Privacy Policy
We are delighted about your visit to our website and your interest in our company. We take the protection of your personal data seriously.
With this Privacy Policy we, the Reflections AG (hereinafter Reflections, we or us), describe how we collect and further process your personal data when you use our website, obtain services from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. These Privacy Notice is aligned with the Swiss Data Protection Act («DPA») and the EU General Data Protection Regulation («GDPR»). However, the application of these laws depends on each individual case.
This Privacy Policy is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements or General Terms and Conditions, Conditions of Participation or similar documents are applicable to specific circumstances.
1. Controller
The controller responsible for data processing as described in this Privacy Policy is:
Reflections AG
c/o Corisol Holding AG
Gotthardstrasse 28
6300 Zug
c/o Corisol Holding AG
Gotthardstrasse 28
6300 Zug
Telephone: +41 41 760 30 26
info@reflections.site
info@reflections.site
2. What data do we process?
We collect and process the following categories of data about you:
- Technical data (such as IP address, browser type, access times, pages visited)
- Communication data (such as name, email address, phone number, postal address)
- Financial data
- Contract data
Much of the data is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). When using our website, the processing of technical data cannot be avoided. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.
If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.
3. Purpose of Data Processing and Legal Basis
We process personal data for the following purposes:
- to provide and improve our website, platforms and services
We analyse, for example, how you navigate through our website or which articles are used by which groups of people in which way and how new articles and services can be designed. For this purpose we process behavioural data and preference data, communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the Internet and other public sources.
- to communicate with you by e-mail and telephone, as well as through messenger services, chats, social media and by letter and to respond to inquiries
Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an access request. The processing also serves to document the communication and its content, for quality assurance and for follow-up inquiries. For this purpose, we use communication data, contract data and registration data in relation to offers and services that you use.
- to fulfil contractual obligations (for the conclusion, administration and performance of contractual relationships)
We conclude various contracts with our customers, suppliers, subcontractors and other parties, such as partners in projects or parties in legal proceedings. As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, advertising service providers, banks, insurance companies or credit information providers, who may in turn provide data to us), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the performance, as are accounting, termination of contracts and public communication. For this purposes we process contract data, communication data, financial data and registration data relating to the customer or the persons for whose benefit the customer has received a service.
- Internal processes and administration and communication with third parties and processing of their request
We process data to ensure our operation including our IT, websites and other appliances, financial management, data archiving. For this purpose, we use communication data, contract data, technical data, financial data and registration data in relation to offers and services that you use.
- Advertisement and marketing (including organizing events and newsletter)
We process data to send our customers and other contractual partners personalized advertising from us (in form of newsletters, electronically, by telephone and through other channels, events). You can object to such contacts at any time or refuse or withdraw consent to be contacted for marketing purposes. For this purpose, we process in particular communication, technical data, contract data and registration data. The relationship management includes addressing existing customers and their contacts, possibly personalized on the basis of behavioral and preference data.
- to comply with legal requirements
This includes for example the disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. For these purposes, we process contract data, communication data and behavioral and preference data.
We primarily process personal data that in the context of our business relationships or that we collect from users when operating our websites and other applications. The legal ground of the processing is initiating or performing a contract with you (Art. 6 Abs. 1 lit b GDPR) or our or a third-party legitimate interest in the particular processing, in particular in pursuing the above mentioned purposes and objectives and in implementing related measures (Art. 6 Abs. 1 lit f GDPR). Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law.If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters), we will process your personal data within the scope of and based on this consent (Art. 6 Abs. 1 lit. a GDPR), unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.
4. Data Sharing and Transfer abroad
We may share your personal data with the following categories of recipients:
- service providers and other business partners
- public, including visitors to websites and social media
- other parties in potential or actual legal proceedings
- domestic and foreign authorities, official bodies or courts.
These are not all located in Switzerland. Your data may therefore be in any country in the world. If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj , unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
5. Retention Periods for your Personal Data
After termination of our business relationship, your personal data will be stored for as long as we are contractually or legally obliged to do so or as long as it is necessary for the purposes pursued with the processing (see section 3 above).
6. Cookies / Tracking and Other Techniques Regarding the Use of our Website
We use cookies and similar tracking technologies on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits.
A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website. If you revisit our website, we may recognize you, even if we do not know your identity. We distinguish the following categories of «cookies» (including other technologies):
- Necessary cookies:
Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to [X] months. - Performance cookies:
In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyse the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Performance cookies also have an expiration date of up to [X] months. Details can be found on the websites of the third-party providers. - Marketing Cookies:
We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiration period of a few days to [X] months, depending on the circumstances. If you consent to the use of these cookies, you will be shown related advertisements. If you do not consent to them, you will not see less advertisements, but simply any other advertisement.
If you do not wish to use cookies, please set the cookie handling in the security settings of your browser accordingly. You will find the setting option in the most common browsers in the “Tools” menu under “Settings” or “Internet options” and the “Privacy” tab. Please note, however, that some websites may not function properly if you do not accept cookies.
We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):
- Analytics and cookies:
Regarding the Use of our Website We use Fathom Analytics, a privacy-focused analytics service that does not use cookies and does not collect any personal data. This allows us to understand website usage patterns while fully respecting your privacy and complying with data protection regulations.We use a single cookie named “reflections-cookie-consent” which stores your consent preferences for embedded content. This cookie has a retention period of 365 days and is necessary for managing your preferences regarding third-party content embeds.
7. Social Plug-Ins
We use plug-ins from social networks such as Facebook, Instagram, TikTok, Youtube, and LinkedIn on our website. This is visible for you (typically based on the respective symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our website and where on our website you are exactly and may use this information for their own purposes. This processing of your personal data lays in the responsibility of the respective operator and occurs according to its data protection regulations. We do not receive any information about you from the respective operator.
If you do not want these providers to collect data about you, you can select the “Block third-party cookies” function in your browser settings. The browser will then not send any corresponding information to the provider's server for embedded content from other providers. With this setting, however, other content on our website may no longer work in certain cases.
Our website includes embedded content from third-party platforms such as TikTok, Vimeo, Facebook, YouTube and Instagram. These embeds are deactivated by default to protect your privacy. They will only be activated after you provide explicit consent through our consent management system. Your consent choice is stored in the “reflections-cookie-consent” cookie for 365 days.When you activate these embeds by giving consent, the respective platform operators (TikTok, Vimeo, YouTube, Instagram) may collect information about your interaction with the embedded content. This processing of your personal data occurs under the responsibility of these operators according to their respective privacy policies. We do not receive any personal information about you from these operators.If you wish to prevent these providers from collecting data about you, you can:
- Leave the embeds deactivated
- Select the “Block third-party cookies” function in your browser settings
- Withdraw your consent at any time, which will deactivate all embeds
Please note that blocking third-party cookies may affect the functionality of other website features in certain cases.
8. Your Rights
You have the following rights regarding your personal data:
- the right to request information from us as to whether and what data we process from you
- the right to correct inaccurate or incomplete data
- the right to request deletion of your data, subject to legal obligations
- the right to restrict processing under certain conditions
- the right to data portability
- the right to withdraw consent at any time
- the right to lodge a complaint with a supervisory authority.
Please contact us in writing (see section 1) if you wish to exercise these right in relation to us. It may be necessary for you to prove your identity to us in a suitable form in order to prevent unauthorized third parties from being given information about your data and/or unauthorized changes and/or unauthorized deletions being made.
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
9. Updates to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website.
Last updated at 22.01.2025