Privacy Policy

Introduction

This Privacy Policy informs you about the nature, scope and purpose of the collection and use of personal data on our website www.loetscher.com (hereinafter the "Website") by LÖTSCHER AG (hereinafter "we" or "us") and provides information about the rights to which you are entitled. These rights are governed by the applicable data protection laws.

Art. 1: Scope of Application

1.1 The Website is generally subject to Swiss data protection law, in particular the fully revised Federal Act on Data Protection (FADP) of 25 September 2020 (in force since 1 September 2023), as well as any applicable foreign data protection law such as the European General Data Protection Regulation 2016/679 (GDPR) of the European Union (EU).

1.2 With its decision COM(2024) 7 final of 15 January 2024, the EU recognises that Swiss data protection law ensures an adequate level of data protection (adequacy decision). This does not release us from compliance with the GDPR to the extent that it is applicable in the individual case.

1.3 The privacy settings displayed when you first visit the Website allow you to access general information, obtain information about essential cookies (see Art. 4: Cookies), activate or deactivate Google Analytics (see Art. 5.4: Google Analytics) and go directly to the relevant privacy policy.

1.4 This Privacy Policy relates exclusively to the processing of personal data in connection with the Website. The processing of personal data in the context of consulting mandates and board of directors mandates is governed by the respective service agreement, our General Terms and Conditions and the applicable statutory confidentiality and professional duties.

Art. 2: Processing of Personal Data

2.1 Personal data means any information relating to an identified or identifiable person. A data subject is a person about whom personal data is processed. Processing covers any handling of personal data, irrespective of the means and procedures applied, in particular the storage, disclosure, acquisition, deletion, saving, alteration, destruction and use of personal data. We comply at all times with the principles for the processing of personal data pursuant to Art. 6 FADP.

2.2 We process personal data in accordance with Swiss data protection law. In addition, we process personal data – to the extent and insofar as the GDPR is applicable – in accordance with the legal bases pursuant to Art. 6 GDPR.

2.3 We process personal data for the period required for the respective purpose or purposes. Where longer retention obligations arise from statutory or other duties to which we are subject, we restrict the processing accordingly.

2.4 We may disclose personal data to third parties to the extent necessary for the fulfilment of the stated purposes or of legal obligations, in particular to authorities and courts, banks and insurance companies, IT and hosting service providers, advisors and other auxiliary persons. These recipients are in turn obliged to comply with the applicable data protection provisions.

2.5 We do not carry out any automated individual decision-making within the meaning of Art. 21 FADP or Art. 22 GDPR, nor any high-risk profiling.

Art. 3: Integration of the Contact Form

3.1 A contact form can be completed on the Website. We store the information that visitors to our Website enter themselves. In addition, the hosting provider notifies us of the IP address as well as the time and date in order to combat misuse such as, in particular, identity theft and spam.

3.2 By entering the personal data and clicking the relevant button with the send function, you declare your consent to the processing of the data that is directly or indirectly necessary to respond to the contact enquiry. You also confirm that you have taken note of this Privacy Policy. You may revoke this consent at any time with effect for the future by contacting us using the contact details below.

Art. 4: Cookies

4.1 We use cookies on our Website. Cookies are small files that are placed on your device and stored by your browser. Some of the cookies we use are automatically deleted when you leave our Website. Other cookies remain stored on your device until you delete them or until they expire. These cookies enable us to recognise your browser on your next visit to our Website.

4.2 You can set your browser so that you are informed in advance about the setting of cookies and can decide in each individual case whether to exclude the acceptance of cookies in certain cases or in general, or so that cookies are blocked completely. This may restrict the functionality of the Website.

Art. 5: Integration of Third-Party Services

5.1 We use various third-party services on our Website. Below, we set out in detail which services are involved, what we use them for and which data is collected. When disclosing personal data abroad, we rely primarily on a decision of the Federal Council on the adequacy of data protection in the recipient state – for certified providers in the USA, in particular on the Swiss-U.S. Data Privacy Framework – and, on a subsidiary basis, on appropriate safeguards such as standard data protection clauses. To the extent required, your consent pursuant to Art. 17 FADP is given by accepting the corresponding prompt on the Website (see Art. 4: Cookies). Your acceptance is stored in the background (browser) until you actively revoke this consent by deleting the setting.

5.2 The Website is hosted by Cloudflare (Cloudflare Germany GmbH in Munich, Germany, or Cloudflare, Inc. in San Francisco, USA). When our Website is accessed and used, Cloudflare collects personal data that your browser automatically transmits to the hosting server. This information is temporarily stored in a so-called log file. When you use our Website, Cloudflare collects the following data, which is technically required to display the Website and to ensure its stability and security: a) IP address of the requesting computer, b) date and time of access, c) name and URL of the retrieved file, d) website from which access is made (referrer URL), and e) browser used and, where applicable, the operating system of your computer as well as the name of your access provider. We have concluded a data processing agreement with Cloudflare; Cloudflare processes your personal data exclusively on our behalf and in accordance with our instructions. Cloudflare operates a global server network; processing takes place in Germany and/or in the USA. For disclosures abroad, we rely on appropriate safeguards in the form of standard data protection clauses (see Art. 5.1). For information on the handling of your personal data, please contact Cloudflare directly and consult the privacy policy of Cloudflare.

5.3 Our e-mail services are provided by domainfactory GmbH in Ismaning (Germany). When you correspond with us by e-mail, the content of your message and the associated connection and sender data (in particular sender and recipient address, subject, date and time, as well as technical transmission data) are processed and stored on domainfactory's servers in Germany. We have concluded a data processing agreement with domainfactory; domainfactory processes your personal data exclusively on our behalf and in accordance with our instructions. For information on the handling of your personal data, please contact domainfactory directly and consult the privacy policy of domainfactory GmbH.

5.4 This Website also uses the web analytics service Google Analytics 4. The provider for users in Switzerland and the EEA is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies and similar technologies that enable an analysis of the use of the Website. Google Analytics 4 does not store or log complete IP addresses; the IP address is used exclusively for rough geographical allocation and is truncated or discarded before storage. The information collected may be transferred to Google servers, including in the USA; Google LLC is certified under the Swiss-U.S. Data Privacy Framework. On our behalf, Google will use this information to evaluate the use of the Website and to compile reports on Website activity. Google Analytics is only activated if you have given your consent in the privacy settings (see Art. 1.3); you may revoke your consent at any time with effect for the future by adjusting the setting. Further information can be found in the privacy policy of Google.

Art. 6: Hyperlinks

6.1 The Website contains so-called hyperlinks to websites of other providers. A linked web page is part of an independent website with its own URL address. Each web page can thus be accessed via this address using a web browser. When you activate these hyperlinks, you are redirected from our Website directly to the website of the other provider. You can recognise this, among other things, by the change of URL.

6.2 We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection provisions. Please inform yourself about the handling of your personal data by these companies directly on their websites.

Art. 7: Rights of Data Subjects

7.1 To the extent provided for by the data protection law applicable to you, you may request, free of charge, information about the data stored about you, its origin and recipients and the purpose of the data processing. Under the statutory conditions, you are also entitled to rectification, deletion, restriction of or objection to the processing as well as to the release of this data for transfer to another body.

7.2 Visitors to the Website and other persons about whom we process personal data may, free of charge, request confirmation as to whether personal data is processed by us and, if so, information about our processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, have their personal data rectified, deleted ("right to be forgotten") or blocked, revoke consent given and object to the processing of their personal data.

7.3 Persons about whom we process personal data have the right to lodge a complaint with a competent data protection supervisory authority. The data protection supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

Art. 8: Data Security and Security Measures

8.1 We are committed to protecting your privacy and treating your personal data confidentially. In order to prevent manipulation, loss or misuse of your data stored with us, we take extensive technical and organisational security precautions, which are regularly reviewed and adapted to technological progress. This includes, among other things, the use of recognised encryption methods (SSL or TLS). However, we point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures may not be observed by other persons or institutions outside our area of responsibility. In particular, data disclosed in unencrypted form – for example by e-mail – may be read by third parties. We have no technical influence on this. It is the responsibility of the user to protect the data they provide against misuse by means of encryption or in any other way.

8.2 Access to this Website is, like any use of the Internet, also subject to general, indiscriminate and suspicionless mass surveillance by security authorities in Switzerland, the EU, the USA and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police authorities and other security authorities.

Art. 9: Controller and Information

9.1 Enquiries from supervisory authorities and data subjects usually reach us by e-mail, but may also be sent by post:

LÖTSCHER AG

Morgartenstrasse 9

CH-6003 Luzern

Switzerland

[email protected]

9.2 The controller for the data processing is the company named in section 9.1.

Art. 10: Up-to-dateness and Status of this Privacy Policy

10.1 As changes to Swiss or European legislation or changes to our processes may make it necessary to amend this Privacy Policy at any time, we ask you to consult this Privacy Policy regularly. The current Privacy Policy can be accessed, saved and printed via the following link.

10.2 Should individual provisions of this Privacy Policy be deemed invalid, unlawful or unenforceable by a competent court or authority under the applicable law, the relevant provision shall be deemed not to form part of this Privacy Policy. However, this shall not restrict the validity, lawfulness and enforceability of the remaining provisions of this Privacy Policy under the law of the relevant country or any other country.

10.3 This Privacy Policy is dated August 2026 and bears the version number 10 (V10).

10.4 If this Privacy Policy is translated into other languages, the German version shall prevail in the event of discrepancies.