Privacy policy

The Goldbach Group is generally responsible for data processing under this Privacy Policy. Goldbach Group is a stock corporation under Swiss law.

If you wish to contact us in this regard, please use the following address:

Goldbach Group
Seestrasse 39
8700 Küsnacht ZH
Switzerland
[email protected]

If you contact us via the form on the website or by email, your provided data will be stored by us for six months for the purpose of processing the inquiry and in case of follow-up questions. We do not pass this data on without your consent.

For concerns from the EU area, you can contact our representative (Art. 27 GDPR):

ePrivacy GmbH
Burchardstrasse 14
20095 Hamburg
Germany
www.eprivacy.eu

If another subsidiary of the Goldbach Group refers to this Privacy Policy on its website or in its processing activities, that subsidiary is responsible for the corresponding data processing, and this processing is subject to this Privacy Policy.

We collect your personal data when you visit our websites or when we have contact with you. The situations in which we have contact with you are diverse. We also process your data when we have contact with your terminal device.

For example, we collect your personal data under the following circumstances:

• You use or communicate with us or third parties via our websites, apps for mobile devices, or offers on internet platforms, multimedia portals, or social networks.
• You visit a website or app marketed by us.
• You use the HbbTV and CTV functions of your Smart TV on a TV channel marketed by us or interact with a DooH screen (digital billboard) marketed by us.
• You supply us with goods or services.
• You participate in our conferences, customer events, or seminars.
• You make use of one of our services.
• You subscribe to a Newsletter.
• You participate in a competition or prize draw.
• You send your contact details via our chat tool.
• You become a member of one of our customer loyalty programs.
• You participate in one of our market research campaigns or opinion polls.
• You communicate with us via telephone, email, voice messages, text messages (SMS), video messages, instant messaging, or social media.
• You come into contact with us at customer events, promotional events, sponsorship events, or similar occasions.

Registration is not required for most of our service offerings; you can therefore visit our website without telling us who you are. However, for some Services, it may be necessary for you to provide personal data. If you decide in such a case not to provide the personal data requested by us, this may result in you being unable to use certain areas of the website or us being unable to answer an inquiry from you.

The personal data collected is diverse. On the one hand, we collect personal data that you provide to us. On the other hand, we collect personal data that is recorded automatically or manually during your contact with us, such as:

Personal data

• Surname and first name;
• Date of birth and age;
• Gender;
• Residential address;
• Delivery address;
• Billing address;
• Language preferences;
• Telephone number(s);
• Email address(es);
• Identification numbers of your technical devices (device identifiers, IP addresses, hashed email addresses);
• Information on subscribed Newsletters or other Advertising;
• Consent for receiving Advertising;
• Memberships within our business area;
• Photo and video recordings of visits to our events, conferences, seminars, or other recordings on our premises.

Customer activity data

• Contract data (including contract date, type of contract, contract content; contracting party; contract duration; contract value; claims asserted under the contract);
• Customer service information;
• Session data related to visits to our websites or offers on internet platforms, multimedia portals, or social networks (including duration and frequency of visits, language and country settings, information about browser and computer operating system, internet protocol addresses, search terms and search results; ratings submitted);
• Information about your use of the online platforms marketed by us (websites, mobile apps, CTV/HbbTV apps, DooH screens);
• Location-based data when using mobile devices;
• Based on the information we collect about your use of the online platforms marketed by us, we create interest profiles, which are still assigned to a pseudonymous device ID;
• Communications via telephone, email, voice messages, text messages (SMS), video messages, or instant messaging;
• The privacy settings you have made (opt-in, opt-out) – so that we know which of your data we may process for which purposes and which we may not.

We process your personal data for various purposes. These purposes can be grouped into different categories. Specifically, we may process your personal data in whole or in part for one or more of the following purposes:

Processing purposes in connection with our website and the provision of the services requested by you:

• Provision of the contractually agreed services, including the management of the business relationship and the billing of services;
• Operation and administration of our website and provision of the content accessed and requested by you.

Processing purposes in connection with customer communication:

• Creation of Advertising for our media products and services (direct marketing), including digital advertising technologies;
• Reporting to our advertisers – we process data to demonstrate to our customers how the advertising recipients interacted with their advertising material (qualitatively and quantitatively);
• Frequency capping – we process data so that you do not see the same Advertising too often;
• Provision, administration, and implementation of customer communication by post and via electronic means of communication;
• Business communication by post and via telephone, email, voice messages, text messages (SMS), video messages, or instant messaging;
• Evaluation of the use of our offers via telephone, email, voice messages, text messages (SMS), or instant messaging such as: type of use, frequency and duration of use, exact location of use.

Processing purposes in connection with special events:

• Organization and implementation of competitions or prize draws, including notification and publication of winners via our websites or our offers on internet platforms, multimedia portals, or social networks;
• Organization and implementation of special events such as conferences, seminars, or customer events.

Processing purposes in connection with the further development and improvement of our websites and services:

• Trend analysis and tracking of your use and interaction with our websites and services so that we can further develop and improve our websites and services and provide our users with more relevant content and services.

Processing purposes in connection with compliance with the applicable GTC/advertising conditions; ensuring the security of our business, preventing or detecting fraud or misuse of our website:

• Tracking the use of our website, verifying activities, investigating suspicious activities, and enforcing our GTC/advertising conditions to promote the security of the website and to protect our rights and the rights of others.

Processing purposes in connection with compliance with legal obligations:

• Cooperation with authorities, courts, or supervisory bodies in accordance with our legal obligations under applicable law, insofar as this processing or disclosure of personal data is necessary to protect our rights or to safeguard our legitimate interests to protect against misuse of our website, to protect personal property or safety, to pursue available legal remedies or to limit the damage suffered by us, to comply with court proceedings, court orders, or legal processes, to respond to legitimate inquiries, or for audit purposes.

We have technical and organizational security procedures in place to maintain the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access. However, you should always be aware that the transmission of information via the internet and other electronic means involves certain security risks and that we cannot guarantee the security of information transmitted in this way. All data via the website, such as Newsletter registration or forms, is transmitted via SSL. With the SSL process, we protect your data that you, as a customer, send over the internet to our company’s servers. SSL provides triple protection:

• The entries to be transmitted are encrypted;
• It is ensured that the form is only sent back to the server from which it was opened;
• It is checked whether the data reaches its respective recipient completely and unchanged.

We retain your personal data for as long as we deem necessary or appropriate to comply with applicable laws or for as long as it is necessary for the purposes for which it was collected. We delete your personal data as soon as it is no longer required and in any case after the expiry of the maximum retention period prescribed by law.

We may pass on your personal data to other subsidiaries of the Goldbach Group as well as to the companies of our parent group TX Group AG for the purposes stated in this Privacy Policy. These other companies may use your personal data in their own interest for the same purposes as we do. The companies of the Goldbach Group may process your personal data in particular for individualized and personalized analyses of customer behavior and for direct marketing activities in their own interest. Within the Goldbach Group, employees only receive access to your personal data insofar as this is necessary for the performance of their activities.

We may also pass on your personal data to other subsidiaries of the Goldbach Group, TX Group AG, and to third parties outside the Goldbach Group in order to make use of technical or organizational services that we require for the fulfillment of the stated purposes or our other business activities. These service providers are contractually obligated to process the personal data exclusively on our behalf and according to our instructions. We also obligate our service providers to comply with technical and organizational measures that ensure the protection of personal data.

If the service providers are located in countries where the applicable laws do not provide for a level of protection of personal data comparable to Swiss or European law, we will contractually ensure that the service providers concerned comply with the Swiss and European level of data protection (for example, with the standard contractual clauses issued by the EU Commission) and, where necessary, take further technical measures.

We may also pass on your personal data if we consider this necessary to comply with applicable laws and regulations, in court proceedings, at the request of the competent courts and authorities, or due to other legal obligations in order to protect and defend our rights or our property.

Finally, it is possible that an advertiser of the Goldbach subsidiaries equips its advertising material with additional tags that allow it to collect data itself at the time of delivery of this advertising material. However, this is not a transfer of data collected by Goldbach. The advertiser itself is responsible for this data collection, and Goldbach Group can neither influence the application of such tags nor is it involved in their technically successful implementation. Should this be the case, such an advertiser will be listed in the Consent Management Platform of the publisher on whose website the Advertising is placed, and you can object to this data collection. Goldbach Group works exclusively with advertisers who are registered in the IAB Transparency and Consent Framework.

On our websites, we also use so-called cookies. These are small files that are stored on your computer or mobile device when you use one of our websites. We would also like to inform you comprehensively about our use of cookies.

Why do we use cookies?

The cookies we use primarily serve to ensure the functions of our websites – such as storing the preferred language. We also use cookies to adapt our internet offering to your customer wishes and to make surfing with us as comfortable as possible for you.

Which cookies do we use?

Most of the cookies we use are automatically deleted from your computer or mobile device at the end of the browser session (so-called session cookies). For example, we use session cookies to store your country and language settings across different pages of an internet session.

In addition, we also use temporary or permanent cookies. These remain stored on your computer or mobile device after the end of the browser session. When you visit one of our websites again, the system automatically recognizes which entries and settings you prefer. These temporary or permanent cookies remain stored on your computer or mobile device for between one month and ten years, depending on the type of cookie, and are automatically deactivated after the programmed time has expired. Please visit our “Cookie Preference Center” mentioned below to learn more about the retention periods for cookies. They serve to make our websites more user-friendly, effective, and secure. Thanks to these cookies, you will, for example, see information on the page that is specifically tailored to your interests.

The cookies stored on your computer or mobile device may also originate from partner companies. These can be other companies of the Goldbach Group or companies outside the Goldbach Group. You can find the list of our partner companies, updated from time to time, and what we use them for below. The cookies of the partner companies remain stored on your computer or mobile device for between one month and ten years and are automatically deactivated after the programmed time has expired.

Information about the purposes of the cookies and which third parties set cookies during your website visit can also be found in the Cookie Settings, Manage Preferences, which is displayed to you during your first website visit or which you can easily find on our website. In the Privacy Center, you also have the option to object to the processing of your personal data for certain purposes or by certain companies.

What data is stored in the cookies?

When a cookie is set, an identification number is assigned to it. This number cannot be linked to specific data about your person (such as name or address) on its own and is instead tied to the device with which you visit our website. Data collection using a cookie identification number is therefore referred to as pseudonymous data. Under this pseudonymous identification number, data about your interaction with our website, for example, can be collected.

How can you prevent the storage of cookies?

Most internet browsers accept cookies automatically. However, you can instruct your browser not to accept cookies or to ask you each time before a cookie from a website you visit is accepted. You can also delete cookies on your computer or mobile device by using the corresponding function of your browser.

You can also use the aforementioned Privacy Center to object to the setting of cookies for certain purposes or by certain companies.

If you decide not to accept our cookies or the cookies of our partner companies, it may be that you cannot see certain information on our websites or cannot use some functions designed to improve your visit.

Data is also collected via API interfaces in the case of mobile and HbbTV apps. An API interface is a programming interface that allows software to communicate with other software. Specifically, this means that information about the use of, for example, a mobile or HbbTV app can reach our service providers via such an interface, who process the information on our behalf for the purposes mentioned above. You can usually control the scope of data collection via API interface within the app, similar to a Consent Management Platform on websites (see above).

Every time you access our websites, certain usage data is transmitted to us by your internet browser for technical reasons and stored in protocol files, so-called log files. This involves the following usage data:

• Date and time of access to our website;
• Name of the accessed website;
• IP address of your computer or mobile device;
• Address of the website from which you came to our website;
• Amount of data transferred as well as the name and version of your browser.

The evaluation of the log files helps us to further improve our internet offerings and make them more user-friendly, to find and fix errors faster, and to manage server capacities. Based on the log files, we can, for example, determine at what time the use of our internet offerings is particularly popular and provide corresponding data volume to ensure you the best possible use.

In order to constantly improve and optimize our internet offering, we use so-called tracking technologies. Web analysis tools provide us with statistics and graphics that give us information about the use of our websites. In the process, the data about the use of a website is transmitted to the server used for this purpose.

You can also use the Privacy Center mentioned in Section 9 to object to the setting of cookies by Google Analytics or other analytics tools used.

In the course of registering for our Newsletter, we process the data that you provide as a newsletter recipient. After your registration, we will send you an email with a link to confirm the registration.

You can cancel the receipt of the Newsletter at any time using the appropriately marked link in each Newsletter. We will then immediately delete your data in connection with the newsletter dispatch, and you will no longer receive any further Newsletters.

Our Newsletter contains a “web beacon”. This is a pixel-sized file that is retrieved from the server of our newsletter service provider when the Newsletter is opened. Technical information about the browser and the operating system of the newsletter recipient as well as the IP address are collected for the purpose of technical improvement of the newsletter dispatch. It is also analyzed whether and when the Newsletters are opened and which links are accessed in order to improve our newsletter content and make it more relevant for the recipients. Individual newsletter recipients are not analyzed or monitored by us.

In some cases, we must redirect you as a newsletter recipient within the Newsletter to the websites of our external service providers, for example, to access the latest version of their privacy policy. Please note that cookies are set on the websites of such service providers and thus personal data may be processed by the service providers and their partners (e.g., Google Analytics). We have no influence over this. You can find further information in the privacy policies of our service provider.

When applying for an open position at the Goldbach Group, you will be automatically redirected to an independent IT infrastructure. The application process is subject to this Privacy Policy and not that of our website.

Our website may contain links to other websites. We are not responsible for the content or the privacy practices of these other websites. Please note this when leaving our website and read the privacy policies of other websites that collect personal data. On these third-party platforms, your data and privacy protection are subject to the respective privacy practices of those platforms.

Insofar as the respective applicable requirements are met and no legal exceptions apply, you also have the right to information, rectification, deletion, restriction of data processing, and the right to receive the personal data provided by you in a common format. You also have the right to revoke any consent given to us with effect for the future.

• Right to Information: You have the right to be informed about how we process your personal data and what rights you have in connection with the processing of your personal data. We fulfill this obligation with this Privacy Policy. If you would like further information, please feel free to contact us.
• Right of Access: You have the right to request information about your personal data stored by us at any time. This gives you the opportunity to check which personal data we process about you. In individual cases, the right of access may be restricted or excluded, especially if there are doubts about identity or if this is necessary to protect other persons.
• Right to Rectification: You have the right to have incorrect or incomplete personal data corrected or completed or supplemented by a note of dispute and to be informed about the rectification.
• Right to Deletion: You have the right to request the deletion of your personal data if the personal data is no longer required for the purposes pursued, you have effectively revoked your consent or effectively objected to the processing, or the personal data is being processed unlawfully. In individual cases, the right to deletion may be excluded, especially if the processing is necessary for the exercise of freedom of expression or for the assertion of legal claims. We can also anonymize personal data so that personal data is no longer present. Please note that even after your request to delete your personal data, we must partially retain it within the scope of our legal or contractual retention obligations and in this case only block your personal data to the extent necessary for this purpose. Furthermore, deletion of your personal data may mean that you can no longer obtain or use the services you have registered for.
• Right to Restriction of Processing: Under certain conditions, you have the right to request that the processing of your personal data be restricted. This can mean, for example, that personal data is (temporarily) no longer processed or that published personal data is (temporarily) removed from a website.
• Right to Data Disclosure or Transfer: You have the right to receive from us the personal data that you have provided to us in a structured, common, and machine-readable format, provided that the specific data processing is based on your consent or is necessary for the fulfillment of a contract, and the processing is carried out using automated procedures.
• Right of Withdrawal: Insofar as we process your personal data on the basis of consent, you have the right to withdraw your consent at any time. The withdrawal only applies to the future; processing activities based on your consent in the past do not become unlawful as a result of your withdrawal. We reserve the right to continue processing personal data based on another ground in the event of a withdrawal of consent.
• Right to Object (Opt-Out) regarding our direct marketing activities. We process your data for the purposes stated in Section 5 because we have a business interest in contacting you and convincing you of our services. Of course, you are free to object to this processing, which we will take into account accordingly. You can object to the processing via the same communication channel through which we contacted you. You can find our contact details under Section 2. You can unsubscribe from our Newsletter dispatch directly using the opt-out link found at the end of every Newsletter (see also Section 12). Information regarding your right to object to the setting of cookies can be found below in Section 9.
• Right to lodge a complaint with the competent supervisory authority. The Swiss supervisory authority can be reached at www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html and the Liechtenstein supervisory authority at www.datenschutzstelle.li.

You can contact us according to Section 2 if you wish to exercise one of your rights or if you have questions about the processing of your personal data. In addition, you can unsubscribe from Newsletters and other promotional emails by clicking on the corresponding link at the end of the email.

We may ask you for a copy of your ID card or other proof of identity. To the extent legally permissible, in particular to protect the rights and freedoms of other persons and to safeguard confidential interests, we may also reject your request in whole or in part (e.g., by blacking out certain content relating to third parties or our business secrets).

You are also free to lodge a complaint with a competent supervisory authority if you have concerns about whether the processing of your personal data is compliant with the law.

The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

This Privacy Policy may be updated from time to time. Please read this Privacy Policy regularly to stay informed about the processing of your data.

The original Privacy Policy is in German. The translated versions are for better understanding only. In case of contradictions, the German text shall prevail.

Last updated: April 28, 2025

Goldbach delivers advertisements (e.g., banners, video spots) from hundreds of advertisers on a variety of media channels (websites, mobile apps, DooH screens, HbbTV applications) (hereinafter “Goldbach Services”). A list of the websites and apps on which Goldbach delivers advertisements is available here.

Within the scope of the Goldbach Services, Goldbach – on its own responsibility and independently of the operator of the website – uses innovative target group products that enable Goldbach to reach its target audience more accurately and to promote websites and apps through the sale of ads. These target group products can also be formed through the use of data that Goldbach collects and processes.

2.1. Cookies – Definition and Purpose

Goldbach uses so-called cookies for the purpose of creating these target group products. These are small text files that are stored on the hard drive of the end device of a visitor to a website or app (hereinafter referred to as the “user”) with the help of the browser and are stored there for data collection purposes. When you, as a user, visit one of the websites or apps in the Goldbach network, the automated systems of their service providers (e.g., ad servers, data management platforms) collect usage data regarding the visit to this website and apps with the help of cookies or, by means of third-party cookies, even beyond the specific domain. Information can be written in these text files that can be read out again at a later point in time.

Some cookies remain stored on your end device until you, as a user, delete them. They enable Goldbach, for example, to recognize your browser on your next visit. Other cookies are only stored for the duration of a visit to a website.

If you do not wish for data to be determined by means of cookies, you can set up your browser so that it informs you about the setting of cookies and you only allow this in individual cases. You can find out more about this under point 2.1.3 “Handling cookies”.

2.1.1 Third-party cookies or cookies from our service providers

Third-party cookies are cookies that originate from a domain other than that of the website. Third-party cookies are generally used by technology providers or advertising networks. Since, for example, some online or mobile advertisers (“advertisers”) and website and app operators (“publishers”) do not want to run campaigns on just one domain or website, third-party cookies enable them to recognize users on different domains and store information in the third-party cookie. For example, if a user visits a website, a third-party cookie is placed on the user’s computer by the advertising network from which an advertisement is provided. With the help of the cookie, user data such as page visits and duration of stay can be tracked. If the user later visits another website on which an advertisement from the same advertising network is located, the same cookie is used despite the different website – because it is the same third-party provider. In this way, the advertising network can track a user across domain boundaries and deliver targeted advertising.

Goldbach uses technologies from service providers or their sub-service providers, which include cookies, for the optimized provision of its services. These are third-party cookies.

Insofar as their service providers process personal data on behalf of Goldbach, they have each concluded a data processing agreement with Goldbach. Such an agreement guarantees that the provider processes the personal data transmitted to it only in accordance with Goldbach’s instructions and not for its own purposes, and takes appropriate technical and organizational measures to ensure the legally compliant protection of your data. You can find the respective privacy policies of the providers at the links listed above. Please note: Cookies are used on the websites of the named providers, and personal data is thus processed by the providers, as well as possibly by their partners and employed service providers.

Furthermore, advertisers can also store third-party cookies on users’ end devices via the advertising spaces provided in the Goldbach network. In this case, the advertisers contractually commit to participating in the IAB Transparency and Consent Framework and to complying with all data protection regulations, whereby they become individually responsible to the user for their data processing.

2.1.2 First-party cookies

First-party cookies are cookies that are tied to a specific domain (e.g., website). Only this domain can write information into the cookie and read it out again at a later point in time. First-party cookies are mainly used to enable the user to have a better and faster surfing experience on a website, as, for example, certain user preferences are stored in the cookie and do not have to be re-entered by the user on every visit.

First-party cookies are also used on Goldbach.com. Please refer to the Goldbach Group privacy policy for information on this.

2.1.3 Your handling of cookies

You can change the settings of your web browser and block all cookies. However, since cookies are widely used, blocking cookies in the web browser may restrict the use of various websites.

You will find a Consent Management Platform at all operators of online platforms that participate in the IAB Transparency and Consent Framework – including this website: a control interface, usually in the form of a (cookie) banner, in which you can make your data protection settings. Here you can allow or prohibit the use of cookies for various purposes. If we use cookies on an online platform you use, you will find us in the Consent Management Platform there. Your settings made there will be taken into account by all participants in the framework, including Goldbach.

Please note that the storage of your data protection settings made in this way may be based on cookie technology (this may vary depending on the operator of the online portal). For users of multiple computers or browsers, this means that you must deactivate the receipt of cookies on each computer or for each browser. Even if users change computers or delete cookies from their computer, they must repeat the deactivation process.

2.2. API interface

An API interface is a programming interface that allows software to communicate with other software. Similar to cookies, this is a technology that can be used for the collection of usage data and is mostly used in connection with apps. Specifically, this means that information about the use of, for example, a mobile or HbbTV app can be transmitted via such an interface to our service providers, who process the information on our behalf for the purposes mentioned above.

You can generally consent to or object to data collection via the API interface within the corresponding application (mobile, HbbTV apps, etc.), depending on the legal basis for processing. Similar to cookies, this takes place on a Consent Management Platform that complies with IAB TCF standards.

3.1. Data we process about you as a contractual partner, interested party, and inquirer

We collect your personal data when you contact us, e.g., as an interested party, inquirer, or contractual partner. This is particularly the case if you are interested in our products, make inquiries, obtain offers, or contact us by email or telephone, as well as if you are in an existing business relationship with us. For contract initiation and fulfillment, as well as for customer contact purposes, we process the following personal data:

• Personal identification details, e.g., first and last name, address, date of birth, nationality, email address, telephone number
• Company data, e.g., industry and commercial register data
• Order and payment data, e.g., product details; means of payment; customer number

3.2. Data we collect about you as an end user of online platforms marketed by Goldbach

In the course of offering your services and products, Goldbach does not process any personal information that directly identifies you as an end user (such as names, residential addresses, email addresses). Identification of end users is not necessary for the purposes of data collection and is not sought in the sense of the principle of data minimization. Rather, user information is linked to pseudonymized data points, such as IP addresses or device identification numbers. These cannot be assigned to an individual without significant additional effort. IP addresses are pseudonymized immediately after collection (e.g., by deleting the last 8 bits). As a result, only a rough location of the user (at the level of postal codes) is possible.

The usage data of end users collected by Goldbach includes information such as visited websites, date and time at which websites or apps were viewed, interactions between content and advertisements, and location data (only after explicit consent). The technologies used to collect this data include cookies or similar technologies that are deleted after a certain period (see section 7 below).
In addition to the collected usage behavior of end users, Goldbach enriches the data pool created in the process with characteristics estimated by them or their service providers in order to be able to derive interest profiles from them. This essentially includes segment identifiers such as football fan, smart shopper, adventure traveler, or similar. Under no circumstances does Goldbach determine probabilities for “sensitive” characteristics such as creditworthiness, susceptibility to illness, political orientation, or similar for individual persons.

3.3. Where does the data processed by Goldbach come from?

Goldbach collects and processes your data, as described in section 3.2, when you interact with online platforms – this can be, for example, a website, a mobile or HbbTV app – which are marketed by Goldbach.

We always treat personal data in accordance with the strict regulations of the applicable data protection provisions (namely the FADP and the GDPR). We collect and store personal or usage-related data only insofar as

• your corresponding consent is available or
• this is necessary for the fulfillment of a contractual or legal obligation or
• we have an overriding legitimate interest in processing your personal data.

Data collection based on consent: Where this is legally required, Goldbach will ask for your consent when processing your data. If you have given Goldbach your consent to process your data (for example, via a Consent Management Platform in the IAB Transparency and Consent Framework), this processing takes place in accordance with your consent. You can revoke your consent at any time.

Data collection to fulfill our contractual obligations: In order to fulfill any contracts with you, we must process your data. This also applies to pre-contractual information and contacts that you make to us as part of an inquiry. The purposes of data processing are primarily based on the respective service or product. To carry out the contractual relationship, we need, for example, your address, your telephone number, or your email address in order to be able to contact you.

Details on the respective purposes of data processing can be found in the contract documents, our General Terms and Conditions, and the product and service descriptions in addition to these privacy policies.

Data collection to fulfill our legal obligations: The processing of your data may be necessary due to legal obligations to which we are subject (in particular for the retention of business letters and contract documents). Such obligations may arise, for example, from the Code of Obligations (CO) or tax law.

Data collection to protect overriding legitimate interests: Goldbach may process your data if it is necessary to protect its legitimate interests, provided that the interests of the users do not override this or consent is required by the applicable legal system. A legitimate interest of Goldbach can, for example, lie in the individual adaptation of the advertisements that users of the online platforms of the Goldbach network see. The user benefits from this due to the better-coordinated advertising placements and the resulting increase in general advertising quality. The processing helps advertisers to play out campaigns to the appropriate target groups. Our legitimate interest in processing your data also exists for our own marketing purposes, for customer loyalty, or for legally permissible direct advertising by means of newsletters. In addition, there is a legitimate interest in processing your data in the context of (potential) legal prosecution and for purposes related to the accounting and auditing obligations of the companies within the Goldbach Group.

Your data will be transmitted to the following categories of recipients:

Service providers and partners employed by Goldbach, such as the providers under section 2.1.1, provided they need your data to fulfill their respective tasks. These service providers are contractually obligated to treat your data confidentially and to process it only as far as necessary for the provision of services. In particular, they are not authorized to further process the received data for their own purposes beyond the provision of your services. In this respect, your data remains within the sphere of Goldbach. A list of the current service providers of the Goldbach Group companies can be found here.

Within the Goldbach Group and its parent company TX Group AG, those employees and departments receive your data who need it to fulfill the respective contractual and legal obligations, as well as the legitimate interests mentioned above.

When it comes to data transfers outside the Goldbach Group and the TX Group, it is particularly important to us that the protection of your data is ensured. Such a transfer therefore generally does not take place or only under the strictest conditions. It may be that we have to disclose personal data to public bodies and authorities upon request because we are legally obliged to do so. Furthermore, data may be disclosed exclusively in an aggregated, anonymized form—ensuring that no conclusions can be drawn about an individual—or in a manner that allows you to maintain constant control over the processing of your data (e.g., via a Consent Management Platform within the IAB Transparency and Consent Framework).

Finally, it is possible that an advertiser of Goldbach may equip its advertising material with additional tags, which enable it to collect data on its part at the time of delivery of this advertising material. However, this is not a disclosure of data collected by Goldbach. The advertiser itself is responsible for this data collection, and Goldbach can neither influence the use of such tags nor is it involved in their technically successful implementation. Should this be the case, such an advertiser will be listed in the Consent Management Platform of the publisher on whose website the advertisement is placed, and you can object to this data collection. Goldbach generally only works with advertisers who are registered in the IAB Transparency and Consent Framework.

We and our service providers have technical and organizational security procedures in place to maintain the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access.

Goldbach does not store your data longer than necessary for the respective processing purposes.

We store your personal data for a maximum duration until the termination of the contractual relationship with you or as long as our legitimate interest in the processing exists. The latter is the case, for example, if legal claims can be asserted from the contractual relationship or as long as legal retention and documentation obligations exist. Reasons for this can be, for example:

• The fulfillment of corporate and tax law retention obligations: in particular according to the Code of Obligations and tax law.
• Obtaining evidence for legal disputes within the framework of the statutory limitation periods.

Temporary or permanent cookies remain stored on your computer or mobile device for between one month and ten years, depending on the type of cookie, and are automatically deactivated after the programmed time has elapsed. We, on the other hand, process the information resulting from the cookies for a maximum of 90 days. Depending on the decision of the website operator, providers other than Goldbach can also use cookies based on consent. The deletion of data in the sense of section 14.2 below can be requested at any time via [email protected].

In order to fulfill our contracts and for our business relationships, as well as for processing and answering contact inquiries, we need the following personal data from you:

• Data required for initiating and carrying out a business relationship or contact inquiry (e.g.: name, address, telephone number, or email address)
• Data necessary for the fulfillment of the associated contractual obligations

Without this personal data, we are generally not able to enter into or execute a contractual relationship with you.

If you do not wish Goldbach to collect your data by means of cookies, you can set this accordingly in the Consent Management Platform of the Goldbach website and the online platforms in the Goldbach partner network. However, the functionality of the relevant websites or apps may be restricted as a result.

To enable Goldbach to create and continuously optimize services and products (target group products), the technical possibility of automated profiling is used, in particular to analyze or predict aspects regarding personal preferences, interests, behavior, location, or change of location.

In some cases, Goldbach processes your data to evaluate certain personal aspects (profiling). This applies, for example, to the following cases:

• Through targeted marketing, Goldbach only wants to make you offers that are tailored to your needs.
• To assess the interests of the users of the websites and apps, Goldbach uses characteristics derived from the cookie data. In doing so, the probability with which a user corresponds to a certain interest category is calculated. This calculation is based on statistical methods. The calculated interests support Goldbach in the allocation of its services and products.

You acknowledge that your data processed by Goldbach may be processed outside the country in which you reside. Goldbach assures its contractual partners and all users from whom data is collected that the data will only be processed in countries in which an equivalent level of data protection as in Switzerland or the EU is guaranteed.

Should data be processed by service providers (processors) outside the EEA, Goldbach ensures that the company concerned has sufficient protection for your data (such as by means of Binding Corporate Rules) or that it is committed to such, for example via Standard Contractual Clauses of the EU Commission (Standard Contractual Clauses, SCC). If these precautions do not lead to sufficient protection of the data, additional measures will be taken. Where possible and if necessary, an alternative service provider will be used.

Data collected by us on our own behalf or on behalf of our customers can be stored and processed in any country in which the Goldbach Group maintains subsidiaries, branches, representatives, or customer facilities. The user acknowledges and accepts that information provided by the user can be transferred outside the country in which the user resides and to all companies belonging to the parent company of Goldbach, i.e., the Goldbach Group, as well as the parent company of the Goldbach Group, i.e., the TX Group AG. Goldbach assures its customers and all users from whom data is collected that the data will only be processed in countries in which an equivalent level of data protection as in Switzerland or the EU is guaranteed. Should data be processed by a company in another state, the data transfer will take place taking into account the criteria of section 10.

Should another company acquire all or substantially all of our company’s assets as a result of consolidation, merger, purchase of assets, or other transactions, we reserve the right to pass on all data (including personal data) in our possession or managed by us to the acquiring party.

Goldbach tries to answer your questions and concerns as quickly as possible. Sometimes, however, it can still take up to a month before you receive an answer. Should we need longer than a month, we will of course let you know in advance.

In some cases, Goldbach cannot or may not provide information. Insofar as this is legally permissible, Goldbach will always inform you promptly of the reason for the refusal in this case. You have the right to file a complaint (see below).

13.1 Right to access, information, and rectification

You can request information about your data processed by Goldbach. Should your data be incomplete, you can request completion. Should your details no longer be accurate, you can request a correction. If Goldbach has passed on your details to third parties, Goldbach will inform these third parties of your correction, provided this is legally required.

13.2 Right to deletion of your personal data

You can request the immediate deletion of your data if:

• Your data is no longer needed for the purposes for which it was collected,
• You revoke your consent and there is no other legal basis for processing by Goldbach,
• You object to the processing and there are no overriding legitimate reasons for processing,
• Your data has been processed unlawfully,
• Your data must be deleted to comply with legal requirements, or
• Your data was collected in relation to information society services (e.g., advertising offers) aimed at children (within the meaning of Art. 8 GDPR).

13.3 Right to restriction of processing of your personal data

You have the right to request a restriction (comparable to a block) of the processing of your data if
the accuracy of your data is disputed by you for the duration Goldbach needs to verify the accuracy,
the processing is not lawful and you request a restriction of use instead of deletion,
Goldbach no longer needs your data for the purposes of processing, but you need it to assert, exercise, or defend against legal claims, or you have lodged an objection as long as it has not yet been determined whether your interests override.

13.4 Right to object

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which takes place on the basis of legitimate interest or to perform a task in the public interest; this also applies to profiling. Goldbach will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the assertion, exercise, or defense of legal claims.

The Goldbach Group is a registered member of the IAB Transparency and Consent Framework 2.0 (Vendor ID 580) and adheres to the guidelines specified for it. The IAB TCF 2.0 is an industry standard that enables all digital market participants (publishers, advertisers, technology service providers, etc.) to inform end users about the processing of their personal data and to give them the opportunity to consent to or object to it. You will find a Consent Management Platform at all operators of online platforms that participate in the framework: a control interface, usually in the form of a cookie or privacy center, within which you can make your data protection settings. If we process your data, you will find us in the Consent Management Platform of the websites, mobile and HbbTV apps, etc. you use. The settings you make therein will be taken into account by all participants in the framework, including the companies of the Goldbach Group.

If personal data is processed to carry out direct advertising (via newsletter or telephone), you have the right to object at any time to the processing of personal data for the purpose of such advertising. You will find the contact details below.

Should you have any questions, concerns, or comments regarding the processing of your personal data or this privacy policy, please contact us by email or post at:

Goldbach Group AGSeestrasse 39CH-8700 Küsnacht ZHSwitzerland
[email protected]

If you contact us via the form on the website or by email, your provided data will be stored by us for six months for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

Operational Data Protection Officer:
Goldbach Group AG
Seestrasse 39
CH-8700 Küsnacht ZH
Switzerland
[email protected]

For concerns from the EU area, you can contact our representative (Art. 27 GDPR):

ePrivacy GmbH
Burchardstrasse 14
20095 Hamburg
Germany
www.eprivacy.eu

We reserve the right to make changes to this privacy policy by publishing an updated version on this page. The date on which the current privacy policy was published will always be indicated at the beginning of this page. All changes to this privacy policy will be carried out in accordance with the applicable (data protection) laws.