privacy policy

Privacy policy

Valid from June 2023

englow gmbh (hereinafter referred to as "englow gmbh", "we" or "us") undertakes to process all Personal Data (hereinafter referred to as "Personal Data") collected via the Portal in accordance with applicable data protection laws and to take appropriate security measures to protect such Personal Data from unauthorized access. This Privacy Policy informs you in particular which Personal Data is collected and processed in connection with the use of the Portal, for which purposes it is used, to whom it may be disclosed and which rights you have regarding englow gmbh's use of your Personal Data. Personal Data means all data relating to an identified or identifiable individual, such as a name, first name, address, email, date of birth or telephone.

By accessing the online Portal (hereinafter referred to as "Portal" or "Website") and using the services and products offered by us, you declare that you have carefully read this Privacy Policy and that you agree with the data processing described. You can send an e-mail to datenschutz@englow.com if you have any questions about this privacy policy. You may not access the Portal or use our services and products if you do not agree with this statement.

1. Responsible party

englow gmbh, Stradun 202CH-7550 Scuol, Switzerland,

e-mail: contact@englow.com, is responsible for data protection.

englow gmbh is responsible for the processing and use of your Personal Data in accordance with this Privacy Policy, as englow gmbh determines the purposes and means of processing your Personal Data. Please contact us at any time by sending an e-mail to contact@englow.com if you have any questions or concerns regarding this privacy policy or the processing of your Personal Data.

2. Data processing

The Swiss Data Protection Act applies to all Personal Data collected via the Website. The collection and processing of Personal Data by us is done carefully and for the purposes described in this privacy policy. Subject to applicable law, we may use your Personal Data differently than described in this Privacy Policy. If we do so, we will provide you with a specific privacy statement or notice when we collect your Personal Data and obtain your consent if necessary. At all times, reasonable efforts will be made to collect data in anonymous or alias form so that you cannot be identified.

Payment Methods

3. Collection of Personal Data and purposes of data processing

3.1 Personal Data automatically transmitted via the use of the Portal

When you visit our Website, englow gmbh collects and stores in "Server Log Files" data that your browser automatically transmits to us. This Personal Data is collected automatically and includes, for example, the following information:

IP address used (if necessary in anonymized, shortened form), date and time stamp, web browser and operating system used, language and version of the browser software, Websites accessed, amount of Personal Data transferred in each case.

We do not combine this Personal Data with other Personal Data, and we store it separately from any other Personal Data that you may provide to us. This data will be deleted by us after [three to six months] at the latest.

englow gmbh uses the Personal Data collected automatically to fulfill the following purposes:

enable the display, operation and functionality of the Portal
ensure the stability and security of the system
improve and protect our services
statistical purposes in the event of attacks on the network infrastructure on which the Website is provided

3.2 Personal Data that the user transmits to us

Personal Data is collected and processed by englow gmbh when the user provides it to us through an online form directly on the Website, through our e-mail, through other programs linked to the Website, by telephone or in any other way. This data comprises e.g. the following Personal Data:

surnames, first names, postal addresses, e-mail address, telephone number, date of birth, gender.

Providing this Personal Data is strictly voluntary. Nevertheless, we are unable to provide you with the services you request without this Personal Data.

englow gmbh will use the Personal Data that the user has made available to us in order to fulfill the following purposes:

provide, maintain, protect and optimize the services and data offered
communicate with you and provide you with the best possible and personalized data you need from us (e.g., about our products and services)
to offer you new services and data and, based on your profile, to suggest services and data tailored to you that may be of interest to you
comply with legal or other regulatory requirements and internal policies
for the establishment, exercise, and/or defense of any actual or potential legal claims, legal proceedings, investigations, or similar matters
for any other legitimate purpose, provided that such processing is implicit in the circumstances or has been stated at the time of collection

3.3 Legal basis of data processing

The processing of this Personal Data is based on the following legal bases:

your consent, only if it can be revoked at any time (e.g. when you sign up for our newsletter and other marketing communications).
for the performance of a contract with you or for the intention to enter into a contract with you (e.g., when purchasing a product).
to comply with a legal obligation (e.g. for tax reasons or for the purpose of judicial investigations or proceedings) or
to protect our legitimate interests, such as protecting and securing our services, systems and assets, complying with legal, regulatory and contractual obligations, establishing, exercising or defending legal claims, maintaining and organizing business operations, improving and developing our services, and selling and marketing our services.

You may withdraw your consent or object to the processing at any time by contacting us directly at contact@englow.com if the processing is based on your consent or our legitimate interests. You should be aware that revoking your consent will not affect the legitimacy of any processing that took place before your consent was revoked.

4. Recipients of Personal Data

englow gmbh will take the necessary steps to ensure that, in order to fulfill the purposes for which your Personal Data has been collected, only our authorized personnel and our agents who have the necessary knowledge have access to your Personal Data.

To the extent necessary for the intended data processing, we may disclose your Personal Data to the following possible categories of recipients in accordance with the purposes and legal bases of processing described above:

experts and other service providers of ENGLOW GMBH within the scope of an inquiry
service providers who process Personal Data on behalf of and at the instruction of ENGLOW GMBH (so-called order processors, such as in the areas of IT, hosting and support).
service providers other business partners and auxiliary persons (e.g. lawyers)
authorities, official agencies, courts or other state institutions
social media
other parties in potential or actual legal proceedings

Partners and contract processors are selected carefully and only when we are satisfied that they have appropriate technical and organizational measures in place to comply with legal requirements. Our order processors may only process Personal Data in accordance with our instructions on record. Unless otherwise required by law, they are all subject to confidentiality obligations and may only use your Personal Data to the extent necessary to fulfill the purpose for which your Personal Data was collected.

5. Transfer of Personal Data outside the EU/EEA

Personal Data collected through our Website is stored in [Switzerland]. We may also transmit, store and process your Personal Data worldwide, including where our third parties or partners reside. As a result, your Personal Data may be transferred to countries outside the European Economic Area (EEA) if this is necessary for the processing of your data as described in this Privacy Policy in accordance with applicable law.

If data is transferred to countries which do not provide an adequate level of protection, we will ensure an adequate level of protection by implementing appropriate security measures, such as contractual safeguards (for example, based on EU standard contractual clauses), based on binding company regulations, transferring data pursuant to your explicit consent, for the purpose of entering into or performing a contract with you, or in connection with the establishment, exercise or enforcement of legal claims. For more data about our reasonable security measures, please contact us by email at contact@englow.ccom

6. Duration of Personal Data retention

Unless longer retention is necessary to comply with legal obligations (e.g., retention and documentation obligations), contractual or pre-contractual obligations, or to protect our legitimate business interests (e.g., to assert, exercise or defend against legal claims), Personal Data will be deleted as soon as it is no longer needed to fulfill the purpose for which it was collected.

Based on this, we generally process Personal Data according to the following rules and obligations:

for the purpose of displaying, operating and ensuring the functionality of the Portal, the Personal Data automatically transmitted by you through the use of our Portal (see point 3.1.) will be deleted within three to six months.
Personal Data that you transmit to us in connection with the use of our services and products offered on our Portal or that you otherwise transmit to us via the e-mail contact address (see point 3.2.) are generally stored by us until you request their deletion, revoke your consent to their storage or the purpose for storing the data no longer exists (e.g. after processing your inquiry).
for contract-related Personal Data (including business records and communications), we will retain Personal Data for as long as the contractual relationship exists and for a further ten years after the termination of the contractual relationship, unless (i) a shorter or longer period of retention is required by law, (ii) retention is required for evidentiary or other legitimate reasons under applicable law, or (iii) deletion is required sooner (e.g., because the data is no longer needed or we are required to delete the relevant information).

7. Cookies

a) Categories of cookies that we use

The cookies we use can be divided into the following categories: functional cookies, performance cookies, and advertising cookies, depending on their function and purpose.

Functional cookies: These cookies are used for a variety of purposes in connection with the presentation, functionality and performance of a Web site, and in particular to enhance the visitor's experience and enjoyment of the Web site. They allow a Website to provide visitors with enhanced, more personalized functionality by remembering data that has already been provided (such as user name, location, or language selection). For example, functional cookies are used to remember things like your login details. These do not allow us to track how you navigate to other Websites.
Performance cookies: We use these cookies to help us understand your use of our site, such as how you arrived at our site, which pages you access most frequently, and any errors you may encounter while visiting our site. We may use these cookies to gather statistical and analytical information, including the number of people who visit our site. These cookies are used to monitor the level of activity on the Website and to improve the performance of the Website.
Advertiser cookie enables us or a third-party vendor to serve ads on our Website or on third party Websites with products that are of interest to you, so that ads you see may be more relevant to your preferences or interests (sometimes referred to as a "targeting cookie"). They may also be used for the evaluation of the effectiveness of advertising and sales promotions.

We or a third party on our behalf may place these cookies. Please visit http://www.allaboutcookies.org/ for more data about cookies and how to use them.

The legal basis for data processing is your consent (Art. 6 para. 1 lit. a GDPR) or our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR). You can prevent cookies from being stored on your computer by adjusting your browser settings. However, if you choose to disable cookies altogether, you may not be able to use all of the features of our Website. By continuing to use our Website and/or accepting this Privacy Policy, you consent to the placement of cookies by us and thus to the collection, storage, and use of personal usage data by us, even after the browser session has been terminated. You can revoke this consent at any time by activating the setting in your browser to refuse cookies from third parties.

b) Google Analytics

ENGLOW GMBH uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses "cookies" which are text files placed on your computer to help the Website analyze how users use the site.

Based on our legitimate interests, we use Google Analytics to analyze and regularly improve our Website, as well as to regularly improve our offerings and make them more interesting for you based on the statistics obtained. In addition, your consent to the tracking of your surfing behavior on our Websites and their analytical evaluation is the basis for the use of Google Analytics.

The data generated by the cookie about your use of the Website is transmitted to and stored by Google on servers in the United States of America. These cookies may include the following data IP address, number, date and time of your visit, length of your visit, the referrer URL, pages you visit on our site, browser type and version, and operating system. Since we have a legitimate interest in analyzing user behavior in order to optimize our Website and advertising, Google will use this data on our behalf. Google will use this data for purposes such as evaluating your use, compiling reports on Website activity for Website operators and providing other services relating Website activity and internet usage. Google may also use this data to create anonymous user profiles for the Website.

We have activated the function (IP anonymization activated (so-called IP masking). This means that within the member states of the European Union, in other signatory states to the Agreement on the European Economic Area and in Switzerland your IP address will be shortened by Google before it is transferred to the USA. The full IP address is transferred to a Google server in the U.S. and shortened there only in exceptional cases.

By adjusting your browser settings, you can prevent the installation of cookies. Please note, though, that if you do so, you may not be able to fully use all of the functions on this Website. You can also prevent the collection of Personal Data generated by the cookie and related to your use of the Website (including your IP address) to Google and the processing of this Personal Data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Alternatively, or within browsers on mobile devices, you can prevent the collection of your Personal Data by Google Analytics by clicking on the following link: Disable collection of Personal Data by Google Analytics for this Website. In this case, a special opt-out cookie will be placed on your device to prevent your Personal Data from being collected when you visit this Website in the future. If you wish to delete the cookies that are stored on your computer, you will need to click on this link again. For more data on how Google Analytics handles user Personal Data, please see Google's Personal Data protection statement: https://support.google.com/analytics/answer/6004245?hl=de.

In addition, Google may analyze the user's use of the Website and may combine the collected Personal Data with other data about the user that Google has independently collected from other Websites visited by the user and may use this data for its own purposes (e.g., to monitor advertising) under its own responsibility in accordance with its own privacy policy. For more data on this and how Google processes Personal Data, please refer to the relevant Google privacy statements: https://policies.google.com/?hl=de; https://policies.google.com/technologies/partner-sites.

c) Google Maps

This Website uses the Google Maps API, a mapping service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. This allows you to conveniently use the map function by displaying interactive maps directly on the Website.

Your consent to have a map created based on your voluntary information, and our legitimate interest in displaying our location and making it easy to find the location we provide on the Site, provide the legal basis for the processing.

Through the use of Google Maps, data about the use of our Website, including your IP address, may be transmitted to a Google server in the U.S. and stored there. Google may also transfer this data about you to third parties where required to do so by law, or where such third parties process the data on Google's behalf.

Under no circumstances will Google associate your IP address with any other data held by Google. However, it would be technically possible for Google to identify individual users on the basis of the data received. Google may use Personal Data and personality profiles about users of the Website for other uses that are beyond our control.

By disabling Javascript in your browser, you can disable Google Maps and prevent data from being sent to Google. Please note, however, that you will not be able to use the map display in this case.

For more data about Google's data collection and processing practices, including your rights and your choices about how Google uses and shares your Personal Data, please visit:
www.google.de/intl/de/policies/privacy.

d) List of cookies

Below is a complete list of the cookies we use or will use on this Website, including data about their use and expiration.

Provider
Cookie name
Category
Purpose and process
Name
e.g. performance cookie
Description

8. Social media plug-ins

We use the social plug-ins listed below on our Website to make our company better known. The underlying promotional purpose is to be regarded as a legitimate interest within the meaning of Art. 6 (1) f GDPR. It is the responsibility of the respective providers to ensure that they operate in compliance with data protection regulations. When you use these plug-ins, the data is processed with your consent.

The social networks will evaluate your use of the plugin if you use the services of these social networks independently or in connection with our Website. In this case, the data about the plug-in will be passed on to the social networking sites.

a) Facebook

Our Website uses plugins from the social network Facebook, which is provided by Facebook Inc. 1601 S. California Ave, Palo Alto, CA 94304, USA. The Facebook plug-ins are identified by a Facebook logo or the words "Like" or "Share. For an overview of the Facebook plug-ins and their appearance, please visit: https://developers.facebook.com/docs/plugins.

Your browser establishes a direct connection to the Facebook servers when you access a page on our Website that contains such a plug-in. Facebook sends the content of the plugin directly to your browser and integrates it into the page.

Through this integration, even if you do not have a Facebook profile or are not currently logged in to Facebook, Facebook receives the data that your browser has accessed the corresponding page on our Website. This data (including your IP address) will be sent by your browser directly to a server of Facebook in the United States of America and will be stored there.

Facebook may associate your visit to our Website with your Facebook profile if you are logged in to Facebook. This data is also sent directly to a Facebook server when you interact with the plugins, such as when you click the "Like" button. In addition, this data will be published on your Facebook profile and will be displayed to your Facebook friends.

Please refer to Facebook's privacy policy for more data on the purpose and scope of data collection, further processing and use of data by Facebook, as well as your rights and settings to protect your privacy: www.facebook.com/policy.php.

b) Instagram

Our Website uses the plug-in of the social network Instagram, which is offered by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA.

Only when the user activates the social media plug-ins by clicking on the selected plug-in is the data sent to the social media provider. Therefore, the user has control over the timing of activation. In such cases, Facebook may establish a direct connection with users while they are on the site, allowing Facebook to learn about their visit and analyze the corresponding information. The further processing of Personal Data is the responsibility of Facebook in accordance with data protection laws and the privacy policy published on their Website (https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Instagram-Hilfebereich&bc[1]=Richtlinien%20und%20Meldungen). For detailed data about the collection and transfer of Personal Data, your rights, and how to achieve satisfactory privacy settings, please read the privacy policies of your social networks carefully.

c) Pinterest

Our Website uses the plug-in of the social network Pinterest, which is operated by Pinterest Inc., 505 Brannan Street San Francisco, CA 94107, USA.

Only when the user activates the social media plugin by clicking on the selected plugin will the data be sent to Pinterest. Therefore, the user can choose when to activate it. In this case, Pinterest can learn about the user's visit and analyze the corresponding data by establishing a direct connection with the user during the user's visit to the Website. Pinterest is responsible for continuing to process Personal Data in accordance with data protection laws and the Privacy Policy posted on its Website (https://policy.pinterest.com/de/privacy-policy). For detailed data about the collection and transfer of Personal Data, your rights, and how to achieve satisfactory privacy settings, please read the privacy policies of your social networks carefully.

d) Twitter

We have integrated plugins from the social networking Website Twitter Inc., 1355 Market St., Suite 900, San Francisco, CA 94103, USA, into our Website. The Twitter logo and the addition "Twitter" identify the Twitter plug-ins ("Twitter" button). A direct connection between your browser and the Twitter server is established when you visit a page on our Website that contains such a plug-in. As a result, Twitter receives the data that you have visited our Website along with your IP address. You can link the content of our pages to your Twitter profile by clicking the Twitter button while logged into your Twitter account. In this way, Twitter will be able to associate your visit to our Website with your user account. Please note that we, as the Website provider, have no knowledge of the content of the transmitted data or its use by Twitter. More data can be found here: http://twitter.com/privacy.

e) Google+

Our Website uses plugins from the social network Google Plus. Google Plus is provided by Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Plug-ins can be identified by buttons with the "+1" sign on a white or colored background. For an overview of Google's plug-ins and how they look, please visit https://developers.google.com/+/plugins.

Your browser establishes a direct connection with Google's servers when you access a page on our Website that contains such a plugin. Google will send the content of the plug-in directly to your browser and integrate it into the page. This integration provides Google with the data that your browser has visited the page on our Website. This is the case even if you do not have a Google Plus profile or are not currently logged in to Google Plus. This data (including your IP address) will be transmitted by your browser directly to and stored by Google on servers in the United States. Google may associate your visit to our Website with your Google Plus profile if you are logged in to Google Plus.

This data is also sent directly to a Google server when you interact with the plugins, such as by clicking the "+1" button. The data will also be made public on Google Plus and will be displayed there to your contacts.

Please see the Google Privacy Policy for more data about the purpose and scope of data collection, Google's further processing and use of the data, your rights in this regard, and the settings you can make to protect your privacy.

f) LinkedIn

Plug-ins from the social network LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA, are installed on our Website. The LinkedIn plugin (the "LinkedIn Recommended" button) is identified by the LinkedIn logo. A direct connection is made between your browser and the LinkedIn server when you visit a page on our Website that contains such a plug-in. LinkedIn receives data that you have visited our site, including your IP address. By clicking the LinkedIn button while logged into your LinkedIn account, you can link content from our pages to your LinkedIn profile. In this way, LinkedIn will be able to associate your visit to our pages with your user account. Please note that we, as the Website provider, are not aware of the content of the transmitted data and LinkedIn's use of it. For more information, please visit www.linkedin.com/legal/privacy-policy

g) XING

Plug-ins of the social network XING, which is operated by Hamburger New Work SE, Hamburg, are installed on our Website. You can recognize the LinkedIn plug-in ("XING" button) by the XING logo. A direct connection is established between your browser and the XING server when you visit a page on our Website that contains such a plug-in. As a result, LinkedIn will receive the data that you have visited our Website along with your IP address. You can link the content of our pages to your XING profile by clicking the XING button while logged in to your XING account. This allows XING to associate your visit to our pages with your user account. Please note that we, as the Website provider, are not aware of the content of the transmitted data or its use by XING. Further data can be found at www.xing.com/app/share?op=data_protection.

5. Transfer of Personal Data outside the EU/EEA

Payment Methods

- Credit / Debit Cards
- PAYPAL

- Offline Payments

- Apple Pay

- Google Pay

Privacy policy

1. Responsible party

2. Data processing

3. Collection of Personal Data and purposes of data processing

4. Recipients of Personal Data

5. Transfer of Personal Data outside the EU/EEA

6. Duration of Personal Data retention

7. Cookies

8. Social media plug-ins

5. Transfer of Personal Data outside the EU/EEA

Payment Methods

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