Privacy policy

Thank you very much for your interest in our company. Data protection is of a particularly high priority for the management of the company Hals-Nasen-Ohren-Center Luzern AG. The use of the Internet pages of the company Hals-Nasen-Ohren-Center Luzern AG is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website / contact form / e-mail, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such “fiduciary” processing, we generally obtain the explicit consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, telephone number, or other personal data of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the company Hals-Nasen-Ohren-Center Luzern AG. By means of this data protection declaration, our company would like to inform the public and employees / customers / partners / suppliers about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration and, where appropriate, any additional consents displayed / provided.

As the controller, the company Hals-Nasen-Ohren-Center Luzern AG has implemented numerous technical and organizational measures, including state-of-the-art technology, industry recommendations and best practices, to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions and internal electronic data processing may have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit or receive personal data to or from us by alternative means, for example by telephone or by encrypted data transfer.

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

General and notes, information and reporting obligations

Based on Article 13 of the Swiss Federal Constitution and the data protection provisions of the Swiss Confederation (Data Protection Act, DSG), every person has the right to protection of their privacy and protection against misuse of their personal data. The fiduciary operators of these pages, services and personal data take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations, information and reporting obligations under the Swiss Data Protection Act and this privacy policy.

In cooperation with our hosting providers, we make every effort to protect the databases as well as possible against unauthorized access, loss, misuse or falsification.

We would like to point out that data transmission over the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. If required and desired, personal data should and can be exchanged via other secure, encrypted channels.

By using this website and our other services, data processing, you consent to the collection, processing and use of data in accordance with the following description. This website can be visited without registration. Data such as pages called up or names of files called up, date and time are stored on the server for statistical purposes without this data being directly related to your person. Insofar as personal data (e.g. name, address or e-mail addresses) is collected on our website, this is always done on a voluntary basis as far as possible. This data will not be passed on to third parties without your express consent.

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 (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to enter into or perform a contract with you (or the entity or person you represent).

1. definitions

The data protection declaration of the company Hals-Nasen-Ohren-Center Luzern AG is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this privacy policy:

§ a) personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

§ b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

§ c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

§ d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of restricting its future processing.

§ e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

§ f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

§ g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

§ h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

§ i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, authorities that may receive personal data in the context of a specific investigation mandate under Union law or the law of the Member States are not considered recipients.

§ j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

§ k) Consent

Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the:

Ear, Nose and Throat Center Lucerne AG

Hünenbergstr. 1

CH-6006 Lucerne

Switzerland

Phone: +41 41 420 6634

E-mail: dpo@hno-luzern.ch -> Dataprotection Officer / person responsible for data protection in the organization – also for inquiries and reports relating to data protection / data security / cybersecurity incidents.

Websites: www.hno-luzern.ch, www.nasenkorrektur-luzern.ch

 

3. cookies, SSL, Google Analytics

The Internet pages of the Hals-Nasen-Ohren-Center Luzern AG use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, the Hals-Nasen-Ohren-Center Luzern AG can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user’s computer system.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

With SSL/TLS encryption

This website uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as requests you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “”http://”” to “”https://”” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the controller responsible for data processing on this website is located outside the European Economic Area or Switzerland, Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as “Google”.

The statistics obtained enable us to improve our offer and make it more interesting for you as a user. This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your usage in the settings there under “My data”, “Personal data”.

The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f GDPR. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. We would like to point out that on this website Google Analytics has been extended by the code “”_anonymizeIp();”” in order to ensure an anonymized collection of IP addresses. This means that IP addresses are processed in abbreviated form so that they cannot be linked to a specific person. If the data collected about you can be assigned to a person, this will be excluded immediately and the personal data will be deleted immediately.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Google Analytics uses cookies. The information generated by cookies about your use of this website is usually transferred to a Google server in the USA and stored there. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: Deactivate Google Analytics.

You can also prevent the use of Google Analytics by clicking on this link: Deactivate Google Analytics. This will store an opt-out cookie on your data carrier, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your end device, these opt-out cookies will also be deleted, i.e. you must set the opt-out cookies again if you wish to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/end device and must therefore be activated separately for each browser, computer or other end device.

 

4. collection of general data and information

The website of the Hals-Nasen-Ohren-Center Luzern AG collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using these general data and information, the company Hals-Nasen-Ohren-Center Luzern AG does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the company Hals-Nasen-Ohren-Center Luzern AG analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. registration on our website or forms

The data subject has the option of registering on the controller’s website (e.g. published email addresses) or contact forms (e.g. Microsoft Forms) by providing personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the transfer to one or more processors, such as a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.

By registering on the controller’s website, the IP address assigned by the data subject’s Internet service provider (ISP), the date and time of registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to enable the investigation of criminal offenses committed. In this respect, the storage of this data is necessary to safeguard the controller. This data will not be passed on to third parties unless there is a legal obligation to pass it on or it serves the purpose of criminal prosecution.

The registration of the data subject with voluntary provision of personal data serves the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller’s database.

The data controller shall provide any data subject with information on which personal data relating to the data subject is stored at any time upon request. Furthermore, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as this does not conflict with any statutory retention obligations. A data protection officer named in this privacy policy and the entirety of the controller’s employees are available to the data subject as contact persons in this context.

6. subscription to our newsletter

On the website of the Hals-Nasen-Ohren-Center Luzern AG, users are given the opportunity to subscribe to our enterprise’s newsletter. Which personal data is transmitted to the data controller when ordering the newsletter is determined by the input mask used for this purpose.

The company Hals-Nasen-Ohren-Center Luzern AG informs its customers and business partners regularly by means of a newsletter about enterprise offers. Our company’s newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation email is sent to the email address entered by a data subject for the first time for the newsletter mailing using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as legal protection for the controller.

The personal data collected when registering for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter dispatch, can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to inform the controller of this in another way.

7. newsletter tracking

The newsletter of the company Hals-Nasen-Ohren-Center Luzern AG contains so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, the company Hals-Nasen-Ohren-Center Luzern AG may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimize the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After a revocation, this personal data will be deleted by the controller. The company Hals-Nasen-Ohren-Center Luzern AG automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. contact possibility via the website

The website of the company Hals-Nasen-Ohren-Center Luzern AG contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purposes of processing or contacting the data subject. This personal data will not be passed on to third parties.

11. storage, duration, deletion and blocking of personal data

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be retained for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply12. Rights of the data subject

§ a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

§ b) Right to information

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to obtain from the controller free information about the personal data stored about him/her and a copy of this information at any time. Furthermore, the European legislator has granted the data subject access to the following information:

  • the purposes of processing
  • the categories of personal data that are processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
  • the existence of a right to lodge a complaint with a supervisory authority
  • if the personal data is not collected from the data subject: All available information about the origin of the data
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

§ c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

§ d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary

  • The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
  • The data subject withdraws consent on which the processing is based according to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 (a) GDPR and there is no other legal basis for the processing.
  • Pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (1) GDPR. 2 GDPR to object to the processing.
  • The personal data was processed unlawfully.
  • The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1 DS-GVO collected.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the company Hals-Nasen-Ohren-Center Luzern AG, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the company Hals-Nasen-Ohren-Center Luzern AG or another employee shall promptly ensure that the erasure request is complied with immediately.

If the personal data have been made public by the company Hals-Nasen-Ohren-Center Luzern AG and our company is responsible pursuant to Art. 17 para. 1 GDPR, the company Hals-Nasen-Ohren-Center Luzern AG is obliged to erase the personal data. Taking account of available technology and the cost of implementation, the controller shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of the company Hals-Nasen-Ohren-Center Luzern AG or another employee will arrange the necessary measures in individual cases.

§ e) Right to restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing pursuant to Art. Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the company Hals-Nasen-Ohren-Center Luzern AG, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the company Hals-Nasen-Ohren-Center Luzern AG or another employee will arrange the restriction of the processing.

§ f) Right to data portability

Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where the processing is based on consent pursuant to Art. 6 (1) GDPR. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR or on the basis of a contract pursuant to Art. 6 para. 1 (b) GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Art. 20 para. 1 GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by the company Hals-Nasen-Ohren-Center Luzern AG or another employee.

§ g) Right of objection

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on Article 6(1) of the GDPR, including profiling based on those provisions. 1(e) or (f) of the GDPR to object. This also applies to profiling based on these provisions.

The company Hals-Nasen-Ohren-Center Luzern AG shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the company Hals-Nasen-Ohren-Center Luzern AG processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to the Hals-Nasen-Ohren-Center Luzern AG to the processing for direct marketing purposes, the Hals-Nasen-Ohren-Center Luzern AG will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Hals-Nasen-Ohren-Center Luzern AG for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR. 1 GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of the Hals-Nasen-Ohren-Center Luzern AG or another employee. The data subject is also free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

§ h) Automated decisions in individual cases including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the company shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests. Ear, Nose and Throat Center Lucerne AG The data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of the controller or another employee of the controller.

§ i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they can contact our data protection officer or another employee of the controller at any time.

13. legal basis of the processing

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Article 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance details or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO are based. Ultimately, processing operations could be based on Art. 6 I lit. f DS-GVO are based. This legal basis is used for processing operations which are not covered by any of the aforementioned legal bases if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

14. legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

15. duration for which the personal data is stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data is routinely deleted, provided it is no longer required for the fulfillment or initiation of the contract.

16. legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer clarifies to the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

17. existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

18. changes

We may amend this privacy policy at any time without prior notice. The current version published on our website applies. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.

19 DPO – Dataprotection Officer – Questions and messages

For further questions about data protection / data security, please use the following centrally managed e-mail address:
dpo@hno-luzern.ch
-> Dataprotection Officer / person responsible for data protection in the organization.

This also applies to inquiries, uncertainty, findings and reports relating to cybersecurity incidents with corresponding response times and reporting obligations.

 

Lucerne, 17.07.2023