Data Protection Policy Declaration
This Data Protection Declaration describes the personal data which the Institute of Franklin Method GmbH, Hittnauerstrasse 40, 8623 Wetzikon, Switzerland (“FM”) collects, as well as the method, scope, purpose and legal basis of the processing (such as collection, storage, use, retention, alteration, disclosure) of such personal data. In addition, FM informs you in this policy declaration about your rights in connection with the collected personal data.
When processing personal data, FM complies with the requirements of the Swiss Data Protection Act (DSG) and the EU General Data Protection Regulation (EU GDPR, Regulation (EU) 2016/679), insofar as is applicable.
- Responsible Body
If there is a concern regarding the collection, processing or use of personal data, the responsible department / person to be contacted is: Eric Noel Franklin, Managing Director, Institute for Franklin Method GmbH, Hittnauerstrasse 40, 8623 Wetzikon.
- Personal Data
Personal data is information concerning factual or personal circumstances pertaining to an identified or identifiable individual. This information includes, e.g., names, addresses, telephone numbers, email addresses, dates of birth, information regarding the individual’s health, personal data, credit card numbers, bank account details or the IP addresses of the individual.
Anonymous or statistical data, which is collected during your visit of FM’s website cannot, or such which can only with unreasonable effort, be identified as being associated with the individual user, and are not included in the term personal data.
- Data Processing when utilizing FM Offers/ Services
Principle: Personal Data is always collected if actively provided to FM in the context of the services offered on this website. The processing of such data generally takes place in direct connection with the conclusion or the execution of a contract or the fulfillment of pre-contractual or contractual obligations.
Data: The information required for this purpose is: (i) first and last name, (ii) address, (iii) telephone number, (iv) email address.
Purpose: The collection and use of this data serve for the correct formation, content and performance of the contractual relationship. This also includes the transmission of personal data to the extent necessary for the performance of the contract to the respective partners and service providers, regardless of whether such companies are located in Switzerland or abroad.
Place and duration: Personal data is stored in Switzerland or within the European Union. FM stores and processes the data only as far as and for as long as the particular purpose of the processing is required, e.g., to process requests and make bookings. After expiration of the time period prescribed in applicable tax and commercial regulations, this data will be deleted, unless FM has received the express consent for further use.
Other uses: FM may also use the personal data collected for the purposes of the contract for purposes other than our original purposes, as long as there is a connection between the purposes of use and the original data collection (for example, customer loyalty and marketing for our own products).
- Disclosure of Data to Third Parties
FM discloses personal information to third parties who are responsible for technical maintenance or who assist FM in conducting business transactions only to the extent necessary to perform the contract.
FM contractually binds such data processors to comply with FM’s data protection and confidentiality regulations and to provide the given technical and organizational data security measures. However, FM and its agent third parties may be required by law, court order, or governmental order to share personal information with government agencies and regulatory bodies.
In addition, FM will only disclose personal data to third parties if express consent has been given or to the extent that may be required by law or if the disclosure of information is required to enforce legal claims by third parties and FM has no reason to believe that you may have an overriding interest in not sharing said information.
- Server Log Files
When accessing FM’s website, the following user data is transmitted through the Internet browser and stored in log files, the so-called server log files: IP address of the user, date and time of access, name of the retrieved website or file, referrer URL, the transmitted amount of data, user’s operating system and information about the type and version of the browser used. The IP addresses are either deleted or anonymized after the termination of access. The user data form the basis for statistical, anonymous evaluations in order to improve the offer on FM’s website and to make it more user-friendly. This data will not be combined with data from other sources.
- Cookies
- General
Cookies are small files that are stored on the user’s device when visiting a website. Cookies allow the website to uniquely identify the browser and remember certain inputs and preferences over a period of time (e.g. preferred language, most visited pages). Cookies give FM information about the way the website is used in order to improve the website, for anonymous statistical evaluation, for market research purposes and to improve FM’s offers. However, FM will only be able to recognize anonymized information such as general usage patterns on the website and not the usage behavior of individuals. Cookie information is not intended to personally identify any user. There is no correlation of personal data to identification numbers.
Most browsers accept cookies automatically. Users can set their web browsers to be informed about the use of cookies and permit them to either allow or deny cookies usage in individual cases, to exclude the acceptance of cookies for certain cases or in general, to activate the automatic deletion of cookies when closing the browser. In addition, all cookies stored on user devices can be deleted at any time. Respective instructions can be found in the browser user manual. However, these settings can lead to reduced availability or impaired functionality of the website.
The users’ IP addresses will be collected and processed with your consent, which is inferred from the users’ behavior when using FM’s website. This Policy provides the basis for appropriate information for voluntary consent. Further, the processing of the IP address of website visitors protects FM’s legitimate interest in offering services that meet user needs. In any case, the restriction of the legitimate interests of website visitors is outweighed because IP addresses are pseudonymized and edited only in this form.
- Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc., USA (“Google”). Google Analytics uses cookies that – with the users’ consent – are stored on their computer and that allow an analysis of their use of the website. The information generated by cookies about their use of this website (including IP address) is usually transmitted to a Google server in the USA and stored there.
IP Anonymization: FM uses the function of Google Analytics “anonymizeIP”. Users’ IP addresses will be collected by Google at their behest only in an abbreviated form and thus anonymized, so that no assignment and no conclusions about their identities are possible (IP masking). If IP anonymization is activated on this website, users’ IP addresses will be shortened by Google for usage within member states of the European Union or other parties to the Agreement on the European Economic Area prior to the transmission to Google’s US server. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
Purpose: Google will use this information on FM’s behalf to evaluate the use of the website, to compile reports on website activity, and to provide FM with other services related to website activity and internet usage. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. This information may also be transferred to third parties if required by law or as far as third parties process this data on behalf of Google.
Job Data Processing: FM has a contract with Google and FM fully implements the data protection requirements when using Google Analytics.
Objection: Users can prevent the storage of cookies by a corresponding setting of their browser software. However, FM wishes to point out that in this case users may not be able to use all functions of this website fully. In addition, users may prevent the collection by Google of the data generated by cookies and related to their use of the website (including IP address) and the processing of this data by Google by using the link available at the following link “Download” and installing the respective browser plugin to disable Google Analytics: http://tools.google.com/dlpage/gaoptout?hl=en.
Further Information: For more information about Google Analytics, please visit http://www.google.com/analytics/terms/en.html and https://www.google.com/intl/en/policies/.
- Google AdSense
This website uses Google AdSense, a service for integrating Google advertisements. Google AdSense uses cookies, which are stored on users’ to allow computer analysis of the use of the website. Google AdSense also uses so-called web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic on these pages.
The information generated by cookies and web beacons on the use of this website (including IP address) and delivery of advertising formats are transmitted to and stored by Google on servers in the USA. This information may be shared by Google with Google affiliates. However, Google will not merge users’ IP addresses with other data users have stored.
Users can prevent the installation of cookies by setting the browser software accordingly. However, users should be aware that in this case they may not be able to fully use all the features of this website. By using this website, users consent to the processing of data about them by Google in the manner and for the purposes set out above.
- Links and Social Media Plug-ins
If users access external links to other websites offered through FM’s website, This Policy does not extend to external links to other websites offered through FM’s website. FM has no influence on other providers’ compliance with privacy and security regulations. Users are required to read about the privacy statements on the websites of the other providers on the respective websites.
FM uses plug-ins for social networks, e.g., Facebook, Google+, Twitter and Xing on its website. Responsibility for the operational compliance with data protection is to be guaranteed by the networks’ respective providers. The integration of these plug-ins takes place in such a way that the data protection of the users is guaranteed as comprehensively as possible.
On FM’s website, plug-ins which are offered by the Facebook Inc., USA (“Facebook”) are integrated. Facebook plug-ins can be recognized by the Facebook logo or the “Like-Button” (“Like”) on the FM website. An overview of the Facebook plug-ins can be found here: http://developers.facebook.com/docs/plugins/.
When visiting FM’s website, the plug-in establishes a direct connection between the user browser and the Facebook server. Facebook receives the information that the user has visited FM’s website including the IP address. If the user clicks on the Facebook “Like-Button” while logged into the Facebook account, the contents of FM’s website can be linked to the user’s Facebook profile. As a result, Facebook can assign the visit to FM’s website to the visiting user account. FM wishes to point out that as provider of the webpages it is not aware of the content of the data transmitted and its use by Facebook. Further information can be found in the Facebook Privacy Policy at https://www.facebook.com/about/privacy/
If the user does not wish Facebook to associate the visit to FM’s webpages with the user’s Facebook account, the user should log out of the Facebook user account.
Functions of Twitter services are integrated on the FM website. These features are offered by Twitter Inc., USA (“Twitter”). By using Twitter and the “Re-Tweet” feature, the web pages visited will be linked to the user’s Twitter account and shared with other users. Thereby, among others, transfer data such as IP address, browser type, visited domains, visited pages, mobile service providers, device and application IDs and search terms are transmitted to Twitter.
FM wishes to point out that as provider of the website it is not aware of the content of the transmitted data and their use by Twitter. Due to continuous updating of the Privacy Policy of Twitter, FM refers to the latest version at (http://twitter.com/privacy).
Users can change their privacy settings on Twitter in the Account Settings at http://twitter.com/account/settings. For any questions, please contact privacy@twitter.com.
- Google+1
Use of the Google+1 button enables the user to publish information worldwide. The Google+1 button provides the individual and other users with personalized content from Google and its affiliates. Google stores both the information that the user adds to +1 for content and information regarding the page viewed when the user clicked +1. The user’s +1 may appear alongside the profile name and photo in Google services, such as search results or in the user’s Google profile, or elsewhere on websites and ads on the web.
Google records information about the user’s +1 activity to improve Google’s services.
To use the Google +1 button, the user’s account needs to be globally visible, i.e., Google public profile that shows at least the name chosen for the profile. This name will be used in all Google services. In some cases, this name may also replace a different name that the user applies when sharing content through the Google Account. The identity of the Google Profile may be displayed to users who know the user’s email address or have other identifying information.
In addition to the uses outlined above, the information provided will be used in accordance with the applicable Google Privacy Policy (http://www.google.com/intl/en/policies/privacy/). Google may publish summarized statistics on users’ +1 activity or share those statistics with FM users and partners, such as publishers, advertisers, or affiliate websites.
- Data Security
FM secures this website and other systems through technical and organizational measures against loss, destruction, unauthorized access, modification or dissemination of user data by unauthorized persons. However, absolute protection cannot be guaranteed.
Where possible, FM data processing systems are privacy-friendly from the outset, e.g., designed by minimizing and pseudonymizing personal data.
- User Rights
Right to Information: Users can always ask FM in writing whether and which personal data is stored about them, as well as all details of any processing. User applications will be completed free of charge (except for excessive or open unsubstantiated applications) and promptly.
Right to Correction, Deletion and Restriction: Users also have the right to rectify incorrect or incomplete data as well as the right to the immediate deletion or restriction of the processing of their data.
Data Portability: Users can transfer personal data from one location to another in a common machine-readable format.
Renunciaton: As far as FM uses data for a purpose that requires user consent in accordance with the applicable law, FM will always ask for the users’ express consent and log the answer. When revoking consent or objecting, a simple message to the address of the responsible body according to para. 2 of this Policy is sufficient.
- Updating and Amendments
FM may amend, change or update any part of the Policy without prior notice.
