1. An overview of data protection
Data collection on our website
Who is responsible for the data collection on this website?
The data collected on this website are processed by the website operator. The operator's contact details can be found in the website's required legal notice.
How do we collect your data?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form.
Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.
What rights do you have regarding your data?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
Analytics and third-party tools
You can object to this analysis. We will inform you below about how to exercise your options in this regard.
2. General information and mandatory information
Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
Notice concerning the party responsible for this website
The party responsible for processing data on this website is:
Top Fifty AG
Phone: +41 41 412 02 02
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).
Revocation of your consent to the processing of your data
Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
Right to file complaints with regulatory authorities / data protection office
If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the data protection officer of the state in which our company is headquartered.
Right to data portability
You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser's address line when it changes from «http://» to «https://» and the lock icon is displayed in your browser's address bar.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
Encrypted payments on this website
If you enter into a contract which requires you to send us your payment information (e.g. account number for direct debits), we will require this data to process your payment.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are only made via encrypted SSL or TLS connections. You can recognize an encrypted connection in your browser's address line when it changes from «http://» to «https://» and the lock icon in your browser line is visible.
In the case of encrypted communication, any payment details you submit to us cannot be read by third parties.
Information, blocking, deletion
As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.
Opposition to promotional emails
We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.
3. Data protection officer
Statutory data protection officer
We have appointed a data protection officer for our company.
Top Fifty AG
Phone: +41 41 412 02 02
4. Data collection on our website
Most of the cookies we use are so-called «session cookies». They are automatically deleted after your visit. Other cookies remain in your device's memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
Server log files
The website provider automatically collects and stores information that your browser automatically transmits to us in «server log files». These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
Should you send us questions via a form, we will collect the data entered on the form, including the contact datas you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the form only with your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
Registration on this website
You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.
To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.
We will process the data provided during registration only based on your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.
Processing of data (customer and contract data)
We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.
Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
Data transferred when signing up for services and digital content
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us, for example, to banks entrusted to process your payments.
Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.
The basis for data processing is Art. 6 (1) (b) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
5. Analytics and advertising
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called «cookies». These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Outsourced data processing
We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the Swiss data protection authorities when using Google Analytics.
Demographic data collection by Google Analytics
This website uses Google Analytics' demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section «Refusal of data collection».
This website uses Google AdSense, a service for including advertisements from Google Inc. («Google»). It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google AdSense uses so-called «cookies», which are text files stored in your computer that enable an analysis of the way you use the website. Google AdSense also uses so-called web beacons (invisible graphics). Through these web beacons, information such as the visitor traffic on these pages can be evaluated.
The information generated by cookies and web beacons relating to your use of this website (including your IP address), and delivery of advertising formats, is transmitted to a Google server in the US and stored there. This information can be passed on from Google to contracting parties of Google. However, Google will not merge your IP address with other data you have stored.
AdSense cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
You can prevent the installation of cookies by setting your browser software accordingly. Please be aware that in this case, you may not be able to make full use of all the features of this website. By using this website, you agree to the processing of data relating to you and collected by Google as described and for the purposes set out above.
Google Analytics Remarketing
Our websites use the features of Google Analytics Remarketing combined with the cross-device capabilities of Google AdWords and DoubleClick. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.
This feature makes it possible to link target audiences for promotional marketing created with Google Analytics Remarketing to the cross-device capabilities of Google AdWords and Google DoubleClick. This allows advertising to be displayed based on your personal interests, identified based on your previous usage and surfing behavior on one device (e.g. your mobile phone), on other devices (such as a tablet or computer).
Once you have given your consent, Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that signs in to your Google Account can use the same personalized promotional messaging.
To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.
You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account; follow this link: https://www.google.com/settings/ads/onweb/.
The aggregation of the data collected in your Google Account data is based solely on your consent, which you may give or withdraw from Google per Art. 6 (1) (a) DSGVO. For data collection operations not merged into your Google Account (for example, because you do not have a Google Account or have objected to the merge), the collection of data is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing anonymous user behavior for promotional purposes.
Google AdWords and Google Conversion Tracking
This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States («Google»).
As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Cookies are small text files that your internet browser stores on your computer. These cookies expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page.
Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not obtain any information that can be used to personally identify users. If you do not want to participate in tracking, you can opt-out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings. In doing so, you will not be included in the conversion tracking statistics.
Conversion cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
We use «Google reCAPTCHA» (hereinafter «reCAPTCHA») on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA («Google»).
reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.
The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.
Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.
Our website measures conversions using visitor action pixels from Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA («Facebook»).
These allow the behavior of site visitors to be tracked after they click on a Facebook ad to reach the provider's website. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization.
You can also deactivate the custom audiences remarketing feature in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You will first need to log into Facebook.
If you do not have a Facebook account, you can opt out of usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.
If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the «unsubscribe» link in the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
This website uses the services of MailChimp to send newsletters. This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
MailChimp is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA.
MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.
We use MailChimp to analyze our newsletter campaigns. When you open an email sent by MailChimp, a file included in the email (called a web beacon) connects to MailChimp's servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.
If you do not want your usage of the newsletter to be analyzed by MailChimp, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.
Data processing is based on Art. 6 (1) (a) DSGVO. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g. email addresses for the members area) remains unaffected.
Completion of a data processing agreement
We have entered into a data processing agreement with MailChimp, in which we require MailChimp to protect the data of our customers and not to disclose said data to third parties. This agreement may be viewed at the following link: https://mailchimp.com/legal/forms/data-processing-agreement/sample-agreement/.
7. Plugins and tools
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.
If you're logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
Our website uses features provided by the Vimeo video portal. This service is provided by Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.
If you visit one of our pages featuring a Vimeo plugin, a connection to the Vimeo servers is established. Here the Vimeo server is informed about which of our pages you have visited. In addition, Vimeo will receive your IP address. This also applies if you are not logged in to Vimeo when you visit our website or do not have a Vimeo account. The information is transmitted to a Vimeo server in the US, where it is stored.
If you are logged in to your Vimeo account, Vimeo allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Vimeo account.
Google Web Fonts
For uniform representation of fonts, this page possibly uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.