1. General provisions
1.1 Purpose and Scope
This Data Protection Declaration (Declaration) describes the handling of personal data by Swiss Health Tourism, Zurich. They should create transparency and enable the user to get a clear picture about what personal data is being processed for what purpose.
Swiss Health Tourism offers its users a range of services via the platform www.swisshealthtravel.ch (platform), which offers users the opportunity to select and apply for various services and memberships. This assumes that Swiss Health Tourism can also process personal data of its users (see section 2 of this Declaration). Swiss Health Tourism is aware that protection of personal data is of utmost importance. To the extent that Swiss Health Tourism processes personal data, the Association will at all times respect all applicable legal and regulatory rules regarding the safe use of such data within the meaning of the Federal Act of 19 June 1992 on Data Protection (DSG).
1.2 Agreement with Declaration
The user agrees to this statement and to the processing of personal data as described therein by using this platform. The user also expressly agrees that Swiss Health Tourism will process information that the user includes in their application or contact forms in accordance with the present Declaration. If users do not agree with this Declaration, they have to renounce the further use of the platform. In addition, the user can revoke his consent to data processing by Swiss Health Tourism at any time in writing, without stating any reasons.
This statement may be updated at any time by Swiss Health Tourism (the date of the last update is stated at the end of this Declaration). The respective versions are applicable in accordance with the date of order.
1.3 Data Processing Principles
In the processing of personal data (in particular on the occasion of their procurement, storage, use, disclosure, archiving and destruction), Swiss Health Tourism observes, in particular, the following principles:
- For every data processing, Swiss Health Tourism observes the principle of proportionality (need-to-know principle);
- Swiss Health Tourism processes personal data only for purposes specified in its procurement, which were evident from the circumstances or which are provided for by law;
- Swiss Health Tourism will only provide personal data to third parties in accordance with the conditions set out in Section 4 of the present Declaration;
- Any person, whose personal data is processed by Swiss Health Tourism, may exercise their legal right to information and correction at any time (see contact address in section 6 of this Declaration);
- Swiss Health Tourism does not sell data to third parties.
2. Categories and processing of personal data
2.1 Categories of personal data
The following is the personal data that Swiss Health Tourism processes in the context of operating the platform, administering and communicating with users:
- Users’ key information (in particular name, telephone number, email address, etc. when provided by user);
- Product related data, contracts, billing information;
- Data on user contacts and correspondence;
- IP addresses of visitors to the swisshealthtravel.ch website
2.2 Processing of personal data
As part of quality assurance the information provided during registration will be checked for correctness by Swiss Health Tourism.
Swiss Health Tourism processes the personal data mentioned in section 2.1 in the context of handling of the offered services. This includes the operation of the platform (mainly maintenance of customer relations), as well as technical operations and billing. Swiss Health Tourism may also use contact information of users for marketing purposes and to inform them of news. If Swiss Health Tourism processes personal data for other purposes, the user will be informed of these purposes at the time of collecting the relevant data.
3. Protection of Personal Data
Swiss Health Tourism takes all organizational and technical measures for the protection of personal data required by Swiss data protection legislation. This protects against the following risks in particular:
- unauthorized or accidental destruction;
- technical errors;
- forgery, theft or unlawful use;
- unauthorized modification, copying, access or other unauthorized edits.
All data will be hosted on servers in Switzerland that guarantee state-of-the-art data security. Swiss Health Tourism will in no case transfer or store data abroad.
4. Transfer of Personal Data
4.1 Principle
With the exception of the cases described in the next paragraph, Swiss Health Tourism will not share personal data with third parties. In particular, Swiss Health Tourism will never sell user data to third parties.
- Swiss Health Tourism transmits data from users to service providers cooperating with Swiss Health Tourism, if it is necessary in the context of the respective order.
- Swiss Health Tourism grants partial access to user data to third parties that Swiss Health Tourism uses for the operation and maintenance of the platform and the provision of services. Swiss Health Tourism grants such third party access only to the extent necessary for the corresponding performance of the third party.
By using the Swiss Health Tourism platform, the customer agrees to the transfer or access of his personal data in the cases described above.
4.2 Exception: Legal obligation
Swiss Health Tourism may provide personal data outside the limits specified in section 4.1 to third parties, as far as Swiss Health Tourism is legally obliged to disclose it.
5. Data transfer via the Internet
As stated in this Declaration, Swiss Health Tourism applies the highest level of technical and organizational security to protect the personal data of users. As users upload data to the platform over the Internet, it should be remembered that risks inherent in any data transfer over the Internet exist. For example, unauthorized third parties may be able to access information that users send via the Internet. This may result in technical errors or in this information being disclosed or changed in content. Even if the sender and the recipient are in the same country, it cannot be ruled out that data sent via the internet will leave their country and will be forwarded to a country with less stringent data protection requirements, than in the country where the user lives. Swiss Health Tourism is unable to control these general risks of any data transfer over the Internet. Users of the platform should note that Swiss Health Tourism is not responsible or liable for the security of user data, as it is transmitted to Swiss Health Tourism over the Internet.
6. Web Analytics with Cookies/Google Analytics
6.1 Cookies
Swiss Health Tourism uses so-called cookies and collects, processes and uses usage data. Cookies are alphanumeric identifiers that are temporarily stored in the working memory or permanently stored on users’ hard drives. The use of these cookies is needed to make websites user-friendly, user-oriented, effective and secure. At the same time, cookies are never used to evaluate users’ health data.
In the settings of the Internet browser used, the user can choose whether to accept cookies, whether information should be given, when setting a cookie, or whether to reject all cookies. However, the functionality of Swiss Health Tourism’s website is not or only partially available if function-related cookies should be rejected; certain functions are only available if and to the extent that the use of function-related cookies is approved.
6.2 Google Analytics
By means of cookies (see section 6.1) which are stored on user’s computer, so called tracking data is collected. The IP address of users is shortened directly to the user’s computer. The transmission and storage of the IP address takes place in this anonymized form. The collected tracking data is used to analyze the website and helps to improve it continuously. Swiss Health Tourism uses the web analytics service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
By using the website, the following data may be stored and evaluated anonymously and exclusively for statistical purposes: IP address (in shortened form), the pages visited and their order, the operating system and browser used, date and time of the page views, the address of the previously viewed website, if a visit was made via a direct link placed there. A personal evaluation of this technical data does not take place.
7. Information on Personal Data
In accordance with Swiss data protection legislation, the user can contact Swiss Health Tourism and
- find out if Swiss Health Tourism is processing personal data concerning him;
- ask Swiss Health Tourism to provide a copy of personal data concerning him;
- instruct Swiss Health Tourism, to correct inaccurate personal data.
8. Sum-up
What we use your data for
When you provide your information in the request form, you agree to our Privacy Policy. Swiss Health Tourism ensures the confidentiality and security of your data. Your data will be used solely for the purposes for which you gave your consent and will never be given to third parties not involved in your specific case (see “Who has access to your personal data” below).
How your data is stored
All health data will be hosted on servers in Switzerland that guarantee state-of-the-art data security. Swiss Health Tourism will in no case transfer or store data abroad.
Your rights and our guarantees
Every user of our services (16 years old or older) has the right to be informed about their personal data we use, and the right to access the data they have given at any point in time. We always leave you the right to modify your data, manage who has the rights to access it or change it, or you can request for your personal data to be completely erased. We are committed to keep you updated about any changes regarding your personal data, and we guarantee not giving your personal information to any third parties.
Who has access to your personal data
Your personal data can only be modified by you and by your data administrator. Requests for information or correction must be sent in writing to the following address: Swiss Health Tourism, Markus Will, Heinrichstrasse 267, CH-8005 Zürich.
Zurich, July 2018