I. Duties to provide information
We are generally subject to Swiss data protection legislation (Data Protection Act/FADP and Data Protection Ordinance/OFADP).
To the extent applicable, we shall, however, also adhere to the EU General Data Protection Regulation (GDPR) of 27 April 2016, which also brings about certain external effects for companies and institutions in the non-EU country of Switzerland. With respect to the upcoming revision of the Federal Act on Data Protection (FADP), which will in part draw on the EU regulations, we will inform you below in accordance with Art. 13 GDPR regarding the collection and processing of personal data by us.
II. Responsibility for data processing / point of contact
1. The responsible body for data processing is:
Organisation of the Swiss Abroad (OSA)
Telephone +41 (0)31 356 61 00
Fax +41 (0)31 356 61 01
2. Representative in accordance with Art. 27 GDPR
Collegamento svizzero in Italia
Via Palestro 2
Milano – 20121
III. Scope of data processing, purpose, legal framework
1. When visiting our websites
When using our websites or the services, which require registration, general data is collected by default and is saved in server log files for each access operation. This concerns the
- browser used (including the version)
- the operating system of your computer that is used
- the website, which you are accessing from
- the IP address (Internet protocol address) of the requesting computer
- the date and time the web pages are accessed
- the country, from which access is occurring and the language settings
- the name and the URL of the file accessed
- the name of your Internet provider
The purpose of processing this data is to permit the use of our websites, optimise the content and the offering as well as to maintain the functions of the websites. We analyse the data, including in particular the IP addresses, statistically in order to be able to also optimise our offering regionally. We have a legitimate interest in this respect and, with respect to this collection of data, draw on Art. 6 para. 1 lit. f GDPR.
In this context, cookies (cf. VII below) and web analytical services (cf. VIII below) are used in this context.
2. When entering reader comments
If you write a reader comment on www.revue.ch, you are providing us with the required information (comment, name, email address) and consenting to the processing of this data for the purposes of publishing your reader comment on the website and making it accessible.
3. For the email notification by the FDFA
When a new edition of the “Swiss Review” is released, the Federal Department of Foreign Affairs (FDFA) sends an email notification to all registered Swiss Abroad (sender: _EDA-Swissabroad firstname.lastname@example.org). The FDFA is responsible for maintaining the data of the recipients.
According to the understanding of the FDFA in consultation with the Federal Data Protection and Information Commissioner (FDPIC), the GDPR does not apply for Swiss authorities (whether they are active in Switzerland or another country in Europe). The Swiss data protection legislation is therefore still relevant.
IV. Forwarding of your data to third parties and contract processing
Your data is only passed on to third parties if you provide us with your express consent of Art. 6 para. 1 lit. a GDPR); we are required by the Art. 6 para. 1 lit. c GDPR) to do so or this is necessary in order to uphold our legitimate interests according to Art. 6 para. 1 lit. f GDPR). Furthermore, forwarding can occur if this is necessary in order to protect your vital interests or those of another natural person Art. 6 para. 1 lit. d GDPR).
In this context, please also refer to VIII (Web Analysis) and IX (Social Media).
Forwarding of your information to third parties can also occur if we engage third parties as contract processors in order to fulfil our obligations. Such third parties process data exclusively on the basis of our order and may not perform any data processing, which does not occur in connection with this privacy statement, in particular the processing of personal data for its own purposes.
V. Transfer to third countries
Transfer to third countries can occur in connection with IV above. If the level of data protection of this third country does not correspond to the Swiss or European level of data protection, we will ensure compliance with the Swiss or European level of data protection contractually. If data processing is performed by third parties, who are privacy shield certified, this shall be deemed an appropriate level of protection.
VI. Technical and organisational measures
We will process data by taking suitable technical and organisational measures to secure the personal data available to us against partial or complete loss, against unauthorised access by third parties and manipulation. Furthermore, our employees, who are entrusted with data processing, as well as our contract processors are obligated to maintain confidentiality and comply with the provisions of data protection law.
Cookies are small text files, which are saved on your computer and serve to track the behaviour of users of our websites or save settings. These cookies serve to track the number and type of visits to the web pages and its sub-pages, to save user preferences for layouts as well as country and language settings. Furthermore, we collect statistical data in order to optimise the content of our web pages and increase their level of user friendliness. When you use www.revue.ch, a session cookies is created provided you are logged in. It allows different transactions to be assigned to you.
You can change the cookie settings in your browser yourself or restrict or deactivate them. Deactivating cookies may result in you not being able to use all functions of our website.
For third-party cookies, see VIII and IX below.
VIII. Web analysis
- browser type/version
- operating system used
- referrer URL (the page previously visited)
- IP address of the accessing computer
- time of the server request
This information is generally transferred to a server of Google in the USA and saved there. For our order, Google will use this information to analyse the use of the website to compile reports on website activities on our behalf and in order to provide further services associated with the use of the website and Internet. An IP address transferred by your browser will not be combined with other data from Google.
You can prevent the storage of cookies by configuring your browser software accordingly (cf. VII).
On our websites, Google Analytics is supplemented with the extension anonymizeIP. As a result, the IP addresses are not sent to Google with reference to persons, instead the last three numbers are anonymised.
You can furthermore prevent the collection of the data generated by the cookie (including the IP address of the accessing computer) by Google with respect to your use of the websites as well as the processing of this data by downloading and installing the following browser plugin: http://tools.google.com/dlpage/gaoptout?hl=de.
Furthermore, you have the possibility of creating an opt-out cookie, which prevents the subsequent collection of your data when surfing on our websites. This cookie is valid for the browser used and only for the website used; it is saved on your computer. If cookies are deleted in the settings of the browser used, the opt-out cookie must be recreated.
Further information on data protection in connection with Google Analytics can be obtained in particular in Google Analytics help:
IX. Social media plugins
Our internet presence uses plugins from social networks (currently only YouTube) On one hand, integration occurs by means of links; in this case, after the corresponding link has been clicked, we no longer have any influence on the processing of any data that is transferred to third parties by clicking the links.
On the other hand, in unique cases, contents from our webpages are directly integrated into social networks (YouTube). Cf. the details below.
If, in the future, we should use LIKE or SHARE buttons on our website, social plugins from Facebook will be in use, the American company Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. We currently do not use these buttons. If this should change, we would inform you accordingly.
By integrating the plugins, Facebook receives the information that your browser has retrieved the corresponding site of our website, even if you do not have a Facebook account or are not currently logged in on Facebook. This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there.
If you are logged in on Facebook, Facebook can associate the visit of our website with your Facebook account directly. If you interact with plugins, the corresponding information is also transmitted directly to a Facebook server and stored there. The information is also published on Facebook and shown to your Facebook friends.
Facebook can use this information for the purposes of marketing, market research and the needs-based display of the Facebook webpages. Facebook use, interests and relationship profiles are created, for example, to evaluate your use of our website with regard to the advertisements shown on your Facebook account, to inform other Facebook users of your activities on our website and to perform further services associated with the use of Facebook.
If you do not want Facebook to associate the data collected via our website with your Facebook account you must log out of your Facebook account before visiting our website.
If, in the future, we should use Tweet button on our website, social plugins from Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA, will be in use. The Twitter plugins (Tweet button) can be identified by the Twitter logo on our website.
If you have activated social plugins, a direct connection is established between your browser and the Twitter server. This allows Twitter to obtain the information that you have visited our website with your IP address. If you click on the Twitter “Tweet button” while you are logged into your Twitter account, you can link the contents of our website to your Twitter profile. This allows Twitter to associate the visit of our website with your user account. We would like to point out that we, as the provider of the website, receive no knowledge of the contents of the data transmitted or the use of this data by Twitter. If you do not want Twitter to be able to associate the visit of our website, please log out of your Twitter account.
YouTube videos are embedded in our website. As a result, plugins from the YouTube page operated by Google are used. The operator is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you access the web pages of our websites provided with such a plugin, a connection is established to the servers of YouTube. At the same time, the YouTube server will be informed that you have visited our pages.
If you are logged into YouTube as a member, YouTube will attribute this information to your personal user account. If the plugin is used e.g. by clicking the start button for a video, this information will also be attributed to your user account. You can prevent such attributing by logging out of your YouTube user account and other user accounts of the companies YouTube LLC and Google Inc. before using our website and delete the corresponding cookies of the companies.
You can find more information on data processing and notes on data protection by YouTube at www.google.de/intl/de/policies/privacy/.
X. Your rights
1. Right to information
You have the right to demand information regarding your personal data we save at any time. This information is generally provided free of charge (Art. 15 GDPR).
2. Right to correction
You have the right to demand the correction and completion of incorrect personal data concerning your person (Art. 16 GDPR).
3. Right to the restriction of processing
You have the right to demand the restriction of data processing and/or to object to data processing (Art. 18 GDPR).
4. Right to erasure (right to be forgotten)
You have the right to demand the erasure of personal data if the data was collected for purposes, for which it is no longer necessary to the extent you revoke your consent or, to the extent the data processing is not based on a legal obligation, to assert, exercise or defend legal claims or in other cases allowed by law in accordance with Art. 6 GDPR. Art. 17 GDPR forms the legal basis.
5. Right to the transferability of data
You have the right to demand that your personal data be issued (right to data portability) or the forwarding of your data to a third party you designate (Art. 20 GDPR).
6. Right of objection
Based on Art. 21 GDPR, you have the right to object to the processing of your personal data for the purpose of direct advertising or profiling in connection with direct advertising.
Furthermore, you have the right, for reasons attributed to your particular situation, to object to the processing of data, which is based on lit. e (public interest) or lit. f (legitimate interest) of Art. 6 para. 1 GDPR.
If you assert an interest, which outweighs our legitimate interests in an individual case, we will no longer process your data.
7. Right to the revocation of consent under data protection law
Based on Art. 7 para. 3 GDPR, you have the right to revoke consent to data processing that you have given. This shall not affect the legitimacy of the processing of the data that occurred on the basis of consent up to revocation.
8. Automated individual decision-making, including profiling
We do not use any automated individual decision-making in the sense of Art. 22 GDPR. If we use such methods in individual cases in the future, we will inform you separately.
Furthermore, we do not perform any profiling. We merely determine the countries from which access operations originate and which parts of our websites are visited as well as the frequency of visits in order to optimise the websites (cf. VIII).
9. Right to object vis-à-vis to a supervisory authority
You have a right to object to a competent regulatory authority in the EU. In Switzerland, you can contact the Federal Data Protection and Information Commissioner with your concerns (www.edoeb.admin.ch).
XI. Duration of storage / deletion of data
We save the data you provided to us as long as necessary for the aforementioned purposes, or as long as, on our part, there is a legitimate interest in the sense of Art. 6 para. 1 lit. f GDPR or – to the extent data processing is based on your consent – as long as you have not revoked your express consent in the sense of Art. 6 para. 1 lit. a GDPR. Any statutory retention regulations shall remain expressly reserved.