Last updated: April 2022
Data protection
With this privacy policy we inform which personal data we process in connection with our activities and operations including our nu.education website. In particular, we inform about what for, how and where we process personal data. We also inform about the rights of persons whose data we process.
Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as General Terms and Conditions ( T&Cs ), Terms of Use or Conditions of Participation.
We are subject to Swiss data protection law as well as any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.
1. Contact addresses
Responsibility for the processing of personal data:
NU Technology AG
Stampfenbachstrasse 57
8006 Zürich
We point out if there are other persons responsible for the processing of personal data in individual cases.
1.1 Data Protection Officer
We have the following data protection officer as a point of contact for data subjects and as a contact for supervisory authorities in the event of data protection-related inquiries:
Ramon Lisibach
NU Technology AG
Stampfenbachstrasse 57
8006 Zürich
1.2 Data protection representation in the European Economic Area (EEA)
We have the following data protection representation according toArt. 27 DSGVO. The Data Protection Representation serves as an additional point of contact for supervisory authorities and data subjects in the European Union (EU) and the rest of the European Economic Area (EEA) for inquiries related to the General Data Protection Regulation (GDPR):
VGS Data Protection Partner UG
At Kaiserkai 69
20457 Hamburg
Germany
2. Terms and legal bases
2.1 Terms
Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data is processed.
Processing includes any handling of personal data, regardless of the means and procedures used, in particular the storage, disclosure, procurement, collection, deletion, storage, modification, destruction and use of personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) plus the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as processing of personal data.
2.2 Legal bases
We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (FADP) and the Ordinance to the Federal Data Protection Act (FADP).
We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:
- Art. 6 par. 1 lit. b GDPR for the necessary processing of personal data for the fulfillment of a contract with the data subject as well as for the implementation of pre-contractual measures.
- Art. 6 par. 1 lit. f GDPR for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject override. Legitimate interests include, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner and to communicate about them, the guarantee of information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 par. 1 lit. c GDPR for the processing of personal data necessary to comply with a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
- Art. 6 par. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest.
- Art. 6 par. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
- Art. 6 par. 1 lit. d GDPR for the necessary processing of personal data to protect vital interests of the data subject or another natural person.
3. Nature, scope and purpose
We process those personal data that are necessary to carry out our activities and operations in a durable, user-friendly, safe and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data, and contract and payment data, in particular.
We process personal data for the period of time necessary for the relevant purpose(s) or as required by law. Personal data whose processing is no longer necessary is anonymized or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also ensure data protection with such third parties.
We process personal data in principle only with the consent of the data subject, unless the processing is permitted for other legal reasons, for example, for the performance of a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.
In this context, we process in particular information that a data subject voluntarily and personally provides to us when contacting us – for example, by mail, e-mail, instant messaging, contact form, social media or telephone – or when registering for a user account. For example, we may store such information in an address book, in a customer relationship management (CRM) system, or with similar tools. If you transmit data about other persons to us, you are obligated to ensure data protection with respect to such persons as well as to ensure the accuracy of such personal data.
We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.
4. Personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We can transfer personal data to all States and territories on earth and elsewhere in the universe export, provided that the local law according to the evaluation of the Federal Data Protection and Information Commissioner FDPIC) or in accordance with a decision of the Swiss Federal Council, adequate data protection and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with decision of the European Commission ensures adequate data protection.
We may transfer personal data to countries whose laws do not ensure adequate data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example, the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees upon request.
5. Rights of persons concerned
Data subjects whose personal data we process have the rights under Swiss data protection law. This includes the right to information as well as the right to rectification, deletion or blocking of the processed personal data.
Data subjects whose personal data we process may – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted (“right to be forgotten”), blocked or completed.
Data subjects whose personal data we process may – if and insofar as the GDPR applies – revoke any consent they have given at any time with effect for the future and object to the processing of their personal data at any time.
Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
6. Data security
We take suitable technical and organizational measures to ensure data security that is appropriate to the respective risk. Unfortunately, we cannot guarantee absolute data security.
Access to our website takes place by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.
Our digital communications – like all digital communications in principle – are subject to mass surveillance without cause and without suspicion, as well as other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.
7. Use of the website
7.1 Cookies
We may use cookies. Cookies – our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data that are stored in your browser. Solche gespeicherten Daten müssen nicht auf traditionelle Cookies in Textform beschränkt sein. Such stored data need not be limited to traditional cookies in text form.
Cookies can be stored in your browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, cookies allow us to recognize your browser the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.
You can disable cookies completely or partially as well as delete them in your browser settings at any time. Without cookies, our website may no longer be fully available. We actively request – if and to the extent necessary – your express consent for the use of cookies.
7.2 Server log files
We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently, user-friendly and reliably as well as to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.
7.3 Tracking pixel
We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.
8. Notifications and messages
8.1 Success and reach measurement
Notifications and messages may contain web links or tracking pixels that capture whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and communications on a personal basis. We need this statistical recording of usage for success and reach measurement in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.
8.2 Consent and objection
In principle, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent, we use the “double opt-in” procedure where possible, i.e. you will receive an e-mail with a web link that you must click to confirm so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.
In principle, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can simultaneously object to the statistical recording of usage for performance and reach measurement. Required notifications and communications in connection with our activities and operations remain reserved.
8.3 Service provider for notifications and messages
We send notifications and messages with the help of specialized service providers.
We use in particular:
- Mailchimp: Communication platform; Provider: The Rocket Science Group LLC d/b/a Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); Privacy Disclosures: Privacy Policy (Intuit) including “Country and Region-Specific Terms”, Cookie Policy, “Privacy Rights Requests”, “Mailchimp and European Data Transfers”, “Security”.
9. Social Media
We are present on social media platforms and other online platforms in order to communicate with interested persons and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).
The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.
10. Third party services
We use third party services to perform our activities and operations in a durable, user-friendly, secure and reliable manner. Such services may also be used to embed content on our website. Such services require your Internet Protocol (IP) address, otherwise the corresponding content cannot be transmitted.
For their own security, statistical and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized or pseudonymized manner. This is, for example, performance or usage data.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and Security Principles”, Privacy Policy, “Google is committed to complying with applicable privacy laws”, “Privacy Guide in Google Products”, “How we use data from websites or apps on or in which our services are used” (Google disclosures), “Cookie types and other technologies used by Google”, “Personalized advertising” (enable/disable/settings).
10.1 Digital infrastructure
We use third-party services in order to be able to make use of required digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from specialized providers.
We use in particular:
- Hostpoint: Hosting; Provider: Hostpoint AG (Switzerland); Data protection information: Privacy policy, “Frequently asked questions about the GDPR”.
- hosttech: Hosting; Providers: hosttech GmbH (Germany) / hosttech GmbH (Austria) / hosttech GmbH (Switzerland); Data protection information: Privacy policy (Germany), Privacy policy (Austria), Privacy policy (Switzerland), “Infrastructure”.
10.2 Contact options
We use third-party services to better communicate with you and others, such as customers.
We use in particular:
- Jira Service Management (Jira Service Desk): Customer Service; Vendors: Atlassian Pty Ltd (Australia) / Atlassian Inc. (USA); Data protection information: Privacy policy.
- Microsoft Dynamics 365: Customer Relationship Management (CRM); Provider: Microsoft Corporation (USA); Information on data protection: Data protection declaration, “Data protection and personal data for Microsoft Dynamics 365”, “Data protection and GDPR”.
10.3 Audio and video conferencing
We use audio and video conferencing services to communicate online. We can use them, for example, to conduct virtual meetings or online lessons and webinars. In addition to this privacy policy, any terms and conditions of the services used, such as terms of use or privacy statements, also apply.
Depending on the life situation in which you are participating in an audio or video conference, we recommend that you mute the microphone by default and blur the background or fade in a virtual background.
We use in particular:
- Microsoft Teams: Platform for audio and video conferencing, among other things; provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the United Kingdom and Switzerland; data protection information: “Data Protection” (“Microsoft Trust Center”), data protection statement, “Data Protection at Microsoft”, “Data Protection and Microsoft Teams”.
- Zoom: Video conferencing; provider: Zoom Video Communications Inc. (USA); privacy disclosures: privacy policy, “Privacy at Zoom,” “Legal Compliance Center.”
10.4 Social media functions and social media content
We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and other ways.
We use in particular:
- Instagram platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: privacy policy (Instagram), privacy policy (Facebook).
- LinkedIn Consumer Solutions Platform: Embedding functions and content from LinkedIn, for example with Plugins like the «Share Plugin»; Providers: LinkedIn Ireland Unlimited Company (Ireland) for users in the European Economic Area (EEA) and in Switzerland / LinkedIn Corporation USA) for users in the rest of the world; privacy information: “Data Protection” (“Privacy”), Privacy Policy, Cookie Policy, Cookie Management / Objection to Email and SMS Communications from LinkedIn, Objection to Interest-Based Advertising.
10.5 Map content
We use third party services to embed maps on our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Google Maps-specific privacy disclosures: “How Google uses location information”.
10.6 Audiovisual media
We use third-party services to enable the direct playback of audiovisual media such as music or videos on our website.
We use in particular:
- Cloudflare Stream: Video platform; provider: Cloudflare Inc. (USA); Privacy information: “Privacy Policy”, Privacy Policy, Cookie Policy.
- SoundCloud: Music and podcasts (widget); Provider: SoundCloud Global Limited & Co. KG (Germany); Privacy information: Privacy policy, Cookie policy.
- Spotify: Music and podcasts (widget); Provider: Spotify AB (Sweden); Privacy information: “Privacy Center”, “Privacy Policy”.
- Vimeo: Videos; provider: Vimeo Inc. (USA); Information on data protection: “Data Protection”, Privacy Policy.
- YouTube: Videos; Provider: Google (in the USA, among other places); YouTube-specific information on data privacy: “Privacy and Security Center”, “My data on YouTube”.
10.7 Documents
We use third-party services to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, tables, and text documents.
We use in particular:
- Microsoft 365 (also Microsoft Office 365): text documents as well as forms, presentations and spreadsheets; provider: Microsoft Corporation (USA); information on data protection: data protection declaration, “Data protection at Microsoft”, “Data protection” (“Microsoft Trust Center”), “Data protection and security with Microsoft 365”.
10.8 E-Commerce
We engage in e-commerce and use third-party services to successfully provide services, content or goods.
10.9 Payments
We use payment service providers to process our customers’ payments securely and reliably. The terms and conditions of the respective payment service providers, such as general terms and conditions (T&C) or data protection declarations, apply to the processing in each case.
We use in particular:
- Stripe: Payment processing; provider: Stripe Inc. (USA) / Stripe Payments Europe Limited (SPEL, Ireland) for users in the European Economic Area (EEA) and Switzerland and partially in the UK / Stripe Payments UK Limited (UK) and Stripe Capital Europe Limited (Ireland) partially for users in the UK; data protection information: “Stripe Privacy Center” (“Stripe Privacy Center”), Privacy policy, Cookie Policy.
11. Extensions for the website
We use extensions for our website in order to be able to use additional functions.
We use in particular:
- Google reCAPTCHA: Spam protection (distinguishing between wanted comments that come from humans and unwanted comments from bots, as well as spam); Google reCAPTCHA-specific privacy information: “What is reCAPTCHA?” (“What is reCAPTCHA?”).
12. Final provisions
We have created this privacy statement with the data protection generator of Datenschutzpartner.
We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.
in Zurich