Privacy Policy
This Privacy Policy provides information about the processing of personal data in connection with our activities and operations, including our website at the domain name www.tibram.ch. In particular, we explain what personal data we process, for what purpose, in what manner, and where. We also provide information about the rights of individuals whose data we process.
We have drafted this privacy policy in German. In the event that it is published in another language, the German version of the privacy policy shall prevail.
We may publish additional privacy policies or other information regarding data protection for specific or additional activities and operations.
We are subject to Swiss law and, where applicable, foreign law, in particular the law of the European Union (EU), including the General Data Protection Regulation (GDPR).
In its decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures an adequate level of data protection. In a report dated January 15, 2024, the European Commission confirmed this adequacy decision.
Table of Contents
- 1. Contact Information
- 2. Definitions and Legal Basis
- 3. Nature, scope, and purpose of the processing of personal data
- 4. Disclosure of Personal Data
- 5. Communication
- 6. Applications
- 7. Data Security
- 8. Personal Data Abroad
- 9. Rights of Data Subjects
- 10. Use of the website
- 11. Social Media
- 12. Third-Party Services
- 13. Website Extensions
- 14. Measuring Success and Reach
- 15. Video Surveillance
- 16. Final Notes on the Privacy Policy
1. Contact Information
The data controller is:
Tibram Ltd.
Tibram Ltd.
Industriestrasse 2
3661 Uetendorf
In certain cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. Upon request, we are happy to provide data subjects with information regarding the respective responsibility.
2. Definitions and Legal Basis
2.1 Definitions
Data subject: A natural person whose personal data we process.
Personal data: Any information relating to an identified or identifiable natural person.
Sensitive personal data: Data regarding trade union, political, religious, or ideological views and activities; data regarding health, privacy, or membership in an ethnic or racial group; genetic data; biometric data that uniquely identifies a natural person; data regarding criminal or administrative sanctions or proceedings, and data regarding social assistance measures.
Processing: Any handling of personal data, regardless of the means and methods used, such as retrieving, comparing, modifying, archiving, storing, reading, disclosing, obtaining, collecting, collecting, deleting, disclosing, classifying, organizing, storing, modifying, disseminating, linking, destroying, and using personal data.
European Economic Area (EEA): Member states of the European Union (EU), as well as the Principality of Liechtenstein, Iceland, and Norway.
2.2 Legal Basis
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
We process personal data—to the extent that the General Data Protection Regulation (GDPR) applies—in accordance with at least one of the following legal bases:
- Article 6(1)(b) of the GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
- Article 6(1)(f) of the GDPR for the processing of personal data necessary to safeguard legitimate interests—including the legitimate interests of third parties—unless the fundamental rights and freedoms, as well as the interests, of the data subject take precedence. Such interests include, in particular, the sustainable, people-friendly, secure, and reliable conduct of our activities and operations, ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
- Article 6(1)(c) of the GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under the applicable laws of Member States within the European Economic Area (EEA).
- Article 6(1)(e) of the GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
- Article 6(1)(a) of the GDPR regarding the processing of personal data with the consent of the data subject.
- Article 6(1)(d) of the GDPR for the processing of personal data necessary to protect the vital interests of the data subject or another natural person.
- Art. 9(2) et seq. of the GDPR regarding the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the handling of personal data as the processing of personal data and the handling of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Nature, scope, and purpose of the processing of personal data
We process the personal data necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may include, in particular, browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact data), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted.
We process personal data, where necessary, with the consent of the individuals concerned. In many cases, we may process personal data without consent, for example to comply with legal obligations or to protect legitimate interests. We may also ask data subjects for their consent even when their consent is not required.
We process personal data for as long as is necessary for the respective purpose. We anonymize or delete personal data, in particular, in accordance with statutory retention and statute of limitations periods.
4. Disclosure of Personal Data
We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized service providers whose services we use. These third parties may, in turn, disclose personal data to other third parties.
In the course of our activities, we may disclose personal data to banks and other financial service providers, government agencies, educational and research institutions, consultants and attorneys, accounting and escrow service providers, debt collection agencies, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.
5. Communication
We process personal data in order to communicate with individuals, as well as with government agencies, organizations, and companies. In particular, we process data that a data subject provides to us when contacting us, for example by mail or email. We may store such data in an address book or using similar tools.
Third parties who provide us with data about other individuals are legally obligated to ensure the data protection of those individuals on their own. In particular, they must ensure that they are authorized to transmit such data and must also guarantee the accuracy of the transmitted data.
6. Applications
We process personal data about job applicants to the extent necessary to assess their suitability for employment or for the subsequent performance of an employment contract. The necessary personal data is derived in particular from the information requested, for example in the context of a job posting. We may publish job postings with the assistance of suitable third parties, for example in electronic and print media or on job portals and recruitment platforms.
We also process personal data that applicants voluntarily provide or make public, particularly as part of cover letters, resumes, and other application materials, as well as through online profiles.
We process personal data regarding applicants—to the extent that the General Data Protection Regulation (GDPR) applies—in particular in accordance with Article 9(2)(b) of the GDPR.
7. Data Security
We implement appropriate technical and organizational measures to ensure data security commensurate with the respective risk. Through our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data we process, without, however, being able to guarantee absolute data security.
Access to our website and other digital platforms is secured using transport encryption (SSL/TLS, specifically the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers issue a warning before visiting a website that does not use transport encryption.
Our digital communications—like all digital communications—are subject to mass surveillance without cause or suspicion by security agencies in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence over the processing of personal data by intelligence agencies, police departments, and other security authorities. Nor can we rule out the possibility that a data subject is being specifically monitored.
8. Personal Data Abroad
We generally process personal data in Switzerland and within the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular to process it there or have it processed there.
We may transfer personal data to any country on Earth or elsewhere in the universe, provided that the laws of that jurisdiction, in accordance with a decision by the Swiss Federal Council and—to the extent that the General Data Protection Regulation (GDPR) applies—also in accordance with a decision by the European Commission, ensures an adequate level of data protection.
We may transfer personal data to countries whose laws do not provide adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific legal requirements under data protection law are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information regarding any such safeguards or to supply a copy of any such safeguards.
9. Rights of Data Subjects
9.1 Claims under data protection law
We grant data subjects all rights provided for under applicable law. In particular, data subjects have the following rights:
- Right of Access: Data subjects may request information regarding whether we process personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data being processed as such, but also, among other things, details regarding 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 inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.
- Opportunity to express one’s own viewpoint and for human review: Data subjects may, in the case of decisions based solely on automated processing of personal data that produce legal effects concerning them or significantly affect them (automated individual decisions), present their own point of view and request a review by a human.
- Deletion and Objection: Data subjects may request the deletion of their personal data (“right to be forgotten”) and object to the processing of their data with future effect.
- Data Disclosure and Data Transfer: Data subjects may request the disclosure of their personal data or the transfer of their data to another controller.
We may defer, restrict, or deny the exercise of data subjects’ rights to the extent permitted by law. We may inform data subjects of any prerequisites that must be met for the exercise of their data protection rights. For example, we may refuse to provide information in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other individuals. We may also, for example, refuse to delete personal data in whole or in part, particularly by citing legal retention obligations.
In exceptional cases, we may charge a fee for the exercise of these rights. We will inform the individuals concerned in advance of any such fees.
We are required to take reasonable steps to identify data subjects who request information or exercise other rights. Data subjects are required to cooperate.
9.2 Legal Protection
Data subjects have the right to enforce their data protection rights through legal action or to file a complaint with a data protection supervisory authority.
The supervisory authority for data protection for private data controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), data protection supervisory authorities have a federal structure, particularly in Germany.
10. Use of the Website
10.1 Cookies
We may use cookies. Cookies—including our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.
Cookies can be stored temporarily in the browser as “session cookies” or for a specific period of time as so-called persistent cookies. “Session cookies” are automatically deleted when the browser is closed. Persistent cookies have a specific storage duration. Cookies enable us, in particular, to recognize a browser on the next visit to our website and thereby, for example, measure the reach of our website. However, persistent cookies can also be used for online marketing, for example.
Cookies can be disabled, restricted, or deleted at any time, either in full or in part, through your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request—at least to the extent required by applicable law—your express consent to the use of cookies.
For cookies used to measure performance and reach or for advertising purposes, many services offer a general opt-out option through 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).
10.2 Logging
For every visit to our website and other digital platforms, we may log at least the following information, provided that this information is automatically collected or transmitted to our digital infrastructure during such visits: Date and time, including time zone, IP address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, individual subpages of our website accessed, including the amount of data transferred, and the last webpage accessed in the same browser window (referrer).
We record such information, which may also constitute personal data, in log files. This information is necessary to ensure that our digital presence is available on a permanent, user-friendly, and reliable basis. This information is also necessary to ensure data security—including through third parties or with the assistance of third parties.
10.3 Pixel Count
We may incorporate web beacons into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are typically small, invisible images or JavaScript scripts that are automatically loaded when you access our digital presence. Tracking pixels can capture at least the same information as is recorded in log files.
11. Social Media
We maintain a presence on social media and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with these platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC), Terms of Use, privacy policies, and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information, in particular, regarding the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
12. Third-Party Services
We use services provided by specialized third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed features and content into our website. When such embedding occurs, the services used collect users’ IP addresses, at least temporarily, for technical reasons.
For necessary security, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data, which is necessary to provide the respective service.
In particular, we use:
- Google Services: Providers: Google LLC (U.S.) / Google Ireland Limited (Ireland), in part for users in the European Economic Area (EEA) and Switzerland; General Information on Data Protection: “Data Protection Practices,” Privacy Policy, “How Google Uses Personal Data,” “Google is Committed to Complying with Applicable Data Protection Laws,” “Guide to Data Protection in Google Products,” “How we use data from websites or apps where our services are used,” Cookie Policy, “Ads you can control” (personalized ad settings).
- Microsoft Services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland, and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; General information on data protection: “Data Protection at Microsoft,” “Data Protection and Privacy,” Privacy Statement, “Data and Privacy Settings.”
12.1 Digital Infrastructure
We use services provided by specialized third parties to access the digital infrastructure required for our activities and operations. These include, for example, hosting and storage services from selected providers.
In particular, we use:
- comotive: Hosting, specifically WordPress hosting; Provider: comotive GmbH (Switzerland); Privacy information: Content Delivery Network (CDN) partially under the domain name sdd1.ch, Privacy Policy.
- Exoscale: Digital infrastructure; Provider: Akenes SA (Switzerland); Privacy information: Privacy Policy, “Exoscale Security Policy.”
- WordPress.com: Blog hosting and website builder; Providers: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe and elsewhere; privacy information: Privacy Policy, Cookie Policy.
12.2 Audio and Video Conferences
We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is also subject to the legal terms and conditions of the individual services, such as privacy policies and terms of use.
Depending on your situation, we recommend that you mute your microphone by default when participating in audio or video conferences, and either blur the background or use a virtual background.
12.3 Online Collaboration
We use third-party services to facilitate online collaboration. In addition to this Privacy Policy, any terms and conditions of the services used that are directly visible—such as terms of use or privacy policies—also apply.
In particular, we use:
- Microsoft Teams: A platform for productive collaboration, particularly through audio and video conferencing; Provider: Microsoft; Teams-specific information: “Security and Compliance in Microsoft Teams,” particularly “Data Protection.”
12.4 Maps
We use third-party services to embed maps on our website.
In particular, we use:
- Google Maps, including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: “How does Google use location information?”
12.5 Digital Content
We use services provided by specialized third parties to embed digital content on our website. Digital content includes, in particular, images, videos, music, and podcasts.
In particular, we use:
- Vimeo: Video platform; Provider: Vimeo Inc. (U.S.); Privacy information: Privacy Policy, “Private Video Hosting.”
- YouTube: Video platform; Provider: Google; YouTube-specific information: “Privacy and Security Center,” “My Data on YouTube.”
12.6 Fonts
We use third-party services to embed selected fonts, icons, logos, and symbols on our website.
In particular, we use:
- Adobe Fonts: Fonts; Providers: Adobe Inc. (U.S.) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Privacy information: “Adobe Privacy Center,” Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), “Questions about privacy?”, “Adobe Privacy Settings,” Cookie Policy.
- Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Your Privacy and Google Fonts,” “Data Protection and Data Collection” (Google Fonts).
13. Website Extensions
We use extensions on our website to provide additional functionality. We may use selected services from suitable providers or implement such extensions on our own digital infrastructure.
In particular, we use:
- Antispam Bee: Privacy-friendly yet efficient and reliable spam protection (distinguishes between desired content from humans and unwanted content from bots and spam); Developers: Pluginkollektiv (in Germany and the rest of Europe); Data protection information: Used on our own digital infrastructure and without cookies; Documentation (Pluginkollektiv); Documentation (GitHub).
14. Measuring Success and Reach
We strive to measure the success and reach of our activities and operations. In this context, we may also measure the impact of third-party content or test how different parts or versions of our digital presence are used (the “A/B testing” method). Based on the results of our success and reach measurements, we can, in particular, fix errors, enhance popular content, or make improvements.
In most cases, the IP addresses of individual users are collected for the purpose of measuring success and reach. In this case, IP addresses are always truncated (“IP masking”) to comply with the principle of data minimization through the corresponding pseudonymization.
Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the user’s location (at least approximately). In principle, any user profiles created are exclusively pseudonymized and are not used to identify individual users. Individual third-party services with which users are registered may, in some cases, associate the use of our online offering with the user account or user profile for the respective service.
In particular, we use:
- Google Marketing Platform: Performance and reach measurement, particularly using Google Analytics; Provider: Google; Google Marketing Platform-specific details: Tracking across different browsers and devices (cross-device tracking) using pseudonymized IP addresses, which are only transmitted in full to Google in the U.S. in exceptional cases; Google Analytics Privacy Policy; “Browser add-on to disable Google Analytics.”
15. Video Surveillance
We use video surveillance to prevent crimes, to preserve evidence in the event of crimes, to exercise and assert our own legal claims, to defend against third-party legal claims, and to enforce our right to manage our premises. In doing so—to the extent that the General Data Protection Regulation (GDPR) applies—overriding legitimate interests pursuant to Art. 6(1)(f) GDPR; in the case of special categories of personal data, with reference to Art. 9(2)(f) GDPR.
We retain recordings from our video surveillance system for as long as they are necessary for the preservation of evidence or for any other specified purpose.
We may back up footage from our video surveillance system and transmit it to the appropriate authorities, such as courts or law enforcement agencies, provided that such transmission is necessary for a specified purpose, in our other legitimate and overriding interests, or to comply with legal obligations.
16. Final Notes on the Privacy Policy
We may update this Privacy Policy at any time. We will notify you of any updates by posting the most current version of the Privacy Policy on our website.