Data protection declaration

In this data protection declaration, we inform you about the personal data we process in connection with our activities and services, including our website. In particular, we provide information on why, how and where we process which personal data. We also inform you of the rights of persons whose data we process.

Supplementary data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply to individual or additional activities and services.

1. Contact addresses

Responsibility for the processing of personal data:

riposa AG Swiss Sleep
Bahnhofstrasse 33
8865 Bilten

We indicate any other persons responsible for processing personal data in individual cases.

Data Protection Officer

The internal Data Protection Officer specified below is the point of contact for data subjects and for supervisory authorities in the event of enquiries related to data protection:

Gabriel Schwyter
c/o riposa AG Swiss Sleep
Bahnhofstrasse 33
8865 Bilten

2. Terms and legal bases

2.1 Terms

Personal data means any information relating to an identified or identifiable person.

A data subject is a person whose personal data is processed.

Processing means any handling of personal data, regardless of the means or methods used, especially the storage, disclosure, acquisition, collection, erasure, recording, alteration, destruction or use 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 (FADP) and the Ordinance to the Federal Act on Data Protection (DPO).

3. Nature, scope and purpose

We process personal data that is required to provide our activities and services in a permanent, user-friendly, secure and reliable manner. In particular, such personal data may fall into the categories of inventory and contact data, browser and device data, content data, metadata or marginal data and usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration that is necessary for the respective purpose(s) or that is required by law. Personal data that is no longer required for processing is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are in particular specialised providers whose services we make use of. We also ensure data protection with regard to such third parties.

We only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard our overriding legitimate interests, because the processing is apparent from the circumstances, or after prior information.

In this context, we process in particular information provided voluntarily by data subjects when they contact us – for example by letter, email, instant messaging, contact form, social media or telephone – or when they register for a user account, or in the context of our activities and operations - e.g. the provision of service or repair services to purchasers (including via third-party companies) or owners of riposa products.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect when carrying out our activities and services, if and to the extent that such processing is permitted for legal reasons.

4. Applications

We process personal data about applicants to the extent that it is necessary for the assessment of suitability for an employment relationship or for the subsequent implementation of an employment contract. The personal data required depends in particular on the information requested, for example in a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular in cover letters, CVs and other application documents or in online profiles.

5. Processing of personal data abroad

In principle, we process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular in order to process it or to have it processed there.

We can transfer personal data to all states and territories around the world and elsewhere in the universe provided that, in the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) or a decision of the Swiss Federal Council, the legislation in force there guarantees an adequate level of data protection.

We may disclose personal data to countries whose laws do not ensure adequate data protection, provided that adequate data protection is ensured for other reasons, for example through appropriate contractual agreements, on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, such as the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of such guarantees on request.

6. Rights of the data subject

Data subjects whose personal data we process have rights under Swiss data protection law, including the right of access as well as the right to rectification, erasure or restriction of the processing of personal data.

Data subjects whose personal data we process have the right to appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

7. Data security

We take appropriate technical and organisational measures to ensure data security in line with the associated risks. We cannot therefore guarantee absolute data security.

Our website is accessed via transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, HTTPS for short). Most browsers indicate transport encryption by displaying a padlock icon in the address bar.

Our digital communications – like all digital communications in principle – are subject to mass surveillance with no basis in cause or suspicion as well as to other surveillance by security authorities in Switzerland, in the rest of Europe, in the United States of America (USA) and in other countries. We cannot directly influence the corresponding processing of personal data by intelligence services, police forces and other security authorities.

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 in text form that are stored in your browser. Such stored data need not be limited to traditional cookies in text form.

Cookies may be stored temporarily in your browser as “session cookies” or for a certain period of time, whereby they are known as permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they make it possible to recognise your browser the next time you visit our website, thereby measuring the reach of our website, for example. However, permanent cookies can also be used for online marketing, for example.

You can deactivate or delete cookies completely or partially in your browser settings at any time. Without cookies enabled, our website may no longer be fully available. If and to the extent necessary, we actively request your express consent to the use of cookies.

With regard to cookies that are used for performance and reach measurement or for advertising purposes, a general opt-out is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the 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 collect the following information on each occasion you access our website, provided that it is transmitted from your browser to our server infrastructure or can be detected by our web server: Date and time, including time zone, Internet Protocol

(IP) address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, pages viewed on our website, including amount of data transferred, last page viewed in the same browser window (referer or referrer).

We store such information, which may also include personal data, in server log files.

We require this information in order to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus, in particular, to guarantee the protection of personal data – including by third parties 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 of third parties whose services we use – are small, usually invisible images that are automatically generated when you visit our website. Tracking pixels allow the same data to be recorded as in server log files.

9. Notifications and messages

We may send notifications and messages by email and through other communication channels such as instant messaging or SMS.

9.1 Performance and reach measurement

Notifications and messages can include 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 may also record the use of notifications and messages in a way that can be attributed to the individual person. We need this statistical recording of usage for performance and reach measurement in order to be able to offer notifications and messages based on the needs and reading habits of the recipients in an effective, user-friendly, permanent, secure and reliable manner.

9.2 Consent and objection

In principle, you must expressly consent to the use of your email address and your other contact addresses, unless such use is permitted for other legal reasons. Where possible, we use “double opt-in” to obtain consent, i.e. you receive an email with a web link which you must click on to confirm your agreement so that no misuse by unauthorised third parties can take place.

We may log such declarations of consent, including your Internet Protocol (IP) address and the date and time, for reasons of security and documentation.

In principle, you can unsubscribe from notifications and messages such as newsletters at any time. By unsubscribing, you can at the same time object to the statistical recording of usage for performance and reach measurement.

We reserve the right to send notifications and messages that are absolutely necessary for our online activities and services.

10. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our activities and services. Personal data may also be processed outside of Switzerland in connection with such platforms.

The general terms and conditions (GTC), terms of use, data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions include information about the rights of data subjects directly with regard to the respective platform, including, for example, the right of access.

11. Third-party services

We may use the services of specialised third parties in order to carry out our activities and services in a permanent, user-friendly, secure and reliable manner. Such services also serve to embed other features and content into our website. For technical reasons, such embedded services record the Internet Protocol (IP) address of the user, at least temporarily.

For their own security, statistical and technical purposes, third parties whose services we use may also process data in an aggregated, anonymous or pseudonymised form in connection with our activities. This concerns performance or usage data in order to be able to offer the relevant service, for example.

We use in particular:

Google services: providers: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; general information on data protection: “Privacy and Security Principles”, Privacy Policy, Google’s commitment to data protection laws, “Google Product Privacy Guide”, “How Google uses information from sites or apps that use our services” (information from Google), “How Google uses cookies”, “Personalized advertising” (activation / deactivation / settings).

Services from Microsoft: providers: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; general information on data protection: “Data Protection with Microsoft”, “Data protection and privacy” (Trust Center)

11.1 Digital infrastructure

We use the services of specialised third parties to access the digital infrastructure required for our activities and services. These services include hosting and storage services from specialised providers, for example.

We use in particular:

Cyon: hosting; provider: Cyon GmbH (Switzerland); data protection information: data protection, privacy policy.

11.2 Audio and video conferences

We use specialised audio and video conferencing services to communicate online. We can use these services to hold virtual meetings, for example, or to conduct online classes and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on the user’s individual environment, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background superimposed.

We use in particular:

Google Meet: video conferencing; provider: Google; specific information for Google Meet:

“Google Meet Security & Privacy for users”

Microsoft Teams: platform for services including audio and video conferencing; provider:

Microsoft; specific information for Teams: “Data Protection and Microsoft Teams”.

• Zoom: video conferencing; provider: Zoom Video Communications Inc. (USA); data protection information: Zoom privacy policy, “Privacy”, “Legal Compliance”.

11.3 Map data

We use third-party services to embed maps into our website.

We use in particular:

• Google Maps including the Google Maps platform: map service; provider: Google;

specific information for Google Maps: “How Google uses location information”.

11.4 Advertising

We use the option of displaying targeted advertisements for our activities and services with third parties such as social media platforms and search engines.

The aim of this advertising is to reach people who are already interested in our activities and services or who might be interested in them (remarketing and targeting). We may transmit relevant – possibly also personal – information to third parties that enable such advertising. Additionally, we are able to determine whether our advertising is successful, i.e. in particular whether it has resulted in visits to our website (conversion tracking).

Third parties with whom we advertise and with whom you are registered as a user may be able to assign the use of our online services to your profile there.

We use in particular:

• Facebook advertising (Facebook Ads): social media advertising; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Facebook Pixel and Custom Audiences, including Lookalike Audiences, privacy policy, “Ad Preferences” (user registration required).

Google Ads: search engine advertising; provider: Google; specific information for Google Ads: advertising based on search queries, among other things, using various domain names – in particular, and – for Google Ads, “Advertising” (Google), why am I seeing a particular advertisement?

Instagram Ads: social media advertising; providers: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with Facebook Pixel and Custom Audiences, including Lookalike Audiences, privacy policy (Instagram), privacy policy (Facebook), “Ad Preferences” (Instagram) (user registration required), “Ad Preferences” (Facebook) (user registration required).

12. Extensions for the website

We use extensions for our website in order to be able to use additional features. In particular, we use:

• Google reCAPTCHA: spam protection (differentiation between wanted comments from humans and unwanted comments from bots or spam); provider: Google; specific information for Google reCAPTCHA: “What is reCAPTCHA?”

13. Performance and reach measurement

We use services and programs to determine how our online services are used.

In this context, we can, for example, measure the performance and reach of our activities and services as well as the impact of third-party links to our website.

However, we can also try out and compare how different versions of our website or parts of our website are used (“A/ B test” method), for instance. The results of performance and reach measurement enable us in particular to correct errors, enhance popular content or make improvements to our website.

The Internet Protocol (IP) addresses of individual users must be stored when we use services and programs for performance and reach measurement.

In principle, IP addresses are shortened (“IP masking”) in order to follow the principle of data economy by means of the relevant pseudonymisation, improving the data protection of users as a result.

Cookies may be stored and user profiles may be created when services and programs are used for performance and reach measurement. User profiles include elements such as the 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, user profiles are created exclusively on a pseudonymous basis. We do not use user profiles to identify individual users. Individual services of third parties to which users are logged in can at most assign the use of our website to the user account or user profile for the relevant service.

We use in particular:

Google Analytics: performance and reach measurement; provider: Google; specific information for Google Analytics: measurement including measurement across different browsers and devices (cross-device tracking) as well as with pseudonymised Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, “Data Protection”, “Google Analytics opt-out browser add-on”.

Google Tag Manager: integration and management of other services for performance and reach measurement, as well as other services from Google and third parties; provider:

Google; specific information for Google Tag Manager: “Data collected by Google Tag Manager”; further information on data protection can be obtained from the individual services integrated and managed on the website.

14. Final provisions

We have created this data protection declaration with the data protection generator from Datenschutzpartner.

We may amend and supplement this data protection declaration at any time. We will inform you about such adaptations and additions in an appropriate form, in particular by publishing the current data protection declaration on our website