Privacy Policy

Privacy Policy

Last change: October 2018

We are very pleased about your interest in our company. Data protection is of particular importance for the management of KünzlerBachmann Directmarketing AG. In principle, it is possible to use the Internet pages of the KünzlerBachmann Directmarketing AG without indicating any personal data. However, if a data subject wishes to take advantage of our company's special services via our website, this might require the processing of personal data.

The processing of personal data always takes place in accordance with the General Data Protection Regulations and according to country-specific data protection provisions applicable to KünzlerBachmann Directmarketing AG, including Swiss data protection law in particular. With this Privacy Policy, our company would like to inform the general public on the nature, extent and purpose of the personal data collected, used and processed by us. Furthermore, data subjects will be informed about the rights to which they are entitled by means of this Privacy Policy.

The controller within the meaning of the General Data Protection Regulations ('GDPR'), as well as other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection law, is:

KünzlerBachmann Directmarketing AG

Haldenstrasse 16A
CH-8306 Brüttisellen
Tel.: +41 (0) 44 872 34 80

Representative within the meaning of Art. 27 of the GDPR:

Mailprofiler Development s.r.o.
Reznicka 1332/7
Czech Republic
Tel.: +6420482427831

1. Collection, processing and use of personal data

1.1 When visiting our website

When visiting the website, the server temporarily stores all access in a log file. Until automatic deletion, the following information will be gathered automatically, including:  the IP address of the requesting computer, the date and time of access, the name and URL of the retrieved file, the website from which the access was made, the operating system of the computer employed by the user and the browser employed by the user as well as the country from which the user has gained access.

The collection and processing of this data is generally carried out on an anonymous basis. This is conducted without personal references for the purposes of facilitating the use of the website (establishing a connection), ensuring sustained system security and stability, and optimising the Internet offer as well as for internal statistical purposes. The above-mentioned information is not linked to or stored with personal data.

Only in the case of an attack on the network infrastructure of KünzlerBachmann Directmarketing AG—or in the event of other suspected unauthorised or abusive website use—will the IP address be assessed for clarification and defence and, if necessary, applied against the relevant users in the context of criminal proceedings for identification purposes, and for action in civil and criminal law.

Our legitimate interest within the meaning of Art. 6 para. 1 lit. f of the GDPR is present in the aforementioned purposes.

1.2 When using the contact form

You will find a button on certain pages of the website which will take you to our contact form. The following data will be requested on this occasion for the input screen:

  • Title
  • First name and surname*
  • Company name*
  • Street/no
  • Post code
  • Telephone*
  • Email address*
  • Query

The information designated with a * must be indicated.

We use this information to answer any queries you have made, to provide the services you requested, or to contact you by phone where necessary. The phone number will not be used for marketing purposes under any circumstances. We have a legitimate interest within the meaning of Art. 6 para. 1 lit. f of the GDPR for processing your contact request. You can object to this data processing at any time (for contact details see below). Moreover, our legal basis exists in the event of an offer request under Art. 6 para. 1 lit. b of the GDPR.

1.3 Registration/login for services

Registration for the email marketing services offered via the website first occurs outside the website, whereby the initial contact can also be made via the website (contact form or contact email).

After making contact, an offer is issued outside the website, and then a user agreement is individually concluded between KünzlerBachmann Directmarketing AG and the customer.

With these logins, the customer is able to log onto the website and make use of the ordered services.

The customer decides which personal data he wants to transmit to KünzlerBachmann Directmarketing AG or, respectively, the KünzlerBachmann Directmarketing AG system in connection with the online services. KünzlerBachmann Directmarketing AG acts as a data processor in connection with the provision of the services. In this situation, the customer is responsible for the processing of personal data.

KünzlerBachmann Directmarketing AG has appointed Mailprofiler Development s.r.o., Reznicka 1332/7, Czech Republic, as a sub-processor for the provision of online services which are offered via the website. The personal data transmitted by the customer in connection with the services offered on the website are stored on the servers of Mailprofiler.

2. Marketing

2.1 Newsletter

You will find a link to sign up for our newsletter on various pages of the website. You can get there via the link to the newsletter input screen. The following data is requested there:

  • Title
  • First name and surname
  • Email address*

The information designated with a * must be indicated.

You can activate the registration for our newsletter after entering the above information. We use the double-opt-in mechanism here. After sending off the registration, you will receive an email from us containing a confirmation link. You must confirm this link in order to definitively sign up for the newsletter.

We will use your data for the newsletter delivery until you withdraw your consent. You can withdraw your consent at any time. The contact details can be found below in section 10. You will also find a link to unsubscribe in all newsletter emails.

We use our own email marketing solution XCampaign for sending our newsletters. The data is encrypted with the service XCrypto in Switzerland and hosted anonymously on servers of Super Network s.r.o. in Prague, Czech Republic.

Our newsletter may contain a so-called web beacon (tracking pixel) or similar technical means. As regards web beacons, these are 1x1 pixel size, invisible graphics that are related to the user ID of the respective newsletter subscriber.

For each newsletter sent, there is information on the address file used, the subject and the number of newsletters sent. Furthermore, it is possible to see which addresses have not yet received the newsletter, to which address it has been sent and for which addresses the delivery has failed. It is also possible to view which addresses have opened the newsletter. Finally, information also exists on which addresses have unsubscribed. We use this data for statistical purposes and to optimise the newsletter in terms of content and structure. This allows us to better adjust the information and offers in our newsletter to the individual interests of the recipient. The tracking pixel is deleted when you delete the newsletter.

In order to disallow the use of the web beacon in our newsletter, please set your email program such that no HTML is displayed in messages (if this is not already the case by default).

With the registration, you grant us your consent to process the provided data for the regular delivery of the newsletter to the address indicated by you as well as for the statistical evaluation of the user behaviour and for the optimisation of the newsletter. This consent constitutes our lawful basis for processing the data for the newsletter within the meaning of Art. 6 para. 1 lit. a of the GDPR

2.2 Re-targeting

KünzlerBachmann Directmarketing AG uses so-called re-targeting technologies on the website. In this respect, the user behaviour on the website is analysed so as to be able to offer the user individual advertising tailored to the user, subsequently even on partner websites. In doing so, user behaviour is recorded as a pseudonym.

Most re-targeting technologies use cookies (see section 5 below concerning this).

Doubleclick by Google—a service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ('Google')—is used on this website. Google uses the so-called DoubleClick cookie for this purpose, which allows for the recognition of the browser used by the user when visiting other websites. The information generated by the cookie on visiting these websites (including the IP address) is transmitted to and stored by a Google server in the United States.

Google will use this information in order to evaluate the use of the website in terms of the advertisements to be placed, to compile reports about website activities and advertisements for the website operator, and to provide other services related to the use of the Website and the Internet. Google may also transmit this information to third parties if necessary, provided that such is required by law or if third parties process this data on behalf of Google. However, in no case will Google link the IP address of the users with other data from Google.

Users can prevent re-targeting at any time by rejecting or disabling the cookies in question in the menu bar of the web browser (see section 5 'Cookies').

Our legitimate interest in a personalised advertising approach is the lawful basis for this data processing within the meaning of Art. 6 para. 1 lit. f of the GDPR. You can object to this data processing at any time. The procedure for this has been shown in the preceding paragraph.

3. Disclosure of data to third parties

We share personal user data only if the user has expressly consented thereto, if there is a legal obligation to do so, or if this is necessary for the enforcement of rights and claims by us.

In addition, we share personal information of users with third parties insofar as this is necessary within the context of website use as well as for answering questions, processing requests or for the provision of any services requested by the user. The use of the data transmitted for this purpose by the third party is strictly limited to the stated purposes.

Various third-party service providers are explicitly mentioned in this Privacy Policy (e.g. section 2.2 'Re-targeting' and section 6 'Tracking tools'). Another service provider to whom the personal data is transmitted or, respectively, who has or may have access to your personal information, is the company that hosts the website. Currently this is SuperNetwork s.r.o. in Prague. The web pages are hosted on servers in Prague, Czech Republic.

4. Contractual object Transfer of personal data abroad

We are also entitled to forward personal data of the users to third party companies and service providers abroad if this is necessary within the scope of the purposes previously mentioned in section 3. In this respect, the legal regulations are of course complied with for the transfer of personal data to third parties.

These third parties are obliged to adhere to data protection to the same extent as us. If the level of data protection does in a country does not comply with Swiss or EU data protection law, we will contractually ensure that the protection of personal data corresponds to that in Switzerland or, respectively, to that in the European Economic Area (EEA) at all times.

Various third-party service providers and their registered office addresses are indicated in the previous section ('Disclosure of data to third parties'). Some of the third party service providers listed in this Privacy Policy are based in the USA (see 'Tracking Tools', 'Re-targeting'). More information on data transfers to the USA can be found under 'Tracking tools'.

5. Cookies

We use cookies on the website

Cookies help in many ways to make your visit to our website easier, more enjoyable and more meaningful. Cookies are information files that your web browser automatically saves onto the hard drive of your computer when you visit our website. Cookies neither damage the hard disk of your computer, nor is any personal data transmitted to us via these cookies.

Most internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or such that a note always appears when you receive a new cookie. Disabling cookies could mean that you may not be able to use all the functions of our portal.

6. Tracking tools

6.1 Google Analytics

We use the web analytics service Google Analytics from Google for the purposes of needs-based design and continuous optimisation of our pages. Pseudonymised usage profiles are created and small text files—which are stored on your computer ('cookies')—are used in this context. The information generated by the cookie about your use of our websites such as

  • browser type/version
  • operating system used
  • referrer URL (the page visited previously)
  • host name of the accessing computer (IP address)
  • time of the server request
  • device

are transmitted to Google servers in the USA and stored there. In the process, the IP address is truncated through the activation of the IP anonymisation ('anonymizeIP') on our web pages prior to transmission within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area or, respectively, Switzerland. The anonymised IP address transmitted as part of Google Analytics from your browser will not be merged with other data from Google. Only in exceptional cases will the full IP address be sent to a Google server in the USA and truncated there. In these cases, we ensure through contractual guarantees that Google complies with a sufficient level of data protection.

The information is used to evaluate the usage of our websites, to compile reports on website activities and to provide additional services associated with website and Internet usage for the purposes of market research and needs-based design of these websites. This information may also be transferred to third parties if this is required by law or if third parties process this data on [our] behalf. According to Google, the IP address will not be linked to other data concerning the user under any circumstances. We use the 'Audiences' functionality in connection with Google Analytics. As a result, in the reports, our website users can be compiled by website usage and the created usage profiles for certain audience groups with comparable profiles.

Users can prevent the entry of data generated by the cookie and related to the website usage by the user in question (including the IP address) to Google, as well as the processing of this data by Google, through the users downloading and installing the browser plugin available on Google.

Our legitimate interest in the optimisation of our website and in the improvement of our services within the meaning of Art. 6 para. 1 lit. f of the GDPR is the legal basis for this data processing. You can object to this data processing at any time. The procedure for this has been shown in the preceding paragraph.

For the sake of completeness, we note that US authorities can carry out monitoring measures under US legislation, within whose framework the general storage of all data forwarded from the European Union to the United States is possible. This is done without distinction, restriction or exception—based on the pursued aim and without objective criteria which would make it possible to restrict the access of US authorities to personal data and its subsequent use—for certain, strictly limited purposes, which would justify access to this data.

Users living in one of the EU Member States should be informed that, from the point of view of the European Union (including on the basis of the topics mentioned in this section), the USA does not have sufficient levels of data protection. Inasmuch as we have explained in this Privacy Policy that data recipients (such as Google) are based in the USA, we will ensure either through contractual arrangements with these companies, or by ensuring the certification of these companies under the EU-US Privacy Shield, that your data is protected by our partners at an appropriate level.

6.2 Google Tag Manager

This website uses Google Tag Manager. The Tag Manager itself does not collect personal data. The tool will activate other tags, which in turn may potentially collect data. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, this will persist for all tracking tags which are implemented with Google Tag Manager. You will find the data protection notice from Google on this tool here:

7. Right to information, rectification, erasure and restriction of processing; right to data portability; right to complain to a supervisory authority

You have the right to request information free of charge about the personal data that we store about you. In addition, you have the right to rectify inaccurate data and the right to erase your personal data, insofar as this is not contrary to a statutory storage obligation, or where it is legally permissible to do so thus allowing us to process the data.

You also have the right to reclaim from us any data you have given to us (right to data portability). You have the right to receive the data in a common file format.

You can reach us for the aforementioned purposes via the email address We may require proof of identity for processing your requests at our sole discretion.

Furthermore, you have the right to complain to a data protection supervisory authority at any time.

8. Data security

We use appropriate technical and organisational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorised access by third parties. Our security measures are continuously improving in accordance with technological developments.

We also take intra-group data protection very seriously. We oblige our employees and the service provider companies commissioned by us to maintain confidentiality and to comply with data protection regulations.

9. Contact partner

If you have questions about data protection on our website as well as about our data processing, or if you wish to request information or to erase your data, please use the following contact address:

KünzlerBachmann Directmarketing AG
Haldenstrasse 16A
CH-8306 Brüttisellen