Ir para o conteúdo The LESS AG (hereinafter the LESS, we or us), a manufacturer of Portuguese leather goods based in Kuesnacht, attaches great importance to the privacy of the persons whose data it processes and is committed to the protection of this personal data – i.e. all information on the basis of which someone can be identified as a person.
We would therefore like to inform you about this in this privacy policy,
• who is responsible for processing the personal data (section 2);
• who may be contacted in the European Union (EU; section 3);
• which personal data we collect and process (section 4);
• how and by whom the personal data is collected and processed (section 4);
• for what purpose and on what legal basis we process the personal data (section 5);
• how the use of our website works (section 6);
• to whom we disclose the personal data (Section 7);
• how long we store the personal data (Section 8); and
• what your rights are as a data subject (Section 9).
When collecting, processing, disclosing and storing personal data, we and our employees comply with this privacy policy as well as the provisions of the applicable data protection regulations – primarily the Swiss Data Protection Act (DPA) and its ordinance. As we also maintain business relationships with partners based in the European Union (EU) or the European Economic Area, our privacy policy also takes into account the requirements of the EU General Data Protection Regulation (GDPR).
If you provide us with data about other persons (e.g. family members or other related persons), we assume that you are authorized to do so and that this data is correct, and that you have ensured that these persons are informed about this disclosure, insofar as a legal obligation to provide information applies (e.g. by bringing this data protection declaration to their attention in advance).
The LESS is responsible for the data processing described here, unless otherwise stated in individual cases. If you have any data protection concerns, you can send
them by e-mail to admin@theless.ch.
As our registered office is outside the European Union (EU), we have appointed an EU representative as a precautionary measure in accordance with Art. 27 DSGVO.
Our representative in the EU is: Mauer & Partner Wirtschaftsprüfer Steuerberater mbB, Borsigstr. 6, Baden-Württemberg, 72760 Reutlingen, Germany, stefan.geburtig@mauer-gruppe.com, 0049 711 2239999.
Data subjects in the EU may contact our EU representative directly with any questions regarding the processing of their personal data.
We primarily collect certain personal data when you visit our website or when you contact us by e-mail or other means of communication. Please note that our website contains links to third party websites. The linked websites are not under the control of the LESS, and we are not responsible for the content, privacy practices or other activities of any linked website or any link contained in a linked website.
The categories of personal data that we collect and process include, but are not limited to
• Personal data for your identification or to contact you, such as e-mail address, first name and surname, telephone number, address, usage data;
• Personal data in connection with communication such as correspondence with you by letter, e-mail, telephone or other means of communication;
automatically transmitted or collected personal data in connection with the use of our website (e.g. date and time of use, previous and accessed page, IP address, data on the browser used, device identifier, current location, insofar as this information is released – otherwise we deliberately refrain from collecting such data as far as possible, see section5 );
• Personal data from the media and the internet (where appropriate in a specific case, e.g. in the context of a job application or marketing) and, where applicable, interests and other socio-demographic data (for marketing).
We operate pages and other online presences on social networks and other platforms operated by third parties and process data about you in this context. In doing so, we receive data from you (e.g. when you communicate with us or comment on our content) and from the platforms (e.g. statistics). The providers of the platforms can analyze your use and process this data together with other data they have about you. They also process this data for their own purposes (e.g. marketing and market research purposes and to manage their platforms), and act as their own data controllers for this purpose. For further information on processing by the platform operators, please refer to the privacy policies of the respective platforms.
We are entitled but not obliged to check third-party content before or after its publication on our online presences, to delete content without notice and, if necessary, to report it to the provider of the platform in question. Some platform operators may be located outside Switzerland. Information on data disclosure abroad can be found below under section 6.
The LESS may use personal data by name for the following purposes:
• To provide and maintain our service and the website, including monitoring the use of our service.
• To contact you: To contact you via email or other forms of communication.
• To manage your requests: To process and manage your requests to us.
• For business transfers: We may use your information to evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information we hold about our service users is among the assets transferred.
• For other purposes: We may use your information for other purposes, such as analyzing data, identifying usage trends, determining the effectiveness of our advertising campaigns, and evaluating and improving our service, products, services, marketing and your experience.
If you have given us your consent to process your personal data for specific purposes, we will process your personal data within the scope of and based on this consent, provided we have no other legal basis and we require one . Consent that has been granted can be revoked at any time, but this has no effect on data processing that has already taken place.
If you apply for a job with us, we will obtain and process the relevant data for the purpose of reviewing the application, carrying out the application process and, in the case of successful applications, for the preparation and conclusion of a corresponding contract. In addition to your contact details and the information from the corresponding communication, we also process the data contained in your application documents and the data that we can additionally obtain about you, e.g. from job-related social networks, the Internet, the media and from references, if you consent to us obtaining references.
When you use our website, data is generated that is stored in logs (in particular technical data). We also use “cookies” and similar technologies on our website to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website. This enables us to recognize you when you return to this website, even if we do not 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 for a certain period of time (e.g. two years) (“permanent cookies”). However, you can set your browser so that it rejects cookies, only stores them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that we can better understand how you use our offers and content. If you block cookies, certain functions (e.g. language selection) may no longer work.
Neither the technical data collected by us nor cookies generally contain any personal data. However, personal data that we or third-party providers commissioned by us store about you (e.g. if you have a user account with us or these providers) may be linked to the technical data or to the information stored in and obtained from cookies and thus possibly to your person.
We also use social media plug-ins. These are small software modules that establish a connection between your visit to our website and a third-party provider. The social media plug-in informs the third-party provider that you have visited our website and may send the third-party provider cookies that it has previously placed on your web browser. For more information on how these third-party providers use your personal data collected via their social media plug-ins, please refer to their respective privacy policies.
We sometimes use Google Analytics or similar services on our website. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google LLC in the USA, www.google.com), with which we can measure and evaluate the use of the website (on a non-personal basis). Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (and does not store any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by the service provider, and use these findings for its own purposes (e.g. control of advertising). 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 provisions. The service provider only informs us how our website is used (no information about you personally).
We may disclose your personal data to third parties in the following situations:
• To Service Providers: We may share your Personal Data with Service Providers to monitor and analyze the use of our Service, to show you advertisements, to support and service our Service, to show you advertisements on third party websites after you have visited our Service. For business transfers: We may share or transfer your Personal Data in connection with or during negotiations of a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• To business partners: We may share your information with our business partners to offer you certain products, services or promotions.
• To other users: If you share personal information or otherwise interact with other users in the public areas, this information can be viewed by all users and made public to the outside world. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service will be able to see your name, profile, pictures and description of your activities. Similarly, other users can view descriptions of your activities, communicate with you and view your profile.
• With your consent, we may disclose your personal data for any other purpose.
We process and store personal data mainly in Switzerland and the European Economic Area (EEA), but potentially in any country in the world. If we transfer personal data to a country without adequate legal data protection, we ensure – as required by law – by using appropriate contracts (namely on the basis of the revised standard contractual clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj, including the supplements required for Switzerland), unless the recipient of the personal data is already subject to a legally recognized set of rules to ensure data protection, or we rely on a legal exception such as consent, contract performance, the establishment, exercise or enforcement of legal claims, overriding public interests, generally accessible personal data or because it is necessary to protect the physical integrity of the data subjects. We may also rely on the exception for data from a register provided for by law (e.g. HR), which we have legitimately obtained access to. You can request a copy of the aforementioned contractual guarantees, if any, at any time by contacting us via the contact information in section 2 . However, we reserve the right to redact copies for reasons of data protection or confidentiality or to provide only excerpts.
We store your personal data in Switzerland and have taken appropriate technical and organizational security measures to protect it from unauthorized access and misuse (e.g. IT and network security solutions, encryption of communication or data carriers, issuing of instructions). We 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. As soon as your personal data is no longer required for the purposes mentioned above under section 4 , it will be deleted or anonymized as far as possible. Shorter retention periods of twelve months or less generally apply to operational data (e.g. system logs, logs).
You have certain rights in connection with our data processing. In accordance with applicable law, you may in particular request information about the processing of your personal data, have incorrect personal data corrected, request the erasure of personal data, object to data processing, request the disclosure of certain personal data in a commonly used electronic format or its transfer to other controllers.
If you wish to exercise your rights against us, please contact us; our contact details can be found at section 2 . So that we can rule out misuse, we must identify you (e.g. with a copy of your ID, if necessary).
Please note that conditions, exceptions or restrictions apply to these rights (e.g. to protect third parties or business secrets). We reserve the right to redact copies for reasons of data protection or confidentiality or to provide only excerpts. We have already informed you about the possibility of revoking your consent in section 4 . Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract with you or cost consequences for you. We will inform you in advance if this is not already contractually regulated.
The exercise of your rights generally requires that you provide us with clear proof of your identity in advance (e.g. by means of a copy of your ID if your identity is otherwise not clear or cannot be verified). The contact details for asserting your rights can be found above at section 2.
If you are in the EEA, you also have the right to lodge a complaint with the competent data protection authority in your country. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_de.
We do not assume that the GDPR is applicable in our case. However, should this be the case in exceptional cases for certain data processing, this Section 9 shall also apply exclusively for the purposes of the GDPR and the data processing subject to it. We base the processing of your personal data in particular on the fact that
• it is necessary to protect our legitimate interests or those of third parties as described in para. 4, namely for communication with you or third parties, to operate our website, to improve our electronic offers and registration for certain offers and services, for security purposes, for compliance with Swiss law and internal regulations, for our risk management and corporate governance and for other purposes such as training and education, administration, evidence and quality assurance, organization, implementation and follow-up of events and to safeguard other legitimate interests (see section 4) (Art. 6 para. 1 lit. f GDPR);
• it is required or permitted by law on the basis of our mandate or our position under the law of the EEA or a member state (Art. 6 para. 1 lit. c GDPR) or is necessary to protect your vital interests or those of other natural persons (Art. 6 para. 1 lit. d GDPR);
• you have separately consented to the processing.
We may amend this privacy policy at any time without prior notice. The current version published on our website applies.
