We are subject to Swiss data protection law as well as any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures adequate data protection.
Responsibility for the processing of personal data:
Headache Centre Hirslanden AG
We point out if there are other persons responsible for the processing of personal data in individual cases.
2. Terms and legal basis
Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, for example, the retrieval, comparison, adaptation, archiving, storage, reading out, disclosure, procurement, recording, collection, deletion, disclosure, ordering, organising, storage, modification, dissemination, linking, destruction and use of personal data.
The processing includes any handling of personal data, regardless of the means and procedures used.
The European Economic Area (EEA) comprises the Member States of the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.
2.2 Legal basis
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (Data Protection Act, DPA) and the Data Protection Ordinance (Data Protection Ordinance, DPA).
We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner and to communicate about them, 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 DSGVO for the necessary processing of personal data to comply with 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 DSGVO 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 DSGVO for the processing of personal data with the consent of the data subject.
- Art. 6 para. 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3. nature, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data and contract and payment data.
We process personal data that is necessary for us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner.
We process personal data for the period necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary will be anonymised or deleted.
We may process personal data for the period of time necessary for the purpose(s) in question or required by law.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
We process personal data jointly with third parties.
We process personal data as a matter of principle only with the consent of the persons concerned. If and to the extent that the processing is permissible for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject provides to us voluntarily when contacting us – for example by letter post, email, instant messaging, contact form, social media or telephone – or when registering for a user account. We may store such information in an address book or similar means, for example. If we receive data about other persons, the transmitting persons are obliged to ensure data protection with regard to these persons as well as to ensure the accuracy of this personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
4. Personal data abroad
We process personal data in principle 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 may process personal data abroad.
We may export personal data to all states and territories on Earth and elsewhere in the universe, provided that the law there is in accordance with decision of the Swiss Federal Council provides for adequate data protection and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – according to Decision of the European Commission ensures adequate data protection.
We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees on request or provide a copy of any guarantees.
5. Rights of data subjects
5.1 Data protection rights
We grant data subjects all rights under applicable data protection law. In particular, data subjects have the following rights:
- Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what that personal data is. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects may have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.
- Data surrender and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.
We may suspend, restrict or refuse the exercise of data subjects’ rights to the extent permitted by law. We can draw the attention of data subjects to 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 business secrets or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to legal obligations to retain data.
We may provide for costs for the exercise of rights exceptionally. We inform data subjects in advance of any costs.
We are obligated to provide information to data subjects.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
5.2 Right to complain
Data subjects have the right to enforce their data protection rights through legal channels or to lodge a complaint with a competent data protection supervisory authority
The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – the right to lodge a complaint with a competent European data protection supervisory authority.
6. Data security
We take appropriate technical and organisational measures to ensure data security appropriate to the risk involved. However, we cannot guarantee absolute data security.
Access to our website is via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication is subject to – as basically any digital communication – mass surveillance without cause and suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot have any direct influence on the corresponding processing of personal data by secret services, police agencies and other security authorities.
7. Use of the website
Cookies can be 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 is closed. Permanent cookies have a specific storage period. Cookies make it possible in particular to recognise 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.
7.2 Server logfiles
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined 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, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).
We store such information for each access to our website.
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
We store such information, which may also represent personal data, in server log files.
7.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.
We have a presence on social media platforms and other online platforms to communicate with interested individuals and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
In each case, the data protection laws also apply.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our Social Media presence on Facebook including the so-called Page Insights – if and to the extent that the General Data Protection Regulation (GDPR) is applicable -. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use Page Insights to help us deliver our social media presence on Facebook in an effective and user-friendly way.
More information about our social media presence on Facebook.
Further information on the nature, scope and purpose of data processing, information on the rights of data subjects as well as the contact details of Facebook as well as Facebook’s data protection officer can be found in the Data Protection Statement of Facebook. We have entered into the so-called “Responsible Party Addendum” with Facebook and have thereby agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the page “Page Insights Information” including “Page Insights Data Information”.
9. Third party services
We use services from specialised third parties to enable us to carry out our activities and operations in a durable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed features and content on our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
9.1 Digital infrastructure
We use services from specialised third parties to access required digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers
We use in particular:
9.2 Map material
We use third party services to embed maps on our website.
We use in particular:
We use third-party services to embed selected fonts and icons, logos and symbols on our website.
We use in particular:
10. Extensions for the website
We use extensions to our website to enable us to use additional features.
We use in particular:
11. Final provisions
We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.