Privacy Policy
In this privacy policy, we provide information on which personal data we process in connection with our activities and operations, including our glarnerland.ch website and the GlarnerlandPass app. In particular, we provide information on why, how and where we process which personal data. We also provide information about the rights of persons whose data we process.
Further data protection declarations and other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation may apply to individual or additional activities and operations.
We are subject to Swiss data protection law as well as any applicable foreign data protection law, in particular that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognises that Swiss data protection law guarantees adequate data protection.
1. contact addresses
Responsibility for the processing of personal data:
Fridolin Hösli
VISIT Glarnerland AG
Sernftalstrasse 3
8762 Schwanden
We would like to point out if there are other controllers 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 in accordance with Art. 27 GDPR:
IT.DS Consulting
IKlecker Weg 14 a
21244 Buchholz
Buchholz, Germany
Phone: +41 40 2109 1514
Web: itdsb.de
The Data Protection Representation serves as an additional point of contact for data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) for enquiries relating to the GDPR.
2. Terms and legal bases
2.1 Definitions
Personal data means any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing includes any handling of personal data, regardless of the means and procedures used, such as querying, matching, adapting, archiving, storing, reading, disclosing, obtaining, collecting, recording, deleting, disclosing, arranging, organising, storing, modifying, disseminating, linking, destroying and using personal data.
The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as 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 bases
We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
If and insofar as the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases:
Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject and for the implementation of pre-contractual measures.
Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or 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 carry out our activities and operations in a permanent, user-friendly, secure and reliable manner and to communicate about them, to ensure information security, to protect against misuse, to enforce our own legal claims and to comply with Swiss law.
Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfil a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
Art. 6 para. 1 lit. e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject.
Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data in order to protect the vital interests of the data subject or another natural person.
3. Type, scope and purpose
We process the personal data required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data as well as contract and payment data.
We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data that no longer needs to be processed is anonymised or deleted.
We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialised providers whose services we use. We also guarantee data protection for such third parties.
We only process personal data with the consent of the data subjects. If and to the extent that processing is permitted for other legal reasons, we may refrain from obtaining consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations or to protect overriding interests.
In this context, we process in particular information that a data subject voluntarily provides to us when contacting us - for example by post, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such data in an address book, in a customer relationship management system (CRM system) or with comparable tools, for example. If we receive data about other persons, the transmitting persons are obliged to guarantee data protection for these persons and to ensure the accuracy of this personal data.
4. job applications
We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent performance of an employment contract. The required personal data results in particular from the information requested, for example in the context of a job advertisement. We also process the personal data that applicants voluntarily provide or publish, in particular as part of cover letters, CVs and other application documents as well as online profiles.
We process - if and insofar as the General Data Protection Regulation (GDPR) is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR.
5. Personal data abroad
We generally process personal data in Switzerland and the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.
We may export personal data to all countries and territories on earth and elsewhere in the universe, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - in accordance with the decision of the European Commission.
We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example the express consent of the data subjects or a direct connection with the conclusion or fulfilment of a contract. We will be happy to provide data subjects with information about any guarantees upon request or provide a copy of any guarantees.
6. Rights of data subjects
6.1 Claims under data protection law
We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular:
- Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, but also information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries and the origin of the personal data.
- Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed and the processing of their data restricted.
- Erasure and objection: Data subjects can have their personal data erased (‘right to be forgotten’) and object to the processing of their data with effect for the future.
- Data disclosure and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another controller.
We may postpone, restrict or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other persons. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations.
In exceptional cases, we may charge costs for the exercise of rights. We will inform data subjects of any costs in advance.
We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to co-operate.
6.2 Right to lodge a complaint
Data subjects have the right to enforce their data protection claims through legal channels or to lodge a complaint with a competent data protection supervisory authority.
The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
Data subjects have - if and insofar as the General Data Protection Regulation (GDPR) is applicable - the right to lodge a complaint with a competent European data protection supervisory authority.
7. Data security
We take appropriate technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.
Our website is accessed using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.
Our digital communication - like all digital communication - is subject to mass surveillance without cause or suspicion and other surveillance by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities.
8. Use of the website
8.1 Cookies
We may use cookies. Cookies - our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) - are data that are stored in the browser. Such stored data does not have to be limited to traditional cookies in text form.
Cookies can be stored in the browser temporarily as ‘session cookies’ or for a certain period of time as so-called permanent cookies. ‘Session cookies’ are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. In particular, cookies make it possible to recognise a browser the next time it visits 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.
Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies - at least if and to the extent necessary.
For cookies that are used to measure success and reach or for advertising, a general objection (‘opt-out’) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).
8.2 Server log files
We may collect the following information for each access to our website, provided that this information 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, last website accessed in the same browser window (referer or referrer).
We store such information, which may also constitute personal data, in server log files. The information is required to provide our website in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.
8.3 Tracking pixels
We may use tracking pixels on our website. Tracking pixels are also known 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. Tracking pixels can be used to collect the same information as server log files.
9. Notifications and messages
We send notifications and messages by email and via other communication channels such as instant messaging or SMS.
9.1 Measuring success and reach
Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personalised basis. We require this statistical recording of usage for measuring success and reach in order to be able to send notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.
9.2 Consent and objection
You must always expressly consent to the use of your email address and other contact addresses, unless the use is permitted for other legal reasons. Wherever possible, we use the ‘double opt-in’ procedure to obtain consent, i.e. you will receive an email with a web link that you must click on to confirm, so that no misuse by unauthorised third parties can occur. We may log such consents, including the Internet Protocol (IP) address, date and time, for reasons of proof and security.
You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved.
9.3 Service providers for notifications and messages
We send notifications and communications with the help of specialised service providers.
In particular, we use:
- Mailchimp: communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc (USA); data protection information: privacy policy (Intuit) including ‘Country and Region-Specific Terms’, ‘Mailchimp Privacy Frequently Asked Questions’, ‘Mailchimp and European Data Transfers’, ‘Security’, Cookie Policy, ‘Privacy Rights Requests’, ‘Legal Terms’.
- Mailjet: Email marketing platform; Service provider: Mailgun Technologies Inc. (USA) together with its subsidiaries (‘Mailgun Group’); Data protection information: Privacy policy, ‘Security & Data protection’, ‘Data protection at Mailjet [...]: Your data is safe with us’.
- SendGrid: Platform for transactional e-mails (‘Sending e-mails made easy’); Provider: Twilio Inc (USA) / Twilio Ireland Limited (Ireland); Privacy Policy: Privacy Policy.
10. social media
We are present on social media platforms and other online platforms in order to communicate with interested parties and to provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside 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 platforms also apply in each case. In particular, these provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information.
We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). 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 on the type, scope and purpose of data processing, information on the rights of data subjects and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called ‘Controller Addendum’ with Facebook and thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page ‘Information on Page Insights’ including ‘Information on Page Insights Data’.
11. services of third parties
We use the services of specialised third parties in order to be able to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Among other things, we can use such services to embed functions and content in our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of users at least temporarily for technically compelling reasons.
For necessary security, statistical and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Provider: Google LLC (USA) / Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: ‘Privacy and Security Principles’, Privacy Policy, ‘Google is committed to complying with applicable data protection laws’, ‘Privacy Policy for Google Products’, ‘How we use data from websites or apps on or in which our services are used’ (information from Google), ‘Types of cookies and other technologies used by Google’, ‘Personalised advertising’ (activation / deactivation / settings).
- Services from Microsoft: Provider: Microsoft Corporation (USA) / Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), the UK and Switzerland; General information on data protection: ‘Data protection at Microsoft’, ‘Data protection and privacy (Trust Centre)’, Privacy Policy, Privacy Dashboard (data and privacy settings).
11.1 Digital infrastructure
We use services from specialised third parties in order to be able to use the necessary digital infrastructure in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
- Exoscale: Digital infrastructure; Provider: Akenes SA (Switzerland); Information on data protection: Privacy Policy, ‘Exoscale Security Policy’.
- Google Cloud including Google Cloud Platform (GCP): Storage space and other infrastructure; Google Cloud-specific providers: Google/ LLC (USA) for users in the USA and elsewhere / Google Ireland Limited or Google Commerce Limited (both Ireland) for users in the European Economic Area (EEA) and Switzerland and elsewhere (see ‘Google Contracting Entity’ for providers in other countries); Google Cloud-specific information: ‘Privacy Resource Centre’, ‘Data Protection’, ‘Compliance Resource Centre’, ‘Trust and Security’.
- Hostpoint: Hosting; Service provider: Hostpoint AG (Switzerland); Data protection information: Privacy Policy.
- METANET: Hosting; Service provider: METANET AG (Switzerland); Information on data protection: Privacy policy, ‘Technical and organisational measures’.
- Hetzner: Hosting and other infrastructure; Provider: Hetzner Online GmbH / Hetzner Cloud GmbH (both Germany); Data protection information: Privacy policy, ‘Data protection FAQ’.
- discover.swiss: Guest profiles and Infopoint; Cooperative disover.swiss (Switzerland); Information on data protection: Privacy policy
- AVS Meldewesen und Cardsystem; AVS Abrechnungs- und Verwaltungs-Systeme GmbH (Germany); Data protection information: Privacy policy
11.2 Contact options
We use services from selected providers in order to be able to communicate better with third parties such as potential and existing customers.
We use in particular:
- HubSpot: Customer Relationship Management (CRM); Provider: HubSpot Inc. (USA) / HubSpot Ireland Limited (Ireland) for users in the European Economic Area (EEA) and the UK; information on data protection: Privacy Policy, ‘Security, data and control mechanisms’, ‘Trust Centre’.
11.3 Audio and video conferencing
We use specialised audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.
Depending on the life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background.
We use in particular:
- Microsoft Teams: Platform for audio and video conferencing, among other things; Provider: Microsoft; Teams-specific information: ‘Data protection and Microsoft Teams’.
11.4 Social media functions and social media content
We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways.
We use in particular:
- AddThis: Sharing of content on social media and other online platforms, use of social media functions and collection of email addresses; Provider: Oracle Corporation (USA); Data protection information: Privacy Policy (AddThis), Privacy Policy (Oracle), ‘Cookie & Pixel Partners’ (‘Cookie & Pixel Partners’), information about / objection to interest-based advertising, objection to receiving emails via AddThis.
- Flockler: Integration of social media content in other digital channels. Information on data protection: Privacy Policy, ,AVV (order processing contract).
11.5 Map material
We use third-party services to embed maps in our website.
We use in particular:
- Google Maps including Google Maps Platform: Map service; Provider: Google; Google Maps-specific information: ‘How Google uses location information’.
- OpenStreetMap (OSM): Map service; Service provider: OpenStreetMap Foundation (United Kingdom); Data protection information: Privacy policy.
- Outdooractive: Map service; Service provider: Outdooractive AG (Germany); Information on data protection: Privacy policy.
11.6 Digital audio and video content
We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts.
We use in particular:
- Vimeo: video platform; provider: Vimeo Inc (USA); information on data protection: privacy policy, ‘Data protection’.
- YouTube: Video platform; provider: Google; YouTube-specific information: ‘Privacy and security centre’, ‘My data on YouTube’.
11.7 Fonts
We use third-party services to embed selected fonts, icons, logos and symbols on our website.
We use in particular:
- Adobe Fonts: Fonts; Provider: Adobe Inc. (USA) for users in North America / Adobe Systems Software Ireland Limited (Ireland) for users in the rest of the world; Data protection information: ‘Adobe Privacy Centre’, Privacy Policy (Adobe Fonts), Privacy Policy (Adobe), ‘Questions about privacy?’, ‘Adobe Privacy Settings’.
- Font Awesome: Icons and logos; Service provider: Fonticons Inc. (USA); Privacy Policy: Privacy Policy.
- fonts.com: Fonts; Service provider: Monotype Imaging Holdings Inc. (USA); Privacy Policy: ‘Your Privacy’, Privacy Policy, ‘Privacy Policy for Web Font Tracking’.
- Google Fonts: Fonts; Service provider: Google; Google Fonts-specific information: ‘Privacy and Google Fonts’, ‘Privacy and data collection’.
- IcoMoon: Icons; Service provider: Roonas (USA); Privacy Policy: Privacy Policy.
11.8 E-Commerce
We operate e-commerce and use third-party services in order to successfully offer services, content or goods.
We use in particular:
- TOMAS: Booking platform; Service provider: my.IRS GmbH (Germany); Privacy Policy: Privacy Policy.
- e-guma: Voucher and ticket system; Provider: Idea Creation GmbH (Switzerland); Data protection information: Privacy policy.
11.9 Payments
We use specialised service providers to process our customers' payments securely and reliably. For the processing of payments, the legal texts of the individual service providers such as General Terms and Conditions (GTC) or data protection declarations also apply.
We use in particular:
- Datatrans: Processing of payments; Service provider: Datatrans AG (Switzerland); Information on data protection: Privacy Policy, ‘Security & Compliance’.
- Worldline: Processing of payments, in particular with mobile payment solutions; Service provider: Worldline Financial Services (Europe) SA (France) and other Worldline companies; Privacy Policy: General Privacy Policy, Privacy Policy of Worldline Financial Services (Europe) SA, ‘Security for cashless payments’.
11.10 Advertising
We use the option of displaying targeted advertising for our activities and operations on third parties such as social media platforms and search engines.
In particular, we would like to use such advertising to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit relevant - possibly also personal - data to third parties that enable such advertising. We can also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).
Third parties with whom we advertise and where you are logged in as a user may be able to assign the use of our website to your profile there.
We use in particular:
- Facebook advertising (Facebook Ads): Social media advertising; Service provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Remarketing and targeting, in particular with the Facebook pixel and custom audiences including lookalike audiences, privacy policy, ‘advertising preferences’ (user registration required).
- Google Ads: Search engine advertising; Service provider: Google; Google Ads-specific information: Advertising based on search queries, among other things, whereby various domain names - in particular doubleclick.net, googleadservices.com and googlesyndication.com - are used for Google Ads, ‘Advertising’ (Google), ‘Why am I seeing a particular advert?’.
- Instagram Ads: Social media advertising; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); Data protection information: Remarketing and targeting, in particular with Facebook pixels and custom audiences including lookalike audiences, Privacy Policy (Instagram), Privacy Policy (Facebook), ‘Advertising preferences’ (Instagram) (registration as user required), ‘Advertising preferences’ (Facebook) (registration as user required).
12. extensions for the website
We use extensions for our website in order to be able to use additional functions.
In particular, we use:
Google reCAPTCHA: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots and spam); Service provider: Google; Google reCAPTCHA-specific information: ‘What is reCAPTCHA?’. (‘What is reCAPTCHA?’).
13. success and reach measurement
We try to determine how our online offer is used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions 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 popular content or make improvements to our online offering.
In most cases, the Internet Protocol (IP) addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are generally shortened (‘IP masking’) in order to comply with the principle of data minimisation through the corresponding pseudonymisation.
Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window, and information on the user's IP address.
In principle, any user profiles are only created in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile with the respective service.
We use in particular:
- AWStats: Success and reach measurement; Developer: AWStats (free open source software); Data protection information: Analysis of server log files on our own server infrastructure, ‘What is AWStats / Features Overview’.
- Google Analytics: Success and reach measurement; Provider: Google; Google Analytics-specific information: Measurement also across different browsers and devices (cross-device tracking) and with pseudonymised Internet Protocol (IP) addresses, which are only transmitted in full to Google in the USA in exceptional cases, ‘Data protection’, ‘Browser add-on to deactivate Google Analytics’.
- Google Tag Manager: Integration and management of other services for measuring success and reach as well as other services from Google and third parties; Provider: Google; Google Tag Manager-specific information: ‘Data collected with Google Tag Manager’; further information on data protection can be found in the individual integrated and managed services.
14. Personal data in the GlarnerlandPass app
We use the discover.swiss middleware in the GlarnerlandPass app to store and use personal data and the login/registration function. To check, change or delete your own details, you must use the discover.swiss login. Changes can be made at https://my.discover.swiss/.
The data protection provisions of Discover.Swiss apply: https://discover.swiss/datenschutz
15. final provisions
We have created this privacy policy using the privacy policy generator from Datenschutzpartner.
We may amend and supplement this privacy policy at any time. We will provide information about such amendments and additions in an appropriate form, in particular by publishing the current privacy policy on our website.