other than the transmission costs according to the basic tariffs. A message in text form to the contact details mentioned in section 1 (e.g. email, fax, letter) is sufficient for this. Of course, you will also find an unsubscribe link in every email.

The legal basis for this is the legal permission according Art. 6 Abs. 1 S. 1 f) DSGVO and Art. 13 DSG.

3.8 Email Contact

If you get in touch with us (e.g. via contact form or email), we process your details in the event that follow-up questions arise.

If the data processing for implementation of pre-measurements that are made at your request, or if you are already our customer, is the legal basis for performance of the contract and for this data processing Art. 6 Abs. 1 S. 1 b) DSGVO and Art. 13 DSG.

Other personal data we process only with your consent (Art. 6 Abs. 1 S. 1 a) DSGVO and Art. 13 DSG) or if we have a legitimate interest in the processing of your data (Art. 6 Abs. 1 S. 1 f) DSGVO und Art. 13 DSG). A legitimate interest lies e.g.in responding to your email.

3.9 Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that enable an analysis of your use of the website. The information generated by the cookie about the use of this website by site visitors is usually transmitted to a Google server in the USA and stored there.

User legitimate interest in accordance Art 6 Abs. 1 S. 1 f) DSGVO or Art. 13 DSG is to find out how often and how our site is used.

Google has submitted to the Privacy Shield Agreement between the European Union and the USA and has been certified. As a result, Google is committed to complying with the standards and regulations of European data protection law. You can find more information in the entry linked below: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

We have activated IP anonymization on this website (anonymizeIp). This will, however, shorten your IP address from Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website activity and internet usage.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.

You can also prevent the additional transmission of the generated by the cookie and related use of the website (incl. Your IP address) to Google and the processing of these data by Google, by download and install the  following link browser plugin: http://tools.google.com/dlpage/gaoptout?hl=de.

3.10 Salesforce

The personal data collected and managed from you in connection with the online shop is transferred to the CRM system (“Customer Relationship Management”) of the cloud provider Salesforce. You can view Salesforce’s privacy policy: https://www.salesforce.com/de/company/privacy/. Further information on the GDPR can be found at https://www.salesforce.com/de/campaign/gdpr/.

Our legitimate interest in accordance with Art 6 Abs. 1 S. 1 f) DSGVO and Art. 13 DSG is to find out how often and how our website is used.

Salesforce is headquartered in the United States. Therefore, it cannot be excluded that the above data will be transferred to the USA. Salesforce is certified under the EU-US Privacy Shield and guarantees that your data is also subject to an adequate level of data protection in the USA. Further information on certification can be found under the following link: https://www.privacyshield.gov/welcome .

4 Storage period

Unless specifically stated, we only store personal data for as long as is necessary to fulfill the purposes.

In some cases, legislators provide for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by us for these legal purposes but will not be processed otherwise and will be deleted after the statutory retention period has expired. 

5 Your Rights as a Data Subject

According to the applicable laws, you have various rights regarding your personal data. If you would like to assert these rights, please send your request by email or post, clearly identifying yourself, to the address given in Section 1.

Below you will find an overview of your rights.

5.1 Right to Confirmation and Information

You have the right for clear information about the processing of your personal data.

In detail:

You have the right to receive confirmation from us at any time as to whether your personal data is being processed. If this is the case, you have the right to request free information from us about the personal data stored about you, along with a copy of this data. There is also a right to the following information:

  1. the processing purposes;
  2. the categories of personal data that are processed;
  3. the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations;
  4. if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
  5. the existence of a right of correction or deletion of the personal data, or limitation of the processing by the controller or the right of appeal against this processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. if the personal data is not collected from you, all available information about the origin of the data;
  8. the existence of automated decision-making, including profiling in accordance with Art. 22 Abs. 1 und 4 DSGVO and – at least in these cases – meaningful information about the logic involved as well as the scope and the intended effects of such processing for you.

If personal data is transmitted to a third country or to an international organization, you have the right to obtain the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transmission.

5.2 Right of Rectification

You have the right to request to correct and, if necessary, to complete your personal data.

In detail:

You have the right to demand the correction of incorrect personal data immediately. Taking into account the purpose of processing, you have the right to request the completion of incomplete personal data – also by means of a supplementary declaration.

5.3 Right to Delete (“Right to be Forgotten”)

In a number of cases, we are obliged to delete your personal data.

In detail:

According to Art. 17 Abs. 1 DSGVO you are entitled to demand that some relevant personal data are deleted immediately, and we are obliged to delete personal data immediately unless one of the following reasons applies:

  1. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. You revoke your consent on which the processing was based in accordance with Art. 6 Abs. 1 S. 1  a) DSGVO or Art. 9 Abs. 2 a) DSGVO, and there is no other legal basis for the processing.
  3. In accordance with Art. 21 Abs. 1 DSGVO and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Art. 21 Abs. 2 DSGVO to object to processing.
  4. The personal data was processed unlawfully.
  5. The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the member states to which we are subject.
  6. The personal data were collected in relation to the services offered by the information society in accordance with Art. 21 Abs. 2 DSGVO.

In case that we made the personal data public, we are committed to their cancellation according to Art. 17 Abs. 1 DSGVO, we take in consideration of the available technology and the costs of implementation appropriate measure, including technical order for the data controller that the personal data processed to inform you that you require the removal of all links of these personal data or copies or replications of personal data.

5.4 Right to Restriction of Processing

In a number of cases, you are entitled to request that we restrict the processing of your personal data.

In detail:

You have the right to request that we restrict processing if one of the following conditions is met:

  1. You contest the accuracy of the personal data for a period of time that enables us to verify the accuracy of the personal data,
  2. That the processing is illegitimate, and you rejected the deletion of personal data and requested a limited use of personal data;
  3. We no longer need the personal data for the purposes of processing, but you need the data to assert, exercise or defend legal claims, or
  4. You object to the processing in accordance with Art. 21 Abs. 1 DSGVO, as long as it is not certain whether the legitimate reasons of our company outweigh yours.

5.5 Right to Assignment of Data 

You have the right to receive, transmit or have us transfer your personal data in a machine-readable manner.

In detail:

You have the right to receive the personal data relating to you that you have provided to us in a structured, common and machine-readable format, and you have the right to transmit this data to another person in charge without hindrance from us, provided that

  1. processing is based on consent in accordance with Art. 6 Abs. 1 S. 1 a) DSGVO or Art. 9 Abs. 2 a) DSGVO or on a contract in accordance with Art. 6 Abs. 1 S. 1 b) DSGVO and
  2. the processing is carried out by using automated processes.

In the exercise your right to data assignment under paragraph 1, you are entitled to obtain, that the personal data directly from us will be transmitted to another person responsible, to the extent technically feasible.

5.6 Right to Object

You have the right to object to process your personal data when your situation is justified and does not outweigh our interests in processing.

In detail:

You have the right, for reasons arising from your particular situation to object at any time to the processing of your personal data, which were processed based of Art. 6 Abs. 1 S. 1 e) or f) DSGVO; this also applies to profiling based on these provisions. We no longer process the personal data unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If we process personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling as it is connected to such direct advertising.

You have the right, for reasons arising from your particular situation against which you relevant processing of respective personal data for scientific or historical research purposes or  for statistical purposes in accordance with Art. 89 Abs. 1 DSGVO, you have to object, unless the processing is necessary to fulfill a task in the public interest.

5.7 Automated Decisions including Profiling

You have the right, not excluded on automated processing – including profiling – to be subjected to a decision that has legal effect on you or similarly significantly affects you

There is no automated decision-making based on the personal data collected.

5.8 Right to Withdraw the Consent under Data Protection Law

You have the right to withdraw your consent to the processing of personal data at any time.

5.9 Right to file a Complaint with a Supervisory Authority

You have the right to complain to a supervisory authority, in the Member State of your residency, your workplace or the location of the suspected violation, if you believe that the processing of your personal data is unlawful.

6 Data Security

We make every effort to ensure the security of your data within the framework of the applicable data protection laws and technical options.

Your personal data will be received encrypted. This applies to your orders as well as to the customer login. We use the SSL (Secure Socket Layer) coding system, but we point out that data transmission over the Internet (e.g. when communicating by email) can have security gaps. It is not possible to completely protect data from third-party access.

To secure your data, we enforce technical and organizational security measures in accordance with Art. 32 DSGVO, which we continually adapt to the state of the art.

We do not guarantee that our offers will be available at certain times; disruptions, interruptions or failures cannot be excluded. The servers which we use are regularly carefully backed up.

7 Forwarding of Data to Third Parties, no Data Transfer to unsafe Third Countries

Basically, we only use your personal data within our company.

In case we involve third parties for the performance of contracts (such as logistics service providers), these personal data will only be received to the extent that the transmission is necessary for the corresponding service.

In the event that we outsource certain parts of data processing (“order processing”), we contractually oblige our contractual partners to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.

A data transfer to bodies or persons outside the EU and Switzerland outside in this statement mentioned in in paragraph 3.9 f. does not take place and is not planned.