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Data protection

Version from August 2nd, 2023

In this data protection declaration we explain (, below we explain how we collect and otherwise process personal data. This is not an exhaustive description; At best, general terms and conditions, conditions of participation and similar documents regulate specific matters. Personal data refers to all information that relates to a specific or identifiable person. 

If you provide us with personal data about other people (e.g. family members, data from work colleagues), please ensure that these people are aware of this data protection declaration and only provide us with their personal data if you are allowed to do so and if this personal data is correct.  

This data protection declaration is designed to meet 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. Information about the person responsible 

The company, Andreas Frutig (Chemin des Jordils 38, 1789 Lugnorre), is responsible for the data processing that we describe here, unless otherwise stated in individual cases. If you have data protection concerns, you can communicate them to us at the following contact address:, Andreas Frutig, Chemin des Jordils 38, 1789 Lugnorre,

2. Collection and processing of personal data 

We primarily process the personal data that we receive from these and other people involved as part of our business relationship with our customers and other business partners or that we collect from their users when operating our website, 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, press, Internet, specialist magazines, associations, etc.) or receive such data from other companies, authorities and other third parties (such as credit checkers, address brokers, etc.). .). In addition to the data about you that you give 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, and information about you in correspondence and discussions with third parties (if we conduct business with you personally), information about you that people in your environment (family, advisors, legal representatives, insurance companies, etc.) give us so that we can conclude contracts with you or with your involvement, or (e.g. information from banks, insurance companies), information from the media and the Internet about you (as far as this is appropriate in the specific case (e.g. as part of an application, press review, marketing/sales, etc.), your addresses and, if applicable. Interests and other socio-demographic data (for marketing) 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 accessed and content , 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 nautical training/exams with our customers, as well as to fulfill 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 persons, to the extent permitted and deemed appropriate to us, also for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose: 

  • Offer and further development of our offers, services and websites, apps and other platforms on which we are present;

  • Communication with third parties and processing their inquiries (e.g. applications, media inquiries);

  • Examination and optimization of procedures for needs analysis for the purpose of direct customer contact as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition; 

  • Advertising and marketing (including the organization of events), unless you have objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then put you on a blocking list against further advertising);  

  • Market and opinion research, media monitoring; 

  • Assertion of legal claims and defense in connection with legal disputes and governmental proceedings; 

  • Preventing and solving crimes and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud); 

  • Warranties of our operations, in particular IT, our websites, apps and other platforms; 

  • Purchase and sale of business areas, companies or parts of companies and other corporate transactions and the associated transfer of personal data as well as measures for business management and to comply with legal and regulatory obligations as well as internal regulations of 

If you have given us your consent to process your personal data for specific purposes (for example when you register to receive newsletters), we will process your personal data within the framework and based on this consent, unless we have another legal basis and we need one. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place. 

4. Cookies / tracking and other technologies related to the use of our website 

We typically use “cookies” and similar technologies on our website that can 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. This way, 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 are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information over a certain period of time (e.g. two years) ("permanent cookies "). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them early. Most browsers are preset to accept cookies. We use permanent cookies to save user settings (e.g. language, autologin) and to better understand how you use our offers and content. Some of the cookies are set by us, and some are also set by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection) may no longer work. 

In some of our newsletters and other marketing emails, and where permitted, we also include visible and invisible image elements, by retrieving them from our servers we can determine whether and when you have opened the email, so that we can also measure here and better understand how to use our offerings and tailor them to you. You can block this in your email program; most are preset to allow you to do this.

By using our website and agreeing to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not want this, you must set your browser or email program accordingly.

Google Maps
We use Google Maps to display interactive maps and to create directions. Google Maps is a mapping service from Google.
By using Google Maps, information about your use of this website, including your IP address and the (starting) address entered as part of the route planner function, can be transmitted to Google in the USA.
When you access a page on our website that contains Google Maps, your browser establishes a direct connection with Google's servers. The map content is transmitted by Google directly to your browser and integrated into the website. We therefore have no influence on the extent of the data collected by Google in this way. According to our level of knowledge, this is at least the following data:

  • Date and time of visit to the relevant website

  • Internet address or URL of the website accessed

  • IP address

  • (Start) address entered as part of route planning.

We have no influence on the further processing and use of the data by Google and can therefore assume no responsibility for this.
If you do not want Google to collect, process or use data about you via our website, you can deactivate JavaScript in your browser settings. However, in this case you cannot use the map display.
The purpose and scope of data collection and further processing and use of the data by Google as well as your related rights and setting options to protect your privacy can be found in Google's data protection information:
By using our website, you agree to the processing of the data collected about you by Google Maps Route Planner in the manner and for the purpose described above.

Google reCAPTCHA
reCAPTCHA is intended to check whether data entry on our website (e.g. in a contact form) is done by a human or by an automated program. Among other things, we limit abusive website requests from automated tools and spam. To do this, reCAPTCHA analyzes the behavior of website visitors based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For analysis, reCAPTCHA evaluates various information (e.g. IP address, length of time the website visitor stays on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyzes run completely in the background. Website visitors are not informed that an analysis is taking place. By blocking the reCAPTCHA  It is possible that you will no longer be able to fully use the services of our website, especially with regard to forms.

Google Analytics
We sometimes use Google Analytics or similar services on our website. This is a service provided by third parties who may be located in any country in the world (in the case of Google Analytics it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as data processor (both “Google”),, with which we can measure and evaluate the use of the website (not personal). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are shortened before being forwarded to the USA and therefore cannot be traced back. We have turned off 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 draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and share this data with Google -Accounts of these people can be linked. 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 in accordance with its data protection regulations. The service provider only tells us how our website is used (no information about you personally).
Google states that it does not associate your IP address with other data. In addition, Google is keeping under Further data protection information is available for you, including, for example, the options for preventing data use.
Google also offers under a so-called deactivation add-on along with further information about this. This add-on can be installed with common Internet browsers and offers you further control over the data that Google collects when you visit our website.

Unless expressly agreed otherwise, electronic communication takes place via non-encrypted emails. The use of email is not technically secure; It may happen that emails are not delivered. When sending emails, they can leave national borders, even if the sender and recipient are within Germany. The confidentiality of emails cannot be guaranteed if encryption is missing or insufficient.
Even when using forms that are available on our website, your message is only transmitted encrypted from your computer to the web server.
By using the forms or sending an email, you agree to communication via email with knowledge of the risks described. The use of encrypted or otherwise secured communication channels must be agreed with us in advance.

Social media

We also use so-called plug-ins from social networks such as Meta, Facebook, Twitter, YouTube, Pinterest or Instagram on our website. This is clear to you in each case (typically via corresponding symbols). We have configured these elements to be disabled by default. If you activate it (by clicking on it), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection regulations. We do not receive any information about you from him. In principle, you can assert your data protection rights with regard to data processing by our company websites both against us and against the respective operator of a platform. However, we would like to point out that these can most effectively be asserted with the respective operator of a platform, as only they have access to the user's data and can take appropriate measures and provide information directly. 

5. Server locations

Our website is hosted by Cyon GmbH in Basel.

Your personal data collected as part of the activities on the website is hosted on the Cyon GmbH servers in Switzerland. The servers are protected as best as possible against unauthorized third-party access. Backups are created regularly to prevent data loss as much as possible.

As far as your personal data is concerned, which we collect directly, it is stored on our own servers as well as on virtual servers of a cloud provider with a good reputation and stored in Switzerland. The servers are protected as best as possible against unauthorized third-party access. Backups are created regularly to prevent data loss as much as possible. 

6. Data transfer and data transfer abroad 

As part of our business activities and the purposes set out in Section 3, we also disclose data to third parties, to the extent permitted and deemed appropriate to us, either because they process it for us or because they use it for their own purposes want. This particularly concerns the following positions:

  • Our service providers (internal and external, such as banks, insurance companies, authorities, shipyards), including order processors (such as IT providers); 

  • Dealers, suppliers, subcontractors and other business partners; 

  • customers; 

  • domestic and foreign authorities, offices or courts; 

  • Media; 

  • Public, including visitors to websites and social media; 

  • Competitors, industry organizations, associations, organizations and other committees; 

  • Acquirers or interested parties in acquiring business areas, companies or other parts of; 

  • other parties in potential or actual legal proceedings.

These recipients are partly domestic, but can be anywhere on earth. In particular, you must expect your data to be transmitted to all countries where the service providers we use are located (such as Google). 

If a recipient is located abroad, cooperation is only an option for us if the country in question has an equivalent level of data protection or we can contractually ensure the equivalence of the level of protection (e.g. through contracts or the conclusion of so-called standard contractual clauses) or an exception provision comes into play. An exception may apply in particular in legal proceedings abroad, but also in cases of overriding public interests or if the execution of a contract requires such disclosure, if you have given your consent or if it concerns data that you have made generally accessible and the processing of which you have not objected to.

7. Duration of storage of personal data 

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

8. Data security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and

9. Obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or process a contract with you (or the entity or person you represent). The website cannot be used if certain information to ensure data traffic (such as IP address) is not disclosed.

10. Profiling

We process some of your personal data automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to provide you with targeted information and advice about products. We use evaluation instruments that enable us to communicate and advertise in line with needs, including market and opinion research. 

To establish and implement the business relationship or otherwise, we generally do not use fully automated decision-making (as regulated in Art. 22 GDPR). If we use such procedures in individual cases, we will inform you separately, provided this is required by law and inform you about the associated rights.

11. Rights of the data subject 

Within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular that for direct marketing purposes , profiling carried out for direct advertising and other legitimate interests in processing as well as the release of certain personal data for the purpose of transferring it to another location (so-called data portability). Please note, however, that we reserve the right to enforce the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (to the extent that we are entitled to rely on this) or use them for the assertion of requirements. If you incur any costs, we will inform you in advance. We have already provided information about the possibility of revoking your consent in Section 3. Please note that exercising these rights may conflict with contractual agreements and this may have consequences such as early termination of the contract or cost consequences. We will inform you in advance if this is not already contractually agreed. 

The exercise of such rights generally requires that you provide clear proof of your identity (e.g. by providing a copy of your ID, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in Section 1.

Every data subject also has the right to enforce their claims in court or to file a complaint with the responsible data protection authority.  The responsible data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (

12. Changes 

We may amend this privacy policy at any time without prior notice. The current version published on our website applies. To the extent that the privacy policy is part of an agreement, in the event of an update, we will inform you of the change in an appropriate manner. 

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