Privacy Policy

Privacy Policy of Andreas Graf, ZTM, Atelier für Zahntechnik AG

Version as of November 15, 2023

In this privacy policy, we, Andreas Graf, ZTM, Atelier für Zahntechnik AG (hereinafter referred to as “we” or “us”), explain how we collect and process personal data. This is not an exhaustive description; in some cases, other privacy policies or general terms and conditions, participation conditions, and similar documents may govern specific matters. Personal data refers to any information that relates to an identified or identifiable individual.

If you provide us with personal data of other individuals (e.g., family members, data of work colleagues), please ensure that these individuals are aware of this privacy policy and only share their personal data with us if you are permitted to do so and if these personal data are accurate.

This privacy policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”) and the Swiss Federal Act on Data Protection (“FADP”). Whether and to what extent these laws are applicable, however, depends on the individual case.

1. Responsible Entity

Responsible for the data processing activities described here is Andreas Graf, ZTM, Atelier für Zahntechnik AG. If you have any data protection concerns, you can communicate them to us at the following contact address: Andreas Graf, ZTM, Atelier für Zahntechnik AG, Falkenstrasse 23, 8008 Zürich, digital@graf-andi.ch.

2. Collection and Processing of Personal Data

We primarily process the personal data that we receive from our customers and other business partners in the context of our business relationships with them and from other individuals involved, as well as the data we collect from users of our websites, apps, and other applications.

To the extent permitted, we also obtain certain data from publicly accessible sources (e.g., debt enforcement registers, land registers, commercial registers, press, internet) or receive such data from authorities and other third parties. In addition to the data you provide us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with administrative and judicial proceedings, information related to your professional functions and activities (so that we can, for example, conclude and process business with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (if we do business with you personally), information about you given to us by people from your environment (family, advisors, legal representatives, etc.) so that we can conclude or process contracts with you or involving you (e.g., references, your address for deliveries, powers of attorney, information for compliance with legal requirements such as anti-money laundering and export restrictions, information from banks, insurance companies, sales and other business partners of ours about the services you use or provide (e.g., payments made, purchases made)), information from the media and the internet about you (if this is indicated in the specific case, e.g., in the context of an application, press review, marketing/sales, etc.), your addresses and possibly interests and other sociodemographic data (for marketing), data related to the use of the website (e.g., IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content retrieved, functions used, referring website, location information).

3. Purposes of Data Processing and Legal Basis

We use the personal data we collect primarily to fulfill our contracts with our customers and business partners. This includes, in particular, processing orders with our customers and purchasing products and services from our suppliers and subcontractors, as well as complying with our legal obligations at home and abroad. If you are acting for such a customer or business partner, you may naturally also be affected by this in your capacity with your personal data.

Furthermore, we process your personal data and that of other individuals, where permitted and as we deem appropriate, also for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

  • Offering and developing our offers, services, websites, apps, and other platforms on which we are present;
  • Communication with third parties and processing their inquiries (e.g., applications, media inquiries);
  • Reviewing and optimizing procedures for needs analysis for the purpose of direct customer approach, as well as collecting personal data from publicly accessible sources for customer acquisition;
  • Advertising and marketing (including conducting events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object at any time, and we will then put you on a block list against further advertising);
  • Market and opinion research, media monitoring;
  • Asserting legal claims and defense in connection with legal disputes and administrative procedures;
  • Prevention and investigation of criminal offenses and other misconduct (e.g., conducting internal investigations, data analysis to combat fraud);
  • Ensuring our operations, especially IT, our websites, apps, and other platforms;
  • Processing employment relationships, including all resulting rights and obligations.

To the extent that you have given us consent to process your personal data for specific purposes (for example, when you sign up to receive newsletters or undergo a background check), we process your personal data within the scope of and based on this consent, unless we have another legal basis and need one. Consent given can be revoked at any time, but this does not affect data processing that has already taken place.

4. Cookies / Tracking and Other Technologies in Relation to the Use of Our Website

We typically use “cookies” and similar techniques on our websites, which can identify your browser or device. A cookie is a small file sent to your computer or automatically saved on your computer or mobile device by the web browser used when you visit our website. When you visit this website again, we can recognize you, even if we don’t know who you are. In addition to cookies used only during a session and deleted after your website visit (“session cookies”), cookies can also be used to store user settings and other information over a certain period (e.g., two years) (“permanent cookies”). However, you can set your browser to reject cookies, save them only for a session, or delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies to better understand how you use our offers and content and to display personalized offers and advertising to you (which can also happen on websites of other companies; however, these companies do not learn from us who you are, if we even know that ourselves, as they only see that the same user who visited a certain page on our site is also on their website). Some of the cookies are set by us, some by partners with whom we collaborate. If you block cookies, certain functionalities (such as language selection) may no longer work.

By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these technologies. If you do not want this, you must adjust your browser or email program accordingly.

In cases where Google Analytics or other statistics services are used, to which no personal data (such as email addresses) are transmitted:

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), which relies on Google LLC (based in the USA) as a processor (both “Google”), www.google.com), with which we can measure and evaluate the use of the website (not personally identifiable). Permanent cookies set by the service provider are also used for this purpose. The service is configured so that Google truncates the IP addresses of visitors in Europe before forwarding them to the USA, making them untraceable. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data to draw conclusions about the identity of the visitors, create personal profiles, and link these data with the Google accounts of these individuals. To the extent that you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider according to their privacy policy. The service provider only informs us how our respective website is used (no information about you personally).

5. Data Sharing and Data Transfer Abroad

In the course of our business activities and for the purposes according to section 3, as far as permitted and as we deem appropriate, we also disclose data to third parties, either because they process it for us or because they want to use it for their own purposes. This particularly includes the following entities:

  • Service providers of ours, including processors (such as Microsoft and Google);
  • Dealers, suppliers, subcontractors, and other business partners;
  • Customers;
  • Domestic and foreign authorities, offices, or courts;
  • The public, including visitors to websites and social media;
  • Competitors, industry organizations, associations, organizations, and other bodies;
  • Other parties in potential or actual legal proceedings;
  • All of these are collectively referred to as “recipients.”

These recipients are partly in the country but can be anywhere in the world. You must particularly expect the transfer of your data to other countries in Europe and to the USA, where the service providers we use are located (such as Microsoft).

If a recipient is in a country without adequate legal data protection, we contractually oblige the recipient to comply with the applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be found here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless they are already subject to a legally recognized set of rules ensuring data protection, and we cannot rely on an exception. An exception may apply in particular in legal proceedings abroad, but also in cases of overriding public interest or if contract processing requires such disclosure, if you have consented, or if the data are generally accessible data made by you and you have not objected to their processing.

6. Duration of Storage of Personal Data

We process and store your personal data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing. This means, for example, for the duration of the entire business relationship (from initiation, processing to the termination of a contract) and beyond according to the legal storage and documentation obligations. It is possible that personal data are kept for the period during which claims can be made against our company and as long as we are otherwise legally obliged to do so or legitimate business interests require it (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they are generally deleted or anonymized, as far as possible. For operational data (e.g., system logs, logs), generally shorter retention periods of twelve months or less apply.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, and audits.

8. Obligation to Provide Personal Data

As part of our business relationship, you must provide the personal data necessary for the initiation and execution of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). Also, the website cannot be used if certain information required to ensure data traffic (such as IP address) is not disclosed.

9. Rights of the Data Subject

Within the framework of applicable data protection law and as far as provided therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing, and otherwise to object to our data processing, especially those for direct marketing purposes, profiling operated for direct advertising, and other legitimate interests in processing, as well as the right to the transfer of certain personal data for transmission to another entity (so-called data portability). Please note, however, that we reserve the right to assert the legally provided restrictions, for instance, if we are obligated to store or process certain data, have an overriding interest in doing so (to the extent we are allowed to rely on it), or need them for the assertion of claims. If there are costs for you, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Note that exercising these rights may conflict with contractual agreements and may have consequences such as early termination of the contract or cost implications. We will inform you in advance in such cases, where this is not already regulated contractually.

Exercising such rights usually requires you to prove your identity unequivocally (e.g., by a copy of an ID if your identity is not otherwise clear or can be verified). To assert your rights, you can contact us at the address provided in section 1.

Every data subject also has the right to enforce their claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

10. Changes

We may adjust this privacy policy at any time without prior notice. The version published on our website is the one that applies. If the privacy policy is part of an agreement with you, we will inform you about the update of the change by email or in another suitable manner in case of an update.