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    Privacy Policy

    This privacy policy informs you which personal data we process in connection with our activities, including our website https://www.mana-designs.ch/. We explain in particular for what purpose, how and where we process which personal data, and inform you about the rights of the people whose data we process.

    Additional privacy notices and other legal documents such as general terms and conditions, terms of use or terms of participation may apply to individual or additional activities.

    We are subject to Swiss data protection law and, where applicable, foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law ensures an adequate level of protection.

    1. Contact details

    Responsible for the processing of personal data:

    Mana Designs By Sophia Engel
    Edisonstrasse 7
    4053 Basel
    Switzerland
    sophia@mana-designs.ch

    In individual cases, there may be other parties responsible for the processing of personal data or joint responsibility with at least one other party.

    2. Definitions and legal bases

    2.1 Definitions

    Personal data means any information relating to an identified or identifiable natural person. A data subject is a person whose personal data we process.

    Processing covers any handling of personal data, regardless of the means and procedures used, for example querying, matching, adapting, archiving, retaining, reading, disclosing, obtaining, recording, collecting, deleting, organising, storing, modifying, distributing, linking, destroying and using personal data.

    The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

    2.2 Legal bases

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

    Where and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data on at least one of the following legal bases:

    • Art. 6(1)(b) GDPR for processing necessary to perform a contract with the data subject or to take pre-contractual steps.
    • Art. 6(1)(f) GDPR for processing necessary to safeguard our legitimate interests or those of third parties, unless overridden by the fundamental rights and interests of the data subject. Legitimate interests include in particular our interest in operating and communicating about our activities in a sustainable, user-friendly, secure and reliable manner, ensuring information security, protection against misuse, enforcement of our legal claims and compliance with Swiss law.
    • Art. 6(1)(c) GDPR for processing necessary to comply with a legal obligation under any applicable EEA member state law.
    • Art. 6(1)(e) GDPR for processing necessary 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 data subject's consent.
    • Art. 6(1)(d) GDPR for processing necessary to protect the vital interests of the data subject or another natural person.

    3. Nature, scope and purpose

    We process the personal data required to carry out our activities in a sustainable, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of master and contact data, browser and device data, content data, meta and usage data, location data, sales data, and contract and payment data.

    We process personal data for as long as required for the respective purpose(s) or by law. Personal data whose processing is no longer necessary is anonymised or deleted.

    We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to them. Such third parties are in particular specialised providers whose services we use. We ensure data protection also with such third parties.

    In principle, we only process personal data with the consent of the data subjects. Where processing is permitted on other legal grounds, we may dispense with obtaining consent. For example, we may process personal data without consent in order to perform a contract, comply with legal obligations or safeguard overriding interests.

    We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities, where such processing is permitted on legal grounds.

    4. Communication

    We process personal data in order to communicate with third parties, in particular data that a data subject sends us when getting in touch, for example by post or email. We may store such data in an address book or comparable tools.

    Third parties who transmit data about other persons are obliged to ensure data protection towards those data subjects. This includes ensuring the accuracy of the personal data transmitted.

    We use selected services from suitable providers to communicate better with third parties. In particular:

    • bexio: Customer Relationship Management (CRM); provider: bexio AG (Switzerland).
    • Copper: Customer Relationship Management (CRM); provider: Copper CRM Inc. (USA).

    5. Data security

    We take appropriate technical and organisational measures to ensure data security commensurate with the respective risk. Our measures ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, although we cannot guarantee absolute data security.

    Access to our website and other online presence takes place via transport encryption (SSL / TLS, in particular Hypertext Transfer Protocol Secure, HTTPS). Most browsers indicate transport encryption with a small padlock in the address bar.

    Our digital communication, like virtually all digital communication, is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence over the corresponding processing of personal data by intelligence services, police forces and other security authorities. Nor can we rule out that individual data subjects may be specifically monitored.

    6. Personal data abroad

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

    We may export personal data to all countries and territories on Earth and elsewhere in the universe, provided that the local law ensures adequate data protection in accordance with a decision of the Swiss Federal Council and, where the GDPR applies, in accordance with a decision of the European Commission.

    We may transfer personal data to countries whose law does not ensure an adequate level of data protection if data protection is otherwise ensured, in particular on the basis of standard contractual clauses or with other appropriate safeguards. In exceptional cases, we may export personal data to countries without an adequate or appropriate level of data protection if the special data protection requirements are met, for example the explicit consent of the data subjects or a direct connection with the conclusion or performance of a contract. We are happy to provide data subjects with information about any safeguards on request or to provide a copy of any safeguards.

    7. Rights of data subjects

    7.1 Data protection claims

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

    • Information: Data subjects can request information about whether we process personal data about them and, if so, which personal data. Data subjects also receive the information necessary to assert their data protection claims and to ensure transparency. This includes the personal data processed as such, but also information about the purpose of processing, the retention period, any disclosure or export of data to other countries, and the origin of the personal data.
    • Rectification and restriction: Data subjects can have inaccurate personal data corrected, incomplete data completed and the processing of their data restricted.
    • Erasure and objection: Data subjects can have personal data erased ("right to be forgotten") and object to the processing of their data with effect for the future.
    • Data release and data portability: Data subjects can request the release of personal data or the transmission of their data to another controller.

    We may postpone, restrict or refuse the exercise of data subjects' rights within the legally permitted framework. We may inform data subjects of any conditions to be met for the exercise of their data protection claims. For example, we may refuse information in whole or in part with reference to business secrets or the protection of other persons. We may also refuse the deletion of personal data in whole or in part with reference to statutory retention obligations.

    We may exceptionally provide for costs to be charged for the exercise of rights. We will inform data subjects in advance of any costs.

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

    7.2 Legal protection

    Data subjects have the right to enforce their data protection claims through legal channels or to file a complaint with a competent data protection supervisory authority.

    The supervisory authority for complaints by data subjects against private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

    European data protection supervisory authorities for complaints by data subjects, where the GDPR applies, are organised as members of the European Data Protection Board (EDPB). In some EEA member states, the data protection supervisory authorities are organised on a federal basis, in particular in Germany.

    8. Use of the website

    8.1 Cookies

    We may use cookies. Cookies, both first-party cookies and third-party cookies whose services we use, are data stored in the browser. Such stored data is 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 as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a defined storage period. Cookies make it possible in particular to recognise a browser on the next visit to our website and thereby, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing.

    Cookies can be wholly or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. Where required, we actively request explicit consent for the use of cookies.

    For cookies used for success and reach measurement or for advertising, a general objection ("opt-out") is possible for many 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).

    8.2 Logging

    For each access to our website and other online presence, we may log at least the following information, provided it is transmitted to our digital infrastructure on such access: 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 sub-page of our website accessed including amount of data transmitted, and the most recently accessed website in the same browser window (referrer).

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

    8.3 Tracking pixels

    We may embed tracking pixels in our online presence. Tracking pixels are also referred to as web beacons. Tracking pixels, including those of third parties whose services we use, are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can capture at least the same information as log files.

    9. Notifications and communications

    We send notifications and communications by email and via other communication channels such as instant messaging or SMS.

    9.1 Success and reach measurement

    Notifications and communications may contain web links or tracking pixels that record whether an individual message has been opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We require this statistical recording of usage for success and reach measurement in order to send notifications and communications effectively, in a user-friendly manner and reliably based on the needs and reading habits of recipients.

    9.2 Consent and objection

    You generally have to consent to the use of your email address and other contact details unless their use is permitted on other legal grounds. To obtain a double-confirmed consent, we may use the "double opt-in" procedure. In this case you receive a message with instructions for the second confirmation. We may log obtained consents including the IP address and timestamp for evidence and security reasons.

    You can generally object to the receipt of notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for success and reach measurement. Notifications and communications necessary in connection with our activities remain reserved.

    9.3 Service providers for notifications and communications

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

    10. Social media

    We are present on social media platforms and other online platforms in order to communicate with interested parties and to inform them about our activities. In connection with such platforms, personal data may also be processed outside Switzerland and the EEA.

    The general terms and conditions, terms of use, privacy notices and other provisions of the respective platform operators also apply. These provisions inform 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 jointly responsible with Meta Platforms Ireland Limited (Ireland) where the GDPR applies. 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 provide our social media presence on Facebook effectively and in a user-friendly manner.

    Further information on the nature, scope and purpose of data processing, on the rights of data subjects and the contact details of Facebook and Facebook's Data Protection Officer can be found in Facebook's privacy notice. We have concluded the so-called "Controller Addendum" with Facebook and have in particular agreed that Facebook is responsible for safeguarding the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information about Page Insights" including "Information about Page Insights data".

    11. Third-party services

    We use services from specialised third parties to operate our activities in a sustainable, user-friendly, secure and reliable manner. Such services allow us, among other things, to embed functions and content in our website. When embedded, the services used capture the IP addresses of users at least temporarily for technically compelling reasons.

    For necessary security-related, statistical and technical purposes, third parties whose services we use may process data related to our activities in aggregated, anonymised or pseudonymised form. This may include, for example, performance or usage data needed to provide the respective service.

    11.1 Digital infrastructure

    We use services from specialised third parties to obtain the digital infrastructure required for our activities. This includes, for example, hosting and storage services from selected providers.

    11.2 Automation and integration of apps and services

    We use specialised platforms to integrate and connect existing third-party apps and services. With such "no-code" platforms we can also automate workflows and activities involving third-party apps and services.

    11.3 Scheduling

    We use services from specialised third parties to schedule appointments online, for example for meetings. In addition to this privacy policy, the directly visible terms of the services used, such as terms of use or privacy notices, also apply.

    11.4 Audio and video conferencing

    We use specialised services for audio and video conferencing in order to communicate online. We can use them to hold virtual meetings or run online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as privacy notices and terms of use additionally apply.

    We recommend, depending on the situation, muting your microphone by default when participating in audio or video conferences and blurring the background or using a virtual background.

    11.5 Online collaboration

    We use third-party services to enable online collaboration. In addition to this privacy policy, the directly visible terms of the services used, such as terms of use or privacy notices, also apply.

    11.6 Social media features and content

    We use third-party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and in other ways.

    11.7 Digital audio and video content

    We use services from specialised third parties to enable direct playback of digital audio and video content such as music or podcasts.

    11.8 Documents

    We use third-party services to embed documents in our website. Such documents may include PDF files, presentations, spreadsheets and text documents. This allows us to enable not only the viewing but also the editing or commenting of such documents.

    11.9 Fonts

    We use third-party services to embed selected fonts as well as icons, logos and symbols in our website.

    11.10 Payments

    We use specialised service providers to process payments from our customers securely and reliably. The legal texts of the individual service providers, such as general terms and conditions or privacy notices, additionally apply to payment processing.

    11.11 Advertising

    We use the option to place targeted advertising for our activities with third parties such as social media platforms and search engines.

    With such advertising we want to reach in particular people who are already interested in our activities or could be interested in them (remarketing and targeting). To this end, we may transmit corresponding, possibly personal information, to third parties enabling such advertising. We can also determine whether our advertising is successful, that is in particular whether it leads to visits to our website (conversion tracking).

    Third parties with whom we advertise and where you are logged in as a user may associate the use of our website with your profile there.

    12. Participation in partner programmes

    We participate in partner programmes. On the one hand, we may be compensated for referring to or linking offers of third parties. On the other hand, we may compensate third parties for referring to our activities or linking to our online offering (affiliate marketing). In this context, it may be recorded, possibly on a personal basis, which offers are taken up and which web links are followed.

    13. Website extensions

    We use extensions for our website to be able to use additional functions. We may use selected services from suitable providers or run such extensions on our own server infrastructure.

    14. Success and reach measurement

    We try to determine how our online offering is used. In this context, we may, for example, measure the success and reach of our activities and the effect of third-party links to our website. We may also try out and compare how different parts or versions of our online offering are used (A/B testing). Based on the results of success and reach measurement, we can in particular fix errors, strengthen popular content or make improvements to our online offering.

    For success and reach measurement, in most cases the IP addresses of individual users are stored. In this case, IP addresses are generally shortened ("IP masking") in order to follow the principle of data minimisation through corresponding pseudonymisation.

    For success and reach measurement, cookies may be used and user profiles created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information about the size of the screen or browser window and the, at least approximate, location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services where users are logged in may associate the use of our online offering with the user account or user profile of the respective service.

    15. Final provisions

    We created this privacy policy with the privacy policy generator of Datenschutzpartner.

    We may amend and supplement this privacy policy at any time. We will inform about such amendments and supplements in an appropriate manner, in particular by publishing the current version of the privacy policy on our website.