With this privacy policy, we provide information about the processing of personal data in connection with our activities and operations, including our website under the domain name sleepexpert.ch. In particular, we explain for what purposes, how and where we process which personal data. We also provide information about the rights of persons whose data we process.
For individual or additional activities and operations, we may publish further privacy policies or other information on data protection.
We are subject to Swiss law as well as any applicable foreign law, in particular that of the European Union (EU) with the European General Data Protection Regulation (GDPR).
With its decision of 26 July 2000, the European Commission recognised that Swiss data protection law ensures an adequate level of data protection. With its report of 15 January 2024, the European Commission confirmed this adequacy decision.
1. Contact addresses
Responsible for the processing of personal data (controller) is:
Prof. Christoph Nissen
Hôpitaux Universitaires de Genève (HUG)
Département de psychiatrie
20bis rue de Lausanne
1201 Genève
In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. Upon request, we are happy to inform data subjects about the respective responsibility.
Data protection representative in the European Economic Area (EEA)
We have the following data protection representative in accordance with Art. 27 GDPR:
VGS Datenschutzpartner GmbH
Am Kaiserkai 69
20457 Hamburg
Germany
The data protection representative 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 Terms
Data subject: Natural person about whom we process personal data.
Personal data: Any information relating to an identified or identifiable natural person.
Sensitive personal data: Data on trade union, political, religious or ideological views and activities, data on health, the intimate sphere or affiliation with an ethnicity or race, genetic data, biometric data that uniquely identify a natural person, data on criminal and administrative sanctions or proceedings, and data on social assistance measures.
Processing: Any handling of personal data, regardless of the means and procedures used, for example querying, matching, adapting, archiving, retaining, reading out, disclosing, obtaining, recording, collecting, deleting, revealing, arranging, organising, storing, altering, disseminating, linking, destroying and using personal data.
European Economic Area (EEA): Member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway.
2.2 Legal bases
We process personal data in accordance with Swiss law, in particular the Federal Act on Data Protection (FADP) and the Ordinance on Data Protection (Data Protection Ordinance, DPO).
Where and to the extent that the European General Data Protection Regulation (GDPR) is applicable, we process personal data on the basis of at least one of the following legal bases:
- Art. 6 para. 1 lit. b GDPR 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 GDPR for the necessary processing of personal data in order to safeguard legitimate interests – including the legitimate interests of third parties – unless overridden by the fundamental freedoms, fundamental rights and interests of the data subject. Such interests include, in particular, the sustainable, user-friendly, secure and reliable performance of our activities and operations, ensuring information security, protection against misuse, the enforcement of our own legal claims and compliance with Swiss law.
- Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to comply with 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 necessary processing of personal data 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 of another natural person.
- Art. 9 para. 2 et seq. GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.
The European General Data Protection Regulation (GDPR) refers to the processing of sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR).
3. Nature, scope and purpose of the processing of personal data
We process the personal data that are necessary to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. The personal data processed may fall in particular into the categories of browser and device data, content data, communication data, metadata, usage data, master data including inventory and contact data, location data, transaction data, contract data and payment data. The personal data may also constitute sensitive personal data.
We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect in the course of our activities and operations, insofar as such processing is permitted.
Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example to comply with legal obligations or to safeguard overriding interests. We may also ask data subjects for their consent even where their consent is not required.
We process personal data for the duration necessary for the respective purpose. We anonymise or delete personal data in particular depending on statutory retention and limitation periods.
4. Disclosure of personal data
We may disclose personal data to third parties, have it processed by third parties or process it jointly with third parties. Such third parties may include, for example, specialised providers whose services we use.
In the context of our activities and operations, we may disclose personal data in particular to banks and other financial service providers, authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit agencies and business information services, logistics and shipping companies, marketing and advertising agencies, media, parent, sister and subsidiary companies, organisations and associations, social institutions, telecommunications companies, insurance companies and payment service providers.
5. Communication
We process personal data in order to communicate with individuals as well as with authorities, organisations and companies. In doing so, we process in particular data that a data subject provides to us when contacting us, for example by post or e‑mail. We may store such data in an address book or with comparable tools.
Third parties who transmit data about other persons to us are obliged to ensure the data protection of those data subjects themselves. In particular, they must ensure that such data are accurate and that they are permitted to transmit them.
We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. With such services, we may also manage and otherwise process the data of data subjects beyond direct communication.
6. Data security
We take appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk. With our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without, however, being able to guarantee absolute data security.
Access to our website and our other digital presence takes place via transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers warn before visiting a website without transport encryption.
Our digital communication is subject – as is in principle all digital communication – to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We have no direct influence on the corresponding processing of personal data by intelligence services, police forces and other security authorities. Nor can we rule out that a data subject may be specifically targeted for surveillance.
7. Personal data abroad
We process personal data in principle 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 there or have it processed there.
We may export personal data to all countries on Earth and elsewhere in the universe, provided that the local law ensures an adequate level of data protection in accordance with the decision of the Swiss Federal Council and – where and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance with a decision of the European Commission.
We may transfer personal data to countries whose law does not ensure an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or with other appropriate safeguards. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the specific data protection requirements for doing so are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. Upon request, we are happy to inform data subjects about any safeguards or provide a copy of any safeguards.
8. Rights of data subjects
8.1 Data protection rights
We grant data subjects all rights under applicable law. In particular, data subjects have the following rights:
- Access: Data subjects may request information as to whether we process personal data about them and, if so, which personal data are concerned. Data subjects also receive the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information about the purpose of the processing, the duration of retention, any disclosure or export of data to other countries and the origin of the personal data.
- Rectification and restriction: Data subjects may have inaccurate personal data rectified, incomplete data completed and the processing of their data restricted.
- Right to state their own position and to human review: In the case of decisions that are based solely on automated processing of personal data and that have legal effects on data subjects or significantly affect them (automated individual decisions), data subjects may state their own position and request review by a human being.
- Erasure and objection: Data subjects may have personal data erased («right to be forgotten») and object to the processing of their data with effect for the future.
- Data delivery and data portability: Data subjects may request the delivery of personal data or the transfer of their data to another controller.
We may defer, restrict or refuse the exercise of data subjects› rights within the legally permissible framework. We may point out to data subjects any requirements that must be met in order to exercise their data protection rights. For example, we may refuse to provide information in whole or in part with reference to confidentiality obligations, overriding interests or the protection of other persons. We may also, for example, refuse to erase personal data in whole or in part, in particular with reference to statutory retention obligations.
We may exceptionally charge costs for the exercise of these rights. We inform data subjects in advance of any costs.
We are obliged to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.
8.2 Legal remedies
Data subjects have the right to enforce their data protection claims through legal proceedings or to lodge a report or complaint with a 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).
European data protection supervisory authorities are organised as members of the European Data Protection Board (EDPB). In some member states of the European Economic Area (EEA), the data protection supervisory authorities are structured on a federal basis, in particular in Germany.
9. Use of the website
9.1 Cookies
We may use cookies. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data need not be limited to traditional cookies in text form.
Cookies may 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 on the next visit to our website and thereby, for example, measure the reach of our website. Permanent cookies may also be used for online marketing, for example.
Cookies can be fully or partially deactivated, restricted or deleted in the browser settings at any time. The browser settings often also allow automated deletion and other management of cookies. Without cookies, our website may no longer be available to the full extent. We actively seek – at least where and to the extent required under applicable law – express consent to 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 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).
9.2 Logging
For each access to our website and our other digital presence, we may log at least the following information, provided it is transmitted to our digital infrastructure during such access: date and time including time zone, 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 the amount of data transferred, web page last accessed in the same browser window (referer or referrer).
We log such information, which may also constitute personal data, in log files. The information is necessary to provide our digital presence in a sustainable, user-friendly and reliable manner. The information is also necessary to ensure data security – including by third parties or with the assistance of third parties.
9.3 Tracking pixels
We may embed tracking pixels in our digital presence. Tracking pixels are also referred to as web beacons. Tracking pixels – including those from third parties whose services we use – are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our digital presence is accessed. Tracking pixels can capture at least the same information as logging in log files.
10. Social media
We are present on social media platforms and other online platforms in order to communicate with interested persons 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 privacy policies and other provisions of the individual operators of such platforms also apply in each case. These provisions provide information in particular about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.
11. Third-party services
We use services from specialised third parties in order to carry out our activities and operations in a sustainable, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content in our website. In the case of such embedding, the services used capture, for technically compelling reasons, at least temporarily the IP addresses of users.
For necessary security-related, 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 includes, for example, performance or usage data in order to be able to offer the respective service.
We use in particular:
- Google services: Providers: Google LLC (USA) / Google Ireland Limited (Ireland) in part for users in the European Economic Area (EEA) and Switzerland; general information on data protection: «Privacy and security principles», «More information on how Google uses personal data», privacy policy, «Google is committed to complying with applicable data protection laws», «Guide to privacy in Google products», «How we use data from websites or apps on or in which our services are used», cookie policy, «Advertising you can control» (settings for personalised advertising).
- Microsoft services: Providers: Microsoft Ireland Operations Limited (Ireland) for users in the European Economic Area (EEA), Switzerland and the United Kingdom / Microsoft Corporation (USA) for users in the rest of the world; general information on data protection: «Privacy at Microsoft», «Privacy and data protection», privacy statement, «Data and privacy settings».
11.1 Digital infrastructure
We use services from specialised third parties in order to obtain the digital infrastructure required in connection with our activities and operations. This includes, for example, hosting and storage services from selected providers.
We use in particular:
- Cyon: Hosting; provider: cyon GmbH (Switzerland); information on data protection: «Data protection», privacy policy.
11.2 Scheduling
We use services from specialised third parties to arrange appointments online, for example for meetings. In addition to this privacy policy, any directly visible terms of the services used, such as terms of use or privacy policies, also apply.
11.3 Audio and video conferencing
We use specialised services for audio and video conferencing in order to communicate online. We can use them, for example, to hold virtual meetings or to conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, apply in addition.
Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or displaying a virtual background.
We use in particular:
- Google Meet: Video conferencing; provider: Google; Google Meet-specific information: «Google Meet – security and privacy for users».
- Zoom: Platform for collaborative working, in particular with video conferencing; provider: Zoom Video Communications Inc. (USA); information on data protection: «Privacy at Zoom», privacy statement, «Legal compliance».
11.4 Online collaboration
We use third-party services to enable online collaboration. In addition to this privacy policy, any directly visible terms of the services used, such as terms of use or privacy policies, also apply.
We use in particular:
- Microsoft Teams: Platform for productive collaboration, in particular with audio and video conferencing; provider: Microsoft; Teams-specific information: «Security and compliance in Microsoft Teams», in particular «Privacy».
11.5 Digital content
We use services from specialised third parties in order to embed digital content in our website. Digital content includes, in particular, images and video material, music and podcasts.
We use in particular:
- Vimeo: Video platform; provider: Vimeo Inc. (USA); information on data protection: privacy policy, «Private video hosting».
11.6 Fonts
We use third-party services in order to embed selected fonts as well as icons, logos and symbols in our website.
We use in particular:
- Font Awesome: Icons and logos; provider: Fonticons Inc. (USA); information on data protection: privacy policy.
- Google Fonts: Fonts; provider: Google; Google Fonts-specific information: «Your Privacy and Google Fonts», «Privacy and data collection» (Google Fonts).
12. Extensions for the website
We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or run such extensions on our own digital infrastructure.
We use in particular:
- CleanTalk: Spam protection for websites; provider: CleanTalk Inc. (USA); information on data protection: privacy policy.
13. Performance and reach measurement
We try to measure the performance and reach of our activities and operations. In this context, we may also measure the effect of third-party references or examine how different parts or versions of our digital presence are used («A/B testing» method). Based on the results of the performance and reach measurement, we may in particular correct errors, strengthen popular content or make improvements.
For performance and reach measurement, the IP addresses of individual users are recorded in most cases. In this case, IP addresses are in principle shortened («IP masking») in order to follow the principle of data minimisation through the corresponding pseudonymisation.
Cookies may be used and user profiles may be created for performance and reach measurement. Any user profiles created include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window and the – at least approximate – location. In principle, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual third-party services with which users are registered may be able to attribute the use of our online offering to the user account or user profile with the respective service.
We use in particular:
- Matomo: Performance and reach measurement; provider: InnoCraft Ltd. (New Zealand, free open-source software); information on data protection: use on our own digital infrastructure and with anonymised IP addresses, «List of all Matomo Features».
14. Final provisions concerning this privacy policy
We created this privacy policy using the privacy policy generator by Datenschutzpartner.
We may update this privacy policy at any time. We provide information about updates in an appropriate form, in particular by publishing the current privacy policy on our website.