1. CONTACT ADDRESSES

Responsibility for processing personal data:

‍2nd Skin AG
Altstetterstrasse 134
8048 Zurich
Switzerland

admin@2ndskn.com

DATA PROTECTION REPRESENTATIVE IN THE EUROPEAN ECONOMIC AREA (EEA)

We have the following data protection representative in accordance with Art. 27 GDPR in the European Economic Area (EEA), including the European Union (EU) and the Principality of Liechtenstein, Iceland, and Norway, as an additional point of contact for supervisory authorities and data subjects for inquiries in connection with the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Germany

info@datenschutzpartner.eu

2. PROCESSING OF PERSONAL DATA

2.1 TERMS

Personal data is any information relating to an identified or identifiable person. A data subject is a person whose personal data is being processed. Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, saving, modification, destruction, and use of personal data.

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

2.2 LEGAL BASIS

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FADP) and the Ordinance to the Federal Act on Data Protection (O-FADP).

We process personal data in accordance with at least one of the following legal bases, insofar as the General Data Protection Regulation (GDPR) applies:

• Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures.
• Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data to safeguard our legitimate interests or those of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests include, in particular, our interest in providing our services in a permanent, user-friendly, secure, and reliable manner and, if necessary, in advertising them, information security and protection against misuse and unauthorized use, the enforcement of our own legal claims, and compliance with Swiss law.
• Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill 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 GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
• Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
• Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

2.3 TYPE, SCOPE, AND PURPOSE

We process the personal data that is necessary to provide our services in a permanent, user-friendly, secure, and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales, contract, and payment data.

We process personal data for as long as is necessary for the respective purpose or purposes or as required by law. Personal data that no longer needs to be processed is anonymized or deleted. Individuals whose data we process have a fundamental right to have their data deleted.

We only process personal data with the consent of the data subject, unless processing is permissible for other legal reasons, for example to fulfill a contract with the data subject and for corresponding pre-contractual measures to protect our overriding legitimate interests, because processing is apparent from the circumstances, or after prior notification.

In this context, we process in particular information that a data subject voluntarily and personally provides to us when contacting us—for example, by letter, email, contact form, social media, or telephone—when registering for a user account, or when publishing their own content. We may store such information in an address book or using similar tools, for example. If you transmit personal data about third parties to us, you are obliged to ensure data protection for such third parties and to ensure the accuracy of such personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources, or collect when providing our services, provided that such processing is permitted for legal reasons.

2.4 PROCESSING OF PERSONAL DATA BY THIRD PARTIES, INCLUDING ABROAD

We may have personal data processed by commissioned third parties or process it jointly with third parties or with the help of third parties or transfer it to third parties. Such third parties are, in particular, providers whose services we use. We also ensure adequate data protection with such third parties.

Such third parties are generally located in Switzerland and the European Economic Area (EEA). However, such third parties may also be located in other countries and territories on Earth and elsewhere in the universe, provided that their data protection laws, in the opinion of the Federal Data Protection and Information Commissioner (FDPIC) and – if and to the extent that the General Data Protection Regulation (GDPR) applies – in the opinion of the European Commission – or if adequate data protection is ensured for other reasons, such as through a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or through corresponding certification. In exceptional cases, such a third party may be located in a country without adequate data protection, provided that the data protection requirements, such as the express consent of the data subject, are met.

3. RIGHTS OF DATA SUBJECTS

Data subjects whose personal data we process have rights under Swiss data protection law. These include the right to information and the right to correction, deletion, or blocking of the processed personal data.

Data subjects whose personal data we process may—if and to the extent that the General Data Protection Regulation (GDPR) applies—request confirmation free of charge as to whether we process their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked, or completed.

Data subjects whose personal data we process may—if and to the extent that the GDPR applies—revoke their consent at any time with future effect and object to the processing of their personal data at any time.

Data subjects whose personal data we process have the right to lodge a complaint with a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

4. DATA SECURITY

We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, despite such measures, the processing of personal data on the Internet can always present security gaps. We therefore cannot guarantee absolute data security.

Access to our online offering is secured by 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.

Access to our online offering is subject—as is all Internet use—to mass surveillance without cause or suspicion, as well as other surveillance by security authorities in Switzerland, the European Union (EU), the United States of America (USA), and other countries. We have no direct influence on the processing of personal data by intelligence services, police agencies, and other security authorities.

5. USE OF THE WEBSITE

5.1 COOKIES

We may use cookies on our website. Cookies—both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)—are data that is stored in your browser. Such stored data is not necessarily limited to traditional cookies in text form. Cookies cannot execute programs or transmit malware such as Trojans and viruses.

When you visit our website, cookies may be stored in your browser temporarily as "session cookies" or for a specific period of time as so-called permanent cookies. Session cookies are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they enable your browser to be recognized the next time you visit our website, allowing us to measure the reach of our website, for example. Permanent cookies can also be used for online marketing, for example.

You can disable cookies in your browser settings at any time, either completely or partially, and you can also delete them. Without cookies, our website may not be fully available. We actively request your express consent for the use of cookies, where and when necessary.

For cookies used to measure success and reach or for advertising, a general opt-out is possible for numerous services via the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance), or Your Online Choices(European Interactive Digital Advertising Alliance, EDAA).

5.2 SERVER LOG FILES

We may collect the following information for each visit to our website, provided that it 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 subpages of our website accessed, including the amount of data transferred, the last website accessed in the same browser window (referrer or referrer).

We store such information, which may also constitute personal data, in server log files. This information is necessary in order to provide our online services on a permanent, user-friendly, and reliable basis, as well as to ensure data security and, in particular, the protection of personal data—including by third parties or with the help of third parties.

5.3 COUNTING PIXELS

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

6. NOTIFICATIONS AND COMMUNICATIONS

We send notifications and communications such as newsletters by email and via other communication channels such as instant messaging.

6.1 SUCCESS MEASUREMENT AND REACH MEASUREMENT

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We require this statistical recording of usage for success and reach measurement in order to be able to offer notifications and messages in an effective and user-friendly manner that is also permanent, secure, and reliable, based on the needs and reading habits of the recipients.

6.2 CONSENT AND OBJECTION

You must expressly consent to the use of your email address and other contact details, unless such use is permitted for other legal reasons. Where possible, we use the "double opt-in" procedure for any consent to receive emails, which means that you will receive an email with a web link that you must click on to confirm, so that no misuse by unauthorized third parties can occur. We may log such consents, including Internet Protocol (IP) addresses and dates and times, for evidence and security reasons.

You can unsubscribe from notifications and communications such as newsletters at any time. This does not apply to notifications and communications that are essential for our services. By unsubscribing, you can object to the statistical recording of usage for the purpose of measuring success and reach.

6.3 SERVICE PROVIDERS FOR NOTIFICATIONS AND MESSAGES

We send notifications and messages via third-party services or with the help of service providers. Cookies may also be used for this purpose. We also ensure adequate data protection for such services.

In particular, we use:

• Mailchimp: Communication platform; provider: The Rocket Science Group LLC d/b/a Mailchimp (USA); information on data protection: privacy policy;"Mailchimp and European Data Transfers."

7. SOCIAL MEDIA

We are present on social media platforms and other online platforms in order to communicate with interested parties and provide information about our services. In doing so, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The general terms and conditions (GTC) and terms of use as well as privacy policies and other provisions of the individual operators of such online platforms also apply. These provisions provide information in particular about the rights of data subjects, including in particular the right to information.

We are jointly responsible with Facebook Ireland Limited in Ireland for our social media presence on Facebook, including the so-called Page Insights, insofar as the GDPR applies. Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to make our social media presence on Facebook effective and user-friendly.

Further information on the type, scope, and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy ("Data Policy"). We have concluded the so-called "Supplement for Controllers" with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the relevant information can be found on the pages "Information about Page Insights, "including "Page Insights Addendum Regarding the Controller" and "Information about Page Insights Data," both from Facebook.

Users of social media platforms have the option of logging in or registering for our online offering using their corresponding user account ("social login"). The respective terms and conditions of the social media platforms in question apply, such as general terms and conditions (GTC) and terms of use or privacy policies.

8. MEASURING SUCCESS AND REACH

We use Google Analytics to analyze how our website is used, which allows us to measure, for example, the reach of our website and the success of third-party links to our website. This is a service provided by the American company Google LLC. For users in the European Economic Area (EEA) and Switzerland, Google Ireland Limited is responsible.

Google also attempts to track individual visitors to our website when they use different browsers or devices (cross-device tracking). Cookies are also used for this purpose. Google Analytics requires your Internet Protocol (IP) address, but this is not combined with other data from Google.

In any case, we anonymize your Internet Protocol (IP) address before Google analyzes it. As a result, your full IP address is never transmitted to Google in the USA.

Further information on the type, scope, and purpose of data processing can be found in Google's privacy and security principles and privacy policy, in the guide to data protection in Google products (including Google Analytics), in the information on how Google uses data from websites that use Google services, and in the information on cookies at Google. It is also possible to use the "Browser Add-on to Deactivate Google Analytics" and to object to personalized advertising.

9. THIRD-PARTY SERVICES

We use third-party services to ensure that our offering is permanent, user-friendly, secure, and reliable. These services also enable us to embed content in our website. Such services—for example, hosting and storage services, video services, and payment services—require your Internet Protocol (IP) address, as otherwise they would be unable to transmit the relevant content. Such services may be located outside Switzerland and the European Economic Area (EEA), provided that adequate data protection is guaranteed.

For their own security-related, statistical, and technical purposes, third parties whose services we use may also process data related to our offering and from other sources—including cookies, log files, and tracking pixels—in aggregated, anonymized, or pseudonymized form.

9.1 DIGITAL INFRASTRUCTURE

We use third-party services to access the digital infrastructure required for our offering. These include, for example, hosting and storage services from specialized providers.

9.2 SOCIAL MEDIA FUNCTIONS AND SOCIAL MEDIA CONTENT

9.2.1 FACEBOOK

We use social plugins from Facebook to embed Facebook functions and Facebook content in our website. Such functions include, for example, "Like" or "Share." Cookies are also used for this purpose. Further information can be found on Facebook's "Social Plugins" page.

The social plugins are provided by Facebook Ireland Ltd. in Ireland or Facebook Inc. in the United States. If you are logged in to Facebook as a user, Facebook can assign your use of our online offering to your profile. Further information on the type, scope, and purpose of data processing can be found in Facebook's privacy policy ("Data Policy").

9.2.2 INSTAGRAM

We use the option to embed Instagram functions and content on our website. This allows us to display images published on Instagram on our website, for example. Cookies are also used for this purpose.

Instagram is a service provided by Facebook Ireland Limited in Ireland and Facebook Inc. in the United States. If you are registered as a user on Instagram or other Facebook services, Facebook may associate your use of our online services with your profile. Further information on the type, scope, and purpose of data processing can be found in Instagram's privacy policy.

9.3 ENTERTAINMENT

9.3.1 We use Vimeo to embed videos in our website. Cookies are also used for this purpose. Vimeo is a service provided by the American company Vimeo Inc. Further information on the type, scope, and purpose of data processing can be found in the questions and answers on data protection at Vimeo and in Vimeo's privacy policy.

9.3.2 We use YouTube to embed videos in our website. Cookies are also used for this purpose. YouTube is a service provided by the American company Google LLC. Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland. Further information on the type, scope, and purpose of data processing can be found in Google's privacy and security principles and privacy policy, in the guide to data protection in Google products (including YouTube), in the information on how Google uses data from websites that use Google services, and in the information on cookies at Google. It is also possible to object to personalized advertising.

9.4 FONT TYPES

We use Google Fonts to embed selected fonts in our website. No cookies are used for this purpose. This is a service provided by the American company Google LLC, which is offered independently of other Google services. For users in the European Economic Area (EEA) and Switzerland, Google Ireland Limited is responsible. Further information on the type, scope, and purpose of data processing can be found in Google's privacy and security principles and in Google's privacy policy.

9.5 ADVERTISING

We use Google Ads (formerly AdWords) to advertise our services on the Google search engine and elsewhere on the internet, for example on other websites, based on search queries, among other things. Google Ads is a service provided by the American company Google LLC. Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland. Cookies are also used in Google Ads. Google uses various domain names—in particular doubleclick.net, googleadservices.com, and googlesyndication.com—for Google Ads.

We use this type of advertising to reach people who are interested in our online offering or who already use our online offering. To do this, we transmit relevant information—including personal data—to Google (remarketing). We can also determine whether our advertising is successful, i.e., whether it leads to visits to our website (conversion tracking).

Further information on the type, scope, and purpose of data processing can be found in Google's privacy and security principles and privacy policy, in the information on how Google uses data from websites that use Google services, and in the information on cookies at Google. It is also possible to object to personalized advertising.

10. EXTENSIONS FOR THE WEBSITE

We use Google reCAPTCHA to protect input forms from bots and spam, while at the same time reliably enabling human input. Cookies are also used for this purpose. This is a service provided by the American company Google LLC. Google Ireland Limited is responsible for users in the European Economic Area (EEA) and Switzerland. Further information on the type, scope, and purpose of data processing can be found in Google's privacy and security principles and privacy policy, as well as in Google's information on cookies.

11. FINAL PROVISIONS

We may amend and supplement this privacy policy at any time. We will provide information about such amendments and supplements in an appropriate form, in particular by publishing the current privacy policy on our website.