PRODUCT & EXPERIENCE DESIGN
INNOVATION FOR SUSTAINABILITY

Privacy Policy

Last update: September 2023

With this privacy policy, we inform you which personal data we process in connection with our activities and operations including our www.milani.ch-Website. In particular, we provide information on what personal data we process, for what purpose, how and where. We also provide information about the rights of persons whose data we process.

For individual or additional activities and activities, further data protection declarations as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

We are subject to Swiss data protection law and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact addresses

Responsibility for the processing of personal data:

Therese Naef
Milani Design & Consulting AG
Seestrasse 95
8800 Thalwil Zurich
Switzerland

welcome@milani.ch

We point out if there are other persons responsible for the processing of personal data in individual cases.

Data protection representation in the European Economic Area (EEA)


We have the following data protection representation according to Art. 27 DSGVO:

Therese Naef
Milani Design & Consulting AG
Seestrasse 95
CH - 8800 Thalwil

naef@milani.ch

The Data Protection Representation serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries related to the GDPR.

2. Terms and legal bases

2.1 Terms

Personal information is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, erasing, disclosing, arranging, organizing, storing, modifying, disseminating, interconnecting, destroying and using personal data.

The European Economic Area (EEA) comprises the Member States of the European Union (EU), plus the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal basis

We process personal data in accordance with Swiss data protection law such as, in particular, the Swiss Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

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

  • Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner, as well as to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
  • Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
  • Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task which is in the public interest.
  • Art. 6 para. 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
  • Art. 6 (1) (d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

3. Nature, scope and purpose

We process those personal data that are necessary to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. In particular, such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or peripheral data and usage data, location data, sales data, and contract and payment data.

We process personal data for as long as necessary for the purpose(s) for which it was collected or as required by law. Personal information that is no longer needed will be anonymized or deleted.

We may use third parties to process personal data. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for these third parties.

As a matter of principle, we only process personal data with the consent of the data subject. If and to the extent the processing is permitted for other legal reasons, we may waive the requirement to obtain consent. For example, we may process personal data without consent in order to fulfill a contract, to comply with legal obligations, or to protect overriding interests.

In particular, we process information that a data subject voluntarily provides to us when contacting us - for example, by mail, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book or similar tool. If we receive information about other individuals, the submitters are required to protect the privacy of those individuals and to ensure the accuracy of that personal information.

We also process personal data that we receive from third parties, that we obtain from publicly available sources, or that we collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.

4. Applications

We process personal data of applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The personal data required is derived in particular from the information requested, for example in connection with a job advertisement. We also process personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.

We process - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - personal data of applicants in particular in accordance with Art. 9 (2) lit. b GDPR.

We may allow candidates to store their details in our talent pool for consideration for future vacancies. We may also use such information to maintain contact and provide news. If we believe that a candidate is eligible for a vacancy based on the information provided, we may notify the candidate accordingly.

5. Personal data abroad

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

We may export Personal Data to all countries and territories on Earth and elsewhere in the universe, provided that the law there ensures adequate data protection in accordance with the decision of the Swiss Federal Council and, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, adequate data protection in accordance with the decision of the European Commission.

We may transfer personal data to countries whose laws do not provide an adequate level of data protection, provided that data protection is otherwise ensured, in particular on the basis of standard data protection clauses or other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, such as the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide information about any warranties or a copy of any warranties to data subjects upon request.

6 Rights of Data Subjects

6.1 Data Protection Rights

We provide data subjects with all rights under applicable data protection laws. In particular, data subjects have the following rights

  • Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what personal data is involved. Data subjects will also receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information about the purpose of the processing, the duration of storage, any transfer or export of data to other countries, and the origin of the personal data.
  • Correction and Restriction: Data subjects may have inaccurate personal data corrected, incomplete data completed, and the processing of their data restricted.
  • Deletion and Objection: Data subjects may have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
  • Data release and transfer: Data subjects may request the surrender of personal data or the transfer of their data to another controller.

We may suspend, restrict or deny the exercise of data subjects' rights to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to trade secrets or the protection of others. We may also, for example, refuse to delete personal data in whole or in part with reference to legal retention obligations.

We may, in exceptional circumstances, charge a fee for exercising rights. We will inform data subjects in advance of any such costs.

We are required to take reasonable steps to identify data subjects requesting information or asserting other rights. Data subjects are required to cooperate.

6.2 Right to complain

Data subjects have the right to assert their data protection claims through the courts or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Data subjects have the right, if and to the extent that the General Data Protection Regulation (GDPR) is applicable, to lodge a complaint with a competent European data protection supervisory authority.

7. Data security

We take appropriate technical and organizational measures to ensure data security commensurate with the risk. However, we cannot guarantee absolute data security.

Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communications, like basically all digital communications, are subject to mass surveillance without cause or suspicion and other monitoring by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct control over the processing of personal data by intelligence, police and other security agencies.

8. Use of the website

8.1 Cookies

We may use cookies. Cookies - both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data is not limited to traditional text cookies.

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, cookies enable us to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Persistent cookies can also be used for online marketing purposes.

Cookies can be completely or partially disabled and deleted at any time in the browser settings. Without cookies, our website may not be fully available. We actively seek your express consent to the use of cookies, at least when and to the extent necessary.

In the case of cookies used for performance and audience measurement or advertising, a general opt-out is available for many services through 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 record the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server 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, individual subpage of our website accessed including the amount of data transferred, website last accessed in the same browser window (referrer).

We store this information, which may include personal information, in server log files. The information is necessary to make our website permanently, user-friendly and reliable, as well as to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.

8.3 Tracking Pixel

We may use web beacons on our website. Tracking pixels are also known as web beacons. Tracking pixels - including from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Web beacons can collect the same information as server log files.

9. Notifications and communications

We send notifications and messages via email and other communication channels such as instant messaging or SMS.

9.1 Measuring performance and reach

Notifications and communications may contain web links or tracking pixels that record whether an individual notification has been opened and which web links have been clicked. Such web beacons and tracking pixels may also record the use of alerts and communications on an individual basis. We need this statistical tracking of usage for performance and reach measurement purposes, in order to send notifications and messages in an effective and user-friendly manner based on the needs and reading habits of the recipients, as well as in a persistent, secure and reliable manner.

9.2 Consent and Objection

As a matter of principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. Wherever possible, we will use the "double opt-in" process, i.e. you will receive an e-mail with a web link that you must click to confirm, to prevent misuse by unauthorized third parties. We may log such consents, including the Internet Protocol (IP) address, date and time, for evidence and security purposes.

In principle, you can object to receiving notifications and communications such as newsletters at any time. By opting out, you may also opt out of statistical usage tracking for performance and audience measurement purposes. We reserve the right to provide necessary notices and communications in connection with our activities and operations.

9.3 Service providers for notices and communications

We send notices and communications with the help of specialized service providers.

In particular, we use

10. Social media

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

The general terms and conditions and terms of use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. In particular, these provisions provide information on the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called Page Insights, we are - if and insofar as the General Data Protection Regulation (GDPR) is applicable - jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta group of companies (including in the USA). Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to help us manage our social media presence on Facebook in an effective and user-friendly manner.

For more information about the nature, scope and purpose of the data processing, information about the rights of data subjects, and contact information for Facebook and the Facebook Data Protection Officer, please see Facebook's Privacy Policy. We have entered into the so-called "Responsible Party Addendum" with Facebook and have agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For Page Insights, you can find the relevant information on the Page Insights Information page, including "Page Insights Data Information.

11. Third party services

We use the services of specialized third parties to conduct our activities and business in a sustainable, user-friendly, secure and reliable manner. Such services enable us, among other things, to embed features and content into our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of users, at least temporarily, for technically compelling reasons.

For necessary security-related, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized or pseudonymized form. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use

11.1 Digital Infrastructure

We use services provided by specialized third parties to enable us to use the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.

In particular, we use

11.2 Audio and Video Conferencing

We use specialized audio and video conferencing services to communicate online. For example, we may use them to hold virtual meetings or conduct online classes and webinars. Participation in audio and video conferences is also subject to the legal texts of the individual services, such as privacy statements and terms of use.

Depending on your circumstances, we recommend that you mute your microphone by default when participating in an audio or video conference, and that you blur the background or fade in a virtual background.

In particular, we use

11.3 Online Collaboration

We use third party services to enable online collaboration. In addition to this Privacy Policy, any directly visible terms and conditions of the services used, such as terms of use or privacy statements, also apply.

In particular, we use

11.4 Map Material

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

In particular, we use

11.5 Digital Audio and Video Content

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

In particular, we use

11.6 Advertising

We use the opportunity to display targeted advertising for our activities and operations on third parties such as social media platforms and search engines.

With such advertising, we would like to reach in particular persons who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may share relevant information, including personal information, with third parties that enable such advertising. We may also determine whether our advertising is successful, in particular whether it results in visits to our website (conversion tracking).

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

In particular, we use

  • Google Ads: Search engine advertising; Provider: Google; Google Ads specific information: Advertising based on search queries using, among other things, various domain names - including doubleclick.net, googleadservices.com and googlesyndication.com - for Google Ads, "Advertising" (Google), "Why am I seeing a particular ad?
  • Instagram Ads: Social Media Advertising Provider: Meta Platforms Ireland Limited (Ireland) and other Meta Companies (including in the U.S.); Privacy Information: Remarketing and Targeting, specifically with Facebook Pixel and Custom Audiences including Lookalike Audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), "Advertising Preferences" (Instagram) (user registration required), "Advertising Preferences" (Facebook) (user registration required).
  • LinkedIn Ads: Social Media Advertising; Provider: LinkedIn Corporation (USA) / LinkedIn Ireland Unlimited Company (Ireland); Privacy Information: Remarketing and targeting specifically with the LinkedIn Insight Tag, "Privacy," Privacy Policy, Cookie Policy, Opting Out of Personalized Advertising.

12. Measuring success and reach

We seek to determine how our online offerings are being used. We may do this by, for example, measuring the success and reach of our activities and operations and the effect of third party links to our website. We may also, for example, test and compare how different parts or versions of our online offering are used ("A/B testing"). Based on the results of the success and reach measurements, we may correct errors, strengthen popular content or make improvements to our online offerings.

In most cases, the Internet Protocol (IP) addresses of individual users are stored for performance and audience measurement purposes. In this case, the IP addresses are generally shortened ("IP masking") in order to follow the principle of data economy through appropriate pseudonymization.

Cookies may be used and user profiles may be created for performance and audience measurement purposes. Any user profiles that may be created include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window, and the - at least approximate - location. Any user profiles are always created in a pseudonymous form and are not used to identify individual users. Individual third-party services to which users are logged in may associate the use of our online services with the user account or user profile at the respective service.

In particular, we use

  • Google Analytics: Performance and reach measurement; Provider: Google; Google Analytics specific information: Measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA as an exception, "Privacy Policy", "Browser Add-on to disable Google Analytics".
  • Google Tag Manager: Integrates and manages other performance and audience measurement services and other services from Google and third parties; Vendor: Google; Google Tag Manager-specific information: "Data collected by Google Tag Manager"; for additional privacy information, see the privacy policies for each of these integrated and managed services.

13.Final provisions

We have created this Privacy Policy using the Privacy Policy Generator from Datenschutzpartner.

We may modify or amend this Privacy Policy at any time. We will provide notice of such changes and amendments in an appropriate manner, in particular by publishing the current Privacy Policy on our website.