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Robotic Ledger AG (Sumpfstrasse 26, 6312 Steinhausen, Switzerland), hereafter ‘we‘, is a company providing business services, which generally do not involve processing data relating to an identified or identifiable natural person (hereafter ‘personal data’). Nevertheless, in the course of our activity we acquire some personal data of our direct or indirect clients, software users or website visitors (hereafter ‘you’). This privacy policy (hereafter ‘Policy’) describes what personal data we collect and process, for what purpose we use it, who has access to it, how long we store it and what rights you have when we process your personal data.
By visiting our website, filling a contact form, scheduling a meeting or starting a business relationship with us you consent to the collection, processing, and use of data in accordance with this Policy. You accept the responsibility to obtain such consent of any person whose data you may directly or indirectly forward to us or grant us access to and you release us from any related claims. We shall treat this data with reasonable care, but we would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.
We process personal data in accordance with the Swiss Federal Act on Data Protection (‘FADP’). We meet the requirements of the EU General Data Protection Regulation (‘GDPR’), to the extent and insofar as it is applicable.
We primarily use the personal data we collect to conclude and execute the contracts with our customers and business partners, in particular the software-as-a-service delivery. Furthermore, we use them in the procurement of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations in Switzerland and abroad.
We may also process your personal data for the following purposes, if applicable and appropriate:
The above scope meets the prerequisites of lawful processing as stated in Art. 6 (1) GDPR: your request or consent for a specific processing purpose, like taking steps prior to entering a contract, or our legitimate interest.
For the purposes set out above, in the course of our business activities we may disclose your personal data to third parties, either because we have contractually assigned to them the data processing or because they need them for their activities. This applies, in particular, to our IT service providers, subcontractors, suppliers and other business partners. In each such case we will require from the third party the sufficient level of data security.
We use technical and organisational security measures in accordance with recognised market standards to protect stored personal data against unintentional, unlawful, or unauthorised manipulation, deletion, alteration, access, disclosure or use and against partial or complete loss. We regularly perform backups of customer data. Our cloud server providers declare data storage in Switzerland. The connection to our servers is made using SSL encryption. Despite all these measures we assume no responsibility for the security of your data during transmission over the Internet and disclaim any liability for direct or indirect losses.
We process personal data as long as it is required for the respective purpose or purposes. In the case of longer-term retention obligations to which we are subject, we restrict processing accordingly.
Certain services can be processed via servers in other countries – with an appropriate level of data protection – whereby the requirements of the FADP or GDPR are always complied with. In case of services integrated on our website provided by companies based in the USA, each one declares GDPR compliance. We would like to point out though that the USA is not a safe third country in the sense of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as a data subject being able to object. It can therefore not be ruled out that US authorities (e.g., intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.
You have the right to request confirmation from us if we process your personal data and what is the scope of processing. You may object to processing or demand:
On the other hand, we may refuse to fulfil your request, if for example we are obliged to retain or process certain data, or we have an overriding interest in doing so.
Our website uses cookies, small text files that make it possible to store specific information related to the user on the user's terminal device while the user is using the website. Cookies remain stored beyond the end of a browser session and can be retrieved when you visit the site again. If you do not wish this to happen, you should set your Internet browser so that it refuses to accept cookies.
The provider of our website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This data cannot be assigned to you and is not merged with other data sources. We reserve the right to check this data retrospectively if we become aware of specific indications of illegal use.
If you send us inquiries via the contact form, your data from the inquiry form including the contact data you provided there will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.
Newsletter
If you would like to receive the newsletter which may be offered on our website or elsewhere, we will require from you an e-mail address as well as information that allows us to verify that you are the owner of the specified e-mail address and agree to receive the newsletter. Further data will not be collected. We use this data exclusively for sending the requested information and do not pass it on to third parties. You can revoke your consent to the storage of the data, the e-mail address, and their use for sending the newsletter at any time, for example via the "unsubscribe link" in the newsletter.
Comments
In case our website offered at some point a comment function, in addition to your comment, details of when the comment was created, your e-mail address and, if you do not post anonymously, the username you have chosen will be stored. Our comment function will store the IP addresses of users who post comments. Since we do not check comments on our site before they are activated, we need this data to be able to take action against the author in the event of legal violations such as insults or misinformation. As a user of the site, you would need to subscribe to comments after registering. You will receive a confirmation email to verify that you are the owner of the email address provided. You can unsubscribe from this feature at any time via a link in the info emails.
Our website uses the reCAPTCHA service of Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland "Google"). The query serves the purpose of distinguishing whether the input is made by a human or by automated, machine processing. The query includes the sending of the IP address and possibly other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transmitted to Google and further used there. However, your IP address will be shortened beforehand by Google 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 transmitted to a Google server in the USA and shortened there. Your data may be transmitted to the USA in the process. On behalf of the operator of our website, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other data from Google. For data transfers to the USA, there is an adequacy decision of the European Commission, the "Privacy Shield". Google participates in the "Privacy Shield" and has submitted to the requirements. By pressing the query, you consent to the processing of your data. The processing is based on Art. 6 (1) (a) GDPR with your consent.
Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited.
This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your usage in the settings there under "My data", "Personal data".
The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. We would like to point out that on this website Google Analytics has been extended by the code ‘anonymizeIp();’ to ensure anonymized collection of IP addresses. This means that IP addresses are processed in abbreviated form, which means that they cannot be linked to a specific person. If the data collected about you is related to a person, this is immediately excluded, and the personal data is deleted immediately.
Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage to the website operator. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: Disable Google Analytics.
In addition, you can also prevent the use of Google Analytics by saving a so-called opt-out cookie on your data carrier, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your terminal device, these opt-out cookies will also be deleted, i.e. you will have to set the opt-out cookies again if you wish to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/end device and must therefore be activated separately for each browser, computer or other end device.
The processing is based on Art. 6 (1) (a) GDPR due to your consent.
Our website may use Google conversion tracking. If you have reached our website via an ad placed by Google, Google Ads will set a cookie on your computer. The conversion tracking cookie is set when a user clicks on an ad placed by Google. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies can therefore not be tracked across Ads customers' websites. The information obtained using the conversion cookie is used to create conversion statistics for Ads customers who have opted in to conversion tracking. Clients learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.
If you do not wish to participate in the tracking, you can refuse the setting of a cookie required for this - for example, by means of a browser setting that generally deactivates the automatic setting of cookies or by setting your browser so that cookies from the domain "googleleadservices.com" are blocked.
Please note that you may not delete the opt-out cookies as long as you do not want any measurement data to be recorded. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.
Our website may use web fonts provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) for the uniform display of fonts. When you call up a page, your browser loads the required web fonts from the provider’s server into its browser cache in order to display texts and fonts correctly. Google receives thereby the information that our website was accessed from your IP address. If your browser does not support web fonts, a standard font is used by your computer.
Alternatively, we may use Adobe Fonts for the visual design of our website. Adobe Fonts is a service provided by Adobe Systems Inc. (345 Park Avenue, San Jose, CA 95110-2704, USA). In order to integrate the fonts we use, your browser must establish a connection to an Adobe server in the USA and download the font required for our website. Adobe thereby receives the information that our website was accessed from your IP address.
Our website may use Google Maps, if we decided to display interactive maps directly on the website and enable you to comfortably use the map function. In such case Google would receive the information that you have accessed the corresponding subpage of our website. This occurs regardless of whether Google provides a user account through which you are logged in or whether there is no user account. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.
Our software-as-a-service applications and related data storage run on a cloud server service provided by Google Cloud EMEA Limited (Velasco, Clanwilliam Place, Dublin 2, Ireland) with a broad group of subprocessors enumerated on https://cloud.google.com/terms/subprocessors webpage. Some of the documents our software receives from you may be forwarded to Google Document AI service for data capture. Google declares Zurich as a data storage location and EU as document processing location.
Requesting a service trial, you call Calendly, a cloud application for meeting scheduling as a service, provided by a US company Calendly LLC (115 E. Main Street, Suite A1B PMB 123, Buford, 30518 GA, United States). The application will store and transfer to us your name and email. By using it you consent to processing of your personal data by Calendly to set up an online meeting and by us to stay in contact with you as a potential client. Calendly claims that it has designed its data privacy program to be compliant with GDPR, but if you have any doubts about data protection, please do not use it.
Our website and our sales function may use HubSpot, a marketing automation software from HubSpot, Inc. (Two Canal Park, Cambridge, MA 02141, USA), a US software company with a European branch in Ireland. Your contact data could be stored in HubSpot to facilitate sales and marketing activities. In case HubSpot helps to analyse the use of web portal, it uses cookies for this purpose. This enables us to send you information and offers tailored to your interests. In the process, your personal data may be forwarded to HubSpot servers in the United States (USA). The appropriate level of protection is established by the fact that HubSpot, Inc. participates in the EU-US Privacy Shield Agreement and is certified for compliance with it. The legal basis for the processing of your personal data by us in connection with the use of HubSpot is Art. 6 (1) f) of the GDPR.
We do not expect to use services of Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA). However, in case we would, and you called up our pages with Facebook plug-ins, a connection would be established between your browser and the Facebook servers. In the process, data would be transmitted to Facebook. If you have a Facebook account, this data could be traced to you personally. Interactions, in particular the use of a comment function or the clicking of a "Like" or "Share" button are also passed on to Facebook. If you do not want such data to be associated with your Facebook account, please log out of Facebook before visiting our site.
Our website does not either use functions of X Corp. (1355 Market St, Suite 900, San Francisco, CA 94103, USA) with a data controller in Europe Twitter International (One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland). Should you call up our pages with Twitter plug-ins, a connection would be established between your browser and the servers of Twitter and data transferred to Twitter. If you have a Twitter account, this data can be linked to you personally. Interactions, in particular clicking on a "re-tweet" button, are also passed on to Twitter. If you do not want this data to be ever associated with your Twitter account, please log out of Twitter before visiting our site.
We don’t know much about Instagram, a service offered by Instagram Inc. (1601 Willow Road, Menlo Park, CA, 94025, USA). We know however that being logged into your Instagram account, you could link the content of our pages to your Instagram profile by clicking on the Instagram button, if we had it on our website. This would allow Instagram to associate the visit to our pages with your user account. We would like to point out that we, as the website administrator, have no knowledge of the content of the transmitted data or its use by Instagram, so we do not put on this button.
LinkedIn is a social network, provided by LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland) which we could actually use for marketing purposes. In such case, it would use cookies to help us analyse your use of the website, for example, measure the success of our ads.
LinkedIn cookie collects information on your operating system, the browser, the website you previously visited (referrer URL), pages you visited on our website, which offers you clicked on, and the date and time of your visit. The information generated by the cookie about your use of the website is transferred pseudonymously to a LinkedIn server in the USA and stored there. LinkedIn therefore does not store the name or email address of the respective user. Rather, the above-mentioned data is only assigned to the person for whom the cookie was generated. This does not apply if the user has allowed LinkedIn to process without pseudonymization or has a LinkedIn account. You may refuse the use of cookies by selecting the appropriate settings on your browser, otherwise you consent to the collection and transfer of data (Art. 6 (1) (a) GDPR).
For the provision of chargeable services, we request additional data, such as payment details, to be able to execute your order. We store this data in our billing systems until the statutory retention periods have expired.
Our website or application may use external payment service platforms to execute payments. The usual service provides are:
PostFinance (https://www.postfinance.ch/de/detail/rechtliches-barrierefreiheit.html)
Visa (https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html)
Mastercard (https://www.mastercard.ch/de-ch/datenschutz.html)
American Express (https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html)
Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full)
Bexio AG (https://www.bexio.com/de-CH/datenschutz)
Payrexx AG (https://www.payrexx.ch/site/assets/files/2592/datenschutzerklaerung.pdf)
Apple Pay (https://support.apple.com/de-ch/ht203027)
Stripe (https://stripe.com/ch/privacy)
Klarna (https://www.klarna.com/de/datenschutz/)
Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/)
Giropay (https://www.giropay.de/rechtliches/datenschutzerklaerung).
Transferring your data to a payment provider requires your consent and serves legitimate interests, both yours and ours. The data processed by the payment service providers includes identification data, such as the name and address, bank data, such as account numbers or credit card numbers, password, PIN, as well as the contract, amount, and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. We as the operator do not receive any information about (bank) account or credit card, but only information to confirm (accept) or reject the payment. Under certain circumstances, the data is transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers. For the payment transactions, the terms and conditions and the privacy policy of the respective payment service providers apply, which can be accessed within the respective website or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information, and other data subject rights.
In case we decide to distribute a newsletter, we may be using the Mailchimp mailing service of the US provider Rocket Science Group LLC (675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA), which is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with the European level of data protection. The transfer of your data to a mailing provider is in our legitimate interest (Art. 6 (1) (a) GDPR) based on a contract with the processor (Art. 28 (3) GDPR). The mailing provider may use the data of the recipients in pseudonymous form, i.e. without assigning to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletters or for statistical purposes. However, the mailing provider would not use the data of our newsletter recipients to write to them on its own or to pass the data on to third parties.
We may use audio and video conferencing services to communicate with you. For instance, we can use them to conduct audio and video conferences, virtual meetings, and training sessions such as webinars. In addition to this privacy policy, any terms and conditions of the services used, such as terms of use or privacy statements, also apply. As a rule, teleconference platforms collect personal data and transfer them abroad, so if you do not consent to it, please do not use such service. Usually we would use Microsoft Teams provided by Microsoft (Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland), certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, with a declared data storage location in Switzerland.
We process the data of our past, current, and potential business partners to provide them with our contractual or pre-contractual services (Art. 6 (1) (a) GDPR). The data processed in this context, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship. The data processed includes the master data of our partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contractual data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history). As a rule, we do not process special categories of personal data, unless these are included in contractual data. We process data that are required for the documenting and execution of contractual services and explain the necessity of their disclosure unless this is evident to the contractual partners. Disclosure to external persons or companies is made only if it is necessary in the context of a contract. When processing data provided to us in the context of an order, we act in accordance with the instructions of the client as well as the legal requirements. In the context of our online services, we may store the IP address and the time of the respective user action. The processing is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims (Art. 6 (1) (f) GDPR) or there is a legal obligation to do so (Art. 6 (1) (c) GDPR). The deletion of the data takes place when the data is no longer required for the fulfilment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed at irregular intervals. In all other respects, the statutory retention obligations shall apply.
We may process your data in the context of our administrative tasks, operational activity or accounting and compliance with legal obligations in accordance with Art. 6 (1) (c) and (f) GDPR. In doing so, we process the same data that we process while providing our contractual services. In this context, we may disclose or transfer your data to the tax authorities, consultants, such as tax advisors or auditors, as well as accounting and tax practices. Furthermore, based on our business interests, we store information on suppliers and other business partners, e.g. for the purpose of contacting them at a later date. The contact data is generally stored permanently, while transactional data usually in line with the statutory retention periods.
We may amend this privacy policy at any time without prior notice. The current version published on our website applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.
Robotic Ledger AG, 01.10.2023