Privacy Policy

Privacy Policy
DeeplySecure – deeplysecure.com


1. Data Controller

Responsible for data processing in connection with this website and the platform offered under deeplysecure.com is:

Teichmann International (IT Solutions) AG

Dufourstrasse 124

9000 St. Gallen, Switzerland

Commercial Register: Canton of St. Gallen

Phone: +41 71 260 2440 · Email: info@teichmann-it.com

(hereinafter "Controller", "we" or "us").

1.1 Data Protection Officer

You can reach our Data Protection Officer at ayvazyan@teichmann-it.com.

1.2 Representative in the European Union (Art. 27 GDPR)

Since we, as a company based in Switzerland, offer goods

or services to persons in the European Union and monitor their behavior, the GDPR applies directly pursuant to Art. 3

Para. 2 GDPR. You can reach our representative in the Union under Art. 27 GDPR

at:

VGS Datenschutzpartner GmbH

Am Kaiserkai 69

20457 Hamburg

Germany

info@datenschutzpartner.eu

2 Applicable Law, Scope, and Principles

This Privacy Policy provides information about the type, scope, and purposes of processing personal data when visiting this website, as well as when using the forms and functions offered on it. Regulating frameworks are the General Data Protection Regulation (GDPR) and – insofar as users in the Federal Republic of Germany are affected – the Federal Data Protection Act (BDSG) and the Telecommunications-Digital Services-Data Protection Act (TDDDG). Additionally, the Swiss Federal Act on Data Protection (revFADP) applies to the Controller. We process personal data according to the principles of lawfulness, data minimization, purpose limitation, transparency, and integrity and confidentiality (Art. 5 GDPR).

2.1 Overview of Legal Bases

Insofar as we process personal data, we base our operations on the following legal bases depending on the processing situation:

• Art. 6 Para. 1 lit. a GDPR – Consent of the data subject;

• Art. 6 Para. 1 lit. b GDPR – Performance of a contract or implementation of pre-contractual measures;

• Art. 6 Para. 1 lit. c GDPR – Compliance with a legal obligation;

• Art. 6 Para. 1 lit. f GDPR – Protection of legitimate interests, except where such interests are overridden by the interests or fundamental rights of the data subject.

The storage of information on your terminal device or access to it (e.g., via cookies or pixels) is done exclusively based on your consent in accordance with Section 25 Paragraph 1 TDDDG in conjunction with Art. 6 Paragraph 1 lit. a GDPR, unless these are strictly necessary processes within the meaning of Section 25 Paragraph 2 TDDDG.

3. Your Rights as a Data Subject in the Learning/Administration/Reporting Environment (SaaS).

You have the following rights against the Controller regarding the personal data concerning you:

• Access to the processed data (Art. 15 GDPR);

• Rectification of inaccurate or completion of incomplete data (Art. 16 GDPR);

• Erasure (Art. 17 GDPR);

• Restriction of processing (Art. 18 GDPR);

• Data portability (Art. 20 GDPR);

• Objection to processing (Art. 21 GDPR);

• Withdrawal of consent given with effect for the future (Art. 7 Para. 3 GDPR)

3.1 Right to Object (Art. 21 GDPR)

Insofar as we process data on the basis of legitimate interests (Art. 6 Para. 1 lit. f GDPR), you have the right to object at any time, on grounds relating to your particular situation, to such processing; this also applies to profiling based on these provisions. If data is processed for direct marketing purposes, you have the right to object at any time without giving reasons.

3.2 Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other legal remedies, you have the right to lodge a complaint with a data protection supervisory authority – in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement. For controllers based in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC) is also responsible

4. Provision of the Website and Server Log Files

This website is operated via the Framer service (Framer B.V., Netherlands, along with deployed Content Delivery service providers). When the website is accessed, information is automatically transmitted from the browser to the server and stored in log files, in particular:

• IP address of the requesting terminal device (regularly shortened/anonymized),

• Date and time of access,

• Accessed page or file as well as transmitted data volume,

• Notification of successful retrieval,

• Browser type and version, operating system, and referrer URL.

The legal basis is Art. 6 Paragraph 1 lit. f GDPR. Our legitimate interest lies in the technically error-free provision, stability, and security of the website. A data processing agreement exists with the hosting service provider pursuant to Art. 28 GDPR.

5. Cookies and Consent Management

Our website uses cookies and comparable technologies (e.g., pixels, local storage techniques). Cookies are small text files that are stored on your terminal device. They do not cause damage and do not contain malware. We use technically necessary cookies, which are strictly required for the operation of the website, based on Section 25 Paragraph 2 TDDDG or Art. 6 Paragraph 1 lit. f GDPR. All non-essential cookies and technologies – in particular the marketing and audience measurement services described in this policy – are only deployed after your explicit consent via our consent management tool (Section 25 Paragraph 1 TDDDG, Art. 6 Paragraph 1 lit. a GDPR). You can change or withdraw your choice at any time with effect for the future via [insert link to cookie settings / consent tool].

6. Contacting Us

When you contact us via contact form, email, or phone, we process the data you provide (e.g., name, company, email address, phone number, content of the request) to handle your request. The legal basis is Art. 6 Paragraph 1 lit. b GDPR, insofar as the request relates to the conclusion or performance of a contract, and otherwise Art. 6 Paragraph 1 lit. f GDPR (legitimate interest in answering requests). The data will be deleted as soon as they are no longer needed to achieve the purpose and no legal retention periods apply.

7. Lead Form and Booking Demo Calls

On our website, we offer a form to initiate contact and and to schedule a non-binding demo call. In doing so, we process the data you provide, in particular:

• First and last name,

• Business email address and phone number,

• Company, position, and company size.

The purpose of processing is to handle your request, prepare and conduct the demo call, and initiate a business relationship. The legal basis is Art. 6 Paragraph 1 lit. b GDPR (pre-contractual measures) as well as – insofar as you consent to advertising addressing or further contact for marketing purposes – Art. 6 Paragraph 1 lit. a GDPR. We obtain and document consent via a separate, non-preselected checkbox in the form. Insofar as a third-party booking function is used ([insert name of booking tool, e.g., Calendly / HubSpot Meetings]), that provider processes the data required for scheduling on our behalf. The data collected in the form is subsequently transferred to our CRM system (see Section 8).

8. Customer Relationship Management (Clio Manage)

To manage prospect and customer contact information, we use the CRM system Clio Manage. Data that you submit via the lead form or in the course of further communication is stored and processed in this system in order to handle inquiries, manage the business relationship, and provide our services. The provider is Themis Solutions Inc. ("Clio"). The required data processing agreements pursuant to Art. 28 GDPR have been concluded with the provider as well as with the group-affiliated Teichmann International (IT Solutions) AG as the entity integrated on the operator side. The legal basis is Art. 6 Paragraph 1 lit. b GDPR (initiation/performance of the business relationship) and Art. 6 Paragraph 1 lit. f GDPR (legitimate interest in efficient, documented contact management). If storage is performed for independent advertising purposes, it is based on your consent pursuant to Art. 6 Paragraph 1 lit. a GDPR.

9. Audience Measurement and Marketing

The services mentioned below are activated exclusively after your consent (Section 25 Paragraph 1 TDDDG, Art. 6 Paragraph 1 lit. a GDPR). Consent also includes the possible transfer of data to third countries described in the services (Art. 49 Paragraph 1 lit. a GDPR). You can withdraw your consent at any time with effect for the future.

9.1 Meta Pixel (Meta Platforms)

We use the "Meta Pixel" of Meta Platforms Ireland Limited (4 Grand Canal Square, Dublin 2, Ireland). This allows the behavior of users to be tracked, the effectiveness of advertisements evaluated (conversion tracking), and target groups for advertising formed. In doing so, data can be transmitted to Meta and linked to a potential user account. A transfer to the USA is possible. Legal basis: Art. 6 Paragraph 1 lit. a GDPR, Section 25 Paragraph 1 TDDDG. Insofar as Meta and we jointly decide on purposes and means, a joint controllership agreement exists in accordance with Art. 26 GDPR.

9.2 LinkedIn Insight Tag / LinkedIn Pixel

We use the LinkedIn Insight Tag from LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland). It allows campaign evaluation, conversion tracking, and retargeting, as well as statistical analysis of website visitors. During this process, data can be transmitted to LinkedIn (including to the USA). Legal basis: Art. 6 Paragraph 1 lit. a GDPR, Section 25 Paragraph 1 TDDDG.

9.3 Google Services

We intend to use services from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), in particular Google Analytics, for audience measurement and the evaluation of advertising measures. During this process, usage data can be processed and transmitted to the USA. Legal basis: Art. 6 Paragraph 1 lit. a GDPR, Section 25 Paragraph 1 TDDDG. This service will only be used productively after activation and obtaining consent; this statement will be updated accordingly at that time.

9.4 Apollo Pixel

We intend to use the Apollo tracking pixel (Apollo.io / Apollo Data Inc., USA) to identify and enrich B2B contact data and to evaluate website usage in the sales context. During this process, usage and device data may be processed and transmitted to the USA, and merged with other company and contact information. Legal basis: Art. 6 Paragraph 1 lit. a GDPR, Section 25 Paragraph 1 TDDDG. Note: Due to the scope of this processing (de-anonymization / identity resolution), necessity, transparency, and, if applicable, a data protection impact assessment must be examined prior to productive use (see notes in the accompanying letter).

10. Social Media Profiles and External Links

We maintain profiles on social networks (including Instagram, LinkedIn, YouTube) and link to them from our website. When accessing these profiles, the privacy policies of the respective providers apply. Simple links do not trigger any transmission of personal data to the providers; processing only occurs once you access the linked service.

11. Data Transfer to Third Countries

For some of the services mentioned, data may be transferred to countries outside the EU/EEA – in particular the USA. In the absence of an adequacy decision by the European Commission, we base such transfers on appropriate safeguards pursuant to Art. 46 GDPR (in particular standard contractual clauses) or – in the case of consent-based services – on your explicit consent pursuant to Art. 49 Paragraph 1 lit. a GDPR. For recipients certified in the USA, the transfer can also be based on the EU-US Data Privacy Framework.

As a Swiss controller, we additionally observe the specifications of the revFADP regarding disclosure abroad.

12. Retention Period

We store personal data only as long as necessary for the respective purposes or as required by statutory retention periods. Once the purpose no longer applies or retention periods expire, the data is deleted or anonymized. Data processed based on consent will be deleted as soon as you withdraw your consent, provided no other legal basis exists.

13. Data Security

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR to protect your data against loss, destruction, manipulation, and unauthorized access, in particular encrypted transmission (TLS). Our measures are continuously adapted in line with technological developments.

14. Up-to-dateness and Changes to this Privacy Policy

This privacy policy is currently valid. Due to the further development of our website and offers or changed legal requirements, it may become necessary to adapt it. The version published on this website always applies.


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