隐私政策

<sup>1. What you  need to know before you read this Privacy Policy
We are committed to handling your personal data responsibly. Your privacy and security are important to us, which is why we process your data properly and in good faith,  in accordance with the Federal Act on Data Protection (“FDPA”), the Ordinance to the Federal Act on Data Protection (“OFDPA”), Telecommunications Act (“TCA”)  and, if applicable, other data protection provisions, in particular the General  Data Protection Regulation (“EU-GDPR”).  When accessing our site, contacting us, or purchasing one of our products, you agree to this Privacy Policy (“Policy”). In the following, we would like to inform you about how we handle your personal data.  Please read this Policy to understand which data we collect and for what purposes we use it.  
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For you to understand our data policy, it is important that you know the meaning of the  following terms: 
a.     Personal data (data): all information relating to an identified or identifiable person;
b.     data subjects: natural or legal persons  whose data is processed;
c.     processing: any operation with personal data,  irrespective of the means applied and the procedure, and in particular the  collection, storage, use, revision, disclosure, archiving, or destruction of  data;
d.     disclosure: making personal data accessible, for example, by permitting access, transmission, or publication;
e.     data file: any set of personal data that is  structured in such a way that the data is accessible by data subject;
f.      federal bodies: federal authorities and services  as well as persons who are entrusted with federal public tasks;
g.     controller of the data file: private persons or  federal bodies that decide on the purpose and content of a data file; 

2. Scope and  purpose of collection, processing, and use of personal data
a. when you visit www.globalswisslearning.com
When you access our website, our servers make a temporary record of each access, which is stored in a "logfile", a file that brings information about various occurrences and events in a system. The following data is temporarily collected  and stored without any action on your part:
- The IP address of  the accessing computer
- The time and date  of access
- The name and URL  of the pages accessed
- The site from  which you access it
- The operating  system of your computer and the browser used
- The country from  which access is being made and the language settings of your browser
- The name of your  Internet Service Provider 

The collection and processing of this data is generally anonymized without personal reference for the purpose of enabling the use of the website (connection establishment), ensuring long-term system security and stability, and optimizing the Internet offer as well as for internal statistical purposes.   

Only in the event of an attack on the network infrastructure of https://www.globalswisslearning.com or in case of a suspicion of another unauthorized or improper use of the website shall the IP address be evaluated for clarification and defense and, if necessary, used within the scope of criminal proceedings for identification and for civil and criminal proceedings against the users concerned. 

This data is collected and processed for the purpose of enabling the use of our website  (establishing a connection), ensuring the long-term security and stability of the system, and allowing the optimization of our offers and advertising, as well as for internal statistical purposes. This is our legitimate data processing interest in accordance with the European Union's General Data  Protection Regulation, Article 6, Paragraph 1, Subparagraph f. The IP address in particular, is used to determine the visitor's country of residence and to set the corresponding language of the website. The IP address is also analyzed in the event of attacks on the network infrastructure of  www.globalswisslearning.com as well as for statistical purposes. When you visit our site, we also use so-called pixels and cookies to display personalized advertising and to use web analytics services.  

b. when you contact us and when you enroll in one of our courses
When you contact us,  as well as when you subscribe to one of our courses, we may collect the  following data:
- first and last  name;
- last name;
- gender;
- address (street,  number, city, postal code, country);
- phone number;
- e-mail address;
- social media contact. 

We only use this data to answer your questions optimally and to keep a register of students enrolled in our courses. For the processing of your contact request, as well as your request to register for one of our courses, our legal basis lies within the meaning of Art. 13 para. 1 or 2 FDPA and Art. 6 para. 1 lit. b or f EU-GDPR. Insofar as we do not fulfill any (pre-) contractual obligations towards you, the authorization permits the processing of personal data within the scope of our legitimate interest. Our legitimate interest lies in the processing of your contact request. You can object to this data processing at any time. 

We may process and  store personal data related to prospects and clients for the purposes of:
• personalization of  content, business information or user experience
• account set up and  administration;
• delivering  marketing and events communication;
• carrying out polls  and surveys;
• internal research  and development purposes;
• providing goods  and services;
• legal obligations  (eg. prevention of fraud, anti-money laundry procedures, governmental and tax  obligations)
• meeting internal  audit and compliance requirements, 

c. when paying for your order
When you place an order on our website, we, Global Swiss Learning, process your payment information for the purpose of payment processing. Depending on the selected payment method, we forward your payment information to third parties. 

We do not collect and store the payment data by ourselves. It is collected directly by the service provider. In addition to the specified payment data, the payment service provider only has knowledge of the order number and the invoice amount. It cannot assign this information to other information. 

Your details are required to process your order or to carry out the payment process. The legal basis for the processing of your personal data lies in the implementation of a contract within the meaning of Art. 13 para. 2 lit. a FDPA and Art. 6 para.  1 lit. b EU-GDPR. 

d. when using  the contact form function
We offer a contact form on the website. The users can contact us using the form and ask questions about our company services, website functions, and products. We thereby collect the  following personal data and information (mandatory*): 
- Name
- E-mail address
- Phone
- Message 

You shall be responsible for the messages or the content that you transmit to us using the contact form. We recommend not transmitting any sensitive information using the form. Only such personal data is collected, which you transmit to us voluntarily. It is, therefore, in your control as to which information you send to us. In order to be able to answer your questions, we ask you to provide us with additional information, such as your e-mail address, your telephone number, etc. We only collect such personal information from you which is needed to answer your questions or to provide the services requested by you.  

Our legitimate interest within the meaning of Art. 13 para. 1 FDPA and Art. 6 para. 1 lit. f  EU-GDPR lies in the processing of your message inquiry. If the aim of the contact is the conclusion of a contract, Art. 13 para. 2 lit. a FDPA and Art.  6 para. 1 lit. b GDPR shall be the additional legal basis for the processing. 

Forwarding of  the data to third parties and transmission of personal data abroad
Sharing your data with third parties or cross-border is done only for the purposes described in this Policy. Global Swiss Learning has the right to share your data with third parties, including cross-border third parties, such as our subsidiaries, business partners, marketing partners, IT service providers, providers of tools and software solutions who also assist us in providing our services, and act on our behalf, authorities and other public bodies to the extent required by law, among others, in connection with the processing of your requests, the provision of services and marketing campaigns. 

Such third-party companies are obliged to protect your data in the same way that we do. If the level of data protection in a country does not correspond to the level of data protection in Switzerland or the European Union, we will ensure by contractual means that the protection of your personal data will always correspond to the protection in Switzerland or the European Union.  

Where we use subcontractors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal requirements.  We protect your data against unauthorized access by third parties.  

When accessing our site, contacting us, or purchasing one of our products, you consent to the sharing of your data with third parties. 

Individuals have the right to access their personal data, and any such requests made to us shall be dealt with in a timely manner.

We ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. All employees will observe all forms of guidance, codes of practice, and procedures about the collection and use of personal data.​ 

Archiving and  Removal
We ensure that  Personal data is stored securely using modern software that is kept up-to-date. Access to personal data is limited to personnel who need access, and appropriate security should be in place to avoid unauthorized sharing of information.
When Personal data is deleted, it is irrecoverable.
We will only retain personal data for as long as reasonably necessary to fulfill the purposes it was collected for, including for the purposes of satisfying any legal,  regulatory, tax, accounting, or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if reasonably believe there is a prospect of litigation.​ 

Your rights
You can at any time object to data processing, particularly to data processing in connection with direct advertisement (e.g. against advertising e-mails). You have the  following rights:
a) information: you have the right to demand an insight into your personal data saved with us at any time and free of charge if we are processing this data. You can check as to which of your personal data is being processed by us, and that we are using it according to the applicable data protection regulations.
b) deletion: you have the right to have your personal data deleted under certain circumstances. In the individual case, the right to deletion may be excluded.
c) correction: you have the right to have incorrect or incomplete personal data corrected and to be informed about the correction. In this case, we shall inform the recipients of the data concerned about the corrections made unless this is impossible or associated with disproportionate effort.
d) anonymization, blocking, or deletion of unnecessary, excessive data.
e) information about the public and private entities with which Global Swiss Learning has shared your data.
f) right to revocation:  you basically have the right to revoke an issued consent at any time. Processing activities in the past based on your consent shall, however, not become illegal through your revocation. 

General Provisions
This policy applies to all Personal data processed by Global Swiss Learning. The Compliance officer shall take responsibility for Global Swiss Learning's ongoing compliance with this policy. This policy will be reviewed at least annually.
To ensure its processing of data is lawful, fair, and transparent, we maintain a Register of all data to be reviewed at least annually. 

Contact us
If you have any  questions on data protection on our website, would like more information or  would like to arrange for your data to be deleted, please get in touch with  us by filling in the relevant online contact form or sending an e-mail to legal@globalswisslearning.com 

By post, please send  your requests to the address below:
Global Swiss Learning AG
Poststrasse 24 - 6300  Zug   

End of the Privacy Policy. 
Version CH (English) 16th October 2023</sup>