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Privacy Policy

1. WHAT IS THIS PRIVACY POLICY ABOUT?

Supertext AG, Hardturmstrasse 253, CH-8005 Zurich, Switzerland (hereinafter “Supertext AG”), and Supertext Deutschland GmbH, Mehringdamm 32/34, DE-10961 Berlin, Germany (hereinafter “Supertext GmbH”), (collectively “Supertext”), collect and process personal data that concerns you and other individuals (“third parties”).

We use the word “data” here interchangeably with “personal data”. “Personal data” means data relating to identified or identifiable individuals, while “processing” means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.

In this Privacy Policy, we describe what we do with your data when you use supertext.com, our other websites or apps (collectively “website”), obtain services from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. In addition, we may inform you about the processing of your data separately (e.g. in forms, terms and conditions or additional privacy policies).

If you disclose data about other persons (e.g. family members, work colleagues) to us, we assume that you are authorised to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Policy.

This Privacy Policy is aligned with the Swiss Federal Act on Data Protection (FADP), the ordinances associated with it, and the EU General Data Protection Regulation (GDPR). However, the application of these laws depends on each individual case.

2. WHO IS THE CONTROLLER FOR PROCESSING YOUR DATA?

Depending on with whom you conclude the contract, communicate or otherwise have dealings, Supertext AG or Supertext Deutschland GmbH is the controller for the data processing under this Privacy Policy, unless we tell you otherwise in an individual case. In the context of data processing on the website and in any case of uncertainty, Supertext AG should be regarded as the controller.

Regardless of which company is the controller in an individual case, you may contact us for data protection concerns and to exercise your rights as follows:

Supertext AG
Hardturmstrasse 253
CH-8005 Zurich
Telephone +41 43 500 33 80
privacy@supertext.com

Supertext AG has voluntarily appointed the following additional positions:

  • Data Protection Representative in the EU according to article 27 GDPR:
    Supertext Deutschland GmbH
    Mehringdamm 32/34
    DE-10961 Berlin
    privacy@supertext.com

Supertext Deutschland GmbH has voluntarily appointed the following additional positions:

  • Data Protection Representative in Switzerland pursuant to article 14 FADP:
    Supertext AG
    Hardturmstrasse 253
    CH-8005 Zurich
    privacy@supertext.com

You can also contact these parties for privacy concerns.

3. WHAT DATA DO WE PROCESS?

We process various categories of data about you. The main categories of data are the following:

  • Master data: This is the basic data (e.g. name, contact details), additional information about you (e.g. your role and function) as well as details of your relationship with us (customer, supplier, partner or employee of such, etc.), your bank details, gender, photographs, customer history, powers of attorney, signature authorisations, declarations of consent and information about third parties (e.g. contacts, representatives).
  • Registration data: This is data that is generated in the course of a registration (particularly on our client portal) with us or that you provide to us in this context (e.g. username, email, password).
  • Contract data: This is data that is collected in connection with a contract concluded by us or in the context of the provision of our services, such as information about the type of contract, date of conclusion of the contract, duration of the contract, contractual services, data that was collected during the period leading up to the conclusion of the contract, information required or used for processing (particularly documents that you provide to us for processing and translation), information about reactions (complaints, feedback about satisfaction, etc.) and financial data (e.g. information about payment practices, solvency/creditworthiness, reminders and debt collection).
  • Communication data: When you are in contact with us or with third parties (e.g. via the contact form, by email, telephone or by letter or other means of communication) we collect the data exchanged between you and us, such as the content of emails or letters, your contact details and the metadata of the communication or if necessary a copy of an ID document.
  • Technical data: When you use our digital offerings (particularly the website), we collect technical data, e.g. the IP address, information about the operating system of your device, the location and the access time. Technical data in itself does not permit us to draw conclusions about your identity. However, technical data might be linked with other categories of data (e.g. registration data) and thus possibly with your person.
  • Behavioural and preference data: This is data about your behaviour and your preferences (e.g. your response to electronic communications, navigation on our website and interactions with our social media pages). We may also supplement this information with third-party information, including from public sources. We describe how tracking works on our website in Section 12.
  • Candidate data: This is data that we process in the context of a job application and that is, among other things, included in your application documents (e.g. employment history, education and training, references). We may also obtain data from public sources, such as professional social networks, the internet and media.
  • Other data: This may include the following data: data collected in connection with administrative or legal proceedings (e.g. files, evidence, etc.), photographs, videos or sound recordings that we produce or receive from third parties and in which you are recognisable (e.g. at events), access data or rights (e.g. visitor list, when you enter certain buildings or which access rights you have), participation in events and when you use our infrastructure and systems.
4. WHAT IS THE SOURCE OF THE DATA?
  • From you: Much of the data set out in Section 3 is provided to us by you (e.g. when you communicate with us, in relation to contracts and our services, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases (e.g. because of legal requirements such as legally required identification). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.
  • From third parties: As far as it is lawful we can also collect data from public sources (e.g. debt collection registers, the media or the internet including social media) and receive data from public authorities and from other third parties (e.g. credit agencies, contractual partners, internet analytics services, etc.). This includes the following categories of data: master data, contract data and other data according to Section 3 as well as data from correspondence and discussions with third parties. If you work for an employer, client or someone else who has a business relationship or other dealings with us, they may also provide us with information about you.
5. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
  • Communication: In order to be able to communicate with you (e.g. to answer enquiries, and in the context of consulting as well as the execution of a contract), we need to process data (in particular communication and master data, and contractual and registration data in connection with the services you use) from you. If we need or want to establish your identity, we collect additional data (e.g. a copy of an ID document).
  • Initiation, administration and execution of contracts: In connection with the conclusion or execution of contracts with our customers, suppliers, subcontractors or other contractual partners (e.g. project partners), we process related personal data. For this purpose, we also process data for opening and managing the customer relationship, for consulting, for customer support and for providing and demanding contractual services. This also includes the enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.), accounting, termination of contracts and public communication. For this purpose, we use in particular master data, contract data and communication data, and possibly also registration data of the customer or of the persons to whom the customer provides a service, as well as technical data (e.g. in the case of digital offers).
  • Marketing purposes and relationship management: For marketing purposes and relationship management, we process data, for example, to send our customers, other contractual partners and other interested parties personalised advertising (e.g. in print, by email, on other digital channels or by telephone) about products, services and other news from us or as part of individual marketing campaigns (e.g. events). You can refuse such contacts at any time or refuse or revoke your consent to be contacted for advertising purposes by notifying us (Section 2). With your consent, we can target our online advertising on the internet more specifically to you (see Section 12). This also includes interaction with existing customers and their contacts, which can be personalised on the basis of behavioural and preference data. As part of relationship management, we may also operate a customer relationship management (CRM) system in which we store the data of customers and other business partners. For marketing purposes and relationship management, we process in particular communication, registration, behavioural and preference data.
  • Market research, improvement of our services and operations, and product development: In order to continuously improve our products and services (including our website) and to be able to respond quickly to changing needs, we analyse, for example, how you navigate through our website or which products are used by which groups of people and in what way, and how new products and services can be designed (for further details, see Section 12). This gives us an indication of the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioural data and preference data, but also communication data and information from customer surveys, polls and studies and other information, e.g. from the media, social media, the internet and other public sources. As far as reasonably practicable, we use pseudonymised or anonymised data for these purposes.​
  • Registration and security purposes as well as technical and physical access controls: In order to use certain offers and services (e.g. login areas), you must register (directly with us or via our external login service providers), for which we process data. Furthermore, we also collect additional personal data about you during the use of the offer or service. We continuously check and improve the appropriate security of our IT and our other infrastructure (e.g. buildings). We therefore process data, for example, for monitoring, controls, analyses and tests of our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of security backups. Access controls include, on the one hand, controlling access to electronic systems (e.g. logging into user accounts), and on the other hand, physical access control (e.g. building access). For security purposes (preventive and incident investigation) we also keep access logs or visitor lists. For this purpose, we process registration data and technical data in particular, but also other data mentioned in Section 3.
  • Compliance with laws, directives and recommendations from authorities and internal regulations (“compliance”): We may process personal data as part of our compliance with laws (e.g. tax law obligations). In addition, data processing may take place in the course of internal investigations as well as external investigations (e.g. by a law enforcement or supervisory authority or an appointed private body). For this purpose, we process in particular master data, contract data and communication data, but under certain circumstances also behavioural data, technical data and data from other data categories. The legal obligations may be Swiss law, but also foreign regulations to which we are subject, as well as self-regulations, industry standards, our own “corporate governance” and official instructions and requests.
  • Risk management and corporate governance: We may process personal data as part of our risk management (e.g. to avoid becoming victims of crime and abuse) and corporate governance, including our business organisation (e.g. resource planning) and corporate development (e.g. acquisition and sale of business units or companies). For this purpose, we process in particular master data, contract data, registration data and technical data, as well as behavioural and communication data.
  • Job application: If you apply for a job with us, we collect and process the relevant data for the purpose of reviewing the application, conducting the application process and, in the case of a successful application, preparing and concluding the relevant contract. Data processing in the context of the employment relationship is governed by a separate privacy policy.
  • Further purposes: These other purposes include, for example, training and educational purposes, administrative purposes, safeguarding our rights and evaluating and improving internal processes. The protection of other legitimate interests is also one of the other purposes, which cannot be named exhaustively.
6. ON WHAT BASIS DO WE PROCESS YOUR DATA?

To the extent necessary and depending on the situation and processing purpose, we base the processing of your data on the following legal basis:

  • Contract: Insofar as we process data for the conclusion and execution of contracts that we conclude or have concluded for you or with you or your employer, client or other persons for whom you work, this is also the legal basis on which we process your data.
  • Legal obligations: We may further process your data based on applicable legal, regulatory and professional requirements with which we must comply.
  • Legitimate interest: We may process your data based on our legitimate interest or a legitimate interest of a third party. This applies in particular in relation to the achievement of the purposes and objectives set out in Section 5 and for the implementation of related measures. Among other things, we have a legitimate (and overriding) interest in improving and marketing our products and services (which includes the use of AI) and in gaining a better understanding of the markets relevant to us and our activities (in particular, in the efficient and secure handling of our processes and the further development of our activities), in the efficient and effective management of our company and in safeguarding the security of our systems and our interests vis-à-vis third parties.
  • Consent: If we ask for your consent to process data from you, this is the legal basis on which we process your data. In doing so, we will inform you of the purpose of the processing. You may revoke your consent at any time by notifying us in writing (by post or, unless otherwise specified or agreed, by email), with effect for the future (see Section 2 regarding our contact details and Section 12 regarding revocation of your consent in the area of online tracking). Once we have received and processed your withdrawal, we will no longer process your data for the purposes to which you originally consented (unless further processing may be carried out on the basis of another legal basis).
  • Other legal bases: In specific cases, we may also carry out data processing based on other legal bases. If this is the case, we will inform you in each individual case.
7. WITH WHOM DO WE SHARE YOUR DATA?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes set out in Section 5, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • Group companies: Supertext AG and Supertext GmbH share personal data with each other. The data processing operations of both companies are described in this Privacy Policy (see Section 5). As a general rule, they process the data on their own responsibility.
  • Service providers: We work with service providers locally and abroad (third parties) who process data about you (i) on our behalf, (ii) under joint responsibility with us or (iii) data they have received from us under their own responsibility (e.g. IT providers, cleaning companies, banks, insurance companies, debt collection companies, credit agencies, address checkers, consulting companies or lawyers).
  • Contractual partners, including customers: This initially refers to customers and other contractual partners of ours where transfer of your data arises from the contract (e.g. because you work for a contractual partner or it provides services to or for you). Recipients further include contractual partners with whom we cooperate or who advertise on our behalf. The recipients process the data under their own responsibility.
  • Authorities: We may disclose personal data to offices, courts and other authorities locally and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The recipients process the data under their own responsibility.
  • Other persons: This refers to other cases where the inclusion of third parties results from the purposes pursuant to Section 5. Other recipients are, for example, delivery addressees or third-party payees specified by you, third parties in the context of agency relationships (e.g. your lawyer or your bank) or persons involved in official or legal proceedings. In the course of business development, we may sell or acquire businesses, operations, assets or companies, or enter into partnerships, which may also result in the disclosure of information (including information about you, for example, as a customer or supplier or as their agent) to the persons involved in those transactions. In the course of communication with our competitors, associations and other bodies, data may also be exchanged which may affect you.

All these categories of recipient may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

We also allow certain third parties to collect personal data from you on our website (e.g. providers of tools that we have embedded on our website, etc.). Insofar as we are not decisively involved in these data collections, these third parties are solely responsible for them. If you have any concerns or wish to assert your data protection rights, please contact these third parties directly. See Section 13 for the website.

8. IS YOUR PERSONAL DATA DISCLOSED ABROAD?

We process and store personal data mainly in Switzerland and the European Economic Area (EEA). However, we may occasionally disclose data to service providers and other recipients (see Section 7) that are located or process data outside of this area, generally in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require that the recipient undertakes to comply with Swiss and EEA data protection standards. For this purpose, we use the European Commission’s revised standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules to ensure data protection and/or we can rely on an exception. An exception may apply for example in the event of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if the data has been made generally available by you and you have not objected to the processing.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

9. HOW LONG DO WE PROCESS YOUR DATA?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically required (e.g. in the case of backups or document management systems). If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our normal processes.

If no legal retention requirements exist in individual cases, we generally process data for the duration of the business relationship or contract term and then, depending on the applicable legal basis, for a further five, ten or more years. This corresponds to the period during which we can assert legal claims against third parties or third parties can assert legal claims against us. Ongoing or anticipated legal proceedings may result in processing beyond this period. See section 12 for more information on the storage period of cookies.

For example, we generally retain data for the periods listed below, although the retention period may vary (particularly for evidentiary reasons, as a result of legal or contractual requirements, or as a result of technical limitations).

  • Master data: Usually 10 years from the last exchange with you, but at least from the end of the contract.
  • Contract data: Usually 10 years from the last contract activity, but at least from the end of the contract.
  • Communication data: Usually 12 months from the last exchange with you.
  • Other data: The retention period of this data depends on the purpose and is limited to what is necessary. This ranges from a few days (e.g. images from security cameras) to several years or longer (e.g. reports on events with images, court proceedings). Data about you as a shareholder or other investor is retained in accordance with company law requirements, but in any case for as long as you are invested.
  • Cookies: See section 12
10. HOW DO WE PROTECT YOUR DATA?

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect it against the risks of loss, accidental loss or alteration, unauthorised disclosure or access. However, security risks cannot be completely eliminated in general – a certain residual risk is unavoidable.

11. WHAT ARE YOUR RIGHTS?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights.

If you wish to exercise any of the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; you will find our contact details in Section 2. In order for us to rule out any misuse, we must identify you (e.g. by means of a copy of your ID card, if this is not possible by less extensive means).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can also contact the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/en/contact-2.

12. DO WE USE ONLINE TRACKING AND SIMILAR TECHNIQUES?

During usage of our website (incl. newsletters and other digital offerings), data (particularly technical data) is generated and stored in logs. We may also use cookies and similar technologies (e.g. pixel tags or fingerprints) to recognise visitors to our website, analyse their behaviour and identify preferences. A cookie is a small text file that is transmitted between the server and your system and enables recognition of a specific device or browser.

You can configure your browser to automatically reject, accept or delete cookies. You can also disable and delete cookies on a case-by-case basis. To find out how to manage cookies in your browser, please consult your browser’s help menu.

Generally speaking, the technical data we collect and the cookies do not contain personal data. However, personal data that we or third-party providers contracted by us store from you (e.g. if you have a user account with us or these providers) may be linked to the technical data or the information stored in and obtained from cookies and thus possibly to your person.

We also use social media plug-ins, which are small pieces of software that establish a connection between your visit to our website and a third-party provider. The social media plug-in tells the third-party provider that you have visited our website and may transmit cookies to the third-party provider that it has previously placed on your web browser. For more information about how these third-party providers use your personal data collected via their social media plug-ins, please refer to their respective privacy policies.

The cookies and similar technologies we use on our websites serve the following purposes (similar technologies are included in each case):

  • Necessary cookies: Some cookies are essential for the use of the website and its functions. These cookies ensure the essential functionality of the website, for example, the ability to navigate from page to page without the disappearance of products placed in the shopping cart. They also ensure that you remain connected to the website. These cookies have an expiration date of up to 18 months.
  • Performance and analytics cookies: Performance and analytics cookies collect information about how our website is used and allow us to perform analytics about how the website is used, such as which pages are viewed most frequently and how visitors navigate our website. These cookies are used to make visiting the website easier and faster and generally improve user experience and comfort. For this purpose, we use third-party analytics services. Before we use such cookies, we ask for your consent. You can revoke this at any time via the relevant function on our website. These cookies have an expiration date of up to 18 months.

Using the relevant function on our website, you also have the option to disable certain categories of cookies by making the appropriate settings.

Some of the third-party vendors we use may be located outside of Switzerland. For information on the disclosure of data abroad, please refer to section 9.

If you consent to the use of cookies, you accept that your data may be transferred to a country that does not have an adequate level of data protection and accept the risk that your data may be exposed to access by foreign authorities in the country of the recipient, who may not adhere to adequate data protection regulations in doing so.

We currently use services from the following service providers:

  • Google Analytics: Google Ireland Ltd. (located in Ireland) is the provider of the service “Google Analytics” and acts as our processor. Google Ireland Limited relies on Google LLC (located in the United States) as its sub-processor (both “Google”). Google collects information about the behaviour of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States so they cannot be traced back. We have turned off the “Data sharing” option and the “Signals” option. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries, where your data may be accessible to authorities that are not subject to adequate data protection regulation. Information about data protection with Google Analytics can be found here and if you have a Google account, you can find more details about Google's processing here.
13. WHAT DATA DO WE PROCESS ON OUR SOCIAL MEDIA PAGES?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and process the data about you described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms’ providers may analyse your use of our online presence (e.g. how you interact with us, how you use our online presence, what you view, comment on or “like”) and process this data along with other data they have about you (e.g. information about your age and gender and other demographic information). In this way, they create profiles about you and statistics about the use of our online presences. They use this data and these profiles to display our or other advertisements and other personalised content on the platform and to drive behaviour on the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. To the extent that we are jointly responsible with the provider for certain types of processing, we will enter into a corresponding contract with the provider. You can find out about the main content of this contract from the provider. They also process this data for their own purposes, in particular for marketing and market research purposes (e.g. to personalise advertising) and to manage their platforms (e.g. to decide what content to show you), and act as separate controllers for this purpose.

We are entitled, but not obliged, to review content before or after it is published on our online presences, to delete content without notice and, if necessary, to report it to the provider of the relevant platform. In the event of violations of decency and conduct rules, we may also notify the provider of the platform on which the user account in question is located for blocking or deletion.

For further information on processing by the platform providers, please refer to the data protection policies of the respective platforms. There you can also find out in which countries your data is processed, what rights of access and deletion you have and how you can exercise these or obtain further information. We currently use the following platforms:

14. CAN WE UPDATE THIS PRIVACY POLICY?

This Privacy Policy is not part of a contract with you. We can change this Privacy Policy at any time. The version published on this website is the current version.

Last updated: March 2025