Privacy notice

Foreword

We, Diment.ch together with our subsidiaries (hereinafter collectively: "the company" , "we" or "us" ) take the protection of your personal data seriously and would like to inform you here about data protection in our company.

Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") in order to ensure the protection of personal data of the person affected by a processing operation (we also address you as data subject hereinafter with "customer", "user", "you", "you" or "data subject").

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Articles 13 and 14 GDPR). With this statement (hereinafter: "Privacy Notice"), we inform you about the manner in which your personal data is processed by us.

Our data protection notices have a modular structure. It consists of a general part for any processing of personal data and processing situations that come into play each time a website is called up (A. General) and a special part, the content of which relates in each case only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites as detailed here (B. Visit to websites).

To find the parts that are relevant to you, please refer to the following overview for the breakdown of the privacy notices:

A. General

(1) Definitions

Following the example of Art. 4 of the GDPR, this privacy notice is based on the following definitions:

- "Personal data " (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).

- "Processing " (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e. acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the change of a purpose or intended use on which a data processing was originally based.

- "Controller " ( Art. 4 No. 7 DS-GVO) means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

- "Third Party " ( Art. 4 No. 10 DS-GVO) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or processor; this also includes other group-affiliated legal entities.

- "A processor " (Art. 4 No. 8 DS-GVO) is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controllers instructions (e.g. IT service provider). In terms of data protection law, a processor is in particular not a third party.

- "Consent " ( Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

(2) Name and address of the controller

We are the controller for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:

DIMENT Reserve AG
Gewerbestrasse 11
6330 Cham
Switzerland
[email protected]

For further information about our company, please refer to the imprint details on our website here

(3) Contact details of the data protection officer

Our company data protection officer is available at all times to answer any questions you may have and to act as your contact person on the subject of data protection at our company. His contact details are:

Alexander Behrendt

(4) Legal basis for data processing

By law, in principle, any processing of personal data is prohibited and only permitted if the data processing falls under one of the following justifications:

- Art. 6 (1) p. 1 lit. a GDPR ("consent"): Where the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;,

- Art. 6 para. 1 p. 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject;

- Art. 6 para. 1 p. 1 lit. c GDPR: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to keep records);

- Art. 6 para. 1 p. 1 lit. d GDPR: If the processing is necessary to protect the vital interests of the data subject or another natural person;

- Art. 6 (1) p. 1 lit. e GDPR: Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or

- Art. 6 (1) p. 1 lit. f GDPR ("Legitimate Interests"): When processing is necessary to protect the legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject override (in particular if the data subject is a minor).

For the processing operations carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.

(5) Data deletion and storage period, duration of data processing

For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in Europe, subject to any transfer that may take place in accordance with the provisions in A.(7) and A.(8).

The requests by contact form are deleted if they are no longer required. We review the necessity every six months; the statutory archiving obligations also apply.

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by legal regulations to which we are subject as the responsible party. If the storage period prescribed by the legal regulations expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

Your data will only be processed for as long as is necessary to achieve the mentioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly.

Third parties engaged by us will store your data on their systems for as long as is necessary in connection with the provision of services for us in accordance with the respective order.

(6) Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

Diment Company takes all reasonable endeavors to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.

We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see under A.(3)).

(7) Cooperation with processors

As with any larger company, we also use external domestic and foreign service providers (e.g. for the areas of IT, logistics, telecommunications, sales and marketing) to process our business transactions. They are only active according to our instructions and are contractually obligated to comply with the data protection regulations according to Art. 28 GDPR.

If personal data from you is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

(8) Conditions for the transfer of personal data to third countries

In the course of our business relationships, your personal data may be transferred or disclosed to third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively for the fulfillment of contractual and business obligations and to maintain your business relationship with us (legal basis is Art. 6 para. 1 lit b or lit. f in each case in conjunction with Art. 44 et seq. GDPR). We will inform you about the respective details of the transfer in the following at the relevant points.

Some third countries are certified by the European Commission as having a level of data protection comparable to the EEA standard through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible via binding company regulations, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 para. 1 , 2 lit. c GDPR (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognized codes of conduct. Please contact our data protection officer (see under A.(3)) if you would like to receive more detailed information on this.

EEA customers:We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Statement. All data you provide to us is stored on our secure servers. Where we transfer our data outside of the EEA, we ensure that adequate safeguards are in place. That includes, where necessary, taking steps to evaluate the risks raised by the transfers in countries that do not offer an adequate level of protection. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

(9) No automated decision making (including profiling).

We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

(10) No obligation to provide personal data.

We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in the context of the products we offer presented below, you will be informed of this separately.

(11) Legal obligation to transmit certain data.

We may be subject to a specific legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public bodies (Art. 6 para. 1 p. 1 lit. c GDPR).

B. Visiting websites

(1) Explanation of the function

You can obtain information about our company and the services we offer in particular Diment.ch together with the associated subpages (hereinafter collectively: "websites"). When you visit our websites, personal data may be processed.

(2) Personal data processed

During the informative use of the websites, the following categories of personal data are collected, stored and processed by us:

"Log data": When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:

-the page from which the page was requested (so-called referrer URL).

-the name and URL of the requested page

-the date and time of the call

-the description of the type, language and version of the web browser used.

-The IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established.

-the amount of data transferred

-the operating system

-the message whether the call was successful (access status/http status code).

-the GMT time zone difference

The collection is pseudonymized and is used to generate anonymous information about the way the site is used and to better tailor the content offered to users.

Different services are used for each individual method and there is an individual right of objection:

"Contact form data": When contact forms are used, the data transmitted through them are processed. This consists of:

- surname and first name

- address

- company

- e-mail address

- time of transmission

- correspondence

The requests are deleted if they are no longer required. We review the necessity every six months; the statutory archiving obligations also apply.

"Google Analytics": The website uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). Google analyzes the use of this website on our behalf. Among other things, we use cookies for this purpose. The data processing is based on Art. 6 para. 1 lit. a GDPR (consent). The information collected by Google about the use of this website (the referring URL, pages visited on our website, web browser used, language setting, operating system used or screen resolution) is transferred to a Google server in the USA, stored there, analyzed and the result made available to us in anonymized form. Your usage data is not linked to your full IP address. We have activated the IP anonymization function offered by Google on this website so that the last octet (type IPv4) or the last 80 bits (type IPv6) of your IP address are deleted. Google is also certified in the EU-US Privacy Shield, so that an appropriate level of data protection is established for data at Google in the USA. You can revoke your consent to web analysis at any time:

- You may refuse the use of cookies by selecting the appropriate settings on your browser, you can close the cookie any time here, however please note that if you do this you may not be able to use the full functionality of this website.

- You can also prevent the collection of data generated by the cookie and related to your use of our website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link (https://tools.google.com/dlpage/gaoptout?hl=de).

Both options prevent web analysis only as long as you use a browser on which you have installed the plugin or as long as you do not delete the opt-out cookie. Further information on Google Analytics can be found in the Google Analytics Terms of Use, in the Google Analytics Security and Privacy Policy and in the Google Privacy Policy. You find more information about the cookie, you can close any time, in our Cookie Policy.

"Google Maps": Each time the "Google Maps " component is called up, Google sets a cookie to process user settings and data when the page on which the "Google Maps " component is integrated is displayed. As a rule, this cookie is not deleted when the browser is closed, but expires after a certain period of time, unless you delete it manually beforehand. If you do not agree with this processing of your data, you have the option of deactivating the "Google Maps " service and thus preventing the transfer of data to Google. To do this, you must deactivate the Java Script function in your browser. However, we would like to point out that in this case you will not be able to use "Google Maps " or only to a limited extent. The use of "Google Maps " and the information obtained via "Google Maps " is subject to the Google Terms of Use google.com/intl/en/policies/terms/regional.html and the additional terms and conditions for "Google Maps " google.com/intl/en_en/help/terms_maps.html.

"Google Fonts": We use Google Fonts on our website. These are the "Google fonts" of Google Inc. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services.

You have given your consent via the cookie banner in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

You do not need to log in or enter a password to use Google fonts. No cookies are stored in your browser either. The files (CSS, fonts) are requested via the Google domains fonts.googleapis.com and fonts.gstatic.com. According to Google, requests for CSS and fonts are completely separate from all other Google services. If you have a Google account, you do not need to worry that your Google account data will be transmitted to Google while using Google Fonts.

With Google Fonts, we can use fonts on our own website, but we do not have to upload them to our own server. Google Fonts is an important component in keeping the quality of our website high.

When you visit our website, the fonts are loaded via a Google server. This external call transmits data to the Google server. The following information is transmitted to Google:

- Language settings

- IP address

- Browser version, screen resolution of the browser and name of the browser

How long and where is the data stored?

Google stores requests for CSS assets for one day on its servers, which are mainly located outside the EU. This allows us to use the fonts with the help of a Google stylesheet. A stylesheet is a format template that can be used to quickly and easily change the design or font of a website, for example.

How can I delete my data or prevent data storage?

The data that Google stores for one day or one year cannot simply be deleted. The data is automatically transmitted to Google when the page is accessed. To delete this data prematurely, you must contact Google support at https://support.google.com/?hl=de&tid=311189069.

You can also find out which data is generally collected by Google and what this data is used for at https://www.google.com/intl/de/policies/privacy/.

(3) Purpose and legal basis of data processing

We process the personal data described in more detail above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) p. 1 lit. f GDPR, the aforementioned purposes also represent our legitimate interests.

The processing of the log data serves statistical purposes and the improvement of the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. a or lit. f GDPR).

Contact form data is processed for the purpose of handling customer inquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f GDPR).

(4) Transfer of personal data to third parties; basis for justification

The following categories of recipients, which are usually processors (see A.(7)), may receive access to your personal data:

-The data is transferred to a third party service provider for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR, insofar as it does not involve order processors;

-State agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c GDPR;

-Persons appointed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR.

List of Third-Party Service Providers with whom Personal Information may be shared:

- Any member of our group, which means our direct or indirect subsidiaries, our ultimate holding company and any other subsidiary of that holding company, including their respective shareholders, directors, officers, affiliates, employees, contractors, agents, partners, insurers, and attorneys or representatives;

For the guarantees of an adequate level of data protection in the event of a transfer of the data to third countries, see A.(8).

In addition, we will only disclose your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a GDPR.

(5) Use of cookies, plugins and other services on our website

a) Cookie

We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic character string and through which certain information flows to the body that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offer as a whole more user-friendly and effective, i.e. more pleasant for you.

Cookies can contain data that makes it possible to recognize the device used. In some cases, however, cookies only contain information about certain settings that are not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:

- "Technical cookies " : these are mandatory to move around the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;

- "Performance cookies " : these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is used only to improve our website and find out what interests our users;

- "Advertising cookies, targeting cookies " : These are used to offer the website user tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

- "Sharing cookies " : These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

The legal basis for cookies that are absolutely necessary to provide you with the expressly requested service is Article 6 (1) sentence 1 lit. a GDPR. Any use of cookies that is not absolutely technically necessary for this purpose constitutes data processing that is only permitted with your express and active consent pursuant to Article 6 (1) sentence 1 lit. a GDPR. This applies in particular to the use of performance, advertising, targeting or sharing cookies. In addition, we will only disclose your personal data processed through cookies to third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a GDPR.

b) Cookie Policy

For more information about which cookies we use and how you can manage your cookie settings and disable certain types of tracking, please see our Cookie Policy.

c) Social media plugins

We do not use social media plugins on our websites. If our websites contain icons of social media providers, we only use these for passive linking to the pages of the respective providers.

(6) Your rights

You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided at the beginning of A.(2), by submitting a customer support ticket, email to Diment [email protected] or a written request to:

DIMENT Reserve AG
Gewerbestrasse 11
6330 Cham
Switzerland
[email protected]

EEA Customers, you have the right as a data subject:

-In accordance with Art. 15 GDPR, you may request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it was not collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;

-In accordance with Art. 16 GDPR, you have the right to demand the correction of incorrect data or the completion of your data stored by us without delay;

-In accordance with Art. 17 GDPR, you may request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the assertion, exercise or defense of legal claims;

-In accordance with Art. 18 GDPR, you have the right to demand the restriction of the processing of your data, insofar as the correctness of the data is disputed by you or the processing is unlawful;

-according to Art. 20 GDPR to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller ("data portability");

-You have the right to object to processing in accordance with Article 21 of the GDPR, provided that the processing is based on Article 6 (1) sentence 1 lit. e or lit. f of the GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the merits of the case and either discontinue or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;

-according to Art. 7 (3) GDPR your consent given once (also before the validity of the DS-GVO, i.e. before 25.5.2018) - i.e. your voluntary will made understandable in an informed manner and unambiguously by means of a declaration or other unambiguous confirming act that you agree to the processing of the personal data in question for one or more specific purposes - to be revoked at any time vis-à-vis us, if you have given such consent. This has the consequence that we may no longer continue the data processing based on this consent for the future and

-In accordance with Art. 77 GDPR, you have the right to lodge a complaint about the processing of your personal data in our company with a data protection supervisory authority, such as the data protection supervisory authority responsible for us. As a Swiss, international company, we do not have a supervisory authority responsible for us. Please find your accurate authority here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

(7) Changes to the data protection notice

In the context of the further development of data protection law as well as technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes in particular on our website at Diment.ch. This data protection notice is valid as of 6st November 2023. Please check back frequently to see any updates or changes to our Privacy Statement.

(8) Contact

Questions, comments and requests regarding this Privacy Statement should be addressed to our customer support service or by email to [email protected] or EEA customers: Should you have any concerns about how we handle your Personal Information, please contact us in the first instance by opening a customer support ticket or sending an email [email protected] We will do our best to resolve your concern. You can also submit a complaint to the national supervisory authority within your jurisdiction, details of which can be found online.

06.11.2023