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Privacy Policy

With this Privacy Policy we inform which personal data we process in connection with our skullpot.com website and our other services. In particular, we inform which personal data we process for what, how and where. We also inform with this privacy policy about the rights of persons whose data we process.

For individual or additional offers and services, special, supplementary or additional data protection statements as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply.

Our offer is subject to Swiss data protection law and any applicable foreign data protection law such as, in particular, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

1. Contact addresses

Responsibility for the processing of personal data:

Skullz GmbH
Hauptstrasse 77
6260 Reiden
Switzerland

[email protected]

We point out if there are other persons responsible for the processing of personal data in individual cases.

Data-protection-representation in the European Economic Area (EEA)

We have the following data protection representation pursuant to Article 27 of the GDPR in the European Economic Area (EEA), including the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway, as an additional point of contact for supervisory authorities and data subjects for inquiries related to the General Data Protection Regulation (GDPR):

VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Germany

[email protected]

2. Processing of personal data

2.1 Terms

Personal data is any information that relates to an identified or identifiable individual. A person concerned is a person about whom personal data are processed. Processing includes any handling of personal data, independent of the means and procedures used, in particular the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.

The European Economic Area (EEA) comprises the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

2.2 Legal basis

We process personal data in accordance with Swiss data protection law such as, in particular, the Federal Data Protection Act (DPA) and the Ordinance to the Federal Data Protection Act (FADP).

We process - if and to the extent that the General Data Protection Regulation (DSGVO) is applicable - personal data in accordance with at least one of the following legal bases:

  • Art. 6 para. 1 lit. b DSGVO for the necessary processing of personal data for the performance of a contract with the data subject as well as for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. f DSGVO for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are in particular our interest in being able to provide our offer permanently, user-friendly, secure and reliable, as well as to be able to advertise for it if necessary, information security as well as protection against misuse and unauthorized use, the enforcement of our own legal claims and compliance with Swiss law.
  • Art. 6 para. 1 lit. c DSGVO for the necessary processing of personal data to comply with a legal obligation to which we are subject pursuant to any applicable law of Member States in the European Economic Area (EEA)
  • Art. 6 para. 1 lit. e DSGVO for the necessary processing of personal data for the performance of a task carried out in the public interest.
  • Art. 6 para 1 lit. a DSGVO for the processing of personal data with the consent of the data subject.
  • Art. 6 para 1 lit. d DSGVO for the necessary processing of personal data to protect vital interests of the data subject or another natural person.

2.3 Type, scope and purpose

We process those personal data that are required to provide our offer permanently, user-friendly, secure and reliable. Such personal data may fall in particular into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales, contract and payment data.

We process personal data for the period required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required will be anonymized or deleted. Persons whose data we process have in principle a right to deletion.

We process personal data in principle only after obtaining the consent of the data subject, unless the processing is permitted for other legal reasons, such as for the performance of a contract with the data subject and for corresponding pre-contractual measures, to safeguard our overriding legitimate interests, because the processing is evident from the circumstances, or after prior information.

In this context, we process in particular information that a data subject transmits to us voluntarily and himself when contacting us - for example, by mail, e-mail, contact form, social media or telephone -, or when shopping in our online store. We may store such information, for example, in an address book or with comparable tools. If you transmit personal data to us via third parties, you are obliged to ensure data protection vis-à-vis such third parties as well as to ensure the accuracy of such personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of providing our services, if and to the extent that such processing is permitted for legal reasons.

2.4 Processing of personal data by third parties, including abroad

We may have personal data processed by commissioned third parties or process it jointly with third parties as well as with the help of third parties or transmit it to third parties. Such third parties are in particular providers whose services we use. We also ensure appropriate data protection for such third parties.

Such third parties are in principle located in Switzerland as well as in the European Economic Area (EEA). Such third parties may also be located in other states and territories on Earth as well as elsewhere in the universe, provided that their data protection laws are in accordance with assessment of the Federal Data Protection and Information Commissioner (FDPIC) and - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - according to assessment of the European Commission an adequate level of data protection is ensured, or if adequate data protection is ensured for other reasons, such as by a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or by a corresponding certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the requirements under data protection law, such as the express consent of the data subject, are met for this purpose.

3. Rights of Data Subjects

Data subjects whose personal data we process have rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.

Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability, and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.

Data subjects whose personal data we process may - if and to the extent that the GDPR applies - revoke any consent they have given at any time with future effect and object to the processing of their personal data at any time.

Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

4. Data security

We take appropriate and suitable technical and organizational measures to ensure data protection and, in particular, data security. However, despite such measures, the processing of personal data on the Internet can always have security gaps. We can therefore not guarantee absolute data security.

The access to our online offer takes place by means of transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

Access to our online offering is subject - as is basically any Internet use - to mass surveillance without cause and without suspicion, as well as other monitoring by security authorities in Switzerland, the European Union (EU), the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies and other security authorities.

5. Use of the website

5.1 Cookies

We may use cookies for our website. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies or third-party cookies) - are data that are stored in your browser. Such stored data need not be limited to traditional cookies in text form. Cookies cannot run programs or transmit malware such as Trojans and viruses.

Cookies may be stored in your browser temporarily as "session cookies" when you visit our website or for a certain period of time as so-called permanent cookies. "Session cookies" are automatically deleted when you close your browser. Permanent cookies have a specific storage period. In particular, they allow us to recognize your browser the next time you visit our website and thus, for example, to measure the reach of our website. However, permanent cookies can also be used for online marketing, for example.

You can disable cookies in your browser settings at any time in whole or in part, as well as delete them. Without cookies, our website may no longer be fully available. We actively request - if and where necessary - your express consent for the use of cookies.

For cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for numerous services via the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

5.2 Server logfiles

We may collect the following information for each access to our website, provided that it is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, website last accessed in the same browser window (referer or referrer). We store such information as follows.

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our online offer permanently, user-friendly and reliable, as well as to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.

5.3 Tracking pixels

We may use tracking pixels on our website. Tracking pixels are also referred to as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. Counting pixels can be used to collect the same information as server log files.

6. Notifications and communications

We send notifications and communications such as newsletters via email and other communication channels such as instant messaging.

6.1 Success and reach measurement

Notifications and communications may contain web links or tracking pixels that record whether an individual communication has been opened and which web links have been clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical tracking of usage for performance and reach measurement in order to provide notifications and communications based on the needs and reading habits of recipients in an effective and user-friendly manner, as well as in a durable, secure and reliable manner.

6.2 Consent and objection

You must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. For any consent to receive e-mails, we use the "double opt-in" procedure whenever possible, which means that you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can occur. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.

You can unsubscribe from notifications and communications such as newsletters at any time. By unsubscribing, you can in particular object to the statistical recording of usage for performance and reach measurement. Notifications and communications that are absolutely necessary for our offer remain reserved.

6.3 Service providers for notifications and communications

We may send notifications and communications via third-party services or with the help of service providers. This may also involve the use of cookies.

7. Social Media

We are present on social media platforms and other online platforms in order to be able to communicate with interested persons and inform them about our offer. In doing so, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions inform in particular about the rights of data subjects, which include in particular the right to information.

We are jointly responsible with Facebook Ireland Limited in Ireland for our Social Media presence on Facebook, including the so-called Page Insights, insofar as and to the extent that the GDPR is applicable. Page Insights provide information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly manner.

Further information about the nature, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in the Data Protection Policy ("Data Policy") of Facebook. We have concluded the so-called "Addendum for Responsible Parties" with Facebook, thereby agreeing in particular that Facebook is responsible for ensuring the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the "Page Insights Information" pages, including "Page Insights Addendum Regarding the Responsible Party" and "Page Insights Data Information" of Facebook, respectively.

8. Third Party Services

We use third-party services to provide our services in a durable, user-friendly, secure and reliable manner. Such services may also be used to embed content on our website. Such services - for example, hosting and storage services, video services and payment services - require your Internet Protocol (IP) address, as such services cannot otherwise transmit the corresponding content.

For their own security, statistical, and technical purposes, third parties whose services we use may also process data related to our offering, as well as from other sources - including with cookies, log files, and tracking pixels - in aggregate, anonymized, or pseudonymized form.

We use in particular:

8.1 Digital Infrastructure

We use services from third parties in order to be able to make use of required digital infrastructure for our offer. This includes, for example, hosting and storage services from specialized providers.

8.2 Fonts

We use third party services to embed selected fonts as well as icons, logos, and symbols on our website.

We specifically use:

8.3 Payments

We use payment service providers to process payments from our customers securely and reliably. The terms and conditions of the respective payment service providers, such as general terms and conditions (GTC) or data protection statements, apply to the processing in each case.

We use in particular:

9. Performance and Reach Measurement

We use services and programs to determine how our online offer is used. In this context, we can, for example, measure the success and reach of our online offering and the effect of third-party links to our website. However, we can also, for example, test and compare how different versions of our online offering or parts of our online offering are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen particularly popular content or make improvements to our online offering.

When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are basically shortened in order to follow the principle of data economy through the corresponding pseudonymization as well as to improve the data protection of visitors to our website ("IP masking").

When using services and programs for performance and reach measurement, cookies may be used and user profiles may be created. User profiles include, for example, the pages visited or content viewed on our website, information about the size of the screen or browser window and the - at least approximate - location. In principle, user profiles are created exclusively in pseudonymous form. We do not use user profiles to identify individual visitors to our website. Individual services with which you are registered as a user can, if necessary, assign the use of our online offer to your profile with the respective service, although you usually had to give your consent to this assignment in advance.

We use in particular:

  • Google Analytics: success and reach measurement; Google Analytics-specific privacy disclosures: measurement also across different browsers and devices (cross-device tracking) as well as with pseudonymized Internet Protocol (IP) addresses, which are only exceptionally transmitted in full to Google in the USA, "Privacy", "Browser Add-on to disable Google Analytics"
  • Google Tag Manager: Integration and management of services for performance and reach measurement as well as other services from Google as well as from third parties; further information on data protection can be found at the individual integrated and managed services.

10. Final provisions

We can adapt and supplement this privacy policy at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.