Lüer Advisory Group GmbH Privacy Policy
Preisarchitekten
Im Russer 11E
CH - 8708 Männedorf
Authorised representative person:
Dr. Patricia Lüer
We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Lüer Advisory Group GmbH, which provides its services under the business name “Preisarchitekten” (hereinafter “Preisarchitekten” or “we”). In principle, use of the Preisarchitekten website is possible without providing any personal data. However, if a data subject wishes to make use of specific services of our company via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory legal basis for such processing, we generally obtain the data subject’s consent.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the Swiss Federal Act on Data Protection (FADP; German: DSG) as well as the General Data Protection Regulation (GDPR), where applicable, and in compliance with the country-specific data protection provisions applicable to Preisarchitekten.
By means of this Privacy Policy, our company would like to inform the public about the nature, scope and purpose of the personal data collected, used and processed by us. In addition, data subjects are informed about their rights by means of this Privacy Policy.
- Definitions
The Privacy Policy of Preisarchitekten is based on the terminology of the Swiss Federal Act on Data Protection (FADP; DSG). Our Privacy Policy is intended to be easy to read and understand for the public as well as for our customers and business partners. In this Privacy Policy we use, inter alia, the following terms:
- a) Personal data
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- b) Data subject
A data subject is any identified or identifiable natural person whose personal data are processed by the person or entity responsible for processing.
- c) Processing
Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their future processing.
- f) Pseudonymisation
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
- g) Person or entity responsible for processing
Person or entity responsible for processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- i) Recipient
Recipient means a natural or legal person, public authority, agency or other body to which personal data are disclosed, whether a third party or not.
- j) Third party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- k) Consent
Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.
- Name and address of the entity responsible for processing
The entity within the meaning of the applicable data protection laws and other provisions of a data protection nature is:
Lüer Advisory Group GmbH (operating under the business name “Preisarchitekten”)
Im Russer 11E
CH - 8708 Männedorf
Switzerland
CHE-322.101.332
Managing Director: Dr. Patricia Lüer
Tel.: +41 79 770 05 25
E-mail:
Website: www.preisarchitekten.ch
Third-party offers accessible via this website or applications are not subject to this Privacy Policy. Any responsibility or liability for compliance with data protection by third-party websites is excluded.
- Cookies
The Preisarchitekten website uses cookies. Cookies are text files that are placed and stored on a computer system via an internet browser.
Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A particular internet browser can be recognised and identified via the unique cookie ID.
By using cookies, Preisarchitekten can provide users of this website with more user-friendly services that would not be possible without setting cookies.
By means of a cookie, the information and offers on our website can be optimised in the interests of the user. Cookies enable us, as mentioned above, to recognise users of our website. The purpose of this recognition is to make it easier for users to use our website.
On our website, cookies are used exclusively to ensure technical functionality (e.g. for the correct transmission of the contact form). Inapplicable examples such as storing login credentials or shopping carts in online shops do not apply to our offering.
The data subject may prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and may thereby permanently object to the setting of cookies. Furthermore, cookies already set may be deleted at any time via an internet browser or other software programs. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable in all cases.
- Collection of general data and information
Each time the Preisarchitekten website is accessed by a data subject or an automated system, a series of general data and information is collected. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the subpages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.
When using this general data and information, Preisarchitekten does not draw any conclusions about the data subject. Rather, this information is required in order (1) to deliver the content of our website correctly, (2) to optimise the content of our website as well as advertising for it, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. Preisarchitekten therefore evaluates this anonymously collected data and information both statistically and with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data from the server log files is stored separately from all personal data provided by a data subject.
- Contact options via the website and requesting white papers
Due to statutory provisions, the Preisarchitekten website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the entity / person responsible for data processing by e-mail or via a contact form, the personal data transmitted by the data subject (i.e. first and last name, e-mail address, date and time of the enquiry, the user’s IP address in the event that the form is used, as well as other contact data provided by you) is automatically stored. Such personal data voluntarily transmitted by a data subject to the entity / person responsible for data processing is stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.
- Routine erasure and blocking of personal data
The entity / person responsible for data processing shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is provided for by the legislator.
If the purpose of storage no longer applies or a statutory retention period expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.
- Rights of the data subject
- a) Right of confirmation
Each data subject has the right to obtain from the entity / person responsible for data processing confirmation as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact an employee of the entity responsible for data processing.
- b) Right of access
Each data subject affected by the processing of personal data has the right to obtain from the entity / person responsible for data processing, at any time and free of charge, information about the personal data stored concerning them, and a copy of such information. Furthermore, the data subject has the right to obtain information about the following:
the purposes of the processing
the categories of personal data being processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request rectification or erasure of personal data concerning them, or restriction of processing by the controller, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority (in Switzerland: the Federal Data Protection and Information Commissioner, FDPIC; in Austria: the Austrian Data Protection Authority; in Germany: the respective competent data protection supervisory authority of the federal state in which you reside)
where the personal data are not collected from the data subject: all available information as to the source of the data
Furthermore, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, they may, at any time, contact an employee of the entity responsible for data processing.
- c) Right to rectification
Each data subject affected by the processing of personal data has the right to obtain from the entity / person responsible for data processing, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed – including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, they may, at any time, contact an employee of the entity responsible for data processing.
- d) Right to erasure (right to be forgotten)
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the entity / person responsible for data processing the erasure of personal data concerning them without undue delay, where one of the following grounds applies and to the extent that processing is not necessary:
The personal data were collected for, or otherwise processed for, purposes for which they are no longer necessary.
The data subject withdraws consent on which the processing was based, and there is no other legal basis for the processing.
The data subject objects to the processing and there are no overriding legitimate grounds for the processing.
The personal data have been processed unlawfully.
Erasure of the personal data is necessary for compliance with a legal obligation under applicable law to which the entity / person responsible for data processing is subject.
The personal data were collected in relation to the offer of information society services.
If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Preisarchitekten, they may, at any time, contact an employee of the entity responsible for data processing. An employee of Preisarchitekten will ensure that the erasure request is complied with without undue delay.
Where Preisarchitekten has made the personal data public and our company is obliged, as entity responsible for data processing, to erase the personal data, Preisarchitekten shall, taking account of available technology and the cost of implementation, take reasonable measures, including technical measures, to inform other entities responsible for processing the published personal data that the data subject has requested the erasure by such other entities responsible for data processing of any links to, or copies or replications of, those personal data, to the extent that processing is not required. The employee of Preisarchitekten will arrange what is necessary in the individual case.
- e) Right to restriction of processing
Each data subject affected by the processing of personal data has the right to obtain from the entity / person responsible for data processing restriction of processing where one of the following conditions applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the entity / person responsible for data processing to verify the accuracy of the personal data.
The processing is unlawful, the data subject opposes the erasure of the personal data and requests restriction of the use of the personal data instead.
The entity / person responsible for data processing no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defence of legal claims.
The data subject has objected to the processing and it has not yet been determined whether the legitimate grounds of the entity / person responsible for data processing override those of the data subject.
If one of the above conditions applies and a data subject wishes to request restriction of personal data stored by Preisarchitekten, they may, at any time, contact an employee of the entity responsible for data processing. The employee of Preisarchitekten will arrange the restriction of processing.
- f) Right to data portability
Each data subject affected by the processing of personal data has the right to receive the personal data concerning them, which were provided by the data subject to a entity / person responsible for data processing, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another entity / person responsible for data processing without hindrance from the entity / person responsible for data processing to which the personal data have been provided, where the processing is based on consent or on a contract and the processing is carried out by automated means.
Furthermore, in exercising their right to data portability, the data subject has the right to have the personal data transmitted directly from one entity / person responsible for data processing to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.
In order to exercise the right to data portability, the data subject may, at any time, contact an employee of Preisarchitekten.
- g) Right to object
Each data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR.
Preisarchitekten shall no longer process the personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. An objection to profiling measures is not relevant for us, as we do not use such procedures.
Where Preisarchitekten processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of the personal data for such marketing. If the data subject objects to Preisarchitekten to the processing for direct marketing purposes, Preisarchitekten will no longer process the personal data for such purposes.
To exercise the right to object, the data subject may contact any employee of Preisarchitekten directly.
- i) Right to withdraw data protection consent
Each data subject affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, they may, at any time, contact an employee of the entity responsible for data processing.
- Legal basis for processing
Where a legal basis is required for processing, the following legal bases may be considered: (a) on the basis of the initiation, handling and/or fulfilment of a contract with you or pre-contractual measures; (b) due to statutory provisions; (c) on the basis of our legitimate interests, in particular (i) in processing activities for pursuing the purposes described in this Privacy Policy and for implementing the corresponding measures, and (ii) in disclosing data to the web hosting provider and the associated objectives. Legitimate interests include our own interests and the interests of third parties in each case.
If you have granted us consent to process your personal data for certain purposes, we will inform you separately about the corresponding processing. Any consent given may be withdrawn at any time with effect for the future (which, however, does not affect processing already carried out). Upon receipt of the withdrawal, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so.
To the extent that the GDPR is applicable, personal data are processed on the following legal bases pursuant to Article 6(1) GDPR: with the consent of the data subject (lit. a); for the performance of a contract with the data subject and for the implementation of corresponding pre-contractual measures (lit. b); for compliance with a legal obligation (lit. c); to protect vital interests of the data subject or of another natural person (lit. d); and for the purposes of legitimate interests (e.g. our commercial interest in providing our website, information security, the enforcement of our own legal claims, compliance with applicable law) (lit. f).
- Processing of personal data by third parties
We use the services of a web hosting provider in order to provide our online offering securely and efficiently. In this context, personal data such as IP addresses, technical metadata and data entered via the contact form are processed on the servers of our hosting provider. We have concluded an agreement on commissioned processing (German: AVV) with our hosting provider, which ensures that the data of our website visitors are processed only in accordance with our instructions and in compliance with the highest security standards. The legal basis for this use is our legitimate interest in a professional presentation and the security of our website.
- Disclosure of data abroad
In the course of our business activities in the DACH region and the use of digital services, it may occur that personal data are transferred to countries outside Switzerland or the European Economic Area (EEA). As a rule, we transfer data only to countries for which an adequacy decision of the Swiss Federal Council and/or the EU Commission exists (e.g. EU Member States, the United Kingdom). For transfers to third countries without an adequate level of data protection (e.g. the USA), we ensure the protection of your data through appropriate safeguards, in particular by concluding the EU Commission’s Standard Contractual Clauses, which are recognised by the Federal Data Protection and Information Commissioner (FDPIC; German: EDÖB), and by implementing additional technical measures.
- Retention period for personal data
The criterion for the retention period of personal data is the respective statutory retention period. After expiry of the period, the corresponding data are routinely erased, provided that they are no longer required for contract performance or contract initiation and that no legal or contractual obligations preclude erasure.
The usual retention and/or storage period is generally (a) for master and contract data as well as communication data such as e-mails and written correspondence: 10 years from the last exchange with the data subject or from the last contractual activity, but at least from the end of the contract/project; (b) for prospect data (leads/white papers): erasure after no later than 3 years without further contact, provided that no consent for longer retention exists. The periods under (a) and (b) may be longer where this is required for evidentiary reasons, to comply with statutory or contractual requirements, or for technical reasons. Where no statutory or contractual retention obligations apply, we delete or anonymise your data after the above-mentioned retention or processing period as part of our usual processes.
- Provision of personal data
We hereby inform you that the provision of personal data is in part required by law (e.g. tax regulations) or may also result from contractual arrangements (e.g. information about the contracting party). In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will clarify, on a case-by-case basis, whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.
- Data security
As the controller, Preisarchitekten has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed via this website. This includes, in particular, the use of SSL/TLS encryption for the entire website. You can recognise an encrypted connection by the browser address line “https://” and the lock symbol in your browser. This encryption prevents data that you transmit to us (e.g. via the contact form or when requesting white papers) from being read by third parties.
Nevertheless, internet-based data transmissions may generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, any data subject is free to transmit personal data to us via alternative means, for example by telephone.