Data Protection Policy

This Data Protection Policy provides information about the processing of personal data in connection with our activities and operations, including our website under the domain name mmq.ch. In particular, we explain what personal data we process, for what purpose, in what manner, and where. We also provide information about the rights of individuals whose data we process.
We have drafted this Data Protection Policy in German. In the event of publication in another language, the German-language Data Protection Policy shall prevail.
We may publish additional data protection policies or other information regarding data protection for specific or additional activities and operations.

1. Contact Information
   The data controller is:
   MMQ Consulting GmbH · Heinrichstrasse 262 · 8005 Zurich · Switzerland · info@mmq.ch
   In certain cases, third parties may be responsible for processing personal data, or there may be joint responsibility with third parties. We are happy to provide data subjects with information regarding the respective data controller upon request.
   
   
2. Definitions and Legal Basis
   1. Definitions
      Data Subject: a natural person whose personal data we process.
      Personal Data: any information relating to an identified or identifiable natural person.
      Sensitive Personal Data: data concerning trade union, political, religious, or ideological views and activities; data concerning health, privacy, or membership in an ethnic or racial group; genetic data; biometric data that uniquely identifies a natural person; data concerning criminal or administrative sanctions or proceedings; and data concerning social assistance measures.
      Processing: any handling of personal data, regardless of the means and procedures used, such as retrieving, comparing, modifying, archiving, storing, selecting, disclosing, obtaining, recording, collecting, deleting, revealing, sorting, organizing, saving, altering, distributing, linking, destroying, and using personal data.
   2. Legal Basis
      We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (Data Protection Act, FADP) and the Data Protection Ordinance (Data Protection Ordinance, DPO).
      
      
3. Nature, Scope, and Purpose of the Processing of Personal Data
   We process the personal data necessary to carry out our activities and operations in a sustainable, people-oriented, secure, and reliable manner. The personal data processed may include, in particular, browser and device data, content data, communication data, metadata, usage data, master data (including inventory and contact information), location data, transaction data, contract data, and payment data. The personal data may also constitute special-category 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, to the extent that such processing is permitted.
   We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to comply with legal obligations or to safeguard overriding interests. We may also request consent from data subjects even when their consent is not required.
   We process personal data for the period necessary to fulfil the respective purpose. We anonymise or delete personal data, in particular in accordance with statutory retention and statute of limitations periods.
   
   
4. Automation and Artificial Intelligence (AI)
   We may process personal data automatically or use artificial intelligence to process personal data.
   We may use profiling to automatically evaluate certain personal aspects relating to data subjects. Profiling is used, for example, to analyse or predict interests, behaviours, or personal preferences.
   We will provide information on a case-by-case basis regarding decisions that are based solely on the automated processing of personal data and which have legal consequences for data subjects or significantly affect them (automated individual decisions).
   
   
5. Disclosure of Personal Data
   We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may, for example, be specialist providers whose services we use. Such third parties may in turn disclose personal data to other third parties.
   In the course of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, public authorities, educational and research institutions, consultants and solicitors, accountancy and fiduciary service providers, debt collection agencies, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media organisations, parent companies, sister companies and subsidiaries, organisations and associations, social welfare organisations, telecommunications companies, insurance companies and payment service providers.
   
   
6. Communication
   We process personal data in order to be able to communicate with individuals, as well as with public authorities, organisations and companies. In doing so, we process, in particular, data that a data subject provides to us when contacting us, for example by post or e-mail. We may store such data in an address book or using similar tools.
   Third parties who provide us with data relating to other individuals are legally obliged to ensure the data protection of those data subjects themselves. In particular, they must ensure that they are authorised to provide such data and must also guarantee the accuracy of the data provided.
   
   
7. Data Security
   We take appropriate technical and organisational measures to ensure a level of data security commensurate with the respective risk. In particular, our measures ensure the confidentiality, availability, traceability and integrity of the personal data processed, although we cannot guarantee absolute data security.
   Access to our website and our other digital presence is secured by means of transport encryption (SSL/TLS, in particular using the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers issue a warning before visiting a website without transport encryption.
   Our digital communications – like all digital communications in general – are subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence over the processing of personal data by intelligence services, police forces and other security authorities. Nor can we rule out the possibility that a data subject may be specifically monitored.
   
   
8. Personal Data Abroad
   As a general rule, we process personal data in Switzerland. However, we may also disclose or export personal data to other countries, in particular to process it there or have it processed there.
   We may disclose personal data to any country on Earth or elsewhere in the universe, provided that the law of that country guarantees an adequate level of data protection in accordance with a decision by the Swiss Federal Council.
   We may disclose personal data to countries whose laws do not guarantee an adequate level of data protection, provided that an appropriate level of data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other suitable safeguards. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements are met, for example, the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. We are happy to provide data subjects, upon request, with information about any safeguards in place or to supply a copy of such safeguards.
   
   
9. Rights of Data Subjects
   1. Rights under Data Protection Law
      We grant data subjects all rights in accordance with applicable law. In particular, data subjects have the following rights.
      • Right of access: data subjects may request information as to whether we process personal data relating to them and, if so, what personal data is involved. Data subjects shall also receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data being processed as such, but also, amongst other things, details of the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.
      • Rectification and restriction: data subjects may have inaccurate personal data rectified, incomplete data supplemented, and the processing of their data restricted.
      • Opportunity to express one’s own viewpoint and request human review: data subjects may, in the case of decisions based solely on the automated processing of personal data which have legal consequences for them or significantly affect them (automated individual decisions), express their own viewpoint and request a review by a human being.
      • Deletion and objection: data subjects may request the deletion of personal data (‘right to be forgotten’) and object to the processing of their data with effect for the future.
      • Data disclosure and data portability: data subjects may request the disclosure of personal data or the transfer of their data to another data controller.
        
        We may defer, restrict or refuse the exercise of data subjects’ rights within the limits permitted by law. We may inform data subjects of any conditions that must be met in order for them to exercise their data protection rights. For example, we may refuse to provide information, in whole or in part, on the grounds of confidentiality obligations, overriding interests or the protection of other individuals. We may also, for example, refuse to delete personal data, in whole or in part, in particular on the grounds of statutory retention obligations.
        In exceptional cases, we may charge a fee for the exercise of these rights. We will inform data subjects in advance of any such costs.
        We are obliged to take reasonable measures to verify the identity of data subjects who request access to data or assert other rights. Data subjects are obliged to cooperate.
        
        
   2. Legal Protection
      Data subjects have the right to enforce their data protection rights through the courts or to lodge a report or complaint with a data protection supervisory authority.
      The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
      
      
10. Use of the Website
    1. Cookies
       We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional text-based cookies.
       Cookies may be stored temporarily in the browser as ‘session cookies’ or for a specific period as so-called ‘persistent cookies’. ‘Session cookies’ are automatically deleted when the browser is closed. Persistent cookies have a specific storage period. In particular, cookies enable us to recognise a browser the next time it visits our website and thereby, for example, measure the reach of our website. However, persistent cookies may also be used for online marketing, for example.
       Cookies can be disabled, restricted or deleted, either in full or in part, at any time via your browser settings. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be available in its entirety. We actively seek your explicit consent to the use of cookies – at least where and to the extent required by applicable law.
       
       
    2. Logging
       For every visit to our website and our other digital presence, we may log at least the following information, provided that this is automatically collected or transmitted to our digital infrastructure during such visits: date and time, including time zone; IP address; access status (HTTP status code); operating system, including user interface and version; browser, including language and version; individual subpages of our website accessed, including the volume of data transferred; and the last webpage accessed in the same browser window (referrer).
       We record such information, which may also constitute personal data, in log files. This information is necessary to enable us to provide our digital presence in a sustainable, user-friendly and reliable manner. The information is also necessary to ensure data security – including through third parties or with the assistance of third parties.
       
       
    3. Tracking Pixels
       We may incorporate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can be used to collect at least the same information as is recorded in log files.
       
       
11. Social Media
    We maintain a presence on social media platforms and other online platforms in order to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland.
    The General Terms and Conditions (GTC) and Terms of Use, as well as data protection policies and other provisions of the individual operators of such platforms, also apply in each case. These provisions provide information, in particular, on the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
    
    
12. Third-party Services
    We use services provided by specialist third parties to enable us to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. These services allow us, amongst other things, to embed functions and content into our website. When such embedding takes place, the services used collect users’ IP addresses, at least temporarily, for technically necessary reasons.
    For necessary security-related, statistical and technical purposes, third parties whose services we use may process data relating to our activities and operations in an aggregated, anonymised or pseudonymised form. This includes, for example, performance or usage data required to provide the respective service.
    
    In particular, we use:
    - Google services: providers: Google LLC (USA) / Google Ireland Limited (Ireland), in some cases for users in the European Economic Area (EEA) and Switzerland.
    - Microsoft services: providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world.
    
    
    1. Digital Infrastructure
       
       We use services provided by specialist third parties to access the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers.
       
       In particular, we use:
       - Novatrend: hosting; provider: NovaTrend Services GmbH (Switzerland).
       
       
    2. Audio and Video Conferences
       We use specialist audio and video conferencing services to enable us to communicate online. This allows us, for example, to hold virtual meetings or conduct online lessons and webinars. The legal documents of the individual services, such as data protection policies and terms of use, also apply to participation in audio and video conferences.
       Depending on your circumstances, we recommend that you mute your microphone by default when taking part in audio or video conferences, and either blur your background or display a virtual background.
       In particular, we use:
       - Google Meet: video conferencing; provider: Google.
       - TeamViewer Meeting: video conferencing; provider: TeamViewer Germany GmbH (Germany).
       - Zoom: platform for collaborative working, in particular via video conferences; provider: Zoom Video Communications Inc. (USA).
       
       
    3. Online Collaboration
       We use third-party services to facilitate online collaboration. In addition to this data protection policy, any terms and conditions of the services used that are directly visible – such as terms of use or data protection policies – shall also apply.
       In particular, we use:
       - Microsoft Teams: platform for productive collaboration, in particular via audio and video conferencing; provider: Microsoft.
       
       
    4. Digital Content
       We use services provided by specialist third parties to embed digital content on our website. Digital content includes, in particular, images, video material, music and podcasts.
       In particular, we use:
       - SoundCloud: music and podcast platform; provider: SoundCloud Global Limited & Co. KG (Germany).
       - Spotify: music and podcast platform; provider: Spotify AB (Sweden).
       - YouTube: video platform; provider: Google.
       
       
    5. Fonts
       We use third-party services to embed selected fonts, as well as icons, logos and symbols, into our website.
       In particular, we use:
       - Google Fonts: fonts; provider: Google.
       
       
13. Website Extensions
    We use extensions on our website to enable additional functions. We may use selected services from suitable providers or implement such extensions on our own digital infrastructure.
    In particular, we use:
    - TinyPNG: image optimisation; provider: Tinify BV (Netherlands).
    
    
14. Final Notes on the Data Protection Policy
    We have drawn up this privacy policy using the data protection policy generator provided by Datenschutzpartner.
    We may update this data protection policy at any time. We will notify you of any updates by publishing the latest version of the data protection policy on our website.