1. Name and contact details of the data processor responsible, the data protection of-ficer and the location of the server.

Responsible in accordance with Article (Art.) 4 Paragraph (para.) 7 of the EU General Data Protection Regulation (GDPR) is

BERNINA International AG
Seestrasse 161
8266 Steckborn
Switzerland

Email: info@bernina.com
Tel.: +41 (0)52 762 11 11 (see Legal notice).
 
Our data protection officer Mr. Denkinger can be contacted via email at datenschutzbeauftragter@bernina.com or at the aforementioned postal address, addressed to "the Data Protection Officer".

In addition, you can also contact the market organization responsible for you with respect to data processing operations: info@bernina.co.uk​​

BERNINA will store personal data on servers in the EU.

2. Collection and storage of personal data; type and purpose of its use

a) When visiting the website
 
When you access our website, information is automatically transferred to us via the browser on your device. When you visit our website, the following data – without any action on your part – will be collected and temporarily stored in a log file:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Contents of the request (specific page)
• Access status/HTTP status code
• the amount of data transferred
• the website from which the request was received
• Browser used
• Language and version of the browser software
• Operating system and its interface

The specified data will be processed by us for the following purposes:
 

• To ensure the smooth establishment of a connection to the website
• To ensure convenient operation of our website
• To evaluate the system security and stability
• For determining the correct country site
• Other administrative purposes

The legal basis for data processing is Art. 6 para. 1 clause 1 littera (lit.) f of the EU General Data Protection Regulation (GDPR). Our legitimate interest arises from the aforementioned purposes for data collection.
 
When you visit our website, we also use analytical services, social media bookmarks/plug-ins and website cookies. Further information on cookies and analytical services can be found under sections 4 and 5 of this privacy policy and information about social media bookmarks/plug-ins can be found under section 6. Sections 7 and 8 provide information about the integration of YouTube Videos and Google Maps.
 
b) When using a contact form or contacting us via email
 
By making contact with us through a contact form or email, the data communicated by you (your email address, name, phone number, address, and any other information you provide on the contact form) are stored by us in order to answer your questions. Insofar as is necessary based on your request, the data can also be transferred to companies affiliated with BERNINA or to independent market organizations and processed by them. We delete any data arising in this context if it is no longer necessary to store it in order to answer your request.
 
The processing of data for the purpose of contacting us is made according to Article 6 para. 1 clause 1 lit. a GDPR on the basis of your voluntarily provided consent.
 
c) when using our customer portal and product registration
 
If you wish to use our customer portal, you must first register by providing your name, your email address, and a password of your choosing. This information will be stored in the Microsoft Azure Cloud, operated by Microsoft Corporation, One Microsoft Way Redmond, WA 98052-6399, USA, on servers in the EU. For this registration, we use for the  double opt-in process, which means your registration is not complete until you confirm the registration using a code sent to you by email. You must provide the aforementioned data to use the customer portal. You can voluntarily provide more information by using our portal.
 
In our customer portal, you can view, change, and add to the personal information that we have on record for you at any time. We use this information for customer data management and, if necessary, to process any warranty claims as well as to personalize advertising. Additionally, you can register your BERNINA products, sign up for the BERNINA newsletter, and identify topics that you are particularly interested in.
 
If you want to register a product, we will save the information you provide (serial number, date of purchase, dealer, product, and other information in the questionnaire) and use it for the purpose of customer data administration and, if necessary, to grant any benefits you may be awarded as a result of registering the product, and to provide personalized advertising.
 
For more information on data privacy when using the newsletter service, please see section 2. d) Newsletter.
 
Information that you provide in the customer portal may be linked to other information we have saved about you in a customer profile. In doing so, we comply with the principle of purpose limitation and link only data that has been collected for the same purposes (e.g. for advertising). BERNINA can provide dealers, suppliers, or service providers with information from your customer profile if you have given your consent, which is revocable at any time, to this submission or if the transmission of this information is necessary in order to process your request. BERNINA will only transmit your data to third parties to the extent required. These third parties are obligated to adequately protect your data and to use it in conformity with the law.
 
The processing of your data when using the customer portal is subject to art. 6 para. 1 sent. 1 lit. a) (if and to the extent you give your consent), lit. b) (product registration), and lit. f) (other cases; in these cases, the legitimate interests of BERNINA are those of direct marketing) of the EU General Data Protection Regulation (GDPR). You are neither legally or contractually obligated to provide information. Use of the customer portal, however, is only possible if the required information specified above has been provided. Any benefits arising from product registration can only be provided if the product has been registered.
 
You can delete individual data stored in the customer portal at any time. All of your stored data may be deleted upon request. Additional information about your information and revocation rights is available in paragraph 10 of the data protection provisions. In all other respects, your data will be deleted when the purpose for which the data was collected no longer exists.
 
d) when signing up for our newsletter
 
You can sign up for our newsletter to receive information about the latest trends in sewing, quilting, and embroidery as well as attractive offers from BERNINA.
 
When registering for our newsletter, we use the double opt-in procedure. This means that we send an email to the specified email address in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be automatically deleted. In addition, we will save your IP addresses as well as the date and time of registration and confirmation. The purpose of the procedure is to verify your registration and, if necessary, to investigate any possible misuse of your personal data.
 
In addition to your email address, on some forms, your name and/or your zip code are mandatory information for sending the newsletter. We want to send our users high-quality newsletters that are customized to their needs. In order to address you personally in the newsletter, and to tailor the newsletter to your needs, we also require your name, and in some cases your zip code, when you subscribe to the newsletter. You are neither legally nor contractually obligated to provide information. However, the use of our newsletter service is only possible if the aforementioned mandatory information is provided.
 
If you sign up for the BERNINA newsletter, the data you enter when registering (name, email address, interests, zip code, and additional information where appropriate) is stored for the purpose of direct marketing (including the delivery of personalized content within the newsletters but also on the BERNINA website) and may be linked to other data that BERNINA has saved about you.
 
Please note that we use our newsletter to evaluate your user behavior. This may be done using an algorithm or manually. If you click on a link in a newsletter, you will be directed to one of our websites via a Salesforce Marketing Cloud server. Salesforce Marketing Cloud evaluates various parameters, e.g. when you click which links in the newsletter and which of our pages you visit. To evaluate user behavior, we link the data generated in this way with other user data, in particular data collected via a Salesforce Marketing Cloud cookie (for more information, see Section 5 i) of this privacy policy below). We use the aforementioned data to create a user profile in order to tailor our digital offers such as the newsletter or websites to your individual interests.
 
For sending newsletters and the subsequent evaluation of your user behavior, we use solutions from the external service provider Salesforce.com, Inc., Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA. This may result in Salesforce.com, Inc. having access to your personal data. The collected data is stored on Salesforce.com, Inc. servers. 
 
In addition to the aforementioned user analysis by Salesforce Marketing Cloud services, some of the services offered by Email on Acid, 5500 Greenwood Plaza Blvd, Suite 220, Greenwood Village, CO 80111, USA are also used, whereby the above statements on data collection/processing and user analysis by Salesforce Marketing Cloud apply accordingly to Email on Acid's analysis and tracking services. This may result in the transmission of your personal data to Email on Acid in the USA. 
 
In addition, we use the services of Email on Acid to test the presentation of newsletters on different email platforms and on different mobile devices. In isolated cases, this can result in the transmission of personal data to Email on Acid.
 
Email on Acid processes this data exclusively on behalf of and in accordance with the instructions of BERNINA.
 
In addition, we use a solution provided by our external service provider, MailChimp, The Rocket Science Group, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. This may result in the transmission of your personal data to MailChimp. 

The legal basis for the aforementioned data processing is Art. 6 para. 1 clause 1 a) of the GDPR or, insofar as consent has not been granted in individual cases, Art. 6 para. 1 clause 1 f) of the GDPR.
 
You can revoke your consent to receiving the newsletter and unsubscribe from the newsletter at any time. You can declare that you revoke your consent by clicking on the link provided in each newsletter email, by sending an email to info@bernina.com or by sending a message to the contact details given in the imprint. This applies equally to an objection against commercial use in the event that you have not given consent to the sending of newsletters.
 
The data collected in relation to this will be stored until the consent is revoked.
 
e) when registering for classes with the BERNINA Creative Center
 
If you sign up for a class with the BERNINA Creative Center, the data you provide (name, address, email address, telephone number, other data you may voluntarily supply) will be processed for the purpose of organizing and running the class you have booked and will be passed on to the class management. The legal basis for the processing is Art. 6 para. 1 clause 1 lit. b of the GDPR. Provided that you have not consented to a longer storage duration, these data will be deleted upon completion of the class.
 
In addition, if you have consented to the use of your data for direct marketing purposes, we will process the data for direct marketing purposes and combine it in a customer profile with other information collected by us for the same purpose. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR.
 
If you have also consented to the publication of photos taken of you during the class for advertising purposes, we will process these photos in accordance with your consent. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR.
 
f) when using our blogs
 
If you sign up for the BERNINA Blog, the mandatory information specified by you when signing up (name, email address, country) as well as any additional data you voluntarily provide to supplement your profile, are saved for the purpose of the blog and for direct marketing purposes and, where appropriate, is linked to other data that BERNINA has saved about you. In the blog, you can publicly post topics, posts, links, comments, photos, sketches, instructions, etc. If you carry out such an action, we will save this internally, publish your action in the BERNINA blog and use these activities, where appropriate, to provide personalized content. Based on your uploaded projects (number of articles written, categories, participation in cooperative actions, tags used to describe articles, first/last entry) we will try to draw conclusions about your interests and use this information for direct marketing purposes.

You can also sign up for our special blog newsletter. For the blog newsletter, the statements under No. 2 lit. d) shall apply accordingly.

Mandatory information is required to use the blog, since we need your email address for authentication, your name in order to be identified as the author of projects/comments, as well as for a personal response from us, and your country in order to be associated with a market organization. You are neither legally nor contractually obligated to provide information. Use of our blog, however, is only possible if the required information specified above has been provided.
 
If you want to leave a comment in the blog, a spam check is carried out in order to prevent misuse of our blogs. As part of this, your email address and your IP address will be saved and compared to a local blacklist. In addition, we use the Anti Spam Bee plug-in to help detect spam. The plug-in allows invisible input fields to be added to the comment form. Since spambots often complete all possible fields, it is possible to determine whether a comment is classified as spam. The plug-in also matches new comments with the metadata from previous spam comments and checks the comments for content that is commonly used by spammers (links, etc.). All of the checks noted above are carried out locally on our servers. No personal data is transferred to third parties. Once the above tests have taken place, your comment, along with your first name and last name, will be published. In addition, the author of the post you commented on receives an alert about your comment which also includes your first and last name.
 
The photos you upload to the blog must first be compressed. We use the Optimus image optimizer from the external service provider proinity GmbH, Rümikerstrasse 60, 8409 Winterthur, Switzerland, to perform this image compression. proinity GmbH compresses the photos and then, after the transfer process has been completed, immediately erases all cached data. No personal data remains on the service provider's servers. Your data is processed by proinity GmbH exclusively on behalf of and in accordance with the instructions of BERNINA subject to these data protection regulations.
 
The legal basis for the processing of your data in the BERNINA blog is Art. 6 para. 1 clause 1 lit. a of the GDPR.
 
The data collected in the context of our blog will be stored until the consent is revoked.

Please refer to the special terms and conditions of use of the BERNINA Blog.

g) when using our web shop inspiration.bernina.com
 
If you wish to order something from our web shop, in order to conclude the contract, you are required to provide the personal data necessary to process your order (mandatory information). The mandatory information required to process the order is marked separately; all other information is voluntary. We process the data you provide for the purpose of processing your order.
 
You can also voluntarily create a customer account, enabling us to save your data for further purchases. When you create a customer account, the optional data you have provided and your previous purchases will be stored unless consent is revoked. One of the advantages of this is that you can download digital content you have purchased (e.g. a digital edition of our customer magazine) from your customer account at any time.
 
If you order print media, we will pass on your details to Medienwerkstatt AG, Steinackerstrasse 8, 8583 Sulgen, Switzerland. Medienwerkstatt AG is responsible for shipping single issues ordered and issues covered by a subscription. If you pay by credit card or PayPal, we will pass on your payment details to the payment service provider SIX Payment Services AG, Hardturmstrasse 201, 8021 Zürich, Switzerland. Credit card information is stored and processed exclusively by SIX Payment Services AG. BERNINA does not save or process your credit card information. If you choose to pay by invoice, the invoice will be issued by Medienwerkstatt AG.
 
Due to commercial and tax regulations, we are obliged to save your address, payment and order data for a period of ten years. Your data will be deleted when the purpose for which the data was collected no longer applies and there is no legal basis for its continued storage. In your customer account, you can edit or delete all optional data yourself under "Addresses" or "Profile data". Your entire customer account can be deleted on request (which you can send to info@bernina.com, for example). More information about your information and consent revocation rights is available in Section 10 of this privacy policy.
 
If you open a customer account, we will link the data you provided when you opened the account and the purchases made with other information that we have stored about you in a customer profile. In doing so, we comply with the principle of purpose limitation and only link data that has been collected for the same purposes (e.g. for personalized advertising).
 
The legal basis for processing the data required to conclude a contract is Art. 6 para. 1 sentence 1 b) of the GDPR and, with regard to all other data, Art. 6 para. 1 sentence 1 a) of the GDPR (if and insofar as you give your consent) or Art. 6 para 1 sentence 1 f) of the GDPR (other cases; in these cases, BERNINA's legitimate interests are direct marketing interests).

h) when downloading free downloads
 
On our website, we provide you with the option of free downloads (e.g. for test versions of embroidery software or upgrades of already purchased software). Before you can start downloading, you are required to complete a form, including providing your name, your email address, your post/zip code and your location. With your consent, we store and share this data with the respective market organization or dealer in your area. The purpose of the processing is to create a statistical record of the downloads carried out as well as promotions and advertising on the part of BERNIINA, the respective market organization or a dealer in your area. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR.
 
In addition, if you have consented to the use of your data for the purposes of sending newsletters, we will process the data for direct marketing purposes and combine it in a customer profile with other information that BERNINA has saved about you. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR.
 
i) when ordering fee-based software downloads (BERNINA Toolbox)
 
For fee-based software, we use the online sales solution, MyCommerce, from Digital River GmbH, Scheidtweilerstr. 4, 50933 Cologne. Digital River GmbH sells our digital software product on our behalf. If you trigger the purchase of fee-based software via our website, you will be redirected to the Digital River GmbH website. Digital River GmbH is the seller of the products and your contractual partner. We assume the role of a “partner” in accordance with the Digital River GmbH data protection policy. The personal data collected by Digital River GmbH during the processing of the order and how this data is processed can be found in the Digital River GmbH data protection policy, which can be viewed at the following link: https://www.mycommerce.com/privacy-policy/. BERNINA has access to the information entered during the ordering process except for the payment details.
 
j) when submitting an application
 
If you submit an application, we will process your application data in order to proceed with the application process. It will be ensured that your personal application data will only be passed on to the internal offices and specialist departments who are responsible for filling the position in question. Your personal application data will not be transferred to third parties. If you are not to be considered as part of the application process, your application data will be automatically deleted six months after the completion of the application process, unless a statutory provision precludes the deletion, further storage is required for the purpose of providing evidence, or you have explicitly agreed to a longer period of storage. In the instance of recruitment, the data you provide during the application process will be stored and processed as employee data. The legal basis for the processing of your data is Art. 6 para. 1 clause 1 lit. a of the GDPR.

3. Use of service providers, communication of data

BERNINA uses selected external service providers to deliver support and administrative functions for our website. These service providers may occasionally have access to your personal information. The service provider processes your data solely on behalf of and in accordance with the instructions of BERNINA and in compliance with this privacy policy and the applicable laws.
 
We currently use the following service providers:
 

 
A transfer of your personal data to other third parties takes place only insofar as the transmission is explicitly stated in this privacy policy or that it happens for one of the following reasons:
 

• You have given your explicit consent in accordance with Art. 6 para. 1 clause 1 lit. a of the GDPR.
• In accordance with Art. 6 para. 1 clause 1 lit. f of the GDPR, the disclosure is required in relation to the assertion, exercise or defense of legal claims, or for the delivery of our website and there is no reason to believe that you have an overriding legitimate interest in the non-disclosure of your information
• In the event that the disclosure is a legal obligation in accordance with Art. 6 para. 1 clause 1 lit. c of the GDPR
• The disclosure is permitted by law and is required to conclude a contractual relationship with you in accordance with article 6 para. 1 clause 1 lit. b of the GDPR

4. Cookies

BERNINA uses cookies on this website. Cookies are small pieces of text information, which are stored by your browser (e.g. Internet Explorer or Mozilla Firefox) on your computer's hard drive and which allow the flow of specific information to us. This does not mean, however, that we can immediately determine your identity.
 
On the one hand, the use of cookies serves to make using our offer more convenient for you. This is why we use so-called session cookies, to recognize that you have already visited individual pages of our website. These are automatically deleted after leaving our site.
 
In addition, we also use temporary cookies to enhance the user experience; these are stored for a specific length of time on your device. Should you revisit our site to make use of our services, it will automatically detect that you previously visited, what you entered, and which settings you selected so that you do not have to enter them again.
 
We also make use of cookies to capture statistical data on the use of our site and to evaluate it in order to optimize our offer to you (see sections 5 and 6 of this privacy policy). When visiting again, these cookies allow our website to automatically detect that you have previously visited us. These cookies are automatically deleted after each defined period of time.
 
The data processed through the cookies is necessary to protect our legitimate interests for the aforementioned purposes as well as those of third parties in accordance with Art. 6 para. 1 clause 1 lit. f of the GDPR.
You can configure your browser settings according to your wishes and refuse, for example, to accept third-party cookies or all cookies. If you opt out of the use of cookies, your ability to use every function on this website to its fullest extent could be limited.
 
The legal basis for the use of cookies is Art. 6 para. 1 clause 1 lit. f of the GDPR.

5. Web analysis

a) Google Analytics

This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). By using Google Analytics, we want to ensure a needs-based design and the continuous optimization of our website as well as statistically capturing the use of our website in order to optimize our offer for you. The legal basis for this is Art. 6 para. 1 clause 1 lit. f of the GDPR.

Google Analytics uses  "cookies", text files that are stored on your computer and enable your use of the website to be analyzed. The information generated by the cookie about your use of the website is usually transmitted to and stored on a Google server in the USA. This website uses Google Analytics with the "_anonymizeIp()“ function. This means that IP addresses are processed in a shortened form so that it is not possible to relate them to a person. Insofar as a personal reference is included in the data collected about you, it is therefore immediately excluded and the personal data thus promptly deleted. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA. 

Google will use this information on behalf of BERNINA to analyze your use of the website for BERNINA, to compile reports regarding website activity and to provide other services related to website and Internet usage (in particular functions for display advertising, such as remarketing, reports on Google Display Network impressions, DoubleClick Campaign manager integration and Google Analytics demographic and interest reports).

Under certain circumstances, Google may analyze your usage behavior over several end devices (PC, smartphone, tablet etc.) and evaluate it for BERNINA using so-called cross-device functions. For this, Google may link information generated by the respective end devices for the purpose of personalized advertising with other such data and with data from your Google Account, if you have a Google Account and your preferences are set to allow Google to link the browsing history to the Google Account and use information from the Google Account to personalize the advertising you receive.

You can prevent Google Analytics cookies from being stored on your computer by selecting the relevant settings in your browser. However, please note that, if you do this, you may not be able to utilize the full functionality of this website. You can also prevent Google from collecting and processing the data generated by the cookie about your use of the website (including your IP address) by downloading and installing the browser plug-in available from the following link: http://tools.google.com/dlpage/gaoptout.

As an alternative to the browser plug-in or in browsers on mobile devices, you can click the following link to set an opt-out cookie that will prevent Google Analytics data collection from this website in the future (this opt-out cookie only works in this browser and for this domain; if you delete your cookies in this browser, you will have to click this link again): Click here to set your opt-out cookie.

Third-party information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, Terms and conditions of use: http://www.google.com/analytics/terms/, Overview of data protection: https://support.google.com/analytics/answer/6004245, as well as the privacy policy: https://policies.google.com/privacy?hl=en.
 
b) DoubleClick by Google
 
This website makes further use of the Online Marketing Tool DoubleClick by Google, part of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google"). DoubleClick uses cookies to place ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads multiple times. Google uses a cookie ID to determine which ads are running in which browser and can therefore prevent them from being displayed multiple times. In addition, DoubleClick uses cookie IDs to capture so-called conversions, which are related to ad requests. This is the case if a user sees a DoubleClick ad and later visits the advertiser's website using the same browser, and then purchases something. According to Google, DoubleClick cookies contain no personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google servers. We have no control over the extent and continued use of the data collected through the use of this tool by Google and therefore inform you to the best of our knowledge: By integrating DoubleClick, Google receives information that you have accessed the respective part of our website or have clicked on an ad from us. If you are signed in to a Google service, Google can link the visit to your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will detect and store your IP address. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

You can prevent participation in this tracking method in different ways: a) by changing the settings on your browser software accordingly. By suppressing third party cookies in particular, you will not receive any ads from third-parties; (b) by disabling cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com, https://adssettings.google.com/?hl=en. When you clear your cookies, you will clear this setting  as well; (c) by disabling interest-based ads from providers who are part of the self-regulatory campaign "About Ads" by using the link http://www.aboutads.info/choices. This setting is deleted when you clear your cookies. (d) by permanently disabling them in your Firefox, Internet Explorer or Google Chrome browsers using the link http://www.google.com/settings/ads/plugin. We should point out that in this case, you may not be able to use all the features of this offer in full.

The legal basis for the processing of your data is Art. 1, clause 1 lit. f of the GDPR. Further information about DoubleClick by Google can be found at https://www.doubleclickbygoogle.com/ and http://support.google.com/adsense/answer/2839090, as well as Google's general data protection policy: https://policies.google.com/privacy?hl=en. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. 
 
c) Google AdWords Conversion Tracking

This website also uses Google AdWords conversion tracking, a web analysis service by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“)., for improving the website and the advertising activities.  The legal basis for this is Art. 6 para. 1 clause 1 lit. f of the GDPR.

The cookie for conversion tracking is set when a user clicks on an ad controlled by Google. These cookies become invalid after 30 days and are not used for personal identification. If you visit certain pages of our website within these 30 days, both we and Google in the USA can recognize that you clicked on the ad and were routed to this site. Every Google AdWords customer gets a different cookie. As a result, cookies cannot be tracked via the websites of AdWords customers. The information obtained by conversion cookies is used to generate conversion statistics for us. We learn the total number of users who clicked on our ad and were routed to our site. However, we do not receive any information by which you can be personally identified. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

If you do not want to participate in the tracking, you can simply disable the Google conversion tracking cookie in your web browser's user settings. In that case you are not included in the conversion tracking statistics. Additional setting options can be found on the web page about disabling Google ads at http://www.google.com/policies/technologies/ads/.

The information under section 5. a) with respect to Google as a third-party provider shall apply mutatis mutandis.
 
d) Google AdWords Remarketing
 
In addition to Adwords Conversion Tracking, we also use Google Remarketing from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google"). This is a process we use when we would like to approach you again. After visiting our website, this application allows you to see our ads as you continue to use the internet. This is done by means of cookies stored in your browser that allow Google to record and evaluate information about your usage behavior when visiting various websites. This is how Google can determine any previous visits to our website. Google claims that they do not merge any of the data collected during the remarketing process with any personal data that may be stored by them. In particular, Google states that they use pseudonyms as part of the remarketing process.

The legal basis for the use of Google AdWords Remarketing is Art. 6 para. 1, clause 1 lit. f of the GDPR. The underlying purpose of advertising is considered a legitimate interest within the meaning of the GDPR.
 
The information under section 5 a) with respect to Google as a third-party provider shall apply mutatis mutandis.

e) Google Tag Manager
 
BERNINA uses Google Tag Manager, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Using this service, website tags (tags are small code elements on the website that among other things, are used to measure traffic and visitor behaviors) can be managed via one interface. Google Tag Manager itself (which implements the individual tags) is a cookieless domain. Personal data is not collected through Google Tag Manager. Its sole purpose is to trigger other tags, which in turn may capture data. Google Tag Manager does not, however, have access to this data. If disabled at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager.
 
The information under section 5. a) with respect to Google as a third-party provider shall apply mutatis mutandis.
 
f) Use of A/B testing by Visual Website Optimizer

The BERNINA website uses the Visual Website Optimizer web analysis service by Wingify Software Private Limited, 14th Floor, KLJ Tower North, Netaji Subhash Place, Pitam Pura, Delhi 110034, India („Wingify“), which is used for A/B and multi-version tests. This service uses cookies to identify a user's browser and to analyseyse the use of this website. The cookies placed by Visual Website Optimizer do not collect personal data. Wingify uses this information on our behalf to evaluate the use of the website by the user, to compile reports about website activities and to provide us with further services related to website activity. 
 
More information about how Visual Website Optimizer processes your data can be found at https://vwo.com/privacy-policy/. You can disable Visual Website Optimizer tracking at any time by following the instructions at https://vwo.com/opt-out/.
 
g) IgnitionOne

BERNINA uses the Digital Marketing Suite (DMS), a service for web analysis by IgnitionOne Deutschland GmbH, Leonrodstr. 52, 80636 Munich, Germany (“IgnitionOne”). The DMS helps BERNINA to analyze user behavior while on bernina.com in order to improve and optimize the website and the provided content continuously. The DMS is also used for direct marketing purposes if you have given consent for the promotional use of your data.
 
Using a tag that runs in the background of bernina.com, IgnitionOne collects information about user behaviors, such as product interests on the website. Once a page is opened, the following data will be transmitted to IgnitionOne: The complete URLs you loaded to enter the page, the page you visited before you entered the currently opened page, the time you stayed on our pages, browser type, operating system and device type, cookie settings and the time you entered the page. This data is used to create an anonymous profile. Furthermore, we assign a user ID to you which is stored in a cookie on your browser, provided you accept cookies and you haven’t withheld your consent for analyzing your behavior (appeal procedures are described below). With every click on a button or link an anonymous profile is updated based on the currently visited page and the page visited before. The profile information will be stored in the BERNINA user database on IgnitionOne servers within the European Union. The collected data will be transferred in part to the BERNINA server where it will be stored and with your consent, will be linked to the other data that BERNINA has stored about you. Depending on the usage of the website, specific forms and offers may be displayed.
 
Should you fill out a usage-based pop-up contact form on our website and give your consent to be contacted by a dealer, as well consent for the commercial use of your data, we will combine the data entered in the contact form (name, address, phone number, email address, product interest) with the previously anonymized data collected via the IgnitionOne tag, link it to a user-related profile and process this information for direct marketing purposes. With repeated searches of the website, the data is updated accordingly. With regards to the aforementioned purpose, this data will be forwarded to IgnitionOne Deutschland GmbH and processed. In addition, the information you provided in the usage-based pop-up contact form will be sent, with your consent, to a dealer in your area.

You can deactivate cookies at any time. However, this might lead to the website not being able to be used without restrictions.  Alternatively, you can perform an opt-out at https://www.ignitionone.com/cookie-opt-out/. Once you’ve done this, IgnitionOne will delete all existing cookies and attempt to set a new one (no-track-cookie) in order to make sure that your deactivation of cookies is valid for future visits to the website. Furthermore, all data that has already been collected by the IgnitionOne data collection tag will be deleted. The no-track-cookie tells the IgnitionOne server that no further user analysis shall be created in the future. If your browser is configured in a way that cookies are not accepted in general, a no-track-cookie cannot be set. Furthermore, if you delete cookies or if you use a different browser or computer, you have to perform the opt-out procedure again.
 
The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR, insofar and to the extent that consent is given, in general Art. 6 Abs. 1, clause 1 lit. f of the GDPR.
 
The data collected using the DMS provided by IgnitionOne will be automatically deleted after 6 months unless you have consented to a longer period of storage of your data and no statutory permission warrants the further storage.

h) Salesforce.com, Inc.
 
BERNINA uses Salesforce Marketing Cloud of Salesforce.com, Inc., Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA. Salesforce Marketing Cloud uses cookies to analyze user behavior on our websites. By using Salesforce Marketing Cloud, we want to analyze which of our websites are visited by users and what products users are interested in, in order to be able to present our users tailored, needs-based content, as well as for direct marketing purposes. The data from the analysis of user behavior is recorded anonymously or, if possible, in user profiles. User behavior may be evaluated using an algorithm or manually.
 
For the evaluation of the user behavior, the information about the use of the web page is linked to an individually generated customer ID and possibly to other data, e.g. with information that we generate about the use of our newsletter (for more information, see Section 2 d) of this privacy policy below), with information about actions taken by the user on our website, with the data listed under Section 2 a), and with other data that may already be stored in a customer profile about the respective user. User behavior is recorded in a user profile and evaluated if consent to the receipt of newsletters has been provided. If such consent has not been provided, the cookie only records anonymous data of the user.

The use of Salesforce.com, Inc. services may result in Salesforce.com, Inc. having access to your personal data. Salesforce.com, Inc. processes your data exclusively on behalf of and in accordance with the instructions of BERNINA. Further information on Salesforce Marketing Cloud can be found at https://www.salesforce.com/uk/products/marketing-cloud/overview/. The collected data is stored on Salesforce.com, Inc. servers. 

You can disable cookies at any time, but this may mean that you no longer have full use of the website. Alternatively, you can use the opt-out process, in which Salesforce.com, Inc. deletes all existing Salesforce.com cookies and attempts to set a new cookie (no-track cookie) so that the opt-out remains in place when the website is accessed in the future. The no-track cookie informs the Salesforce.com server that no more user analytics should be created for you in the future. A no-track cookie cannot be set if your browser is set up in such a way that cookies are not accepted in general. Also, if you delete your cookies, or use another computer or web browser, you will need to perform the opt-out process again.

The legal basis for this is Art. 6 para. 1 clause 1 a) of the GDPR, insofar and to the extent that consent is given, otherwise Art. 6 para. 1, clause 1 f) of the GDPR.

6. Use of Social Media Links and Plug-ins

a) Social Media Links

On our website, we use links to our social media profiles on Facebook, Instagram, Twitter, Google+, Flickr as well as YouTube in order to raise the awareness of the profiles of BERNINA.
 
These services are only included as links to the relevant social networks. No data can be transferred to the providers of the social networks if you do not click on the respective links. After clicking on the embedded links, you will be redirected to the page of the respective provider. Only then will user information be transmitted to the respective provider.
 
Addresses of respective providers and the URLs for their data privacy notices:
 
a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information about data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. 

b) Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA, further information on data collection: https://help.instagram.com/155833707900388.

c) Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. 

d) Google LLC., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://policies.google.com/technologies/partner-sites?hl=en. 

e) Flickr: Oath, Inc., Oath, Inc. 770 Broadway Fl 4 New York, NY 10003-9558, USA, further information on data collection: https://policies.oath.com/ie/en/oath/privacy/products/flickr/index.html.

f) YouTube LLC., 901 Cherry Ave., San Bruno, CA 94066, USA; https://policies.google.com/privacy?hl=en. Google, the parent company of YouTube, LLC, also processes your personal data in the USA.
 
b) Social Media Plug-ins
 
On the basis of Art. 6 para. 1, clause 1 lit. f of the GDPR, we use a social media plug-in from the Pinterest social network on the article pages on our blog to raise the awareness of BERNINA and to allow our users to share content with friends and acquaintances. The underlying purpose of advertising is considered a legitimate interest within the meaning of the GDPR.
 
If you access a page that contains a social media plug-in from Pinterest, no personal data will be initially passed on to Pinterest. Only when you click on the social button of the Pinterest plug-in provider will you establish a connection to the Pinterest server. By creating a connection to the Pinterest server, log data will be transferred to Pinterest. This log data may include your IP address, the address of sites you have visited that also contain Pinterest features, the type of browser and its settings, the date and time of the request, how you use Pinterest and cookies. Personal data may therefore be transmitted to Pinterest and stored (possibly in the USA).
 
We have no control over the data collected and the data processing operations, nor are we aware of the full scope of the data collected by Pinterest, the purposes of the processing, and the retention periods. We also have no information with respect to deleting the data collected by Pinterest. Responsibility for operations that comply with data protection is to be guaranteed by Pinterest.
 
Pinterest stores the data collected about you as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged-in) for the presentation of demand-oriented advertising and to inform other Pinterest users about your activities on our website. You have the right to object to the creation of this user profile and you must contact Pinterest to exercise this.
 
The data transfer takes place irrespective of whether you have an account with Pinterest and are logged in. If you are logged in to Pinterest, your data that is collected from us will be associated directly with your Pinterest account. If you press the button and, for example, link to the page, Pinterest also saves this information in your user account and communicates this to your contacts publicly.
 
For more information on the purpose and scope of the data collection and its processing by Pinterest, please read the privacy policy of Pinterest which is linked below. You will also find further information about your rights and settings options pertaining to the protection of your privacy:
 
Pinterest Europe Ltd. Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland, https://policy.pinterest.com/en/privacy-policy.

7. Integration of YouTube Videos

We have integrated YouTube videos from YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA ("YouTube"), in our online offer, which are stored on http://www.youtube.com and can be played directly from our website. The YouTube videos are integrated for the purpose of ensuring a comfortable user experience of the website. The legal basis for this is Art. 6 para. 1 clause 1 lit. f of the GDPR.

By visiting the website, YouTube receives the information that you have accessed the corresponding sub-page of our website. In addition, log data in accordance with section 2. a) of this policy is transferred. This happens regardless of whether YouTube provides a user account that you are logged in to, or if there is no user account. If you are logged in to Google, your data will be associated directly to your account. If you do not want this to be associated with your profile on YouTube, you must log out before visiting our website. YouTube stores your data as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged in) for the delivery of demand-oriented advertising and to inform users of other social networks about your activities on our website. You have the right to object to the creation of this user profile and you must contact YouTube to exercise this.
 
More information on the purpose and scope of the data collection and its processing by YouTube can be found in the YouTube data protection policy. You will also find further information about your rights and settings options pertaining to the protection of your privacy: https://policies.google.com/privacy?hl=en. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

8. Google Maps

On this website we use a service from Google Maps by Google LLC., 1600 Amphitheater Parkway, Mountainview, California 94043, USA ("Google"). This allows us to show you interactive maps directly on the website and allows you to conveniently use the map feature. The legal basis for this is Art. 6 para. 1 clause 1 lit. f of the GDPR.

By visiting the website, Google receives the information that you have accessed the corresponding sub-page of our website. In addition, the data specified under Section 2. a) of this declaration is transmitted to Google. This happens regardless of whether Google provides a user account that you are logged in to, or if there is no user account. If you are logged in to Google, your data will be associated directly to your account. If you do not want this to be associated with your Google profile, you must log out before visiting our website. Google stores your data as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged in) for the delivery of demand-oriented advertising. You have the right to object to the creation of this user profile and you must contact Google to exercise this.
More information on the purpose and scope of the data collection and its processing by Google can be found in the Google data protection policy. You will also find further information about your rights and settings options pertaining to the protection of your privacy: https://policies.google.com/privacy?hl=en. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

To best protect your data, we have signed a contract processing agreement with Google.
 
More information on the purpose and scope of the data collection and its processing by Google can be found in the Google data protection policy. You will also find further information about your rights and settings options pertaining to the protection of your privacy: https://policies.google.com/privacy?hl=en. Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

9. Data security

When you visit the website, we use the widely used TLS (Transport Layer Security) protocol in conjunction with the highest encryption level supported by your browser. We also take 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. Our security measures are continuously improved in line with technological developments. However, BERNINA cannot guarantee the security of the data transmitted by you as a user. Any transmission of data is undertaken at your own risk.

10. Your Rights

You have the right:

• in accordance with Art. 15 of the GDPR, to request information about your personal data processed by us. In particular, you can request information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned storage period, the right to modifications, deletion, limitation of processing or contradiction, the existence of the right to appeal, the origin of the data insofar as it was not collected from us, and the existence of automated decision-making, including profiling and, where appropriate, descriptive information about the details thereof
• in accordance with Art. 16 of the GDPR to immediately request the correction of inaccurate or the completion of personal data stored by us
• in accordance with Art. 17 of the GDPR to request the deletion of your personal data stored by us, insofar as the processing is not required for the exercise of the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal rights
• in accordance with Art. 18 of the GDPR to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you reject its deletion and we no longer need the data, yet you need this to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 of the GDPR
• in accordance with Art. 20 of the GDPR, to receive your personal data, which you have provided to us, in a structured, common and machine-readable format or to request its transmission to another responsible person
• in accordance with Art. 7 para. 3 of the GDPR, to revoke the consent granted to us at any time. The consequence is that we are no longer allowed to continue data processing, based on this consent, in the future.

To exercise the aforementioned rights, please send an email to info@bernina.com or send us a message to the contact details given in the Legal notice.

Right of objection:
If we process your personal data to protect legitimate interests within the meaning of Art. 6 (1) sentence 1 lit. f GDPR, then in accordance with Art. 21 para. 1 GDPR, you have the right to object to this processing for reasons that arise from your particular situation. You can object to the processing of your data for direct marketing purposes at any time and without reason, in accordance with Art. 21 (2) GDPR. In order to exercise your right to object, it is sufficient to send us an informal notification, e.g. via email to info@bernina.com.
 
Right of appeal:
If you believe that the processing of personal data concerning you violates the General Data Protection Regulation, then in accordance with Art. 77 of the GDPR you have the right to complain to a supervisory authority for data protection.

11. Currency of and amendments to this privacy policy

This privacy policy is currently valid and was last updated on August 21^st, 2020.
 
As a result of the further development of our website and offers, or due to amended statutory or regulatory requirements, it may be necessary to change this privacy policy. The respective current privacy policy can be consulted at any time on our website at https://www.bernina.com/privacy and can be printed out.