Privacy Policy

dctrl is a studio for creative technology based in Zurich/Switzerland. This privacy policy is issued on behalf of dctrl, so when we mention “dctrl”, “we”, “us” or “our” here, we are referring to our company responsible for processing your data.

dctrl is the controller and is responsible for this website in terms of European data protection legislation.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Our full details are:
Full name of legal entity: dctrl gmbh
Name or title of data protection officer: Andreas Lorenz
Email address: legal@dctrl.ch
Postal address of data protection officer: dctrl gmbh, Konradstrasse 17, 8005 Zurich, Switzerland

If you are a European Union citizen you have the right to make a complaint at any time to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your local supervisory authority so please contact us in the first instance.

Personal data, means any data or information about an individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).

We may collect, use, store, and transfer different types of personal data about you which we have grouped together as follows:

• Contact data which includes your postal address, email address(es) and telephone numbers.
• Identity Data which includes your first name, last name, title, gender, birth date and job title.
• Marketing and communications data which includes your preferences in receiving marketing from us, and your communication preferences.
• Profile Data includes your username and password, preferences, feedback and survey responses.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.

We may use the above personal data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased services from us, or if you have provided us with your details when you entered a survey or registered for an event or a promotion, and, in each case, you have not opted out of receiving that marketing.

You can tell us not to contact you with marketing communications either at the point such information is collected or by following the unsubscribe instructions in any communication sent to you. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Policy.

Please note that where you opt out of receiving marketing messages, this will not delete other personal data we hold on you.

We do not collect personal data about you other than the information which you voluntarily provide to us through this site to fulfill the purpose of your request such as to subscribe to our newsletter.

We do not collect any Special Categories of Personal Data about you (this mean details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data or any information about criminal convictions and offences).

Please note that we will get your express opt-in consent before we share your personal data with any company outside dctrl for marketing purposes.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• fill in a form on this website (such as the contact page)
• subscribe to any publications;
• request marketing to be sent to you; or
• when you give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that when you disable or refuse cookies, some parts of this site may become inaccessible or may not function properly. With respect to cookies and data analytics which are captured when you visit our website, please refer to our cookies policy at the following link: https://dctrl.ch/cookies/
• Third party analytics providers. We receive technical data (standard internet log information and details of visitor behavior) from Google Analytics about visitors to this website. This information does not identify anyone. To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at legal@dctrl.ch

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

We may have to share your personal data with the parties set out below for the following purposes:

• Internal third parties as set out in the Glossary.
• External third parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We operate in countries around the world.

dctrl has implemented global privacy practices for processing personal data protected under various data protection laws. dctrl transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data privacy laws, including standards and conditions related to security and processing.

If you reside outside of the European Economic Area (EEA) or Switzerland, by providing your personal data, you consent to the sharing of your personal data as described above and any resulting cross-border transfers.

Transferring data between internal third parties or to external third parties may involve transferring your data outside the EEA or Switzerland.

Whenever we transfer your personal data out of the EEA whether to dctrl or to external third parties, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; or
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Collection of information by third party sites

Like many other commercial websites, our site contains links to other sites whose information collection practices may be different than ours. Users should consult the other sites' privacy policies, as we do not have any control over any information that may be submitted to, or collected by, such third parties.

Although we employ security measures to prevent unauthorized access to information we collect online, we cannot guarantee the privacy of personal data you transmit over the web, or that may be collected in transit by third parties, including any consultants that provide services to us.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Under certain circumstances, and depending on your location you have rights under applicable data protection laws in relation to your personal data. The following descriptions provides you with more information about these rights if you are a European Union citizen dctrl will respect regardless of where you visit this website from:

Request access to your personal data

This right enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing such personal data. In order to comply with your request, we may ask you to verify your identity.

Request correction of your personal data

This right enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data that you provide to us.

Request erasure of your personal data

This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it or where applicable law requires erasure. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

If there is something about your particular circumstance that makes you want to object to processing on this ground as you feel it adversely affects your fundamental rights and freedoms please contact us. In some instances, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data

This right enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us

Process for responing

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Revisions to this Privacy Policy

We may periodically update this Policy to comply with privacy regulations, describe new website features, products or services we offer and how it may affect our use of information about you.