Privacy Statement
This Privacy Statement describes the collection and further processing of personal data by companies of the V-ZUG Group and its affiliates (collectively V-ZUG) as far as they are not covered by other data protection policies or are evident from the circumstances or are provided for by applicable law. The term “personal data” shall include all information relating to an identified or identifiable person.
This Privacy Statement describes in Section I the processing of personal data by V-ZUG in general. Section II contains specific provisions for different applications (e.g. online shops, newsletter, etc.) and for data processing in connection with the use of the V-ZUG apps.
- Controller, data protection officer, representative
- Processing of personal data
- Purpose of the processing and legal basis
- Disclosure of data to third parties and transfer of data abroad
- Retention of data
- Cookies, google analytics and social media plug-ins
- Promotions
- Data subject rights of business partners
- Changes to the data protection policy
- Online-Shops
- Physical stores
- Customer service
- Newsletter and banner advertisement
- GuidedCooking app
- V-ZUG-Home App
- V-Kitchen App
- Audio and video conferencing
I. General Provisions
1. Controller, data protection officer, representative
Every website (including online shops and mini sites for special offers), every presence on social media, multimedia portals, chatbots and every app of V-ZUG (each a “website”) has a controller – where personal data is collected – within V-ZUG according to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) (or comparable provisions according to applicable data protection laws). Unless provided otherwise on the website (according to the legal notice, the terms of use, etc.) or under section II, the controller is: V-ZUG Ltd, Industriestrasse 66, 6300 Zug, Switzerland. The respective V-ZUG subsidiary or affiliate is the controller in case V-ZUG communicates through other means of communication (e-mail, letter, telephone, audio or video conferencing, etc.) and the communication does arise in the course of an activity for which V-ZUG has appointed a specific controller within this Privacy Statement or otherwise.
Should a V-ZUG company or affiliate disclose personal data to another V-ZUG company or affiliate for certain purposes of the receiving company or affiliate, such company or affiliate is the controller according to Art. 4 (7) GDPR. A comprehensive list of companies and affiliates of V-ZUG can be found here. V-ZUG has not appointed a data protection officer according to Art. 37 GDPR (or comparable provisions according to applicable data protection laws), except for V-ZUG Deutschland GmbH. Any enquiry, claim or concern regarding data protection at V-ZUG can be addressed to the following contact unit: privacy@vzug.com, or concerning V-ZUG Deutschland GmbH: info@leidel-rae.de. In cases where a V-ZUG company that is processing personal data is not located in the EU or the EEA and the data is being processed in conjunction with an offer of goods or services to data subjects in the EU or the EEA, and in cases in which the behaviour of data subjects in the EU or the EEA is being observed, the following representative within the Union has been designated in accordance with Art. 27 GDPR: V-ZUG Europe BV, Evolis 102, 8530 Harelbeke-Kortrijk, Belgium. In cases where a V-ZUG company processing personal data is not located in the United Kingdom and the data is being processed in conjunction with an offer of goods or services to data subjects in the United Kingdom, as well as in cases where the behaviour of data subjects in the United Kingdom is being observed, the following representative within the United Kingdom has been designated in accordance with Art. 27 UK GDPR: V-ZUG UK Ltd., 27 Wigmore St, London W1U 1PN, United Kingdom.
2. Processing of personal data
V-ZUG collects and processes personal data of:
- visitors of its websites registered or not registered with V-ZUG;
- contact persons and employees of service providers, suppliers, retailers, vendors and providers of V-ZUG products and parts of products;
- customers, buyers, recipients and beneficiaries or prospective customers of products and services (including warranty, repair and maintenance services) of V-ZUG or its contact persons and employees;
- contact persons and employees of business partners and associated companies, personnel providers and employment agencies (as well as brokered employees/workers) and further commercial and economic partners;
- shareholders and beneficiaries of other rights to shares of V-ZUG Holding AG as well as respective interested parties;
- recipients of ad hoc-information and newsletters of V-ZUG;
- participants in competitions, market research campaigns and opinion surveys conducted by V-ZUG;
- participants in courses, seminars and other training organized by V-ZUG;
- users of Wi-Fi provided at V-ZUG stores, showrooms, business premises and other locations;
- individuals ordering or using V-ZUG customer loyalty programmes; and
- registered participants of V-ZUG customer loyalty programmes (business partner programme) (collectively “business partners”).
The personal data of business partners is generally collected directly during the course of using the website, upon demand for or use of products or services, upon submission of reviews or reports, participation in competitions, market research or other surveys, in stores, sales offices or at events of V-ZUG or V-ZUG approved retailers or during direct communication with V-ZUG via e-mail, telephone, audio or video conferencing or in any other way. However, personal data can also be collected indirectly, namely when the business partner engages in a commercial activity which does not correspond with the person benefiting from the commercial activity or if a purchase is shipped to a different person (e.g. warranty, repair or service work), based on the recommendation of a third party (e.g. recommendation by friends and acquaintances of the business partner) or through further obtaining or acquisition of supplementary information from third party data sources (e.g. social media, address brokers, providers of commercial information, etc.).
In particular, the following categories of personal data are processed by V-ZUG:
- Personal data and contact information: including but not limited to first and last name, address, residence, telephone number, e-mail address, age, date of birth, gender, marital status, relatives, details of secondary contact, where applicable, photos, information about function within the company, information about business relationships with this data subject, information about commercial transactions, enquiries, offers, quotes, stipulations and contracts, statements about work or other interests of the data subject, etc.;
- Data pertaining to deliveries and sales as well as orders and purchases: including but not limited to payment information, credit card details and other payment details, billing and shipping address, products and services delivered and sold as well as ordered and purchased, information connected to queries, complaints and disagreements relating to products and services or respective contracts entered into such as warranty claims, rescissions and disputes, information regarding business partners blacklisted by V-ZUG, etc.;
- Data in connection with the marketing of products and services: including but not limited to information about marketing activities such as the receipt of newsletters, newsletter opt-ins and opt-outs, documents received, invitations to and participations at events and special activities (as far as they are not part of a customer loyalty programme), personal preferences and interests, etc.;
- Data concerning the use of the website: including but not limited to the IP address and other identification (e.g. social media username, MAC address of smartphones or computers, cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies) or other technologies, with which personal data is collected), date and time of website visits, visited sites and contents, referring websites, etc.;
- Data of shareholders and beneficiaries of shares and related communication: including but not limited to number of shares, share transfers, entitlement, security deposit account, bank account for dividends, preferred means of communication, correspondence, correspondence language and communication with V-ZUG (including records of the communication), etc.;
- Data that was collected in connection with a customer programme: such as membership number, access details (including passwords), preferred language, gift certificate number, date and duration of the membership, payment information of the customer or third party, where applicable, information concerning recipients of gifts, number of visits of the website, purchase history, products acquired, etc. (besides traditional customer loyalty programmes, all website accounts, activities and events for which a business partner must register with his personal data and thus enter into a contract with V-ZUG shall be deemed a customer programme for the purposes of this policy);
(collectively “business partner data”).
3. Purpose of the processing and legal basis
In accordance with applicable law, V-ZUG may process business partner data namely for, but not limited to, the following purposes:
- In connection with products and services offered, conclusion of contracts (in particular purchases and sales of products and services), execution of contracts (in particular purchase and supply agreements and contracts regarding participation in customer programmes and events) or other business relationships, maintenance and development of relations with business partners and shareholders or other beneficiaries or prospective shareholders of V-ZUG Holding Ltd (in particular invitations to and staging of events, activities and campaigns on behalf of and with business partners), communication, customer service and support (in particular orders and enquiries), marketing, promotion and advertising activities (including newsletters and promotions);
- Management of the users and visitors of the website and other activities in which business partners participate; operation and enhancement of the website (including the provision of functions that require identifiers or other personal data) and further IT systems, identity verifications;
- Quality control, market research, enhancement of products and services, creation of statistics, budgets, records and management information as well as further reports on business partners, transactions and activities, offers and other commercial aspects of V-ZUG for the purposes of company management and development of the company, its range of products and services, its activities and project management;
- protection of business partners, employees and other individuals and protection of data, secrets and assets of and entrusted to V-ZUG, security of systems and premises of V-ZUG;
- compliance with legal and regulatory requirements (in particular company law and stock exchange law and rules, ad hoc information etc.) and internal rules of V-ZUG, pursuit and enforcement of various rights, defence against legal claims, litigation, complaints, combating fraud and abusive conduct, engaging in legal investigations and proceedings and responding to enquiries from public authorities;
- sale or acquisition of business divisions, companies or parts of companies and other corporate transactions and the transfer of business partner data associated therewith;
- for other purposes as far as a legal obligation requires processing and such processing was evident from the circumstances or indicated at the time of the collection;
(collectively the “purpose of processing”).
V-ZUG uses the business partner data for the purpose of processing based on the following legal grounds:
- performance of contracts;
- compliance with legal obligations of V-ZUG;
- consent of the business partner (only insofar as the processing is based on a specific query from V-ZUG and can be withdrawn by the business partner at any time, namely the receipt of newsletters for which the client has registered);
- legitimate interests of V-ZUG, including but not limited to
- purchase and shipment of products and services, also in connection with individuals who are not direct contractual partners (e.g. individuals receiving gifts);
- carrying out advertisement and marketing activities;
- efficient and effective customer support, maintenance of contacts and other communication with business partners outside of the processing of contracts;
- understanding customer behaviour, activities and needs, market research;
- efficient and effective improvement of existing products and services and development of new products and services;
- efficient and effective protection of business partners and other individuals as well as protection of data, secrets and assets of or entrusted to V-ZUG, security of systems and premises of V-ZUG;
- maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further development of the website and other IT systems;
- reasonable corporate governance and development;
- successful sale and acquisition of business units, companies or parts of companies and other corporate transactions;
- compliance with legal and regulatory requirements and internal rules of V-ZUG;
- concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of legal claims and actions against V-ZUG, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defence against legal actions.
Where applicable data protection laws permit, V-ZUG may process the data of registered and non-registered website visitors for the purposes of maintaining and developing the website (including the provision of functions that require identifiers or other personal data), for statistical analysis regarding the use of the website as well as for combating abusive conduct, for purposes of legal investigations or proceedings and for responding to enquiries from public authorities. The visitor data shall be processed in accordance with the principles set out for business partner data above.
All the purposes of processing shall be applicable for the whole of the V-ZUG Group, i.e. not only for the company which initially collected the personal data. All personal data of business partners is collected for the purposes of all V-ZUG companies.
Personal data is only processed or used for purposes other than those for which the personal data was collected in compliance with the applicable mandatory provisions or where necessary with the consent of the data subject.
4. Disclosure of data to third parties and transfer of data abroad
Where applicable laws permit, V-ZUG may disclose business partner data to the following categories of third parties who process business partner data in accordance with the purpose of data processing on behalf of V-ZUG or for their own purposes:
- Service providers (within V-ZUG as well as external, for example for share registers, support and service), including processors;
- Distributors, suppliers and other business partners;
- Customers and buyers of V-ZUG products and services;
- Local, national and foreign authorities as well as stock exchanges and related supervisory and enforcement bodies (including SIX Exchange Regulation AG, the Swiss Financial Market Supervisory Authority FINMA, law enforcement authorities and courts);
- Media and private reporters and journalists;
- The general public, including visitors to V-ZUG websites and social media channels;
- Industry organizations, associations, organizations and other committees;
- Competitors;
- Acquirers or parties interested in acquiring business units, companies or other parts of V-ZUG;
- Other companies of V-ZUG
(collectively “third parties”).
V-ZUG may disclose business partner data within the V-ZUG Group as well as to third parties and in every country worldwide, including all countries in which V-ZUG is represented by companies, affiliates, exhibition and other sales premises and representatives or distributors as well as to countries in which service providers of V-ZUG process their data. If data is disclosed to countries that do not guarantee adequate protection, V-ZUG will ensure adequate protection of data by way of technical and organizational measures and putting adequate contractual guarantees in place, namely on the basis of an international treaty; the data protection clauses in a contract between V-ZUG and a processor which have been notified in advance to the Federal Data Protection and Information Commissioner (FDPIC); the currently valid EU standard clauses; standard contractual clauses approved, issued or recognized in advance by the FDPIC; binding internal company data protection rules approved in advance by the FDPIC or by another competent supervisory authority of a state that ensures adequate protection; or other suitable guarantees under applicable data protection law. In the absence of such guarantees, V-ZUG relies on the exception of consent, the performance of the contract, the establishment, exercise or enforcement of legal claims, overriding public interests, the data published by the business partner or the grounds that it is necessary to protect the integrity of such persons. The business partner can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact unit named in Section I, para. 1. V-ZUG reserves the right to redact such copies for reasons of data protection or secrecy reasons.
5. Retention of data
As a rule, V-ZUG retains contract-related business partner data as long as the contractual relationship is ongoing and for ten years after the termination of the contractual relationship unless a longer statutory store obligation is applicable on a case-by-case basis, this is required for reasons of proof or another valid reason for an exception is pertinent based on applicable law, or the deleting of the data is required earlier (namely because the data is no longer required or V-ZUG is obligated to delete the data). As a rule, shorter retention periods are applicable for operational data containing business partner data (e.g. protocols, logs). Business records, including communications, will be retained as long as V-ZUG has an interest in them (namely an interest in reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis) or is obligated to do so (by way of contract, law or other provisions). Deviating legal obligations are reserved namely with respect to anonymization or pseudonymization.
6. Cookies, google analytics and social media plug-ins
V-ZUG uses cookies on its website. Cookies are a widespread technique that allocates an identification to the browser of the user of a website which the user saves and shows upon request. On the one hand, V-ZUG uses session cookies which are automatically erased when the user closes the website and which enable the server to establish a stable connection to the user (so that the content of a shopping basket is not lost, for example) for as long as the user browses on the website. On the other hand, it may use permanent cookies which are only erased after a period defined per website (e.g. two years after the last visit). Permanent cookies allow the saving of certain settings (e.g. language) for multiple sessions or allow for an automated log-in. Cookies that are not absolutely necessary for the correct operation of the website are only processed in compliance with the applicable mandatory provisions or where necessary with the consent of the data subject (cf. Section I, para. 8). The user may block the application of cookies on his browser or delete cookies there which may, however, impair use of the website.
Should V-ZUG place a third-party advertisement on the website (e.g. banners) or intend to place its own advertisement on the website of a third party, cookies from companies specializing in the use of such advertisements may be used. V-ZUG will not disclose personal data to such companies, i.e. they only place a permanent cookie with users of the website in order to recognize users and do so in the sole interest of V-ZUG. This allows V-ZUG to place targeted advertisements for these individuals on external websites. V-ZUG will not disclose personal data to the operators of external websites.
V-ZUG may use PIWIK (https://piwik.org), Google Analytics or similar services on its website. These applications are third-party services which allow V-ZUG to measure and analyse the use of its website. The provider of these services may be located in any country worldwide (in the case of Google Analytics which is operated by Google Inc. it is the USA, www.google.com). The service provider uses permanent cookies for these applications. V-ZUG will not disclose any personal data to the service provider (who will also not save any IP addresses). The service provider may, however, monitor the use of the website by the user and combine this data with data from other websites monitored by the same service provider which the user has visited, and use these findings for its own benefits (e.g. control of advertisement). If the user who has registered with the service provider himself, the service provider is able to determine their identity. In this case, the processing of personal data will be the service provider’s responsibility and data shall be processed according to the data protection policies of the service provider. The service provider will provide data on the use of the website to V-ZUG.
V-ZUG may integrate and use various services on its websites for the purpose of displaying targeted advertising (remarketing/retargeting) and measuring the success of advertising campaigns (conversion tracking). These technologies help V-ZUG to analyse the behaviour of website visitors and to design websites that are user-friendly and effective by displaying personalised advertising and evaluating the effectiveness of marketing measures. The default settings of the V-ZUG websites are configured so that all integrated remarketing technologies are deactivated by default. Activation only takes place within the framework of the applicable legal regulations and, if necessary, with the consent of the person concerned. If a visitor to the V-ZUG website is redirected to a service provider’s website after interacting with an activated technology, the data protection provisions of the respective service provider apply. In this case, once the relevant technology has been activated, a direct connection is established between the visitor’s browser and the service provider’s server.
Among other things, the service provider receives the visitor’s IP address and information that the V-ZUG website has been accessed. If the visitor is logged into the service provider’s user account at the same time, the service provider can assign the information to the individual user profile and use it for its own purposes. V-ZUG may use the technologies of the following service providers: Google Ads / Google Remarketing from Google LLC, USA, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Further information is available at https://policies.google.com/technologies/ads, and settings can be adjusted at: https://adssettings.google.com; Meta Ads (formerly Facebook Ads) from Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. Further information at: https://www.facebook.com/privacy/policy/, adjustment of settings at: https://www.facebook.com/adpreferences/ad_settings/; LinkedIn Ads & Insight Tag from LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. Further information at https://www.linkedin.com/legal/privacy-policy, adjustment of settings at: https://www.linkedin.com/psettings/advertising; Microsoft Advertising & UET Tag from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Further information at: https://privacy.microsoft.com/de-de/privacystatement, adjustment of settings at: https://account.microsoft.com/privacy/ad-settings/; Pinterest Ads & Conversion Tag from Pinterest Inc., 505 Brannan Street, San Francisco, CA 94107, USA. Further information at https://policy.pinterest.com/de/privacy-policy, adjustment of settings at: https://www.pinterest.com/settings/privacy; TikTok Pixel from TikTok Pte. Ltd., 1 Keong Saik Road, Singapore 089109, Singapore. Further information at: https://www.tiktok.com/legal/privacy-policy, adjustment of settings at: https://www.tiktok.com/settings/ads.
In addition, V-ZUG may use plug-ins (also add-ons) from social media networks such as Facebook, Twitter, WhatsApp, LinkedIn, YouTube, Google+, Google Maps, Pinterest, Instagram or from business partners on its websites or integrate RSS feeds or graphics from other websites. In the default settings of the website, plug-ins and other embedded third-party technologies are deactivated. The user can thus choose when to activate them. Should the user do so, the social media and other third party service providers are able to establish a direct connection to the user during his visit to the website, which allows the provider to be aware of the user’s visit and may analyse the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the provider and according to his data protection policies. The provider of the respective social media offering will not disclose any information to V-ZUG.
7. Promotions
V-ZUG may use personal data of business partners with their consent (if such consent is required under applicable law), or based on other grounds recognized under data protection law, in order to provide them with information about goods or services (promotions, e.g. marketing communications, competitions or campaigns). The promotions may be carried out in compliance with the relevant applicable law, in particular on the websites of V-ZUG, third-party websites, via newsletters, by e-mail and by post (see Section II. para. 4) and/or on social networks. Further information can be found in the details on the individual promotions.
8. Data subject rights of business partners
Any data subject may request information from V-ZUG as to whether data concerning them is being processed. In addition, they have the right to request the correction, deletion or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the data subject may withdraw consent at any time. In countries of the EU and EEA the data subject may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable/electronic format which allows for further use and transfer. Requests in connection with these rights shall be submitted to the data protection officer or contact unit (see Section I, para. 1). V-ZUG reserves the right to restrict the rights of the data subject in accordance with applicable law and, for instance, not to disclose comprehensive information or delete data.
Should V-ZUG make an automated decision with respect to a certain individual which may have a legal effect for the data subject or seriously affect them in a similar way, the data subject shall have, in accordance with applicable law, the right to communicate with a responsible person of V-ZUG and to request a reconsideration of the decision or to request the prior evaluation by a person. In this case, the data subject might no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance.
Any data subject may also file a complaint with the competent data protection authority.
9. Changes to the data protection policy
V-ZUG is entitled to amend this Privacy Statement at any time and without prior notice or announcement. The latest version according to the website shall be applicable. Should the Privacy Statement form part of an agreement with business partners, V-ZUG may inform them of an update by e-mail or in another appropriate manner. The new Privacy Statement shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection, V-ZUG shall be free to terminate the agreement exceptionally and with immediate effect.