Privacy policy

1. Controller

The controller for the processing of personal data in connection with this website is:

Twing Group AG
Blegistrasse 11B
6340 Baar
Switzerland

Email: hallo@twing.swiss
Phone: +41 41 244 42 60

Below we inform you which personal data we collect when you use our website twing.swiss, what we use it for, which service providers we work with and what rights you have. Personal data is any information relating to an identified or identifiable person.

2. Legal bases

We process personal data under the Swiss Data Protection Act (DPA). Where the General Data Protection Regulation of the European Union (GDPR) applies in an individual case, for example because you are in the EU, we base the processing on art. 6 para. 1 lit. a GDPR (consent), lit. b GDPR (contract or enquiry) or lit. f GDPR (legitimate interest in the secure and economical operation of our website and in communication with prospects and clients).

We only process your personal data to the extent necessary to operate a functioning website, to answer your enquiries, to process orders or for the purposes to which you have consented.

3. Hosting and access data

Our website is hosted by Netlify, Inc., 512 2nd Street, San Francisco, CA 94107, USA, and delivered through their global network. When a page is called up, your browser automatically transmits technical data to Netlify's servers, where it is stored in log files:

• IP address
• date and time of the request
• page called up and volume of data transferred
• access status (HTTP status code)
• website the request comes from (referrer)
• browser type, browser version, operating system and language

This data is technically necessary to display the website to you and to ensure its stability and security. It is not combined with other personal data. Netlify processes the data on our behalf; the transfer to the USA is based on a data processing agreement with the standard contractual clauses approved by the EU Commission. Further information: https://www.netlify.com/privacy/

4. Images and content

The content of this website is managed in a content management system provided by Sanity AS, Oslo, Norway. Images are loaded directly from Sanity's delivery network when the page is called up. Your IP address is transmitted to Sanity in the process, which is technically necessary for the delivery of the images. Norway has a level of data protection recognised as adequate by Switzerland and the EU. Further information: https://www.sanity.io/legal/privacy

5. Contact form and enquiries

When you send us an enquiry through the contact form, we process the details you enter: name, company, email address, telephone number, your request, your message and, if you attach a file, that file, for example a logo or print data. We use these details exclusively to answer your enquiry and to make you an offer.

The form entries are technically received and stored by Netlify, Inc. (see section 3) and delivered to us by e-mail. Netlify automatically checks every entry for spam using the Akismet service of Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; the entries and your IP address are transmitted to Akismet for this purpose (https://akismet.com/privacy/). For every enquiry we also store the page from which you sent the form, the language of the page and the information about the origin of your visit described in section 6. When your phone number is checked, your approximate location (country) is derived from your IP address to suggest the country code; this information is not stored.

When you contact us by email or telephone, we store the personal data you provide in order to answer your enquiry. We delete the data as soon as storing it is no longer necessary, or restrict the processing if statutory retention obligations apply.

6. Origin of your visit (measuring our advertising)

We want to know which of our advertising activities lead to enquiries. For this purpose, our website notes, when a page is first opened, how you reached us: the referring website, any campaign parameters in the address (UTM parameters) and click identifiers from advertising platforms (Google Ads, Microsoft Advertising, LinkedIn, Meta) if you arrived through an advertisement.

This information is stored exclusively in your browser: the origin of your first visit for 30 days in local storage, the origin of the current visit in session storage until the browser window is closed. No cookies are set for this and no data is transmitted to third parties. As long as you do not submit a form, the information does not leave your browser.

Only when you submit an enquiry or a newsletter sign-up is the origin information transmitted together with your entry and stored with the enquiry (see section 5). We evaluate it to see which campaigns trigger enquiries and to allocate our advertising budget accordingly. This processing is based on our legitimate interest in measuring the success of our advertising.

If an enquiry originates from a Google Ads advertisement, we may tell Google that the ad click in question led to an enquiry or an order (a so-called offline conversion). In that case Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, receives only the click identifier, the time and the type of conversion. Your name, contact details and the content of your enquiry are not transmitted.

You can delete the stored origin information at any time by clearing the site data for twing.swiss in your browser. You can also object to this processing by e-mail to hallo@twing.swiss; we will then remove the origin information from your enquiry.

7. Newsletter

If you would like to receive the newsletter offered on the website, we need your email address. The sign-up is recorded through our website (Netlify, see section 3) and stored in our newsletter system. The processing is based exclusively on your consent.

You can withdraw your consent at any time, most easily through the unsubscribe link in every newsletter or by email to hallo@twing.swiss. The lawfulness of the processing carried out until the withdrawal is not affected. We store the data provided for the purpose of the newsletter until you unsubscribe and delete it afterwards.

8. Live chat

Our website offers a live chat through which you can ask us questions directly. We use the HubSpot service of HubSpot Ireland Limited, 1 Sir John Rogerson’s Quay, Dublin 2, Ireland; our account is operated in data centres in the European Union. The chat is loaded only when you click the chat button. When you use the chat, we process the messages you write to us and the information you volunteer in order to answer your questions.

The chat sets a technically necessary cookie so that your conversation history is kept when you next open a page. We have deactivated HubSpot’s analytics functions: no cookies are set to record your browsing behaviour and no page views are recorded. Chat histories are stored in our HubSpot account and, if the conversation becomes an enquiry, treated as an enquiry under section 5. Further information: https://legal.hubspot.com/privacy-policy

9. Embedded third-party services

On individual pages we embed content from third parties. When such content is loaded, your IP address is transmitted to the provider in question, and the provider may set cookies.

Google Maps. On the contact page we show a map with our location. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When the contact page is called up, data is transmitted to Google, possibly also to servers in the USA. Google is certified under the Swiss-U.S. Data Privacy Framework and the EU-U.S. Data Privacy Framework. Further information: https://policies.google.com/privacy

YouTube. On the home page we show a video that is embedded through YouTube in extended privacy mode (youtube-nocookie.com). The video is only loaded once the corresponding section comes into view on a desktop device; on mobile devices a still image is shown. The provider is Google Ireland Limited. Further information: https://policies.google.com/privacy

Fonts. The fonts used on this website are loaded from our own servers. No connection is made to Google Fonts or other font providers.

10. Links to social networks

Our website contains links to our profiles on Instagram, LinkedIn, Facebook and TikTok as well as a link for getting in touch via WhatsApp. These are pure links; no data is transmitted to these providers when you visit our website. Only once you click a link do the data protection provisions of the provider in question apply.

11. Cookies and local storage in the browser

For the operation of the website itself we set no cookies that identify you as a person. The live chat sets a technically necessary cookie for the conversation history (section 8), and the website uses your browser’s local storage for the origin information described in section 6.

We set cookies for web analytics and online advertising (section 12) only if you have consented in the cookie banner. For the banner and the management of your consent we use the CookieYes service of Mozilor Limited, 71-75 Shelton Street, London WC2H 9JQ, United Kingdom. Your choice is stored in a cookie (cookieyes-consent) for twelve months, so that the banner does not reappear on every visit, and passed to Google as a consent status (Google Consent Mode), so that Google’s services process data only to the extent you have allowed. You can change or withdraw your choice at any time by reopening the cookie banner via the cookie icon on the website. Further information: https://www.cookieyes.com/privacy-policy/

Cookies may also be set by the third parties named in section 9 when their content is loaded. You can set your browser to refuse cookies and site data or to delete them after your visit; some functions of the website may then be unavailable.

12. Web analytics and online advertising

With your consent we use services to understand how our website is used and to measure the success of our advertising. The services are integrated through Google Tag Manager. Google Analytics data first passes through our own tagging server at sst.twing.swiss (server-side tagging) and is forwarded to Google from there; this server is operated for us by Stape Inc., 1160 Battery Street East, San Francisco, CA 94111, USA, on servers in the European Union.

Google Analytics 4. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics records which pages you visit, how long you stay, which source you come from and which device and browser you use, and compiles pseudonymous usage statistics from this. Cookies are set for this purpose (_ga, _ga_*), valid for up to two years. Google Analytics does not store IP addresses. Data may be transmitted to Google servers in the USA; Google is certified under the Swiss-U.S. Data Privacy Framework and the EU-U.S. Data Privacy Framework. Usage data is deleted after 14 months at the latest. Further information: https://policies.google.com/privacy

Google Ads. We place advertisements on Google. To measure which advertisements lead to enquiries and to show visitors to our website relevant advertisements later (remarketing), Google Ads sets cookies with your consent and records ad clicks, page views and conversions. When you submit an enquiry, we may additionally transmit your e-mail address and phone number to Google in hashed, non-reversible form (enhanced conversions); Google matches these values against Google account data to improve measurement. The values are not transmitted to Google in plain text. The provider is Google Ireland Limited (see above). Ads settings: https://adssettings.google.com

LinkedIn Insight Tag. To measure the success of our advertisements on LinkedIn and to show visitors to our website relevant advertisements there, we use, with your consent, the Insight Tag of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. It records the pages visited, the browser and the IP address and sets cookies. Further information and advertising preferences: https://www.linkedin.com/legal/privacy-policy and https://www.linkedin.com/psettings/guest-controls

Microsoft Advertising. For advertisements in the Bing search engine we use, with your consent, the Universal Event Tracking of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. It measures whether an ad click led to an enquiry and sets cookies for this purpose. Further information: https://privacy.microsoft.com/privacystatement

Hotjar. To understand how our pages are used, we use, with your consent, Hotjar of Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta. Hotjar compiles aggregated representations of clicks, mouse movements and scrolling (heatmaps) and may record individual visits pseudonymously; entries in form fields are not recorded. Hotjar sets cookies (_hjSession*), valid for up to one year. Further information: https://www.hotjar.com/privacy

Independently of this website, we place advertising on third-party platforms, in particular on LinkedIn (LinkedIn Ireland Unlimited Company, Ireland). The targeting is based on the details you have given to the platform in question; its data protection provisions apply. Advertising preferences on LinkedIn: https://www.linkedin.com/psettings/guest-controls

You can withdraw your consent to web analytics and online advertising at any time via the cookie settings (section 11). Withdrawal applies to the future; data collected up to that point is unaffected.

13. Other service providers

For internal processes we use service providers that may process personal data on our behalf:

• Stape Inc. (USA, servers in the EU): operation of our tagging server (section 12)
• Mozilor Limited (United Kingdom): consent management CookieYes (section 11)
• Hotjar Ltd (Malta): usage analysis (section 12)
• HubSpot Ireland Limited (Ireland, data processing in the EU): live chat (section 8)
• Automattic Inc. (USA): spam checking of form entries with Akismet (section 5)
• OpenAI (EU/USA) for assisted processing of text data, for example when preparing replies to enquiries
• Make.com (EU/USA) for the automation of internal work processes
• Slack (USA) for internal coordination and approval processes

This may involve data transfers to countries outside Switzerland and the EU. The providers use the recognised standard contractual clauses for this, which ensure an adequate level of protection. These systems serve exclusively as technical support; decisions concerning clients are always checked and approved by our staff. No automated decision-making or profiling takes place.

14. Disclosure to third parties

We only pass on personal data where this is necessary to fulfil an order, for example to production and logistics partners for the manufacture and delivery of ordered products, where you have consented or where we are legally obliged to do so. We do not sell personal data.

15. Retention and deletion

We retain personal data for as long as it is necessary for the respective purpose. We delete data from enquiries as soon as the enquiry has been dealt with conclusively and no business relationship arises. We retain data from orders for the duration of the statutory retention obligations, as a rule ten years. Log data from the hosting is deleted by the provider after a short time.

The following periods apply in particular:

• Your cookie choice: twelve months (section 11)
• Origin information in your browser: 30 days (section 6)
• Usage data in Google Analytics: 14 months at most (section 12)
• Hotjar cookies: one year at most (section 12)
• Chat histories: until finally dealt with, then as enquiries (section 8)

16. Data security

We protect our website and our systems with technical and organisational measures against loss, destruction, access, alteration or distribution of your data by unauthorised persons. The transmission between your browser and our website is encrypted end to end with TLS. Despite regular checks, complete protection against all risks is not possible.

17. Your rights

You have the following rights towards us with regard to your personal data:

• right of access to the personal data we store
• right to rectification or erasure
• right to restriction of processing
• right to object to the processing
• right to the release and portability of data
• right to withdraw a consent given, with effect for the future

A message to hallo@twing.swiss or to the postal address named in section 1 is enough to exercise your rights. You also have the right to lodge a complaint with a data protection supervisory authority; in Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC).

18. Changes

We can adapt this privacy policy at any time, in particular if we use new services or if the legal situation changes. The version published on this website applies.