The data controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:
FINWIWO AG
Oberstrasse 153
9000 St. Gallen
Phone: 071 552 30 00
Email: info@finwiwo.ch
Website: https://finwiwo.ch/
General Note
Pursuant to Article 13 of the Swiss Federal Constitution and the federal data protection provisions (Data Protection Act, DSG), every person has the right to privacy and to protection against the misuse of their personal data. The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable data protection laws and this Privacy Policy.
In cooperation with our hosting providers, we strive to protect our databases as best we can against unauthorized access, loss, misuse, or tampering.
Please note that data transmission over the Internet (e.g., when communicating via email) may be subject to security vulnerabilities. It is not possible to completely protect data from access by third parties.
By using this website, you consent to the collection, processing, and use of data as described below. In general, this website can be visited without registration. Data such as the pages accessed, the names of the files accessed, and the date and time are stored on the server for statistical purposes without being directly linked to you personally. Personal data, in particular your name, address, or email address, is collected on a voluntary basis whenever possible. Your data will not be disclosed to third parties without your consent.
Processing of Personal Data
Personal data refers to any information relating to an identified or identifiable individual. A data subject is an individual whose personal data is being processed. Processing encompasses any handling of personal data, regardless of the means or methods used, including, in particular, the retention, disclosure, collection, deletion, storage, modification, destruction, and use of personal data.
We process personal data in accordance with Swiss data protection law. Furthermore, to the extent that the EU GDPR applies, we process personal data in accordance with the following legal bases in connection with Article 6(1) of the GDPR:
- (a) Processing of personal data with the consent of the data subject.
- lit. b) Processing of personal data to fulfill a contract with the data subject and to carry out related precontractual measures.
- lit. c) Processing of personal data to fulfill a legal obligation to which we are subject under any applicable EU law or under any applicable law of a country in which the GDPR applies in whole or in part.
- lit. d) Processing of personal data to protect the vital interests of the data subject or another natural person.
- lit. f) Processing of personal data to safeguard our legitimate interests or those of third parties, unless the fundamental freedoms, rights, and interests of the data subject take precedence. Legitimate interests include, in particular, our business interest in being able to provide our website, information security, the enforcement of our own legal claims, and compliance with Swiss law.
We process personal data for as long as is necessary for the respective purpose or purposes. In cases where we are subject to longer retention requirements due to legal or other obligations, we restrict our processing accordingly.
Privacy Policy for Cookies
This website uses cookies. These are small text files that make it possible to store specific, user-related information on the user’s device while they are using the website. Cookies enable us, in particular, to determine the frequency of use and the number of users of the pages, to analyze user behavior, and to make our website more user-friendly. Cookies remain stored after 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 configure your web browser to refuse cookies.
A general objection to the use of cookies for online marketing purposes can be submitted for a wide range of services—particularly in the case of tracking—via the U.S. website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, you can prevent cookies from being stored by disabling them in your browser settings. Please note that doing so may prevent you from using all features of this website.
Privacy Policy for SSL/TLS Encryption
This website uses SSL/TLS encryption for security purposes and to protect the transmission of confidential information, such as the inquiries you send to us as the website operator. You can recognize an encrypted connection by the fact that the address bar in your browser changes from “http://” to “https://” and by the padlock icon in your browser’s address bar.
If SSL or TLS encryption is enabled, the data you send to us cannot be read by third parties.
Privacy Policy for the Contact Form
If you submit inquiries to us via the contact form, we will store the information you provide in the inquiry form—including the contact information you provide there—for the purpose of processing your inquiry and in case of follow-up questions. We will not share this data without your consent.
Privacy Policy for Newsletter Data
If you would like to subscribe to the newsletter offered on this website, we need your email address as well as information that allows us to verify that you are the owner of the email address provided and that you consent to receiving the newsletter. No other data is collected. We use this data exclusively to send you the requested information and do not share it with third parties.
You may revoke your consent to the storage of your data and email address, as well as their use for sending the newsletter, at any time—for example, by clicking the “Unsubscribe” link in the newsletter.
Use of Google Maps
This website uses Google Maps. This allows us to display interactive maps directly on the website and enables you to conveniently use the map feature. When you visit the website, Google receives information that you have accessed the corresponding page on our website. This occurs regardless of whether you are logged in to a Google account or do not have a Google account. If you are logged in to Google, your data will be directly associated with your account. If you do not wish for this data to be associated with your Google profile, you must log out before clicking the button. Google stores your data as usage profiles and uses them for advertising, market research, and/or to tailor its website to your needs. Such analysis is carried out in particular (even for users who are not logged in) to deliver targeted 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; to exercise this right, you must contact Google. For more information on the purpose and scope of data collection and its processing by Google, as well as further information on your rights in this regard and settings options to protect your privacy, please visit: www.google.de/intl/de/policies/privacy.
Google AdWords
This website uses Google Conversion Tracking. If you arrived at our website via an ad placed by Google, Google AdWords 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 expire after 30 days and are not used for personal identification. If the user visits certain pages on 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 that page. Each Google AdWords customer receives a different cookie. Cookies cannot therefore be tracked across the websites of AdWords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted in to conversion tracking. Customers are informed of 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 tracking, you can refuse the placement of the cookie required for this purpose—for example, by using a browser setting that generally disables the automatic placement of cookies, or by configuring your browser to block cookies from the domain “googleleadservices.com.”
Please note that you must not delete the opt-out cookies as long as you do not want your usage data to be tracked. If you have deleted all cookies from your browser, you will need to set the respective opt-out cookie again.
Use of Google Remarketing
This website uses the remarketing feature provided by Google Inc. This feature is used to display interest-based ads to website visitors within the Google Display Network. A so-called “cookie” is stored in the website visitor’s browser, which makes it possible to recognize the visitor when they access websites that are part of Google’s advertising network. On these sites, the visitor may be shown ads related to content they previously viewed on websites that use Google’s remarketing feature.
According to Google, it does not collect any personal data during this process. However, if you do not wish to use Google’s remarketing feature, you can generally disable it by adjusting the relevant settings at http://www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising through the Network Advertising Initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp.
Privacy Policy for Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the data controller for this website is located outside the European Economic Area or Switzerland, data processing for Google Analytics is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as “Google.”
The statistics we collect allow us to improve our services and make them more interesting for you as a user. This website also uses Google Analytics to analyze visitor traffic across devices using a user ID. If you have a Google account, you can disable cross-device analysis of your usage in your account settings under “My Data” > “Personal Data.”
The legal basis for the use of Google Analytics is Article 6(1)(f) of the GDPR. The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google. Please note that on this website, Google Analytics has been extended with the code “_anonymizeIp();” to ensure the anonymized collection of IP addresses. As a result, IP addresses are processed in a truncated form, thereby preventing any personal identification. If the data collected about you is personally identifiable, such identification is immediately ruled out, and the personal data is promptly deleted.
Only in exceptional cases is the full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website and Internet usage to the website operator. For the exceptional cases in which personal data is transferred to the United States, Google has complied with the EU-U.S. Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
Google Analytics uses cookies. The information generated by the cookie regarding your use of this website is typically transmitted to a Google server in the United States and stored there. You can prevent the storage of cookies by adjusting your browser settings accordingly; however, please note that in this case, you may not be able to use all features of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plugin available at the following link: Disable Google Analytics.
You can also prevent the use of Google Analytics by clicking this link: Disable Google Analytics. This will store a so-called opt-out cookie on your device, which prevents Google Analytics from processing personal data. Please note that if you delete all cookies on your device, these opt-out cookies will also be deleted; this means you will need to set the opt-out cookies again if you wish to continue preventing this form of data collection. The opt-out cookies are set per browser and per computer/device and must therefore be activated separately for each browser, computer, or other device.
Privacy Policy for Google Ads
This website uses Google’s online marketing tool, Google Ads (“Google Ads”). Google Ads uses cookies to display ads relevant to users, improve campaign performance reports, or prevent a user from seeing the same ads multiple times. Using a cookie ID, Google tracks which ads are displayed in which browser and can thus prevent them from being shown multiple times. In addition, Google Ads can use cookie IDs to track so-called conversions related to ad requests. This occurs, for example, when a user sees a Google Ads ad and later visits the advertiser’s website using the same browser and makes a purchase there. According to Google, Google Ads cookies do not contain any personally identifiable information.
Due to the marketing tools used, your browser automatically establishes a direct connection to Google’s server. Through the integration of Google Ads, Google receives information that you have accessed the relevant section of our website or clicked on one of our ads. If you are registered with a Google service, Google can associate your visit with your account. Even if you are not registered with Google or are not logged in, it is possible that Google may obtain and store your IP address.
You can prevent your participation in this tracking process in several ways:
- by adjusting your browser settings accordingly; in particular, blocking third-party cookies will prevent you from receiving ads from third-party providers;
- by disabling cookies for conversion tracking by configuring your browser to block cookies from the domain “www.googleadservices.com,” https://adssettings.google.com; however, this setting will be reset when you clear your cookies;
- by disabling interest-based ads from providers participating in the “About Ads” self-regulatory campaign via the link https://www.aboutads.info/choices; please note that this setting will be reset if you clear your cookies;
- by permanently disabling cookies in your Firefox, Internet Explorer, or Google Chrome browsers via the link https://www.google.com/settings/ads/plugin. Please note that, in this case, you may not be able to fully use all features of this website.
The legal basis for the processing of your data is a balancing of interests, according to which there are no overriding interests on your part that would preclude the processing of your personal data as described above (Art. 6(1), first sentence, lit. f of the GDPR). For more information about Google Ads from Google, please visit https://ads.google.com/intl/de_DE/home/, and for general information about Google’s privacy practices, please visit https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at https://www.networkadvertising.org.
Privacy Policy for Facebook
This website uses features provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. When you visit our pages that contain Facebook plug-ins, a connection is established between your browser and Facebook’s servers. Data is transmitted to Facebook as part of this process. If you have a Facebook account, this data may be linked to it. If you do not want this data to be associated with your Facebook account, please log out of Facebook before visiting our site. Interactions—in particular, using the comment feature or clicking a “Like” or “Share” button—are also shared with Facebook. For more information, visit https://de-de.facebook.com/about/privacy.
Privacy Policy for Instagram
Our website incorporates features from the Instagram service. These features are provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. If you are logged into your Instagram account, you can link the content on our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to associate your visit to our pages with your user account. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how Instagram uses it.
For more information on this, please see Instagram's Privacy Policy: http://instagram.com/about/legal/privacy/
Newsletter – Mailchimp
Newsletters are sent via the mailing service provider “MailChimp,” a newsletter distribution platform operated by the U.S. provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the mailing service provider’s privacy policy here. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Framework and thereby guarantees compliance with European data protection standards (Privacy Shield). The mailing service provider is used on the basis of our legitimate interests pursuant to Art. 6(1)(f) of the GDPR and a data processing agreement pursuant to Art. 28(3), sentence 1 of the GDPR.
The mailing service provider may use the recipients’ data in pseudonymous form—that is, without linking it to a specific user—to optimize or improve its own services, such as for the technical optimization of newsletter delivery and presentation, or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to contact them directly or to share the data with third parties.
Newsletter via WhatsApp
You can also subscribe to our free newsletter via the WhatsApp instant messaging service. WhatsApp is a service provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, a subsidiary of WhatsApp Inc., 1601 Willow Road, Menlo Park, California 94025, USA; both are hereinafter referred to as “WhatsApp.” Some user data is processed on WhatsApp’s servers in the United States.
However, through its certification under the EU-U.S. Privacy Shield, WhatsApp guarantees that EU data protection requirements are met even when data is processed in the United States. WhatsApp also provides additional information on data protection.
To receive our newsletter via WhatsApp, you need a WhatsApp user account. For details on what data WhatsApp collects during registration, please refer to WhatsApp’s privacy policy mentioned above.
If you then sign up to receive our newsletter via WhatsApp, the cell phone number you enter during the sign-up process will be processed by WhatsApp. In addition, your IP address, as well as the date and time of your sign-up, will be stored. As part of the rest of the sign-up process, we will obtain your consent to receive the newsletter, describe its content in detail, and refer you to this Privacy Policy.
The legal basis for sending the newsletter and conducting the analysis is Article 6(1)(a) of the GDPR.
You may revoke your consent to receive the newsletter at any time with immediate effect, in accordance with Article 7(3) of the GDPR. To do so, you simply need to notify us of your revocation. You can also block the receipt of the newsletter by adjusting the settings in the WhatsApp app on your device.
Real Estate Brokerage Services
We process the data of our customers, clients, and prospective customers (collectively referred to as “customers”) in accordance with the federal data protection provisions (Data Protection Act, DSG) and the EU GDPR, pursuant to Article 6(1)(b) of the GDPR, in order to provide them with our contractual or pre-contractual services. The data processed in this context, as well as the nature, scope, purpose, and necessity of its processing, are determined by the underlying engagement. This generally includes customers’ profile and master data (name, address, etc.), as well as contact information (email address, phone number, etc.), contract details (scope of the engagement, fees, terms, information on the brokered companies/insurers/services), and payment data (commissions, payment history, etc.). We may also process information regarding the characteristics and circumstances of individuals or property belonging to them if this is part of the scope of our assignment. This may include, for example, information regarding personal living circumstances or movable or immovable property.
As part of our engagement, it may also be necessary for us to process special categories of data pursuant to Article 9(1) of the GDPR, specifically information regarding a person’s health. To this end, we will, where necessary, obtain the client’s explicit consent in accordance with Article 6(1)(a), Article 7, and Article 9(2)(a) of the GDPR.
To the extent necessary for the performance of the contract or required by law, we disclose or transfer customer data in connection with coverage inquiries, the conclusion and settlement of contracts, to providers of the brokered services/properties, insurers, reinsurers, broker pools, technical service providers, other service providers such as cooperating associations, as well as financial service providers, credit institutions, and investment companies, and social security agencies, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen, and the Swiss Financial Market Supervisory Authority (FINMA) or the Federal Financial Supervisory Authority (BaFin). Furthermore, we may engage subcontractors, such as sub-brokers. We obtain consent from customers if such consent is required for the disclosure or transfer of data (which may be the case, for example, with regard to special categories of data pursuant to Art. 9 of the GDPR).
Data is deleted once statutory warranty obligations and similar obligations have expired, and the necessity of retaining the data is reviewed at irregular intervals. In all other respects, statutory retention requirements apply. In the case of statutory archiving requirements, the data is deleted once those requirements have expired.
Contractual Services
We process the data of our contractual partners and prospective customers, as well as other clients, customers, or contractual partners (collectively referred to as “contractual partners”) in accordance with the federal data protection provisions (Data Protection Act, DSG) and the EU GDPR pursuant to Art. 6(1)(b). GDPR, in order to provide our contractual or pre-contractual services to them. The data processed in this context, as well as the nature, scope, purpose, and necessity of its processing, are determined by the underlying contractual relationship.
The data processed includes the master data of our contractual partners (e.g., names and addresses), contact information (e.g., email addresses and phone numbers), as well as contract data (e.g., services used, contract terms, contractual communications, names of contact persons) and payment data (e.g., bank account information, payment history).
As a general rule, we do not process special categories of personal data, unless they are part of commissioned or contractual processing.
We process data that is necessary for establishing and fulfilling contractual obligations and will inform you of the necessity of providing such data if this is not obvious to the contracting parties. Data will only be disclosed to external individuals or companies if required under the terms of a contract. When processing data entrusted to us as part of an assignment, we act in accordance with the client’s instructions and applicable legal requirements.
When you use our online services, we may store the IP address and the time of the respective user action. This data is stored based on our legitimate interests, as well as the users’ interests in protection against misuse and other unauthorized use. We do not generally disclose this data to third parties, unless it is necessary to pursue our claims in accordance with Article 6(1)(f) of the GDPR or there is a legal obligation to do so in accordance with Article 6(1)(c) of the GDPR.
Data will be deleted when it is no longer necessary for the fulfillment of contractual or statutory duties of care, or for addressing any warranty or similar obligations; the necessity of retaining the data is reviewed at irregular intervals. In all other respects, the statutory retention requirements apply.
Copyrights
The copyright and all other rights to content, images, photos, or other files on this website belong exclusively to the operator of this website or to the specifically named rights holders. Prior written consent from the copyright holder must be obtained for the reproduction of any files.
Anyone who infringes copyright without the consent of the respective rights holder may be subject to criminal penalties and, in some cases, liable for damages.
General Disclaimer
All information on our website has been carefully reviewed. We strive to ensure that the information we provide is up-to-date, accurate, and complete. Nevertheless, the occurrence of errors cannot be completely ruled out, and therefore we cannot guarantee the completeness, accuracy, or timeliness of the information, including journalistic and editorial content. Liability claims for material or non-material damages resulting from the use of the information provided are excluded, unless there is proven intent or gross negligence on our part.
The publisher may, at its sole discretion and without notice, modify or delete text and is under no obligation to update the content of this website. Use of or access to this website is at the visitor’s own risk. The publisher, its clients, or partners are not responsible for any damages—including direct, indirect, incidental, special, or consequential damages—allegedly arising from a visit to this website and therefore assume no liability for such damages.
The publisher also assumes no responsibility or liability for the content or availability of third-party websites accessible via external links on this website. The operators of the linked sites are solely responsible for their content. The publisher hereby expressly distances itself from all third-party content that may be relevant under criminal or civil law or that violates public decency.
Changes
We may update this Privacy Policy at any time without prior notice. The most current version, as published on our website, is the one that applies. If this Privacy Policy is part of an agreement with you, we will notify you of any changes via email or by other appropriate means in the event of an update.
Questions for the Data Protection Officer
If you have any questions about data protection, please send us an email or contact the data protection officer listed at the beginning of this Privacy Policy directly.
St. Gallen, Dec. 17, 2020
Source: SwissAnwalt
