Privacy Policy

Privacy Policy

With this Privacy Policy we inform you which items of your personal data we collect in connection with our activities and operations including our website. In particular, we provide information on the reasons why as well as how and where we process personal data. We also provide information about the rights of individuals whose data we process.

Individual or additional activities and operations may be subject to further Privacy Policies as well as other legal documents such as General Terms and Conditions (GTC), Terms of Use or Conditions of Participation.

Our content is subject to Swiss data protection law and any applicable foreign data protection law, particularly that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures an adequate level of data protection.


  1. Contact Addresses

Responsibility for the processing of personal data:

Max Zeller Söhne AG
Seeblickstrasse 4

8590 Romanshorn

We will provide notification if, in specific cases, a different party is responsible for processing personal data.


1.1 Data Protection Officer

We have the following Data Protection Officer as a point of contact for data subjects and as a contact for supervisory authorities in the event of data protection-related enquiries:

Matthias Oswald
Seeblickstrasse 4
8590 Romanshorn


1.2 Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR. The data protection representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries related to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner UG
Am Kaiserkai 69

20457 Hamburg



  1. Terms and legal bases

2.1 Terms

Personal data includes any information that relates to an identified or identifiable person. A data subject is any person whose personal data is processed.

Processing comprises any handling of personal data, irrespective of the means and procedures applied, in particular any retention, disclosure, collection, erasure, storage, modification, destruction and utilisation of personal data.

The European Economic Area (EEA) consists of the member states of the European Union (EU) plus the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of data relating to individuals.

2.2 Legal Bases

We process personal data in line with Swiss data protection law, particularly including the Swiss Federal Act on Data Protection (FADP) and the Swiss Ordinance to the Federal Act on Data Protection (OFADP).

If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:

  • Art. GDPR Art. 6(1)(b) for the required processing of personal data for the performance of a contract with the data subject as well as in order to take action prior to entering into a contract.
  • Art. GDPR Art. 6(1)(f) for the required processing of personal data for the purpose of protecting our legitimate interests or those of a third party, except where such interests are overridden by the fundamental rights and freedoms as well as the interests of the data subject. Legitimate interests are, in particular, our interest in our ability to carry out our activities and operations sustainably, in a user‑friendly, secure and reliable manner and to communicate about them, as well as the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. GDPR Art. 6(1)(c) for the required processing of personal data for the performance of a legal obligation to which we are subject according to any applicable legislation of member states of the European Economic Area (EEA).
  • Art. GDPR Art. 6(1)(e) for the required processing of personal data for the performance of a task carried out in the public interest.
  • Art. GDPR Art. 6(1)(a) for the processing of personal data with the consent of the data subject.
  • Art. GDPR Art. 6(1)(d) for the required processing of personal data for the protection of the vital interests of the data subject or of another natural person.


  1. Type, Scope and Purpose

We process the personal data that is necessary for us to be in a position to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. This personal data may, in particular, fall under the categories of inventory and contact data, browser and device data, content data, metadata, usage data, location data, sales data, contract data and payment data.

We process personal data for the duration that is needed for the relevant purpose or purposes or that is legally required. Personal data which no longer needs to be processed is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. In particular, these third parties are specialist providers whose services we use. We also guarantee data protection with such third parties.

We only process personal data with the consent of the data subject unless the processing is permitted for other legal reasons. Processing without consent may be permissible, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, in order to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after giving prior information.

Within this framework, we process, in particular, any information that is sent voluntarily to us by data subjects themselves on making contact, for example by letter, e-mail, messaging, contact form, social media or telephone, or on registration for a user account. We may store this information in an address book, for example, or using comparable tools. If we receive data about other persons, the persons transmitting the data to us are obliged to guarantee data protection with regard to these persons and to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, acquire from publicly accessible sources, or collect as part of our activities, insofar as and to the extent that such processing is legally permissible.

  1. Applications

We process personal data about applicants to the extent that is necessary for the assessment of their suitability for employment or for the subsequent performance of an employment contract. The necessary personal data originates in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular in covering letters, CVs and other application documents as well as online profiles.

If and insofar as the General Data Protection Regulation (GDPR) is applicable, we process personal data about applicants in particular in accordance with Art. 9(2) b GDPR.


  1. Personal data abroad

We process personal data predominantly in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process the data there or have the data processed there.

We can transfer personal data to all countries and territories around the world and elsewhere in the uni verse provided that, in the opinion of the Federal Data Protection and Information Commissioner (FDPIC) or in accordance with decision of the Swiss Federal Council adequate data protection is assured, and also, if and insofar as the General Data Protection Regulation (GDPR) is applicable, in accordance with the Decision of the European Commission.

We may transfer personal data to countries whose law does not ensure adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, for example if the express consent of the data subjects is given or a direct connection with the conclusion or performance of a contract exists. We will be happy to provide data subjects with information about any guarantees or supply a copy of any guarantees upon request.


  1. Rights of Data Subjects

Data subjects about whom we process personal data have rights under Swiss data protection law. This includes the right to information and the right to rectification, erasure or blocking of the personal data processed.

Data subjects whose personal data we process may, if and to the extent that the General Data Protection Regulation (GDPR) applies, request confirmation free of charge as to whether we are processing personal data relating to them. In this case, data subjects can request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted ("right to be forgotten"), blocked or have additions made to their personal data.

Data subjects whose personal data we process, may at any time and with future effect revoke any consents given and object to the processing of their personal data if and to the extent that the GDPR applies.

Data subjects about whom we process personal data have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).


  1. Data Security

We take suitable technical and organisational measures to ensure data security appropriate to the relevant risk. However, we cannot guarantee absolute data security.

Our online content is accessed with transport encryption (SSL/TLS, in particular with the Hypertext Transfer Protocol Secure, "HTTPS" for short). Most browsers indicate transport encryption with a padlock symbol in the address line.

Our digital communications, like the vast majority of all digital communications, are subject to mass surveillance without cause or suspicion as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the processing of personal data in this way by intelligence agencies, police services and other security authorities.


  1. Use of the Website

8.1 Cookies

We may use cookies. Cookies, our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third party cookies), are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as "session cookies" or for a certain period of time as so-called "permanent cookies". "Session cookies" are automatically deleted when the browser is closed. Permanent cookies are stored for a specific period of time. In particular, they enable us to recognise your browser when you re-visit our website; this allows us to measure, for example, the reach of our website. However, permanent cookies may also be used for online marketing purposes, for instance.

Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, however, our website might no longer be available to its full extent. We actively request, at least if and to the extent necessary, explicit consent to the use of cookies.

For numerous services, it is possible to lodge a general objection to cookies used for measuring performance and reach or for advertising ("opt out") via 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).


8.2 Server Log Files

We may gather the following information for any visit made to our website provided that the information can be transmitted by your browser to our server infrastructure or detected by our web server: the date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, the individual pages of our website accessed including the amount of data transferred, the last web page opened in the same browser window (referrer).

We store this information, which may also constitute personal data, in server log files. We require this information in order to make our online content user-friendly, reliable and permanently accessible, and to ensure data security and therefore particularly the protection of personal data, including by third parties or with the help of third parties.

8.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also called web beacons. Tracking pixels, which may also originate from third parties whose services we use, are small, usually invisible graphics which are automatically loaded when you visit our website. Tracking pixels can collect the same information as server log files.


  1. Notifications and Messages

We send notifications and communications by email and through other communication channels such as instant messaging or SMS.

9.1 Performance and Reach Measurement

Notifications and messages may contain web links or tracking pixels which gather data on whether an individual message was opened and which web links in it were clicked on. These web links and tracking pixels can also collect data on how notifications and messages are used by individuals. We need this statistical gathering of usage data in order to measure performance and reach, to make notifications and messages effective and user‑friendly based on the needs and reading habits of the recipients, and to send them securely and reliably over the long term.

9.2 Consent and Objection

In principle, you must explicitly consent to the use of your e-mail address and your other contact addresses, unless use of these is permissible for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure where possible; this means that you receive an e-mail with a web link which you must click as confirmation so that no misuse by unauthorised third parties can occur. We can log these consents including the internet protocol (IP) address, date and time for evidential and security reasons.

In principle, you can object to the receipt of notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is subject to any necessary notifications and communications in connection with our activities and operations.


9.3 Service Providers for Notifications and Messages

We send notifications and messages with the help of specialised service providers.

We use in particular:


  1. Social Media

We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

In each case the General Terms and Conditions, Terms of Use, Privacy Policies and other provisions of the individual operators of these online platforms apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the relevant platform, which include, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including what are called "Page Insights", insofar as and to the extent that the GDPR is applicable. Meta Platforms Ireland Limited is part of the Meta Group of companies (located in the USA and elsewhere). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook effective and user-friendly.

Further information on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook as well as Facebook's Data Protection Officer can be found in Facebook's Data Policy. We have concluded an agreement known as the "Controller Addendum" with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. The corresponding information on so-called Page Insights can be found on the page "Information on Page Insights including "Information on Page Insights Data".


  1. Third party services

We use the services of specialised third parties in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. With such services we are able, among other things, to embed functions and content in our website. In the case of embedding of this nature, the services used record the internet protocol (IP) addresses of the users at least temporarily for technically compelling reasons.

Third parties whose services we use may process data related to our activities and operations in an aggregated, anonymised or pseudonymised manner for necessary security, statistical and technical purposes. This data is, for example, performance or usage data to enable the relevant service to be offered.

We use in particular:


11.1 Digital Infrastructure

We use the services of specialised third parties to provide us with the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

We use in particular:


11.2 Audio and Video Conferences

We use specialised audio and video conferencing services to communicate online. We can use these services to hold virtual meetings, for example, or to conduct online classes and webinars. The legal texts of the individual services, such as Privacy Policies and Terms of Use, also apply as supplements for participation in audio and video conferences.

Depending on the living conditions, we recommend muting the microphone as the default condition when participating in audio or video conferences, as well as blurring the background or superimposing a virtual background.

We use in particular:


11.3 Social media functions and social media content

We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.

We use in particular:


11.4 Maps

We use third party services to embed maps in our website.

We use in particular:


11.5 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.

We use in particular:


11.6 Documents

We use third party services to embed documents in our website. Such documents can include, for example, forms, PDF files, presentations, tables and text documents. We can therefore enable not only viewing, but also editing or commenting on such documents.


11.7 Fonts

We use third-party services to embed selected fonts as well as icons, logos and symbols in our website.

We use in particular:


11.8 Advertising

We take advantage of the ability of displaying targeted advertisements for our activities and operations on third party sites such as social media platforms and search engines.

With advertising of this nature we particularly want to reach people who are already interested in our activities and operations or who could be interested in them (remarketing and targeting). For this purpose, we may transmit corresponding information, which may include personal information, to third parties that offer such advertising. We may also identify whether our advertising is successful, i.e. whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to match the use of our online services with your profile there.

We use in particular:


  1. Add-ons for the Website

We use add-ons for our website so we can use additional functions.

In particular, we use:

  • Google reCAPTCHA: protection against spam (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); provider: Google; Google reCAPTCHA-specific information: "What is reCAPTCHA?".


  1. Performance and Reach Measurement

We use services and programmes to analyse how our website is used. As part of this, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our website or parts of our website are used ("A/B test" method). Based on the results of the performance and reach measurement, we can in particular correct errors, enhance popular content or upgrade our website.

The use of services and programmes for performance and reach measurement requires the Internet Protocol (IP) addresses of individual users to be stored. IP addresses are always abbreviated ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymisation and thus to improve the data protection of users.

Services and programmes for performance and reach measurement may require the use of cookies and the creation of user profiles. User profiles include, for example, the pages visited or content viewed on our website, information on the size of the screen or browser window and at least the approximate location. User profiles are as a rule always created with a pseudonym and not the person’s name. We do not use user profiles to identify individual users. Individual third party services with which users are registered can match the use of our website and, at most to the user account or user profile, when the service in question is used.

We use in particular:


  1. Final Provisions

We have created this privacy statement with the data protection generator of Privacy Partner.

We may amend and make additions to this Privacy Policy at any time. We will provide notification of any such amendments or additions in a suitable form, in particular by publishing the latest Privacy Policy on our website.

Romanshorn, March 2023