Data privacy policy

1. Subject Matter of Data Privacy and Legal Basis
2. Server Log Data
3. Contact Form / E-Mail
4. Online Job Applications
5. Registration for Vocational Taster Programme
6. Newsletter
7. Cookies
8. Web Analysis
   a) Google Analytics
   b) Hotjar
9. Retargeting / Remarketing
10. Integration of Videos
11. Other Services and Contents of Third-Party Providers
12. Links to our Social Media Presences; Sharing Contents
13. Recipients of Personal Data
14. Data Processing in Third Countries
15. Duration of Storage, Erasure
16. Your Rights
17. Our Data Protection Officer
18. Our EU Representative
19. Data Safety
20. Amendments

We,
Oertli Instrumente AG
Hafnerwisenstrasse 4
9442 Berneck Switzerland (Imprint)

(hereinafter also referred to as „we“ or „Oertli“)

as the Controller, would like to inform you below about aspects relevant to data privacy law regarding the use of the websites https://www.oertli-instruments.com and https://oertli-jobs.com (hereinafter also referred to collectively as the “Website”) and about your rights as the data subject.
For better readability, the generic masculine form is used in the following text. Female and other gender identities are also meant at the same time insofar as is necessary for the statement made.

Processing of your personal data takes place exclusively within the framework of the applicable statutory provisions of data privacy law, in particular the Swiss Federal Act on Data Protection („FADP“), the EU General Data Protection Regulation („GDPR“) and other statutory provisions on data privacy (hereinafter referred to collectively as “Data Privacy Laws”).

This Data Privacy Policy only applies to the Websites accessible under the domains oertli-instruments.com and oertli-jobs.com including all subdomains. Other internet sites and offers of Oertli are subject to the data privacy policies retrievable at those sites, where applicable. It is possible that further data privacy information will be made available to you in other situations where contact is established or where data is processed, and if so, you should take note of such information. The following information does not relate to the internet sites of other, external providers where links are provided on the Website.

Our registered office is in Switzerland and our website is operated from Switzerland so that, in principle, the processing of your personal data takes place in Switzerland, unless otherwise indicated in this Data Privacy Policy. Insofar as the data-processing is performed by us in Switzerland, as regards website visitors from the European Union (EU) or the European Economic Area (EEA), an adequate level of data protection is ensured in accordance with the adequacy decision of the EU for Switzerland.

The subject-matter of data privacy is the protection of personal data in the sense of the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR). Personal data means any information relating to an identified or identifiable natural person (the so-called data subject).

We process the following categories of personal data relating to you on a regular basis:

• Master data, especially your surname, first name and title.
• Contact data, especially your e-mail address, telephone number and address.
• Profile/Content data, especially the text you enter into blank spaces and the data contained in the correspondence between yourself and us.
• Use data, especially the pages of our Website that you visit, access times, your IP address and information contained in cookies.

We only process your data where permitted by an applicable legal provision. The processing of your data by us is based among other things on the following legal basis:

• Consent: We will process certain data solely on the basis of your express consent granted to us in advance and voluntarily. You are entitled to withdraw your consent at any time, with future effect.
• Performance of a Contract and/or Implementation of Pre-contractual Measures: For the negotiation and performance of a contractual relationship with Oertli especially, we require certain data from you.
• Satisfaction of a Legal Obligation: In addition, we process your personal data in order to satisfy statutory obligations such as, for example, supervisory requirements or safe-keeping obligations under commercial and tax law.
• Safeguarding Legitimate Interests: We will process certain data in order to safeguard our legitimate interests or those of third parties. However, this only applies where your interests do not take precedence in an individual case.

Please note that this is not a complete or exhaustive list of a possible legal basis, but, rather, merely examples intended to render the legal basis of data privacy law more transparent. Further information on the legal basis of individual instances of data-processing on our Website can be found in the explanations set out below.

Visits to our Website mean that the following information on the access obtained will be stored:

• IP address
• name of the web page and data file accessed,
• notification about successful access,
• the internet site from which you visit our Website (Referrer URL),
• time zone difference to GMT time zone,
• access status/http status code,
• quantity of data transferred in each case,
• date and time of the request made to server,
• browser (incl. language and version),
• operating system used on the computer sending the request.

This data is processed on the basis of our legitimate interest in making the Website available, in order to ensure the technical operation and safety of our IT systems. In doing so, our interest lies in enabling our Website and its technical functions to be used, also in the long term. This data is automatically processed when our Website is accessed. In this respect, corresponding information can be stored on your end device and/or access can be obtained to corresponding information already stored on your end device. The storage of and/or access to such information is essential in order to ensure the operation of our Website and IT security, and in order to make our Website available to you as intended. Otherwise it is not possible for you to use our website. We do not use the data to draw conclusions as to your identity.

The automatically collected data is, as a rule, deleted after the purpose for which it was collected no longer applies, unless another legal basis exists in an exceptional case. If another legal basis does exist, we will erase the data as soon as that basis ceases to exist.

We are unable to honour an objection against the collection and storage of your server log-in data because the data is necessary for the smooth operation of the Website.

You can get in touch with us using a Contact Form.

If you use the Contact Form, we will collect and store the following data:

• first name and surname
• e-mail address
• country
• message/request.

You can also inform us voluntarily about:

• postal code
• town/city
• name of your company
• telephone number.

Alternatively you can contact us using our e-mail address. In that case we will process the personal data you provide voluntarily (e.g. contact data such as name, e-mail address).

The data you provide using our Contact Form or by e-mail is transmitted to us via a secure connection (for details see No. 17). The collection, processing and use of your contact data takes place solely for the specific purpose of receiving and, if appropriate, responding to your request or query. The processing of data provided within the context of communication via the Contact Form or by e-mail takes place either in order to negotiate or perform a contractual relationship with you, or on the basis of our legitimate interest. In the latter case we have a legitimate interest in processing contact requests addressed voluntarily to us.

We will delete the data you provide as soon as the purpose of its collection ceases to exist, subject to the satisfaction of ongoing statutory safe-keeping obligations.

Where your data is processed on the basis of a legitimate interest, you are entitled to object to the storage of your personal data at any time. In that case we will no longer process your data unless we are able to prove a legitimate interest or are otherwise under a statutory obligation to store it. In order to exercise your right to object to the storage, please contact us in writing or by e-mail.

Please note, however, that we are unable to guarantee full data security for communication using the contact form and especially by e-mail. Especially where confidential information is involved, we therefore recommend dispatching such information using a secure communication channel, e.g. a standard postal service.

You can apply for vacant positions or send us an unsolicited job application. We will process the data you send us in connection with your application in order to verify your suitability for the position, the apprenticeship or internship (or, if appropriate, for other vacant positions) and in order to conduct the application procedure.

The processing of your personal data within the application procedure serves to prepare for or, if appropriate, perform an employment, apprenticeship or internship agreement. Hence, the processing of data is lawful insofar as it is necessary in connection with the decision about the establishment of a contractual relationship.

Evidently, your application to us is completely voluntary. If you do decide to apply, you should provide the personal data necessary in order to establish an employment relationship and/or an internship. Without such data we will be unable to take your application into account.

The storage of any additional information provided voluntarily by the applicant takes place on the basis of our legitimate interest in processing such additional information you provide voluntarily for the purpose of conducting the application procedure.

You are entitled to object to the processing of data provided voluntarily without stating any reasons, at any time, with future effect. In that case we will no longer process your data unless we are able to prove a legitimate interest or are otherwise under a statutory obligation to store it. In order to exercise your right to object to the storage, please contact us in writing or by e-mail.

Should the data be required after completion of the application procedure, e.g. for prosecution purposes, data may be processed in order to safeguard legitimate interests. In the present case our interest lies in enforcing or averting claims. If your application is unsuccessful your data will as a rule be erased 3 months after you are notified of our decision.

Should you be selected for a position during the application procedure, the data from the online application procedure will be incorporated into and processed within our personnel information system, insofar as it is necessary to establish and conduct the employment relationship.

Within the company, as a matter of principle only those persons who need the data for proper implementation of the application procedure will have access to it.

Within the context of the application procedure described, we use the services of the company rexx systems GmbH, Süderstrasse 75–79, 20097 Hamburg, Germany (“rexx”). The Swiss branch is rexx systems Schweiz AG, Badenerstrasse 623, 8048 Zurich. Following the entry and provision of personal data within the application procedure, your data will be transferred directly to rexx using an encrypted connection and will be stored in encrypted form on rexx servers in Germany.

The data processing by rexx takes place in this respect upon our commission on the basis of an agreement on commissioned data processing that we have concluded with rexx. In that agreement rexx agrees to protect the relevant personal data and to process it solely in accordance with our instructions and the commission we awarded. rexx will not process the relevant data for its own purposes.

The transfer of your personal data to Germany will take place in accordance with the applicable Data Privacy Laws, and appropriate contractual, technical and organizational measures are in place. Both the controller and the provider employ technical and organizational safety measures in order to protect your collected personal data against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Data transfers to Germany take place on the basis of the adequacy decision of the Swiss Federal Council (see https://www.newsd.admin.ch/newsd/message/attachments/75620.pdf).

Any questions concerning data privacy in connection with the application procedure should be addressed to hrm@oertli-instruments.com.

You can apply for our vocational taster programme using the navigation path Career. We will process the data that you provide to us in connection with your application in order to conduct the registration process and the vocational taster programme properly, and in order to take account of your professional preferences during the registration process. We will necessarily collect and store the following data within the context of your registration for the vocational taster programme:

• preferences concerning the apprenticeships,
• first name and surname,
• address, postal code, place of residence,
• date of birth,
• telephone number,
• e-mail address,
• current school year,
• curriculum vitae,
• relevant school reports.

You are also able to attach further documents you think are relevant, in the form of PDF files.

Processing of your personal data takes place in order to exercise our legitimate interest in proper implementation of the registration process and in order to take your preferences into account during the registration process.

The storage of any additional documents and information provided voluntarily takes place on the basis of our legitimate interest in processing such additional information you provide voluntarily for the purpose of conducting the registration process and the vocational taster programme.

You are entitled to object at any time to the processing in our legitimate interest without stating any reasons, with future effect. In that case we will no longer process your data unless we are able to prove a legitimate interest or are otherwise under a statutory obligation to store it. In order to exercise your right to object to the storage, please contact us in writing or by e-mail.

Within the company, as a matter of principle only those persons who need your personal data for proper implementation of the vocational taster programme will have access to it.

At various places on our Website we offer you the possibility of subscribing to our newsletter. We will collect and store the following data within the context of registration for our newsletter:

• salutation,
• first name and surname,
• e-mail address,
• country,
• product interests.
  

Within the context of registration for one of our newsletters the contents of which are specifically described, such contents govern the scope of the consent granted. Our newsletters also contain information about our products, offers, campaigns and our enterprise.

You may withdraw your consent at any time if, at a later point in time, you no longer wish to receive the newsletter. Notification in text form (e.g. per e-mail or letter) to the above-mentioned contact addresses will suffice. An unsubscribe link is also included in every newsletter.

We would also like to point out that your user behaviour is analyzed by us with regard to our newsletter after it is dispatched. The e-mails dispatched include so-called web beacons, also referred to as tracking/counting pixels, for analysis purposes. These are 1x1 pixel files that link to our Website and thus enable us to analyze your user behaviour with regard to our newsletter and thus to conduct statistical analyses (e.g. analysis of opening rates). This is done by collecting technical information, e.g. about your browser, your system, your IP address and the exact time of retrieval, as well as web beacons attributed to your e-mail address and linked to their own ID. In doing so, corresponding technical information can be stored on your end device and/or access can be obtained to corresponding information already stored on your end device. This takes place on the basis of your consent.

Tracking using web beacons is not possible if, in your e-mail programme, you have deactivated the display of images by default. In that case, however, the newsletter will not be displayed to you in full and you might not be able to use all the functions. If you manually activate the display of images, the above-mentioned tracking will take place.
Within the context of dispatching the newsletter we use the ActiveCampaign services of the provider ActiveCampaign LLC, 1 North Dearborn St., 5th Floor, Chicago, IL 60602, USA (hereinafter: “ActiveCampaign”). Subject to your consent to receipt of our newsletter, the above-mentioned data will be transferred to ActiveCampaign and possibly stored and processed on servers outside the EEA, in particular in the USA.

ActiveCampaign has been certified under the EU-U.S. Data Privacy Framework and under the Swiss-U.S. Data Privacy Framework (see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000GnH6AAK&status=Active). Any transfer of the personal data of persons resident in the EU to the USA is governed by the adequacy decision of the EU Commission based on the EU-U.S. Data Privacy Framework. Any transfer of the personal data of persons resident in Switzerland to the USA is governed by the standard contractual clauses agreed with ActiveCampaign, which are available here: https://www.activecampaign.com/legal/dpa.

The Website uses cookies and similar tracking technology (hereinafter referred to collectively as “Cookies”) for the best possible configuration of the Website. Among other things, this enables us to facilitate the navigation and to make the Website easy to use.

As a rule, cookies are small identifiers sent by our web servers to your browser and stored on your computer if permitted by your standard settings. They can be used to establish whether there has already been communication between your end device and us. They thus serve the purpose of making use more comfortable for you and of optimizing our offers by enabling us to analyze the use of our Website. Cookies can be placed by us or by third-party providers, for example by our partners for analysis, marketing and social media. The storage and use of cookies as well as the related data processing takes place either on the basis of our legitimate interests or your consent, insofar as you have expressly consented to the storage and use of cookies. Personal data may then be stored in cookies if this is technically necessary, if you have granted your consent or do not raise objections. The right to have recourse to another statutory legal basis remains expressly reserved.

If you grant us your consent to the use and storage of non-essential cookies (see below No. 7 b), c) and d)), you may withdraw that consent at any time with future effect in the cookie settings of our Website.

You can also prevent the storage of necessary cookies at any time by technical means, by selecting “do not allow any cookies” in your browser settings. The procedure for the technical management and deletion of cookies in the settings of your browser can be found in its help function.

You can also prevent the storage and use of all cookies by using technical browser add-ons that are free of charge, such as “Adblock Plus” (adblockplus.org/de) in combination with the “EasyPrivacy” list (easylist.to).

However, if you prevent the storage of all cookies, this can lead to restrictions in the functions of the Website.

a) Vercel (Hosting and website delivery)

Our website is hosted and delivered via Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. Vercel provides the infrastructure through which our website is made available. In this context, the following data may be processed:

• IP address
• date and time of request
• accessed pages or content
• browser and operating system information

This data is required to deliver the website, ensure system security and optimise performance. A transfer of data to the USA cannot be excluded. In such cases, data is transferred in compliance with Swiss data protection law, in particular by applying appropriate contractual safeguards such as standard contractual clauses. Further information: https://vercel.com/legal/privacy-policy

b) Payload CMS (Content Management System)

We use the Content Management System (CMS) Payload CMS to manage and provide website content. Payload is used as a technical system for content administration. In this context, technical data may be processed, in particular:

• access data (e.g. IP address)
• system and log data

The specific scope of data processing depends on the configuration and hosting setup of the system.

c) Frontify

We use external service providers to deliver and optimise our online offering. In this context, personal data may be processed. Frontify (CDN for media content) We use a Content Delivery Network (CDN) provided by the company Frontify AG, based in St. Gallen, Switzerland, to deliver images and media content efficiently. When content is accessed via the CDN, the following data in particular may be processed:

• IP address
• date and time of access
• requested content
• browser and device information

This data is required to ensure fast, stable and secure delivery of content. Processing is based on our legitimate interest in the secure and efficient provision of our website in accordance with Art. 31 revDSG. Further information: https://www.frontify.com/en/legal-and-privacy

d) Necessary Cookies

We use the following necessary cookies on our Website that are required for its functions and in the storage of which we have a legitimate interest since otherwise we would be unable to offer certain fundamental functions on our Website (e.g. you would otherwise have to reset the Website settings each time when switching pages):

cookiefirst-consent – Cookie
The cookiefirst-consent cookie is provided by Digital Data Solutions B.V. and stores the cookie settings selected for this website. These settings can be changed and consent can be withdrawn at any time. It is stored as a first-party cookie for 365 days.

cookiefirst-consent – Local Storage
The cookiefirst-consent entry is also stored in the website’s first-party local storage. It is provided by Digital Data Solutions B.V. and stores the selected cookie settings. These settings can be changed and consent can be withdrawn at any time. The information is stored permanently.

cookiefirst-id
The cookiefirst-id entry is provided by Digital Data Solutions B.V. and contains a unique identifier that enables CookieFirst to identify visitors to the website. The information is stored permanently in the website’s first-party local storage.

PHPSESSID
The PHPSESSID cookie is provided by The PHP Group and is generated by applications based on the PHP programming language. It serves as a general identifier for managing session variables during a website visit. The identifier usually consists of a randomly generated number and may be used, for example, to retain a visitor’s login status when navigating between pages. It is stored as a first-party cookie and expires when the session ends.

i18n_redirect
The i18n_redirect cookie is used to store a visitor’s local settings. The provider is unknown. It is stored as a first-party cookie for 366 days.

Necessary cookies can only be deactivated technically via your browser settings or by using browsers add-ons. Further details can be found in the paragraphs above. This can lead to restrictions of the functions on the website.

e) Performance Cookies

Performance cookies help us to better understand how users interact with our website and our contents, by analyzing information on use. In doing so we also employ cookies from third-party providers that, if placed, enable them to obtain information about your user behaviour and to use such information for their own purposes (see No. 8 et seq.). Kindly visit the websites of the third-party providers for further information on their use of cookies. We use the following performance cookies on our Website:

ActiveCampaign

• The cookie Prism__226269363 is set by ActiveCampaign LLC. It registers a unique ID for each website visitor to track how that visitor uses the website. This first-party cookie is stored for 360 days.

Google Analytics

• The cookies _ga, _ga_EWHJP3GD82 and _ga_WGXK7MO547 are set by Google Ireland Ltd. They register or store a unique ID for each website visitor and track how that visitor uses the website. The collected data is used for statistical purposes. These first-party cookies are stored for 400 days.
• The cookie _gat_UA-72920104-1 is used on websites with high traffic volumes to limit data collection and reduce the request rate. This restricts the amount of data that Google Analytics can collect from the website. This first-party cookie is stored for one minute.
• The cookie _gid registers a unique ID for each website visitor to track how that visitor uses the website. This first-party cookie is stored for 24 hours.

Hotjar

• The cookies _hjAbsoluteSessionInProgress and _hjFirstSeen are used by Hotjar Ltd. for performance and analysis purposes. Both first-party cookies are stored for 30 minutes.
• The cookie _hjIncludedInSessionSample_3112266 informs Hotjar whether a visitor is included in the data sample defined by the daily session limit of our website. This first-party cookie is stored for two minutes.
• The entry _hjRecordingEnabled is used for website tracking and is stored in first-party session storage for the duration of the session.
• The entry hjRecordingLastActivity registers a unique ID for each website visitor to store activities performed on the website. The data is stored in first-party session storage for the duration of the session.
• The cookie _hjSession_3112266 contains the current session data. This allows subsequent requests within the session period to be assigned to the same Hotjar session. This first-party cookie is stored for 30 minutes.
• The cookie _hjSessionUser_3112266 stores a unique Hotjar user ID for the website within the browser. This allows visitor behaviour during subsequent visits to be attributed to the same user ID. This first-party cookie is stored for 365 days.
• The cookie hjActiveViewportIds is used for performance and analysis purposes and is stored permanently.
• The entry hjViewportId records the screen resolution of the device used. The data is stored in first-party session storage for the duration of the session.

LinkedIn

• The cookie ln_or is set by LinkedIn Ireland Unlimited Company. It records statistical data about user behaviour on the website. This first-party cookie is stored for 24 hours.

The storage and use of performance cookies takes place on the basis of your consent insofar as you have granted it to us. Please see the above paragraphs and No. 8 below for further details. You are entitled to withdraw your consent at any time, with future effect, in the cookie settings on this Website.

f) Advertising / Tracking Cookies

In order to avail of marketing services (see No. 9) and links especially to social media products (see No. 12), we also employ cookies from third-party providers that enable them, for example, to obtain information about your user behaviour and to use such information for their own purposes. Kindly visit the websites of the third-party providers for further information about their use of cookies. We use the following advertising / tracking cookies:

Meta Pixel

• The cookie _fbp is set by Meta Platforms Ireland Ltd. for advertising purposes and conversion tracking. This first-party cookie is stored for 90 days

Google Ads and DoubleClick

• The cookie _gcl_au is set by Google Ireland Ltd. for Google AdSense experiments involving advertising across websites. This first-party cookie is stored for 90 days.
• The cookie IDE is set by Google Ireland Ltd. through DoubleClick. It is used to analyse and optimise advertising campaigns. This third-party cookie is stored for 390 days.

LinkedIn

• The cookie AnalyticsSyncHistory is set by LinkedIn Ireland Unlimited Company. It stores information about the time of synchronisation with the lms_analytics cookie for users in designated countries. This third-party cookie is stored for 30 days.
• The cookie bcookie is used by LinkedIn in connection with sharing buttons and advertising tags for retargeting purposes. This third-party cookie is stored for 365 days.
• The cookie li_gc stores the visitor’s consent to the use of LinkedIn cookies for non-essential purposes. This third-party cookie is stored for 180 days.
• The cookies li_sugr and lidc are used by LinkedIn in connection with sharing buttons and advertising tags for retargeting purposes. li_sugr is stored for 90 days, while lidc is stored for 24 hours. Both are third-party cookies.
• The cookie UserMatchHistory records visitor behaviour on the website and collects statistical information about website use, such as the time of the most recent visit. This third-party cookie is stored for 30 days.

YouTube

• The cookie VISITOR_INFO1_LIVE is set by Google Ireland Ltd. and enables YouTube to verify bandwidth usage. This third-party cookie is stored for 180 days.
• The cookie YSC registers unique IDs and enables statistical analysis of which videos users have viewed on YouTube. This third-party cookie is stored for the duration of the session.
• The entry yt-player-headers-readable stores the user’s individual configuration. The data is stored permanently in third-party local storage.
• The entries yt-remote-cast-installed, yt-remote-fast-check-period, yt-remote-session-app and yt-remote-session-name are used for retargeting purposes. They are stored in third-party session storage for the duration of the session.
• The entries yt-remote-connected-devices, yt-remote-device-id, yt.innertube::nextId, yt.innertube::requests and ytidb::LAST_RESULT_ENTRY_KEY are also used for retargeting purposes. They are stored permanently in third-party local storage.

The storage and use of advertising and tracking cookies takes place on the basis of your consent insofar as you have granted it to us. For further details on data processing and the purposes thus pursued, kindly see the above paragraphs and the following descriptions of the individual services and functions in No. 9 et seq., that are based on the use of such cookies. You are entitled to withdraw your consent at any time, with future effect, in the cookie settings on this Website.

a) Google Analytics

Insofar as you have granted corresponding consent, we use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Analytics employs so-called cookies. Hence, information can be stored on your end device and/or access obtained to information already stored on your end device (see also in this respect No. 5). The information generated by the cookie about your use of this Website is generally transferred to and stored on a Google server in the USA. The legal basis for the data processing is your consent. The right to have recourse to another statutory legal basis remains expressly reserved. The Google parent corporation, Google LLC, has been certified under the EU-U.S. Data Privacy Framework and under the Swiss-U.S. Data Privacy Framework (see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active). Any transfer of the personal data of persons resident in the EU to the USA is governed by the adequacy decision of the EU Commission. Any transfer of the personal data of persons resident in Switzerland to the USA is governed by the standard contractual clauses agreed with the Google parent corporation, Google LLC, which are available here: https://privacy.google.com/businesses/processorterms/mccs/.

At our request, Google will use such information to analyze your use of the Website, to compile reports about website activities and to provide further services to us relating to use of the Website and of the internet. Pseudonymous user profiles can be compiled using the processed data.

We use Google Analytics solely with activated IP anonymization. This means that within Switzerland and within the EU Member States and in other EEA Contracting States the user’s IP address is abbreviated by Google. The full IP address is communicated to a Google server in the USA and abbreviated there in exceptional cases only.

The data is erased as soon as it is no longer required for our recording purposes. In our case, as a rule, this will be after 14 months.

You are entitled to withdraw at any time your consent to the use of Google Analytics, in the cookie settings of this Website. You may also prevent the storage and use of cookies technically by means of corresponding browser settings or browser add-ons (see No. 5 above). You can also prevent the tracking by Google of the data (including your IP address) generated by the cookie and relating to your use of the Website and the processing of such data by Google by downloading and installing the browser plug-in available under the following link: tools.google.com/dlpage/gaoptout?hl=en.

Further information on the use of data by Google, on settings options and on raising objections can be found on the Google websites under the following links:

https://policies.google.com/technologies/partner-sites?hl=en (“Data use by Google when you use websites or apps of our partners”),

https://www.google.com/policies/technologies/ads (“Data use for advertising purposes”),

https://adssettings.google.de/anonymous?hl=en (“Manage information used by Google in order to display advertising to you”).

b) Hotjar

Insofar as you have granted your consent, we use Hotjar on our Website. This is analysis software offered by Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta (“Hotjar”). This tool enables the measuring and analysis of use behaviour (e.g. clicks, mouse movements, scroll heights, etc.) on our Website. In doing so, information can be stored on your end device and/or access can be obtained to information already stored on your end device (see also in this respect No. 5). The information thus generated by the tracking code and cookies about your visit to our Website is communicated to and stored on the Hotjar servers in Ireland. The following information can be captured by your device and your browser:

• IP address of your device;
• your e-mail address including your first name and your surname if you provided them via the Website, for example by filling in a form;
• screen dimensions of your device;
• type of device and browser information;
• geographical location (country only);
• preferred language for presentation of our Website;
• user interactions;
• mouse occurrences (movement, position and clicks);
• input using keyboard;
• date and time of access.

Hotjar will use this information upon our commission in order to analyze your use of our Website, to compile reports about such use and to provide other services relating to use of the Website. To this end we have entered into an agreement on commissioned data processing with Hotjar. Further information about Hotjar and on data privacy protection at Hotjar can be found at https://www.hotjar.com/privacy/.

You are entitled to withdraw at any time your consent to the use of Hotjar, in the cookie settings of this Website (see supra No. 5). You may also prevent the storage and use of cookies technically by means of corresponding browser settings or browser add-ons (see No. 5 above). You can also prevent the tracking of the data generated by the cookie and relating to your use of the Website and the processing of such data by Hotjar by activating the opt-out available under the following link: https://www.hotjar.com/opt-out.

In order to optimize the products we offer, we employ retargeting / remarketing services on our Website, also from third parties. The data processing and any storage and/or the harvesting of information on/from your end device takes place on the basis of your consent where you have granted it. The right to have recourse to another statutory legal basis remains expressly reserved.

a) How Retargeting/Remarketing works

Data is collected on our Website on the basis of cookie/tracking technology in order to optimize our advertising and the entire online product portfolio (so-called retargeting/remarketing). This data is not used by us to identify you personally, but, rather, serves to analyze the use of our Website and to present interest-related advertising to users who have already shown an interest in our contents and products offered on our Website and on other internet sites and social media channels of our partners. We believe that the insertion of interest-related advertising is generally more interesting to the user than advertising without such a personal connection. The insertion of advertising on our Website or on the websites of our partners takes place on the basis of an analysis of previous user behaviour. The compilation of user profiles is based on the information of the providers of the retargeting/remarketing services we employ, as a rule in anonymous or pseudonymous form. At no time is such data combined with the other personal data we store. The following part of this Data Privacy Policy details the third-party providers we work with, how your data is processed in that context, and explains how you can deactivate retargeting/remarketing technologies.

b) Google Ads/ Google Marketing Platform

On our Website we employ the function Remarketing or “Similar Segments” in Google Ads/Google Marketing Platform (formerly DoubleClick by Google) of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”).

Google uses cookie and tracking technologies stored on your end device in order to enable an analysis of your use of the Website and to display adverts for products or services that might interest you. According to Google, the cookies placed for this purpose do not contain personal information. The information generated by cookie and tracking technologies regarding your use of this Website is transferred to and stored on a Google server in the USA. If you are registered with and logged-in to a Google service, Google can attribute your visit to our Website to your account. Even where you are not registered with Google, it is possible for Google to obtain your IP address and thus to compile and store a user profile about you. We do not use the function of comparison with customer lists that is offered by Google.

Further information about the analysis of your search and surf behaviour is available here:

https://policies.google.com/privacy?hl=en and
https://www.google.com/policies/technologies/ads/ and
https://marketingplatform.google.com/about/enterprise/.

You can deactivate interest-related adverts at Google under the following link: http://www.google.com/settings/ads/plugin

c) Facebook Pixel

In addition, the services of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter: “Meta”), such as Facebook-Pixel, are used for retargeting/remarketing purposes on our Website.

When you visit our Website and if you grant the relevant consent to us, a direct connection is established between your browser and the Meta server located in the USA, using Facebook-Pixel. Meta is thus notified that you have visited our Website, and we are able to configure our Facebook activities more effectively and, for example, can display articles or adverts solely for visitors to our Website. Using Facebook-Pixel, we are able to analyze use of this Website and insert adverts concerning contents and products that might interest you. The data captured is transferred to Meta solely in encrypted form and is anonymous for us, i.e. we are unable to access the personal data of individual users. We do not use the “advanced matching” function in Facebook-Pixel.

For further information on Facebook-Pixel, on the nature, scope, purposes, legal basis of and options for raising objections to data processing by Meta and for your settings options to protect your private sphere, kindly see the Meta Data Privacy Policy at https://www.facebook.com/about/privacy/ and at https://www.facebook.com/business/‌learn/facebook-ads-pixel.

d) LinkedIn Insight Tags

In addition, services of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”), such as the LinkedIn Insight Tag, are used for retargeting/remarketing purposes on our Website.
When you visit our Website and if you grant the relevant consent to us, a direct connection is established using the LinkedIn Insight Tag between your browser and the LinkedIn server located in the USA. LinkedIn is thus notified that you have visited our Website, and we are able to configure our LinkedIn activities more effectively and, for example, can display contributions or adverts solely for visitors to our Website. Using the LinkedIn Insight Tag, we are able to analyze use of this Website and insert adverts concerning contents and products that might interest you. The data captured is transferred to LinkedIn solely in encrypted form and is anonymous for us, i.e. we are unable to access the personal data of individual users. We do not use the “matched audiences” function of the LinkedIn Insight Tag.

For further information on the LinkedIn Insight Tag, on the nature, scope, purposes, legal basis and objection options of data processing by LinkedIn and for your settings options to protect your private sphere, kindly see the LinkedIn Data Privacy Policy at https://www.linkedin.com/legal/privacy-policy and at
https://business.linkedin.com/marketing-solutions/insight-tag.

The consent you may have granted to the storage and use of cookies by us (including Facebook-Pixel and the LinkedIn Insight Tag) for retargeting/remarketing purposes can be withdrawn at any time by you with future effect in the cookie settings of this Website. You may also prevent the storage and use of marketing cookies (including Facebook-Pixel) technically by means of corresponding browser settings or browser add-ons (see No. 5 above).

YouTube videos are integrated on our Website. This service is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google” or “YouTube”). The data processing and any storage and/or the harvesting of information on/from your end device takes place on the basis of your consent where you have granted it, and otherwise on the basis of our legitimate interest. Our legitimate interest lies in the commercial operation of our Website and in optimizing our complete online product portfolio. The storage and/or harvesting of information on/from your end device is also essential in order to be able to make the desired service (viewing of integrated video) available. The right to have recourse to another statutory legal basis remains expressly reserved.

The YouTube videos integrated on our Website are stored at https://www.youtube.com and can be viewed directly from our website, they are all integrated in the “extended data privacy modus”, i.e. according to YouTube, no data about you as a user will be transferred to YouTube unless you view the videos. When the integrated video is accessed, as a rule a connection to YouTube servers in the USA is established and certain information (e.g. your IP address) is sent to and stored on YouTube servers in the USA, although you are not registered on that server. The Google parent corporation, Google LLC, has been certified under the EU-U.S. Data Privacy Framework and under the Swiss-U.S. Data Privacy Framework (see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active). Any transfer of the personal data of persons resident in the EU to the USA is governed by the adequacy decision of the EU Commission. Any transfer of the personal data of persons resident in Switzerland to the USA is governed by the EU standard contractual clauses concluded with the Google parent corporation, Google LLC, which are available here: https://privacy.google.com/businesses/processorterms/mccs/.

As a matter of principle, we have no knowledge of the nature and extent of the data collected by YouTube, nor do we have any influence on how it is used. Insofar as you have granted your consent to us, the services of YouTube can also be used for retargeting/remarketing purposes (see details in No. 5).

Further information on the purpose and scope of the collection, further processing and use of the data captured by Google and on your rights in that respect as well as the existing settings options in order to protect your privacy are set out in the data privacy policies of Google, which also include YouTube: policies.google.com/privacy?hl=en&gl=en.

If you do not want Google to attribute your visit to our Website to your user account there, you have to log out of the relevant service before visiting our Website. Although you are not registered with the third-party provider, data can be sent from websites with integrated videos to the third-party provider, using cookies, enabling the third-party provider to, for example, compile a user profile in anonymous/pseudonymous form.

You are entitled to withdraw at any time your consent to the storage and use of cookies in connection with the integrated videos, in the cookie settings of our Website (see supra No. 5). You may also prevent the storage and use of cookies technically at any time, by means of corresponding browser settings or browser add-ons (see No. 5 above).

We also use plugins from third-party providers on our Website in order to integrate their contents and services such as maps (hereinafter referred to collectively as “Contents”). The processing of your data and any storage and/or the harvesting of information on/from your end device takes place in that context on the basis of your consent where you have granted it, and otherwise on the basis of our legitimate interest. Our legitimate interest lies in the commercial operation of our Website and in optimizing our Website (especially its ease of use). In addition, the storage of and/or harvesting of information on/from your end device is essential in order to ensure the operation of our Website and IT security, and in order to make our Website available to you as intended. The right to have recourse to another statutory legal basis remains expressly reserved.

The third-party providers of such Contents always obtain knowledge of your IP address since without the IP address they are unable to transfer the Contents to your end device. The IP address is required for presentation of such Contents. Third-party providers may also place cookies on your end device. This information thus generated (including your IP address) is, if appropriate, transferred to and stored on the third-party providers’ servers in the USA. Data transfers to the USA are subject to the EU standard contractual clauses or a corresponding adequacy decision.

You can deactivate the downloading and storage of plugins as well as the use of cookies in the settings of your browser or by using browser add-ons such as “Adblock Plus” (https://adblockplus.org/en/) in combination with the “EasyPrivacy” list (https://easylist.to/) (see No. 5); however, we would like to point out that this might prevent the use of some functions of our Website.

a) Google ReCaptcha

In order to recognize Bots, e.g. where online forms are filled in, we use the “ReCaptcha” function provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Further information on the use of data by Google, on settings options and options for submitting objections to Google can be found on the Google websites under the following links:

https://policies.google.com/technologies/partner-sites?hl=en (“Data use by Google when you use websites or apps of our partners”);
https://www.google.com/policies/technologies/ads (“Data use for advertising purposes”);
https://adssettings.google.de/anonymous?hl=en (“Manage information used by Google in order to display advertising to you”).

b) Google Maps

For the presentation of maps we use the “Google Maps” service from the third-party provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google“). The data processed can include, in particular, IP addresses and location data which, however, will not be collected without your consent (as a rule, using corresponding device settings). Further information on the use of data by Google, on settings options and options for raising objections can be found on the Google websites under the following link: policies.google.com/privacy?hl=en.

c) Google Tag Manager

We use the “Google Tag Manager” provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, on our Website. Google Tag Manager enables us to manage other services we use on our Website, such as Google Analytics, without having to amend the source text of the Website.

Further information on the use of the Google Tag Manager can be found on the Google websites under the following links:

https://support.google.com/tagmanager/answer/9323295?hl=en (Google Data Privacy Policy);

https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/ (Terms of use for Google Tag Manager).

This Website contains links (hyperlinks) to the social networks and platforms of Facebook, LinkedIn, Instagram and YouTube. These services are offered by the enterprises (hereinafter also referred to as “Third-Party Providers”) listed below:

• Facebook is operated by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”).
• LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”).
• Instagram is operated by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”).
• YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

The purpose and scope of the collection, processing and use of the data by Meta, LinkedIn and YouTube and your corresponding rights and the existing settings options in order to protect your privacy are set out in the data privacy policies of the Third-Party Providers:

Facebook data privacy policy: https://www.facebook.com/privacy/explanation, https://de-de.facebook.com/legal/terms/ and https://www.facebook.com/about/privacy/update and
https://www.facebook.com/policies/cookies/;

LinkedIn data privacy policy: https://www.linkedin.com/legal/privacy-policy;

Instagram data privacy policy: https://help.instagram.com/519522125107875;

Google data privacy policy which also covers YouTube: https://policies.google.com/privacy?hl=en&gl=en.

If you do not want a Third-Party Provider to attribute your click on a link leading to its product portfolio to your user account there, you have to log out of the relevant service before clicking on the link. Even where you are not registered with the Third-Party Providers, data can be sent to those Providers after a link has been clicked, using cookies.

We only provide your personal data to external recipients if this is necessary in order to handle or process your concerns, if you have granted your consent or if there is statutory authorization.

Potential external recipients are, in particular:

• Processors: Processors are service providers we use for the provision of services, for example in the areas of technical infrastructure and maintenance of our Website. Such Processors are carefully selected by us and verified regularly to ensure that your privacy remains safeguarded. These service providers may use the data solely for the purposes we stipulate and in accordance with our instructions. Subject to the observance of statutory requirements, we are entitled to avail ourselves of such Processors.
• Public Offices: Public offices are authorities, government institutions and other entities governed by public law, for example supervisory authorities, courts, the prosecution services and the tax authorities. Personal data is communicated to such public offices solely on compelling statutory grounds. Satisfaction of a legal obligation constitutes the legal basis for such a communication, where applicable.
• Private Offices: Service providers and auxiliary personnel to which data is communicated on the basis of a statutory obligation or to safeguard legitimate interests, for example, tax advisors and auditors. The data is then communicated on the basis of your consent, the necessity of satisfying a contractual or legal obligation and/or our legitimate interests.

Insofar as we transfer your data to third countries outside Switzerland, the EU and/or the EEA in accordance with the above explanations, before the transfer we ensure that, save for exceptional cases permitted by law, there is either an adequate level of data protection at the recipient or that you consent to the transfer of data. An adequate level of data protection is ensured, for example, by certification of the recipient under the EU-U.S. Data Privacy Framework, by the conclusion of EU standard contractual clauses or by the existence of so-called Binding Corporate Rules (BCR). Please contact us via the above-mentioned communication channels in order to receive a copy of the specific guarantees for the transfer of your data to third countries.

We only store your personal data as long as it is required for the fulfillment of the purposes or - if consent has been granted - until you withdraw your consent. Should an objection be raised, we will no longer process your personal data unless continued processing thereof is permitted or even obligatory under the pertinent statutory provisions (e.g. within the context of safe-keeping obligations under commercial or tax law). We also erase your personal data when we are obliged to do so by law.

Apart from this, kindly consult the individual explanations in the sections mentioned above for details on the duration of the storage of your personal data.

As a data subject affected by the data-processing, you are entitled to numerous rights. These are, in detail:

• Right to Information: You are entitled to obtain information from us about the personal data about you that we have stored.
• Rights to Rectification and Erasure: You may require us to rectify data that is incorrect and - insofar as the statutory requirements are met - to erase your data.
• Right to Restrict Processing: Insofar as the statutory requirements are met, you may require us to restrict the processing of your data.
• Right to Data Portability: If you have provided data to us on the basis of a contract or your consent, where the statutory requirements are met, you may obtain the data you provided, in a structured and common format, or that we transfer such data to another responsible person or body.
• Right to Object to Data-Processing Based on Legitimate Interests: You are entitled to object at any time, on grounds relating to your particular situation, to the processing by us of personal data concerning you insofar as such data-processing is based on “legitimate interests”. If you exercise your right to object, we shall discontinue the processing of your data unless we are able to prove compelling grounds for the continued processing that merit protection, grounds that override your rights.
• Withdrawal of Consent: Insofar as you have granted your consent to us for the processing of your personal data, such consent may be withdrawn at any time with future effect. This shall not affect the lawful nature of the processing of your data up to the time your consent is withdrawn. Please note the explanations in No. 5 if you wish to withdraw your consent to the use of certain cookies.
• Right to Complain to a Supervisory Authority: You are also entitled to submit a complaint to the competent supervisory authority if you believe that the processing of your personal data is in breach of the law in force. To this end, you may choose to contact the data protection authority responsible for your place of residence, your place of work or the place of the suspected breach, or the data protection authority responsible for us. The data protection supervisory authority responsible for us according to the FADP is: Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter [Federal Data Protection and Information Commissioner], Feldeggweg 1, CH-3003 Bern, Switzerland, Tel.: +41 (0)58 462 43 95, Fax: +41 (0)58 465 99 96. An overview and the contact details of all European supervisory authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
  

In case of questions about the processing of your personal data, your rights as a data subject and any consent granted, please do not hesitate to contact us on the above-mentioned communication channels.

We have designated an external data protection officer. Our data protection officer can be reached via the following contact details:
c/o V-Formation GmbH
Stephanienstr. 18
76133 Karlsruhe, Germany
E-Mail: datenschutz.oertli-instrumente@v-formation.de Website: https://www.v-formation.de/

We have designated a representative in an EU member state. Our EU representative can be reached via the following contact details:

Simone Vonbank
Oertli Ophthalmedic Österreich GmbH
Schwefel 93 6850 Dornbirn, Austria
Website: https://www.oertli-ophthalmedic.at/impressum-agb
E-mail: simone.vonbank@oertli-ophthalmedic.at

We employ technical and organizational safety measures in order to protect your personal data against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons. These safety measures are adjusted accordingly in each case, taking into account the current state of the art.

Your personal data transferred within the context of your use of our Website is transferred safely by us in encrypted form. In doing so, we employ the encryption protocol Transport Layer Security (TLS), more broadly known under its previous name Secure Socket Layer (SSL).

A confidentiality obligation is imposed on our employees.

From time to time it might be necessary to amend the contents of this Data Privacy Policy. We therefore reserve the right to amend the contents at any time. Where your consent is required for an amendment, we will obtain it from you. We will also publish the amended version of the Data Privacy Policy here. When you visit our Website again, you should therefore re-read the Data Privacy Policy.

As at: July 2026