Home Page / Data Protection Notice /

General HOPPE privacy policy

1. Subject matter and scope

We take the protection of your personal data very seriously. With this Privacy Policy, we would like to inform you about which personal data we collect and how and for what purposes it is processed.

This Privacy Policy applies to visits to our website and to various other data processing operations, for example when you visit our social media pages, when you contact us, when we work with you as a customer or as a supplier or when you apply to work for us as an employee or other third party.

We always treat your personal data in accordance with the statutory data protection regulations and this Privacy Policy.

2. Controller and data protection officer

2.1 Controller of the data processing is as follows:

HOPPE Holding AG
Via Friedrich Hoppe
7537 Müstair
Switzerland
[email protected]

2.2 Data Protection Officer for the HOPPE Group:

Christian Schmoll, lawyer, IT law specialist, CIPP/E, CIPM, FIP, DSB (TÜV)
LUCID Compliance GmbH
Ledererstrasse 19
80331 Munich
Germany
E-mail: [email protected]

3. Visiting our website

Each time you visit our website, our system automatically collects data and information from the computer system of the accessing computer. In order for the pages to be displayed in your browser, the IP address of the end device you are using must be processed. In addition, there is further information about the browser of your end device.

Ensuring the confidentiality and integrity of the personal data processed with our IT systems is of great importance to us. The data is also used to correct errors on websites.

For these purposes, the following data is logged:

  • IP address of the calling computer
  • Operating system of the calling computer
  • Browser version of the calling computer
  • Name of the retrieved file
  • Date and time of the retrieval
  • Amount of data transferred
  • Referring URL

This data is regularly deleted automatically after a few days.

Our websites are hosted by a data processor on the basis of a data processing pursuant to Art. 28 GDPR.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation of this website and the implementation of the protection goals of confidentiality, integrity and availability of the data.

4. Content Delivery Network (CDN)

We use the Content Delivery Network (CDN) of the service provider Cloudflare Germany GmbH in Germany (hereinafter “Cloudflare”) to increase the security and delivery speed of the website and the platform. A CDN is a network of servers distributed worldwide that is capable of delivering optimized content to users. For this purpose, personal data may be processed in server log files by Cloudflare.

Cloudflare acts as a data processor for us on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Since a CDN represents a network of servers distributed worldwide, the use of a CDN may result in the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (EU Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is to increase the security and delivery speed of the website and the platform.

5. Contacting us

If you contact us to request information or documents, the information you provide will be stored for the purpose of processing your request.

We need the information requested in a contact form on the website to process your enquiry, to address you correctly and to send you a reply.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is communication with interested parties, visitors and customers as well as our interest in marketing our products.

If the contact or communication is aimed at the conclusion of a contract or takes place within the context of an existing contractual relationship, the legal basis for the processing is Art. 6 (1) lit. b) GDPR.

Enquiries and orders are stored in our CRM system for as long as this is necessary to achieve the above stated purposes or as stipulated by the storage periods provided for by law.

6. Customer and supplier data

We process the data of our prospective customers, customers, service providers and suppliers within the framework of the provision of our contractual services. In doing so, we may process master data (such as name and address), contact data (such as e-mail address and telephone number), content data (such as photos and videos), contract data (such as subject matter of the contract and term), payment data and data collected in the course of providing the service and/or processed to provide the service. This data is regularly stored in our CRM system (see also above under ”Contacting us”).

The legal basis for this storage and processing is the fulfilment of the contract or the implementation of pre-contractual measures pursuant to Art. 6 (1) lit. b) GDPR.

7. Customer portal

When you register to use our customer portal, we process the personal data required to set up and manage your customer account. This currently includes the following information (to the extent provided): name of the contact person including functional area/function, customer number, telephone and fax number as well as the e-mail address,

The legal basis for the processing of your personal data is Art. 6 (1) lit. b) GDPR if the data processing is necessary for the performance of a contract. If it is not you but your employer who maintains a contractual relationship with us, the legal basis is the legitimate interest, Art. 6 (1) lit. f) GDPR. Our legitimate interest is the provision of our service/fulfilment of our contractual obligation to our customer.

Your personal data will be stored for the use of the customer portal no longer as required to achieve the above stated purposes or as stipulated by the storage periods provided for by law.

8. Newsletter

8.1 Registration for our newsletter

On our website, you can register to receive a newsletter by e-mail. During registration, the data from the input screen, the IP address of the calling computer and the date and time of registration are transmitted to us. For the processing of the data, your consent is obtained during registration and reference is made to this Privacy Policy.

In order to verify that a registration for the sending of a newsletter is made by the actual owner of an e-mail address, we use the so-called “double opt-in” procedure. In this process, after registration of an e-mail address, a confirmation e-mail is sent to the registered e-mail address. Registration for the newsletter is only completed when a confirmation link contained in the confirmation e-mail is activated. The IP address of the calling computer and the date and time of activation of the confirmation link are also transmitted to us.

The registration for the newsletter can be terminated at any time by using the unsubscribe link contained in each newsletter or by contacting us at the above contact details.

The legal basis for the processing of data after registration for the newsletter is your consent pursuant to Art. 6 (1) lit. a) GDPR.

8.2 Newsletter analysis

A statistical analysis of usage data may be carried out for our newsletters. For this purpose, we may record both the openings of the e-mail and the internal clicks. This information serves the purpose of measuring and optimizing the success of our newsletter campaigns by making the newsletter content more relevant to our target group.

The legal basis for this analysis is your consent pursuant to Art. 6 (1) lit. a) GDPR.

8.3 Newsletter service provider

We use an external service provider as a data processor for sending and analyzing our newsletter on the basis of a data processing agreement pursuant to Art. 28 GDPR. Currently, the service provider used is Inxmail.

This may involve the transfer of personal data to a third country outside the EU. If this is the case, we provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses/Standard Data Protection Clauses) at any time upon request. Please contact us using the contact details above.

9. Cookies and third-party tools/functions

Our website uses cookies and implements third-party tools and functions.

Cookies are pieces of information that are transferred from our web server or third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Information is stored in cookies that is related to the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that we gain immediate knowledge of your identity.

We also use third-party tools and functions, for example, to expand the functional scope of the website, to analyze the use of the website, and to optimize the content accordingly.

When integrating tools and functions from third-party providers, personal data may be transmitted to the providers of the integrated tools and functions in order to be able to provide the tools and functions.

Cookies and third-party tools and functions are hereinafter uniformly referred to as “cookies” for the sake of simplicity.

9.1 Essential and Non-Essential Cookies

When visiting our website, cookies are set that are absolutely necessary for the operation of the website. These essential cookies may be, for example, cookies that are required for the display of the website with a content management system, which are used to recognize language settings, or which are used to document whether you have consented to the setting of further (non-essential) cookies or whether you have rejected them.

The technically necessary cookies, including their purpose and storage period or deletion period, are explained to you in our cookie banner, which is displayed when you access the website.

The legal basis for the processing of personal data using essential cookies is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation and provision of our website.

We also use non-essential cookies, for example to collect additional information about the interests of visitors to our websites or about their usage behavior, to analyze and optimize our website and generally our customer interactions on this basis.

Non-essential cookies, including their purpose and storage period or deletion period, are also explained to you in our cookie banner, which is displayed when you access the website.

Non-essential cookies are only set if you have expressly consented to the setting of non-essential cookies. You can also select different categories of non-essential cookies that you wish to allow in the cookie banner.

9.2 Consent Management

On our website, we use the cookie consent management tool Borlabs to obtain your consent to store certain cookies in your browser and to document this in accordance with the relevant data protection law. The provider is Borlabs GmbH, Hamburger Str. 11, 22083 Hamburg, Germany (hereinafter Borlabs).

When you access our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are being stored. This data is not shared with the Borlabs provider. You can change the Borlabs settings here:

Cookie preferences

The collected data will be stored until you request us to delete it or until you delete these Borlabs or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on data processing by Borlabs can be found at: What data does Borlabs cookie store?

The legal basis for this data processing is initially Art. 6 (1) lit. f) GDPR, the provision of our website and ensuring the possibility to obtain consent for non-essential cookies. If you give consent, the legal basis for the processing of the data relating to your consent is Art. 7 (1) and 6 (1) lit c) GDPR.

10. Web analysis via Google Analytics

We use the Google Analytics service with IP anonymization for usage analysis. Google Analytics is provided by Google Ireland Limited in Ireland (hereinafter “Google”).

JavaScript tags allow us to collect information about your use of the platform. Google Analytics also regularly uses cookies to collect information about a user's interactions with the platform.

As part of the use of Google Analytics, your IP address and information about the use of the platform, browser type and version, operating system used, the previously visited page and the time of the server request are transmitted to Google servers and processed there.

Within the scope of IP anonymization, the collected IP addresses of users within the European Economic Area are shortened before being transmitted to the USA. Only in exceptional cases, in the event of technical malfunctions in Europe, will the unabbreviated IP address be transmitted to Google in the USA and shortened there. The transmitted IP addresses are not merged with other data from Google.

Google will act for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

As explained, this may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) a) GDPR.

You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser or activating the “Do Not Track” setting of your browser. You can also prevent the collection of data generated by the Google cookie and related to your use of the website (incl. your IP address) and the processing of this data by Google by downloading and installing the browser plug-in available at the following link https://tools.google.com/dlpage/gaoptout?hl=en. Google's security and privacy policy can be found at https://policies.google.com/privacy.

11. YouTube

YouTube videos are embedded on our website. These are provided, via a plugin, by Google Ireland Ltd. in Ireland (“YouTube”).

We use the “extended data protection settings” for embedded YouTube videos, this means that YouTube does not set any cookies.

Nevertheless, when you visit a website with the YouTube plugin, a connection to YouTube is inevitably established and your IP address is transmitted to YouTube in the process.

When using YouTube, personal data may be transferred to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses/Standard Data Protection Clauses) at any time upon request.

Further information on data protection at YouTube can be found in YouTube's Data Protection and Security Centre: https://support.google.com/youtube/topic/2803240?hl=en&ref_topic=6151248&sjid=3625751773740300425-EU

The legal basis for this data processing when using YouTube is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is the integration of videos and the associated optimization of the interactivity of our website and our customer interactions.

12. Social media buttons

Social media buttons of various social media networks (e.g., Xing, LinkedIn, Facebook) are integrated on our website.

If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account on the social media network.

For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policies of the providers of the social media networks.

The legal basis for the integration and use of the social media buttons is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is the marketing of our offers and our website.

13. Social media pages (“fanpages”)

We maintain a publicly accessible profile on various social media networks, for example Facebook, YouTube and/or LinkedIn (“social media pages” or “fan pages”).

If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account on the social media network and supplement it there. Even if you are not logged in or if you do not have an account on the respective social media network, personal data may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.

The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.

If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal data that takes place there. For information on the collection and processing of your personal data that takes place there, please refer to the privacy policies of the respective social media network. We do not have any further information on this.

You can assert your data subject rights in accordance with Chapter III of the GDPR (right to information, correction, deletion, restriction of processing, data portability, etc.) both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal data and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider.

The legal basis for our use of social media pages is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the presence and marketing of our products and services on the Internet.

14. Applications

We collect and process the personal data transmitted to us by an applicant for the purpose of carrying out the application process. The data requested as mandatory fields are required for the application process. All other information is voluntary. Applicant data is only made accessible to those persons in our company who prepare the hiring decision or are involved in it. This may involve relevant employees of affiliated companies.

If we conclude an employment contract with an applicant, the data provided will be processed for the purpose of implementing the employment relationship in compliance with the statutory provisions.

If an employment relationship is established, we store the applicant data for as long as it is required for the employment relationship and to the extent that legal regulations justify an obligation to store it.

If no employment contract is concluded with an applicant, we store the applicant data, subject to the jurisdiction, for a maximum of six months on the basis of our overriding legitimate interest in enabling the defense of claims or a function of preserving evidence in accordance with applicable anti-discrimination and equal treatment laws and regulations (e. g., Allgemeines Gleichbehandlungsgesetz (AGG) in Germany or Gleichbehandlungsgesetz (GIG) in Switzerland). After expiry of this period, the application documents are deleted unless the applicant has expressly consented to longer storage.

The legal basis for the processing of application documents is Art. 6 (1) lit. b) and f) GDPR.

If the applicant has consented to a longer storage of his/her data, we will store the data submitted as part of the application in our applicant pool for a further 2 years after the end of the application process in order to identify future positions of potential interest to the applicant and, if necessary, contact the applicant in this regard.

Such consent to the storage of application data in our applicant pool can be revoked at any time for the future. To do so, please send us an e-mail to [email protected].

The legal basis for the storage of application documents in our applicant pool is, if applicable, the applicant's consent pursuant to Art. 6 (1) lit. a) GDPR.

15. Video conferences

If you participate in a video conference, webinar or online meeting etc. (hereinafter “video conferences”) organized by us, we process your personal data as part of your participation.

When you participate in a video conference, various categories of data are processed. The scope of the data also depends on the data you provide before or during participation in a video conference.

If you participate in a video conference organized by us, you usually have to provide at least a name when registering. However, you can also use a pseudonym. Your IP address will also be processed to enable your participation, and login information and device/hardware information will be stored. Your e-mail address and profile picture will also be processed, if provided. If you dial in by phone, your phone number and IP address, if any, will be processed.

To enable participation in the video conference, data from your terminal's microphone and any terminal video camera and, if you share your screen, information from this “screenshare” are processed. You can switch off or mute the camera or microphone yourself at any time. You always decide yourself whether and which parts of your screen are shared.

Audio and video recordings of the video conference can be made. In this case, MP4 files of all video, audio and presentation recordings are processed. There will always be an indication of the recording if one is made and, if necessary, the explicit consent of the participants to the recording will always be obtained.

You may have the opportunity to use the chat, question or survey functions in a video conference. In this respect, the text entries you make are processed in order to display them in the video conference and, if necessary, to record them.

If German law is not applicable to the processing of employee data or if, in connection with participation in video conferences, the processing of personal data is not necessary for the establishment, implementation or termination of the employment relationship, but is nevertheless an elementary component of participation in a video conference, our overriding legitimate interest pursuant to Art. 6 (1) lit. f) GDPR is the legal basis for the data processing. In these cases, our legitimate interest is in the effective implementation of video conferences.

Furthermore, the legal basis for data processing when conducting video conferences is Art. 6 (1) lit. b) GDPR, insofar as the meetings are conducted in the context of contractual relationships or with a view to initiating a contractual relationship (for example, in the case of video conferences with our customers in the context of the implementation of a project or participation in a webinar).

Furthermore, the legal basis for data processing in the context of your participation in a video conference organized by us is our overriding legitimate interest pursuant to Art. 6 (1) f) GDPR. Our legitimate interest in these cases is the effective implementation of video conferences.

We use one or more service providers as processors for the implementation of video conferences on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. In this case, we provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses/Standard Data Protection Clauses) upon request. Please contact us using the contact details above.

16. Recipients of data

Within our company, your data will be received by those internal areas that need it to fulfil their tasks, where applicable to fulfil contracts with you, to process data with your consent or to protect our (overriding) legitimate interests.

Data will only be passed on to third parties within the framework of legal requirements. We only pass on your data to third parties if this is necessary, e. g. on the basis of Art. 6 (1) lit. b) GDPR for contractual purposes or to protect our overriding legitimate interest in accordance with Art. 6 (1) lit. f) GDPR in the effective performance of our business operations.

Insofar as we use service providers or third-party providers in the context of providing the website and/or providing our services, we take appropriate legal precautions as well as corresponding technical and organizational measures to ensure the protection of your personal data.

If, in the course of providing the website and/or our services, we use content or tools from service providers or third-party providers whose registered office is in a third country, data is regularly transferred to a third country. Third countries are countries in which the GDPR is not directly applicable law, i. e. countries outside the EU or the European Economic Area. The transfer of data to third countries only takes place if either an adequate level of data protection, consent or other legal permission, in particular appropriate safeguards in accordance with Art. 46 GDPR, exists.

17. Your rights

You have the right to free information about your stored personal data, its origin and recipient and the purpose of the data processing and a right to correction, blocking or deletion of this data. You also have the right to restrict processing and to object to processing.

You also have the right to have your data that we process, automatically handed over to you or to a third party in a common, machine-readable format.

To exercise your rights, please contact us using the contact details above.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

18. Withdrawal of consent

Some data processing operations are only possible with your express consent. You can withdraw your consent at any time. To do so, it is sufficient to send us an informal message by e-mail using the contact details provided above. The legality of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

19. Right to object

INSOFAR AS YOUR DATA IS PROCESSED TO PROTECT OUR OVERRIDING LEGITIMATE INTERESTS, AS EXPLAINED IN THIS PRIVACY POLICY, YOU MAY OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE. TO DO SO, PLEASE CONTACT US USING THE CONTACT DETAILS PROVIDED ABOVE.

IN PRINCIPLE, YOU ONLY HAVE THIS RIGHT TO OBJECT IF THERE ARE GROUNDS ARISING FROM YOUR PARTICULAR SITUATION (ART. 21 (1) GDPR). AFTER EXERCISING YOUR RIGHT TO OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE PROCESSED FOR THESE PURPOSES UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF THE PROCESSING IS FOR THE PURPOSES OF DIRECT MARKETING, YOU MAY EXERCISE YOUR RIGHT TO OBJECT AT ANY TIME (ART. 21 (2) GDPR) AND YOUR PERSONAL DATA WILL THEN NO LONGER BE PROCESSED FOR THE PURPOSES OF DIRECT MARKETING, REGARDLESS OF THE GROUNDS FOR THE OBJECTION.

20. Automated decision-making

We do not use automated decision-making including profiling.

21. Retention and deletion

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as stipulated by the storage periods provided for by law.

If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

22. Data security

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, enquiries or payment data that you send to us.

24. Changes to this privacy policy

We reserve the right to amend this Privacy Policy from time to time so that it always complies with the current legal requirements or in order to implement changes to our services in the Privacy Policy, e. g. when introducing new services. The new Privacy Policy will then apply to your next visit.

Version: November 2023