Data Protection Policy:

In this Privacy Policy, we, HSM Schlobach.Peter (hereinafter HSM, we, or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; other privacy policies [or general terms and conditions, conditions of participation, and similar documents] may regulate specific issues. Personal data refers to all information relating to an identified or identifiable individual.

If you provide us with personal data of other individuals (e.g., family members, data of work colleagues), please ensure that these individuals are aware of this Privacy Policy and only provide us with their personal data if you are permitted to do so and if this personal data is correct.

This Privacy Policy is designed to comply with the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DSG"), and the revised Swiss Data Protection Act ("revDSG"). However, whether and to what extent these laws are applicable depends on the individual case.

1. Controller / Data Protection Officer / Representative
HSM Schlobach Peter is responsible for the data processing described here.
If you have any data protection concerns, you can contact us at the following address:
CH-8280 Kreuzlingen, Berneggstrasse 16
schlobach.peter@gmail.com

2. Collection and Processing of Personal Data
We primarily process the personal data we receive from our customers and other business partners and other parties involved in our business relationships, or that we collect from their users when operating our websites, apps, and other applications.
To the extent permitted, we also obtain certain data from publicly accessible sources (e.g., debt collection registers, land registers, commercial registers, the press, the internet) or receive such data from other companies, authorities, and other third parties (such as credit agencies). In addition to the data you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (insofar as we conduct business with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) give us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information from banks, insurance companies, sales and other contractual partners of ours for the use or provision of services by you (e.g. payments made, purchases made)), information about you from the media and the Internet (insofar as this is appropriate in the specific case, e.g. in the context of an application, press review, Marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data related to the use of the website (e.g., IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location information).

3. Purposes of data processing and legal basis
We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of sales and service transactions with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity.

3. Purposes of data processing and legal basis
We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of sales and service transactions with our customers and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this capacity. In addition, we process personal data from you and other individuals, where permitted and deemed appropriate, for the following purposes, in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:
• Offering and further developing our offers, services and websites, apps, and other platforms on which we are present;
• Communicating with third parties and processing their inquiries (e.g., applications, media inquiries);
• Testing and optimizing needs analysis procedures for direct customer contact and collecting personal data from publicly accessible sources for customer acquisition;
• Advertising and marketing (including organizing events)
Unless you have objected to the use of your data (if we send you advertising as an existing customer, you can object at any time; we will then place you on a block list to prevent further advertising mailings);
• Market and opinion research, media monitoring;
• Asserting legal claims and defending yourself in connection with legal disputes and official proceedings;
• Preventing and investigating criminal offenses and other misconduct (e.g., conducting internal investigations, data analyses to combat fraud);
• Ensuring our operations, in particular IT, our websites, apps, and other platforms;
• Buying and selling business units, companies, or parts of companies, and other corporate transactions, including the associated transfer of personal data, as well as measures for business management and to the extent necessary to comply with legal and regulatory obligations.
If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or conduct a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and we require one. Consent given can be revoked at any time; however, this will not affect data processing that has already taken place.

4. Cookies / Tracking and other technologies in connection with the use of our website
We typically use "cookies" and similar technologies on our websites that can be used to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. When you visit this website again, we can recognize you, even if we don't know who you are. In addition to cookies that are only used during a session and deleted after your website visit ("session cookies"), cookies can also be used to store user preferences and other information for a specific period of time (e.g., two years) ("permanent cookies"). However, you can configure your browser to reject cookies, store them only for a single session, or otherwise delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that we can better understand how you use our services and content. Some cookies are set by us, and others are also set by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.

We sometimes, and where permitted, include visible and invisible image elements in our newsletters and other marketing emails. By retrieving these from our servers, we can determine whether and when you opened the email. This allows us to measure and better understand how you use our offerings and tailor them to your needs. You can block this in your email program; most are preconfigured to do so.

By using our websites and agreeing to receive newsletters and other marketing emails, you consent to the use of these technologies. If you do not want this, you must configure your browser or email program accordingly.
We sometimes use Google Analytics on our websites. This is a service provided by third parties that may be located in any country in the world (in the case of Google Analytics, this is Google Ireland (based in Ireland); Google Ireland relies on Google LLC (based in the USA) as a processor (both "Google"), www.google.com), with which we can measure and evaluate the use of the website (not personally identifiable). For this purpose, permanent cookies placed by the service provider are also used. We have configured the service so that the IP addresses of visitors in Europe are shortened by Google before being forwarded to the USA and thus cannot be traced back. We have deactivated the "Data Sharing" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles, and link this data to these people's Google accounts. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider.
service provider in accordance with its privacy policy. The service provider only informs us how our respective website is used (no information about you personally).

5. Data Sharing and Data Transfer Abroad
Within the scope of our business activities and for the purposes set out in Section 3, we also disclose data to third parties, to the extent permitted and deemed appropriate, either because they process it for us or because they intend to use it for their own purposes. This applies in particular to the following parties:
• Our service providers, including contract processors (such as IT providers);
• Dealers, suppliers, subcontractors, and other business partners;
• Customers;
• Domestic and foreign authorities, offices, or courts;
• Media;
• The public, including visitors to websites and social media;
• Competitors, industry organizations, associations, organizations, and other bodies;
• Other parties in potential or actual legal proceedings;
all of them jointly referred to as recipients.

Some of these recipients are located in Germany, but they may be located anywhere in the world. In particular, you must agree to the transfer of your data to other European countries and the USA, where the service providers we use are located (such as Microsoft and Praxedo, the application for planning service routes).
If a recipient is located in a country without adequate legal data protection, we will contractually oblige the recipient to comply with the applicable data protection regulations (for this purpose, we use the revised standard contractual clauses of the European Commission, which are available here:
https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exception. An exception may apply, in particular, in legal proceedings abroad, but also in cases of overriding public interest or when the performance of a contract requires such disclosure, if you have consented, or if the data you have made publicly available is data whose processing you have not objected to.

6. Duration of Retention of Personal Data
We process and store your personal data as long as it is necessary to fulfill our contractual and legal obligations or otherwise for the purposes pursued by the processing, i.e., for example, for the duration of the entire business relationship (from initiation and processing to termination of a contract) and beyond, in accordance with statutory retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company and to the extent that we are otherwise legally obligated to do so or legitimate business interests require it (e.g., for evidentiary and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will generally be deleted or anonymized as far as possible. For operational data (e.g., system logs, logs), shorter retention periods of twelve months or less generally apply.

7. Data Security
We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as issuing instructions and training our employees.

8. Obligation to Provide Personal Data
As part of our business relationship, you must provide the personal data necessary to establish and conduct a business relationship and fulfill the associated contractual obligations (you generally have no legal obligation to provide us with data). Without this data, we will generally not be able to conclude or process a contract with you (or the entity or person you represent). The website cannot be used if certain information required to secure data traffic (such as your IP address) is not disclosed.

9. Profiling and Automated Decision-Making
We generally do not use fully automated decision-making (as regulated, for example, in Art. 22 GDPR) to establish and conduct our business relationship, or otherwise. Should we use such procedures in individual cases, we will inform you separately, provided this is required by law, and we will inform you of the associated rights.

10. Rights of the Data Subject
Within the scope of the data protection law applicable to you and to the extent provided therein (such as in the case of the GDPR), you have the right to information, rectification, erasure, restriction of data processing, and otherwise the right to object to our data processing, in particular that for direct marketing purposes.
marketing and other legitimate interests in processing, as well as the disclosure of certain personal data for transmission to another party (so-called data portability). Please note, however, that we reserve the right to assert the legally stipulated restrictions, for example, if we are obliged to retain or process certain data, have an overriding interest in doing so (to the extent that we are entitled to rely on this), or require it to assert claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of revoking your consent in Section 3. Please note that exercising these rights may conflict with contractual agreements and may result in consequences such as early termination of the contract or additional costs. We will inform you in advance of this unless already contractually agreed.
The exercise of such rights generally requires that you clearly prove your identity (e.g., by providing a copy of your ID card where your identity is otherwise unclear or cannot be verified). To assert your rights, you can contact us at the address provided in Section 1.
Every data subject also has the right to enforce their claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Changes
We may amend this Privacy Policy at any time without prior notice. The most recent version published on our website applies. If the Privacy Policy is part of an agreement with you, we will notify you of any changes by email or other appropriate means.
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