Privacy Policy

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: December 19, 2025

Table of Contents

Controller

Ingrid & Reinhold Ruff
Egga 516
3925 Grächen
Switzerland

E-mail address:

Imprint: https://www.millegga-graechen.ch/impressum/

Overview of processing activities

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects concerned.

Types of data processed

  • Inventory data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of data subjects

  • Communication partners.
  • Users.

Purposes of processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (referred to as “Swiss DPA”). Unlike, for example, the GDPR, the Swiss DPA does not generally require a legal basis to be specified for the processing of personal data, and the processing of personal data is carried out in good faith, lawfully, and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). In addition, personal data is only collected by us for a specific purpose recognizable to the data subject and is only processed in a manner compatible with that purpose (Art. 6 para. 3 of the Swiss DPA).

Security measures

In accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances, and purposes of processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or there are no further legal bases for the processing. This applies in cases where the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for the prosecution of legal claims or for the protection of the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are several indications of the retention period or deletion deadlines of a date, the longest period always applies. We process data that is no longer required for the originally intended purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:

  • 10 years – Retention period for books and records, financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices, as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (OR)).
  • 10 years – Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries, based on past business experience and customary industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is relevant, which is applicable in certain cases (Art. 127, 130 OR). After five years, claims for rent, lease, and capital interest, as well as other periodic payments, from the supply of food, for catering and for inn debts, as well as from handicraft work, small retail of goods, medical care, professional work of lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees expire (Art. 128 OR).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the time when the termination or other end of the legal relationship becomes effective.

Rights of data subjects

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right to information: You have the right to request confirmation as to whether personal data relating to you is being processed, and to receive the information necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data that you have provided to us in a common electronic format.
  • Right to rectification: You have the right to request the rectification of incorrect personal data concerning you.
  • Right to object, erasure, and destruction: You have the right to object to the processing of your data, as well as to request that the personal data concerning you be erased or destroyed.

Provision of the online offer and web hosting

We process the data of users in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files regarding logins or the retrieval of data or access times.).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the “General information on data storage and deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the accessed web pages and files, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used on the one hand for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offers, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal requirements. For this purpose, we obtain the user’s consent in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. These include, for example, the storage of settings and the ensuring of the functionality and security of our online offer. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g., as part of obtaining consent), they should assume that these are permanent and the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their given consents at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which the user’s consent to the use of cookies or to the procedures and providers mentioned in the context of the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read, and process information on the user’s devices. Within the framework of this procedure, the user’s consents for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the option of managing and revoking their consents. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of consent (e.g., categories of cookies and/or service providers concerned) and information about the browser, the system, and the device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Contact and request management

When contacting us (e.g., by post, contact form, e-mail, telephone, or via social media) and within the framework of existing user and business relationships, the information of the requesting persons is processed to the extent necessary to answer the contact inquiries and any requested measures.

  • Processed data types: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and posts as well as the information concerning them, such as information on authorship or time of creation); usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the “General information on data storage and deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Amendment and update

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definition of terms

In this section you will find an overview of the terms used in this privacy policy. If the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to serve understanding.

  • Inventory data: Inventory data includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions or systems by enabling unique assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
  • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses and e-mail addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Meta-data, also known as data about data, includes information that describes the context, origin and structure of other data. They may include information about file size, creation date, author of a document, and change histories. Communication data captures the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and through which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission or deletion.

Created with free privacy policy generator Dr. Thomas Schwenke