Privacy Policy

Ramona Feyrer
In der Bänklen
Kilchberg 8802
Switzerland

E-Mail: info@flow-focus.com

Authorized Representatives:

Ramona Feyrer

Company Name: Ramona Feyrer

Data Protection Officer:

Ramona Feyrer
+41 44 542 25 62
info@ramona-feyrer.com

General / Introduction

Based on Article 13 of the Swiss Federal Constitution and the federal data protection regulations (Data Protection Act, DSG), every person is entitled to protection of their privacy and against misuse of their personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with legal data protection regulations and this privacy policy.

In collaboration with our hosting providers, we strive to protect the databases from unauthorized access, loss, misuse, or falsification as much as possible.

We would like to point out that data transmission over the Internet (e.g., when communicating via email) can have security vulnerabilities. Complete protection of data from access by third parties is not possible.

By using this website, you agree to the collection, processing, and use of data in accordance with the following description. This website can generally be visited without registration. Data such as accessed pages or names of accessed files, date, and time are stored on the server for statistical purposes, without these data being directly related to your person. As far as personal data (e.g., name, address, or email addresses) is collected on our pages, this is always done on a voluntary basis as much as possible. This data will not be passed on to third parties without your express consent.

Processing of Personal Data

Personal data are all information related to an identified or identifiable person. An affected person is someone whose personal data is processed. Processing includes any handling of personal data, regardless of the means and procedures used, especially the storage, disclosure, acquisition, deletion, retention, modification, destruction, and use of personal data.

We process personal data in accordance with Swiss data protection law. To the extent that the EU GDPR is applicable, we also process personal data on the following legal bases in connection with Art. 6 (1) GDPR:

lit. a) Processing of personal data with the consent of the affected person.

lit. b) Processing of personal data for the fulfillment of a contract with the affected person and for the implementation of corresponding pre-contractual measures.

lit. c) Processing of personal data to fulfill a legal obligation to which we are subject under applicable EU law or under the law of a country where the GDPR is fully or partially applicable.

lit. d) Processing of personal data to safeguard vital interests of the affected person or another natural person.

lit. f) Processing of personal data to safeguard the legitimate interests of us or third parties, provided that the fundamental freedoms and rights and interests of the affected person do not prevail. Legitimate interests include, in particular, our business interest in being able to provide our website, information security, enforcement of our own legal claims, and compliance with Swiss law.

We process personal data for the duration necessary for the respective purpose or purposes. In the case of longer storage obligations due to legal and other obligations to which we are subject, we restrict processing accordingly.

Cookies

This website uses cookies. These are small text files that store specific, user-related information on the user’s device while using the website. In particular, cookies make it possible to determine the frequency of use and the number of users of the pages, to analyze patterns of page usage, and also to make our offer more customer-friendly. Cookies remain stored beyond the end of a browser session and can be retrieved when the page is revisited. If you do not want this, you should set your internet browser to refuse the acceptance of cookies.

A general objection to the use of cookies for online marketing purposes can be declared for many services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, cookies can be saved by deactivating them in the browser settings. Please note that not all functions of this online offer can be used in this case.

With SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, such as inquiries that you send to us as the site operator, this website uses SSL/TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from «http://» to «https://» and by the lock symbol in your browser line.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Server Log Files

The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version

Operating system used

Referrer URL

Hostname of the accessing computer

Time of the server request

This data cannot be attributed to specific individuals. This data will not be combined with other data sources. We reserve the right to check this data retrospectively if we become aware of specific indications of illegal use.

Third-Party Services

This website may use Google Maps for embedding maps, Google Invisible reCAPTCHA for protection against bots and spam, and YouTube for embedding videos.

These services of the American company Google LLC use cookies, among other things, which results in data being transmitted to Google in the USA. However, we assume that merely using our website does not result in any personal tracking.

Google has committed to ensuring adequate data protection in accordance with the US-European and the US-Swiss Privacy Shield.

Further information can be found in Google’s privacy policy.

Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide, will be stored with us for the purpose of processing the inquiry and in case of follow-up questions. We will not pass on this data without your consent.

Rights of the Data Subject

Right to Confirmation

Every data subject has the right to request confirmation from the website operator as to whether personal data concerning them is being processed. If you wish to exercise this right of confirmation, you can contact the data protection officer at any time.

Right to Information

Every person affected by the processing of personal data has the right to obtain free information about the data stored about them by the website operator at any time, and to receive a copy of this information. Furthermore, information may be provided about the following:

Purpose of processing

Categories of personal data being processed

Recipients to whom the personal data has been or will be disclosed

If possible, the planned duration for which the personal data will be stored, or if this is not possible, the criteria used to determine this duration

The existence of a right to correction or deletion of personal data concerning them, or to restrict the processing by the controller, or a right to object to such processing

The existence of a right to lodge a complaint with a supervisory authority

If the personal data is not collected from the data subject: All available information about the source of the data.

In addition, the data subject has the right to know whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.

If you wish to exercise this right to information, you can contact our data protection officer at any time.

Right to Correction

Every person affected by the processing of personal data has the right to request the immediate correction of inaccurate personal data concerning them. Furthermore, considering the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, also by means of a supplementary statement.

If you wish to exercise this right to correction, you can contact our data protection officer at any time.

Right to Deletion (Right to be Forgotten)

Every person affected by the processing of personal data has the right to request the immediate deletion of personal data concerning them from the controller of this website, provided one of the following reasons applies and the processing is no longer necessary:

The personal data was collected or otherwise processed for purposes for which they are no longer necessary.

The data subject revokes their consent on which the processing was based, and there is no other legal basis for the processing.

The data subject objects to the processing for reasons arising from their particular situation, and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing in the case of direct advertising and associated profiling.

The personal data was processed unlawfully.

The deletion of personal data is required to fulfill a legal obligation under Union law or the law of the member states to which the controller is subject.

The personal data was collected in relation to the offered services of the information society directed directly at a child.

 

If one of the above reasons applies and you wish to request the deletion of personal data stored by the operator of this website, you can contact our data protection officer at any time. The data protection officer of this website will ensure that the request for deletion is promptly complied with.

Right to restriction of processing

Any person affected by the processing of personal data has the right to request from the person responsible for the processing of this website that the processing be restricted if one of the following conditions is met:

The accuracy of the personal data is contested by the data subject, for a period that allows the data controller to verify the accuracy of the personal data.

The processing is unlawful, the data subject opposes the erasure of the personal data and requests instead the restriction of the use of the personal data.

The data controller no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defense of legal claims.

The data subject has objected to the processing for reasons arising from their particular situation, and it has not yet been determined whether the legitimate interests of the controller outweigh those of the data subject.

If one of the aforementioned conditions is met, you can contact our data protection officer at any time to request the restriction of the processing of personal data by the operator of this website. The data protection officer of this website will arrange for the processing to be restricted.

Right to data portability

Any person affected by the processing of personal data has the right to receive the personal data concerning them in a structured, commonly used, and machine-readable format. Moreover, the data subject has the right to have these personal data transmitted directly from one data controller to another, where technically feasible, and provided this does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, you can contact the data protection officer appointed by the operator of this website at any time.

Right to object

Any person affected by the processing of personal data has the right, for reasons arising from their particular situation, to object at any time to the processing of personal data concerning them.

The operator of this website will no longer process the personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims.

To exercise your right to object, you can directly contact the data protection officer of this website.

Right to withdraw data protection consent

Any person affected by the processing of personal data has the right to withdraw their consent to the processing of personal data at any time.

If you wish to exercise your right to withdraw your consent, you can contact our data protection officer at any time.

Objection to email marketing

The use of contact data, published under the obligation of an imprint, for sending unsolicited advertising and information materials is hereby rejected. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails.

Paid services

For the provision of chargeable services, we request additional data, such as payment data, to execute your order. We store this data in our systems until the statutory retention periods have expired.

Copyrights

The copyright and all other rights to the contents, images, photos, or other files on the website belong exclusively to the operator of this website or the specifically named rights holders. Prior written consent from the copyright holders must be obtained for the reproduction of any files.

Anyone who commits a copyright infringement without the consent of the respective copyright holder may be liable to prosecution and may potentially have to pay damages.

Disclaimer

All information on our website has been carefully checked. We strive to ensure that the information we provide is up-to-date, correct, and complete. Nevertheless, the occurrence of errors cannot be completely ruled out. Therefore, we cannot guarantee the completeness, accuracy, and timeliness of the information, including journalistic and editorial content. Liability claims relating to material or non-material damage caused by the use or non-use of the information provided or by the use of incorrect and incomplete information are generally excluded.

The publisher can change or delete texts at their own discretion and without prior notice and is not obliged to update the contents of this website. The use of this website or access to it is at the visitor’s own risk. The publisher, its customers, or partners are not responsible for damages such as direct, indirect, incidental, consequential or punitive damages allegedly caused by visiting this website and therefore do not assume any liability for such damages.

The publisher also assumes no responsibility or liability for the content and availability of third-party websites that can be accessed via external links from this website. The operators of the linked pages are solely responsible for their content. The publisher expressly distances itself from all foreign content that may be criminal or liable under civil law or that may offend public decency.

Google Ads

This website uses Google Conversion Tracking. If you have reached our website via an ad placed by Google, Google Ads will set a cookie on your computer. The cookie for conversion tracking is set when a user clicks on an ad placed by Google. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Therefore, cookies cannot be tracked across the websites of Ads customers. The information obtained using the conversion cookie is used to create conversion statistics for Ads customers who have opted for conversion tracking. Customers will know the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they will not receive any information that can be used to personally identify users.

If you do not wish to participate in tracking, you can refuse to set a cookie required for this – for example, by setting your browser to deactivate the automatic setting of cookies in general or by setting your browser to block cookies from the domain «googleleadservices.com».

Please note that you must not delete the opt-out cookies as long as you do not want measurement data to be recorded. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.

Google Remarketing

This website uses the remarketing feature of Google Inc. This function is used to present interest-based advertisements to website visitors within the Google advertising network. A so-called «cookie» is stored in the browser of the website visitor, which makes it possible to recognize the visitor when they visit websites that belong to the Google advertising network. On these websites, visitors can be shown advertisements that refer to content that the visitor has previously accessed on websites that use Google’s remarketing function.

 

According to its own statements, Google does not collect any personal data during this process. However, if you do not wish to use Google’s remarketing function, you can generally deactivate it by adjusting the appropriate settings at http://www.google.com/settings/ads. Alternatively, you can deactivate the use of cookies for interest-based advertising via the Advertising Network Initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp.

Google reCAPTCHA

This website uses the reCAPTCHA service provided by Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland «Google»). The query is used to determine whether the input is made by a human or through automated, machine processing. The query involves the transmission of the IP address and possibly other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transmitted to Google and used there. However, your IP address will be shortened by Google within member states of the European Union or in other states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser as part of reCaptcha will not be merged with other Google data. Your data may also be transferred to the USA. For data transfers to the USA, there is an adequacy decision of the European Commission, the «Privacy Shield». Google participates in the «Privacy Shield» and has submitted to its requirements. By activating the query, you consent to the processing of your data. The processing is based on Art. 6 (1) lit. a DSGVO with your consent. You can revoke your consent at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation.

For more information about Google reCAPTCHA and the associated privacy policy, please visit: https://policies.google.com/privacy?hl=en

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Ireland Limited. If the person responsible for data processing on this website is located outside the European Economic Area or Switzerland, then Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as «Google».

The statistics obtained allow us to improve our offer and make it more interesting for you as a user. This website also uses Google Analytics for cross-device analysis of visitor flows, which is carried out via a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your use in the settings there under «My Data», «Personal Data».

The legal basis for using Google Analytics is Art. 6 Para. 1 S. 1 lit. f DS-GVO. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. We would like to point out that this website has expanded Google Analytics with the code «_anonymizeIp();» to ensure anonymized collection of IP addresses. This means that IP addresses are processed in abbreviated form so that they cannot be linked to a specific person. If the data collected about you can be assigned to a person, this will be excluded immediately and the personal data will be deleted immediately.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website and internet use to the website operator. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. You can prevent the storage of cookies by adjusting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: Disable Google Analytics.

In addition, you can prevent the use of Google Analytics by clicking on this link: Disable Google Analytics. This will store a so-called opt-out cookie on your storage medium, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your device, these opt-out cookies will also be deleted, i.e. you must reset the opt-out cookies if you still want to prevent this form of data collection. Opt-out cookies are set per browser and computer/device and must therefore be activated separately for each browser, computer or other device.

Google WebFonts

This website uses so-called web fonts provided by Google for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly. If your browser does not support web fonts, a standard font from your computer will be used.

For more information about Google Web Fonts, please visit https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/

Google TagManager

 

The Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus, for example, integrate Google Analytics and other Google marketing services into our online offer. The Tag Manager itself, which implements the tags, does not process any personal user data. With regard to the processing of users› personal data, we refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/en/tagmanager/use-policy.html.

HubSpot
Our website uses HubSpot, a marketing automation software from HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland. HubSpot is a software company from the USA with a European branch in Ireland. HubSpot helps us analyze the use of our portal. For this purpose, HubSpot uses cookies. Certain usage data is linked to your person (e.g., after entering a registration form) and stored in our CRM. This allows us to send you information and offers tailored to your interests. Your personal data may also be transferred to HubSpot servers in the United States (USA). An appropriate level of protection is ensured by the fact that HubSpot, Inc. participates in the EU-US Privacy Shield Agreement and is certified for its compliance. We use HubSpot to send you information and offers tailored to your needs. Accordingly, we have a legitimate interest within the meaning of Art. 6(1)(f) GDPR in this processing. The legal basis for our processing of your personal data in connection with the use of HubSpot is Art. 6(1)(f) GDPR. In connection with the use of HubSpot, we store your personal data for as long as necessary to send you information and offers tailored to your needs. Providing the personal data collected via HubSpot is not required by law or contract or necessary for the conclusion of a contract. If you do not provide us with this data, we cannot send you information and offers tailored to your needs. For more information about HubSpot’s data usage, see HubSpot’s privacy policy at: https://legal.hubspot.com/de/privacy-policy. You can object to the use of your data at any time, e.g., by sending an email to the email address provided in this privacy policy. HubSpot is certified under the «EU-U.S. Privacy Shield Framework» and is subject to the TRUSTe Privacy Seal and the «U.S.- Swiss Safe Harbor Framework». Further information on HubSpot’s privacy policy. Further information from HubSpot on EU data protection regulations. Further information from HubSpot about cookies set in a visitor’s browser. More information about cookies set on HubSpot websites.
 
Adobe Fonts
We use Adobe Fonts for the visual design of our website. Adobe Fonts is a service of Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe), which provides us access to a font library. To integrate the fonts we use, your browser must establish a connection to an Adobe server in the USA and download the font required for our website. This informs Adobe that our website was accessed via your IP address. More information about Adobe Fonts can be found in Adobe’s privacy policy, which you can access here: https://www.adobe.com/de/privacy/policy.html.
 
Monotype Fonts
This website uses Fonts.com, a service provided by Monotype Imaging Holdings Inc. for font visualization, allowing the website to embed relevant content on its pages. Personal data collected includes usage data and various types of data as described in the service’s privacy policy. Place of processing: United States of America (USA); Privacy policy.
 
Audio and Video Conferences
We use audio and video conferencing services to communicate with our users and others. In particular, we can conduct audio and video conferences, virtual meetings, and training sessions like webinars. We only use services that ensure an adequate level of data protection. In addition to this privacy policy, the terms and conditions of the services used also apply, such as terms of use or privacy policies. Specifically, we use Zoom, a service of the American company Zoom Video Communications Inc. Zoom also grants users in Switzerland rights under the European General Data Protection Regulation (GDPR). For more information on the type, scope, and purpose of data processing, see Zoom’s privacy policy and the «Legal Terms and Privacy» page, respectively.
 
Contractual Services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, or contractual partners (collectively referred to as «contractual partners») in accordance with the data protection provisions of the Federal Data Protection Act (DSG) and the EU-DSGVO according to Art. 6 para. 1 lit. b. DSGVO, to provide them with our contractual or pre-contractual services. The data processed in this context, type, scope, and purpose, and the necessity of its processing, arise from the underlying contractual relationship. The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., email addresses and telephone numbers), contract data (e.g., services used, contract content, contract communication, names of contact persons), and payment data. We generally do not process special categories of personal data unless they are part of a commissioned or contractual processing. We process data necessary for the establishment and fulfillment of contractual services and point out the necessity of their disclosure unless this is obvious to the contractual partners. Data is only disclosed to external persons or companies if required within a contract. When processing data provided to us within the scope of an order, we act according to the instructions of the client and the legal provisions. When using our online services, we may store the IP address and the time of each user action. The storage is based on our legitimate interests as well as the users› interests in protection against abuse and other unauthorized use. This data is not generally passed on to third parties unless necessary to pursue our claims according to Art. 6 para. 1 lit. f. DSGVO or there is a legal obligation according to Art. 6 para. 1 lit. c. DSGVO. The data is deleted when it is no longer necessary for the fulfillment of contractual or statutory duties of care and for dealing with any warranty and comparable obligations, whereby the necessity of keeping the data is checked at irregular intervals. Otherwise, the statutory storage obligations apply.
 
Data Transfer to the USA
Our website includes tools from companies based in the USA. When these tools are active, your personal data may be transferred to the respective companies› US servers. We note that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to hand over personal data to security authorities without you, as the data subject, being able to legally object. It cannot be excluded that US authorities (e.g., intelligence agencies) process, evaluate, and permanently store your data stored on US servers for surveillance purposes. We have no influence on these processing activities.
 
Changes
We may change this privacy policy at any time without prior notice. The current version published on our website applies. If the privacy policy is part of an agreement with you, we will notify you of an update by email or other appropriate means in the event of a change.
 
Disclaimer
The author assumes no liability for the accuracy, precision, timeliness, reliability, and completeness of the information.
Claims for damages against the author, whether material or immaterial in nature, arising from the access or use or non-use of the published information, through misuse of the connection, or due to technical malfunctions, are excluded.
 
All offers are non-binding. The author expressly reserves the right to modify, supplement, delete parts of the pages or the entire offer without separate notice or to cease the publication temporarily or permanently.

Source: BrainSolutions