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Privacy Policy

This data protection declaration provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name gemmi-health.ch. In particular, we provide information on why, how, and where we process which personal data. We also provide information about the rights of individuals whose data we process. For individual or additional activities and operations, we may publish further data protection declarations or other information on data protection.

We are subject to Swiss law and any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).

The European Commission recognized this with its decision of July 26, 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. In its report dated January 15, January 2024, the European Commission confirmed this adequacy decision.

1. Contact addresses

The following is responsible in terms of data protection law:

Gemmi Lodge & Spa 2350
Gemmi Lodge & Spa 2350
Gemmistrasse 14
3954 Leukerbad

roger.buechel@gemmi.ch

In individual cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We will be happy to provide data subjects with information about the respective responsibility upon request.

2.1 Terms

Data subject: Natural person about whom we process personal data.

Personal data: All information relating to an identified or identifiable natural person.

Sensitive personal data: Data relating to trade union, political, religious, or philosophical views and activities, data concerning health, privacy or membership of an ethnic or racial group, genetic data, biometric data that uniquely identifies a natural person, data concerning criminal and administrative sanctions or prosecutions, and data concerning social assistance measures.

Processing: Any handling of personal data, regardless of the means and procedures used, for example, querying, comparing, adapting, archiving, storing, reading, disclosing, obtaining, recording, collecting, deleting, disclosing, arranging, organizing, saving, changing, distributing, linking, destroying, and using personal data.

European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway.

We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).

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

  • Art. 6 (1) (b) 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 (1) (f) GDPR for the necessary processing of personal data to safeguard legitimate interests – including the legitimate interests of third parties – unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests include, in particular, the long-term, people-friendly, secure, and reliable exercise of our activities and operations, ensuring information security, protection against misuse, enforcing our own legal claims, and complying with Swiss law.
  • Art. 6 para. 1 lit. nbsp;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 (1) (e) GDPR for the necessary processing of personal data to perform a task carried out in the public interest. 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 (1) (a) GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6 (1) (d) GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.
  • Art. 9 (2) et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.

The European General Data Protection Regulation (GDPR) defines the processing of personal data as the processing of personal data and the processing of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).

3. Nature, scope, and purpose of personal data processing

We process personal data that is necessary to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The personal data processed data processed may fall into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data, and payment data. Personal data may also constitute particularly sensitive personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, insofar as such processing is permissible.

We process personal data, where necessary, with the consent of the persons concerned. In many cases, we can process personal data without consent, for example to comply with legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required.

We process personal data We process personal data for the duration necessary for the respective purpose. We anonymize or delete personal data in particular in accordance with statutory retention and limitation periods.

4. Disclosure of personal data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialized providers whose services we use.

We may disclose personal data in the course of our activities and operations, in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers , cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, parent, sister, and subsidiary companies , organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

5. Communication

We process personal data in order to communicate with individuals, authorities, organizations, and companies. In particular, we process data that a data subject provides us with when contacting us, for example by letter or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data about other individuals are obliged to ensure the data protection of these individuals themselves. In particular, they must ensure that such data is accurate and may be transmitted.

6. Data security

We take appropriate technical and organizational measures to ensure data security commensurate with the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability, and integrity of the personal data processed, without, however, being able to guarantee absolute data security. Access to our website and our other digital presence is via transport encryption (

Access to our website and our other digital presence is provided using transport encryption (SSL / TLS, in particular with the 7. Personal data abroad

We process personal data in principle in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular for processing or to have it processed there.

We may export or transfer personal data to all countries on earth and elsewhere in the universe, provided that the law there complies with decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance with decision of the European European Commission ensures adequate data protection.

We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the express consent of the data subjects or a direct connection to the conclusion or execution of a contract. We will be happy to provide data subjects with information about all of this upon request. explicit consent of the persons concerned or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees.

8. Rights of data subjects

8.1 Data protection claims

We grant data subjects all claims in accordance with applicable law. Data subjects have the following rights in particular:

  • Information: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage storage, any disclosure or export of data to other countries, and the origin of the personal data.
  • Correction and restriction: Data subjects can correct inaccurate personal data, complete incomplete data, and have the processing of their data restricted.
  • Opportunity to express one's own point of view and request human review: Data subjects may express their own point of view and request human review in the case of decisions that are based solely on automated processing of personal data and that have legal consequences for them or significantly affect them (automated individual decisions). automated individual decisions), express their own point of view and request verification by a human being.
  • Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with future effect.
  • Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller.

We may postpone, restrict, or refuse the exercise of data subjects' rights within the legally permissible scope. We may inform data subjects of any prerequisites that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part, citing confidentiality obligations, overriding interests, or the protection of other persons. . For example, we may also refuse to delete personal data in whole or in part, in particular with reference to statutory retention obligations.

We may charge a fee for exercising these rights in exceptional cases. We will inform the persons concerned in advance of any costs that may be incurred.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

Data subjects have the right to enforce their data protection claims in court or to lodge a complaint or report with a data protection supervisory authority.

The data protection supervisory authority for private controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

European data protection supervisory authorities are organized as members members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), data protection authorities are are structured along federal lines, particularly in Germany.

9. Use of the website

9.1 Cookies

We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies)& nbsp;– are data that are stored in the browser. Such stored data are not necessarily limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a specific period of time as so-called permanent cookies. “Session cookies” are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies enable us, in particular, to recognize a browser when it next visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example. Cookies can be completely or partially deactivated, restricted, or deleted at any time in the browser settings. The browser settings often also allow for automated deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies, at least to the extent required by applicable law.

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

9.2 Logging

We may log at least the following information for each access to our website and our other digital presence, provided that this information is determined or transmitted as standard when such accesses are made to our digital infrastructure: Date and time including time zone, 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 amount of data transferred, last website accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files. This information is necessary in order to provide our digital presence in a permanent, user-friendly, and reliable manner. The information is also necessary to ensure data security, including by third parties or with the help of third parties.

9.3 Tracking pixels

We may integrate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels—including those from third parties whose services we use—are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when you access our digital presence. Tracking pixels can be used to collect at least the same information as is recorded in log files.

10. Notifications and communications

10.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels which 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 send notifications and messages effectively and in a user-friendly manner, as well as permanently, securely, and reliably, based on the needs and reading habits of the recipients.

10.2 Consent and objection

You must always consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. We may use the “double opt-in” procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may store the consent obtained, including IP address and timestamp for evidence and security reasons.

You can in principle object to receiving notifications and communications such as newsletters at any time. By objecting, you can also object to the statistical recording of usage for the purpose of measuring success and reach. This does not apply to necessary notifications and communications in connection with our activities and operations.

10.3 Service providers for notifications and communications

We send notifications and communications with the help of specialized service providers.

In particular, we use:

  • SendGrid: Platform for transactional emails (“Email delivery made easy”); Providers: Twilio Inc. (USA) / Twilio Ireland Limited (Ireland) ; information on data protection: Privacy Policy.

11. 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 activities. In connection with such platforms, 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 platforms also apply. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.

For our social media presence on Facebook, including the so-called page insights, we are – insofar as the General Data Protection Regulation (GDPR) applies – – together with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). 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 about the type, scope, and purpose of data processing, information about the rights of data subjects, and the contact details of Facebook and Facebook's data protection officer can be found in the Facebook Privacy Policy. We have concluded the so-called “Supplement for Controllers” with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For so-called Page Insights, the relevant information can be found on the page " Information about Page Insights“ page, including ”Information about Page Insights data".

12. Third-party services

We use specialized third-party services to ensure that our activities and operations are sustainable, user-friendly, secure, and reliable. friendly, secure, and reliable. These services enable us, among other things, to embed functions and content into our website. When embedding such content, the services used collect the IP addresses of users, at least temporarily, for technical reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data in order to be able to offer the respective service.

In particular, we use:

Digital infrastructure

We use services from specialized third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.

In particular, we use:

13. Success and reach measurement

We try to measure the success and reach of our activities and operations. In this context, we can also measure the impact of third-party references or check how different parts or versions of our digital presence are used (A/B testing method). Based on the results of the success and reach measurement, we can, in particular, correct errors, strengthen popular content, or make improvements.

In most cases, the IP addresses of individual users are recorded for success and reach measurement. In this case, IP addresses are always shortened (“IP masking”) in order to comply with the principle of data minimization through appropriate pseudonymization.

Cookies may be used to measure success and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the location (at least approximately). As a matter of principle, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services to which users are registered may assign the use of our online offering to the user account or user profile for the respective service.

In particular, we use:

14. Final notes on the data protection declaration

We have created this data protection declaration using the data protection generator protection generator from Daten­schutz­partner

We may update this privacy policy at any time. We will inform you of any updates in an appropriate manner, in particular by publishing the current privacy policy on our website.