Privacy Policy

NINECUBES Lernmedien GmbH, Bahnhofstrasse 10, 9100 Herisau, Switzerland (hereinafter NINECUBES) is the author of this Privacy Policy and responsible for data processing at NINECUBES and the systems used by NINECUBES.

Data Protection Officer at NINECUBES:
Alexander.Stork@ninecubes.ch

 

(1) General information
(1.1) Transparency
For the sake of transparency and clarity, this Privacy Policy avoids the use of legal jargon and cryptic clauses. If you have any questions, the Data Protection Officer will be happy to assist you.

(1.2) Data economy
In the interests of data economy, NINECUBES has processed only a minimum amount of data since the company’s founding. It only collects and processes data that is absolutely necessary for managing the respective business relationship and providing corresponding services.

(1.3) Definition: «Technical data»
When using the online systems operated by NINECUBES – i.e. when visiting the NINECUBES websites or when using the Interpersonal Skills LAB servers – technical data is inevitably exchanged and temporarily stored between these online systems and your computer. This technical data consists of the IP address of your computer, your browser (type, version, language), operating system used, your internet service provider, the date and the time of access.

(1.4) Privacy
According to the European General Data Protection Regulation (GDPR), the IP address of your computer is to be treated as personal data. An intermediate storage of this IP address on the online systems operated by NINECUBES cannot be prevented from a technical standpoint. NINECUBES respects your privacy. For this reason, the websites operated do not provide access to the temporarily stored technical data or to analysis tools that could be used to identify visitors. NINECUBES can only view the application log files on the Interpersonal Skills LAB servers for quality assurance purposes. These log files do not contain any personal data.

 

(2) Systems storing personal data
NINECUBES processes and stores personal data using the following systems:

(2.1) Websites operated by NINECUBES (server location: Germany)
Personal data stored:
(a) Technical data (see above)

NINECUBES reserves the right to store cookies on your web browser. Cookies are basically harmless small files in which a web browser stores data or settings (such as the language settings) for a website. The websites operated by NINECUBES only store cookies of the category «absolutely necessary». These cookies are necessary for the proper functioning of the website and they do not store any personal data.

The websites contain embedded videos. When you access websites with such videos, your data (IP address, date and time of the visit, etc.) is also transferred to the following third-party provider, which displays and plays the videos. In addition, your web browser may be prompted to store cookies from this third party. For the processing of your data and the handling of cookies, the data protection regulations of the third-party provider apply:
Wistia (Wistia Inc.), 17 Tudor Street, Cambridge, MA 02139, USA
(For Wistia’s privacy policy, please see: https://wistia.com/privacy)

The websites contain links to external third-party websites or to social media articles (e.g. licensed training providers, news, events, etc.). Clicking on such links opens a new browser window that displays the content of these external websites. The resulting transmission of your data (IP address, date and time of the visit, etc.) to these external websites is subject exclusively to their data protection guidelines.

(2.2) Interpersonal Skills LAB servers (online server location: Germany)
Personal data stored:
(a) Technical data (see above)
(b) E-mail address

The Interpersonal Skills LAB servers allow your browser to store cookies. No personal data is stored.

(2.3) Mailing list/newsletter (server location: Switzerland)
Personal data stored:
(a) Name
(b) E-mail address

NINECUBES maintains mailing lists for groups such as interested parties with the newsletter, technical contact to Interpersonal Skills LAB, etc. Recipients of the newsletters/e-mails can be removed from the list at any time without the need to provide a reason.

(2.4) Email server and archive (server location: Switzerland)
Personal data stored:
(a) Technical data (see above; including IP addresses of all sending and intermediate mail servers)
(b) E-mail address
(c) Everything entered in the e-mail text

NINECUBES operates an automatic audit-proof e-mail archiving system, which archives all incoming and outgoing e-mails immediately and in a non-manipulable manner.

(2.5) Telephony systems (storage location: Switzerland)
Personal data stored:
(a) Telephone number and date/time of in/outgoing calls

(2.6) Customer/CRM database (location: Switzerland)
Personal data stored:
(a) Name
(b) Company name
(c) Address (street, number, city, postal code, country)
(d) Telephone number
(e) E-mail address

 

(3) The rights and obligations of NINECUBES
(3.1) Right to processing and storage
When you contact NINECUBES or its systems, you automatically grant NINECUBES the right to process the data you provide and to store the data necessary for the purpose of the contact and any resulting business relationship.

(3.2) Intended use of data
NINECUBES undertakes to use the data received from you only for the purpose intended by you.

(3.3) Disclosure of your data
To the extent necessary for NINECUBES to prepare offers or provide services, NINECUBES may share your information with external partners (e.g., licensees of Interpersonal Skills LAB), even if they are located abroad, unless you object in advance.

 

(4) Your rights and obligations
(4.1) Right of access, rectification and deletion
In connection with the processing of your personal data, you have the following rights – provided that this does not contradict the rights of third parties or any archiving obligations and procedures:
(a) You may request information about your personal data stored by NINECUBES at any time and free of charge
(b) You may have incorrect or incomplete data corrected and/or supplemented
(c) You have the right to request the deletion of your personal data if this data is no longer required for the purposes pursued, if you revoke your consent or if the personal data is processed unlawfully.

(4.2) Data economy, e-mail and audit-proof archives
The deletion of data from audit-proof archives (e.g. e-mail archives) is not technically possible, or, more precisely, is only possible with a disproportionately large effort so that NINECUEBS can only provide such efforts against payment at the regular hourly rate.

In general, NINECUBES does not provide extracts from the e-mail archives – for example in connection with information about the storage of personal data – in order to prevent a violation of the law through the disclosure of third-party personal data. If you wish to view your e-mail correspondence with NINECUBES, please use your e-mail archives.

Consequently, NINECUBES expects you to comply with the principle of data economy when transmitting data to NINECUBES or its systems and to transmit only the data that is necessary for the intended purpose. This also applies in particular to the sending or forwarding of e-mails, as personal data is often found in e-mail footers or forwarded e-mail texts.

(4.3) Right of appeal
If you believe that your rights are being violated in regard to data processing, you should attempt to reach an agreement with NINECUBES. If you continue to believe that your rights have been or are being violated, you can complain to the appropriate regulatory authority. In Switzerland, please contact the Federal Data Protection and Information Commissioner (FDPIC).

 

(5) Data security
(5.1) Organizational measures
Access to your personal data is only provided to persons if and insofar as this is necessary for the performance of the respective activity. All persons – employees and external partners of NINECUBES – are subject to the obligation to process personal data confidentially and exclusively in accordance with the applicable data protection regulations.

(5.2) Technical measures
In close cooperation with our suppliers, we strive to protect our systems and databases as best as possible against unauthorized access, data loss, misuse or falsification.

(5.3) Legal, political and technical situation
We live in times in which communication protocols considered secure (e.g. the https protocol) can be compromised by hackers, in which states and their organizations can intercept communication channels, gain access to servers, or force the operators of data centers to release data by invoking applicable law. Despite careful selection of the operators and locations of its online systems, NINECUBES cannot exclude the possibility that data may fall into the hands of unauthorized third parties (e.g. hackers, government organizations, etc.) for the aforementioned reasons. By using the online systems operated by NINECUBES, you accept the fact that NINECUBES does not have the financial means to guarantee absolute protection of the data on the online systems.

(5.4) Risk and prevention
The online systems operated by NINECUBES do not require you to enter or store personal data. If you want to avoid any risk of disclosure of personal data stored on online systems operated by NINECUBES, you can:
(a) Apply the principle of data economy and refrain from entering and storing personal data in the online systems
(b) Use a unique password that you do not otherwise use on any other account
(c) Disguise your IP address (relevant tips can be found on the internet under the keywords «Tor Browser», «Surfing via VPN server», «Surfing via mobile hotspot»).

 

(6) Changes
This Privacy Policy may be revised from time to time at the sole discretion of NINECUBES and without prior notice.

 

Valid from: November 15, 2019