1. Introduction

Respect for your privacy is important to us. The State Secretariat for Economic Affairs (referred to below as “SECO”, “it”, “we” or “us”) as the operator of the central electronic platform for facilitating the provision of government services to businesses (referred to below as “EasyGov”) treats the data that you provide carefully and responsibly and in compliance with the relevant provisions of data protection law. This Privacy Policy contains information on how SECO, as the operator of EasyGov, handles personal data.

2. Scope

This Privacy Policy applies to EasyGov, which is accessible via the website www.easygov.swiss. If services from other authorities (referred to below as “partner authorities”) are accessed via EasyGov, their privacy policies apply.

3. What are “personal data” and what is meant by “processing”?

The Federal Act of 25 September 2020 on Data Protection (Data Protection Act, FADP; SR 235.1) regulates the processing of personal data. “Personal data” means any information that can be associated with a specific natural person. This may include the following information:

• Contact information, such as: first name(s), surname, postal address, email address or telephone number;
• Personal details, such as: gender, date of birth and age, marital status or nationality.

“Processing” means any handling of your personal data. This includes, for example, the following actions:

• Collection and storage;
• Adaptation and modification;
• Use and exploitation;
• Matching with other data;
• Deletion and destruction.

4. Who is responsible for processing your personal data?

The following are responsible for processing your personal data:

4.1 SECO as the operator of EasyGov

State Secretariat for Economic Affairs SECO
Promotion Activities Directorate
SME Policy Department
Holzikofenweg 36
CH-3003 Bern
admin@easygov.swiss

4.2 The partner authorities as providers of public services

If you as a user record personal data on EasyGov and this data is disclosed to a partner authority for the purpose of using a public service, both SECO and the partner authority offering the relevant public service are the data controller in terms of the data protection legislation. With regard to data processing by our partner authorities, you should consult the privacy policy of the partner authorities concerned. This privacy policy will also indicate who is responsible for deciding the purpose and means of data processing.

5. Data protection officer

If you have any concerns regarding data protection (section 12), please feel free to contact our data protection officer:

Mr
Adrian Indermühle
State Secretariat for Economic Affairs SECO
Holzikofenweg 36
CH-3003 Bern
adrian.indermuehle@seco.admin

6. Purpose of the data processing

EasyGov supports users in making submissions to partner authorities. It enables users to:

• collect and manage data for later use in submissions to partner authorities;
• import data from official registers (e.g: commercial register, UID[1] register), provided that the law governing the registers does not prevent this; and
• transmit documents to or receive documents from a partner authority.

For this to be possible, it must also be possible for certain personal data to be processed by SECO as the operator of EasyGov. Personal data are collected by users and stored on EasyGov.

We process different types of personal data depending on the occasion and purpose. You will find a summary of the personal data processed and the related purposes in Section 7.

7. What personal data do we process?

7.1 Access, use and consultation

When EasyGov is accessed, used and consulted, SECO processes the following personal data:

• information on the use of EasyGov, including your user name, password and any details you provide to SECO;
• technical data, in particular the IP (Internet Protocol) address used to connect your digital device (e.g. computer, tablet, mobile phone, etc.) to the Internet, the type of mobile device used, a unique device ID (e.g. the IMEI number of the mobile phone, the MAC address of the wireless network interface or the mobile phone number used by the device); and
• your location information.

These personal data are collected primarily by means of cookies and similar technologies (see Section 13). You can deactivate these cookies at any time via your browser.

Data processing is, for example, intended to enable you to navigate more efficiently between pages using the data collected on your usage preferences and to optimise your experience as a user of EasyGov.

In addition, analysis tools (see Section 13) are used to better understand your usage habits and to evaluate them statistically. No personal data are collected or passed on in the process. The IP addresses are anonymised.

7.2 Information on platform updates

The range of public services on EasyGov is constantly being expanded. When EasyGov undergoes major updates, all registered users are informed by email. These EasyGov platform updates are usually carried out two to three times a year and in response to specific occurrences. This service cannot be cancelled.

7.3 Subscribe to the SME newsletter via EasyGov

The SME Newsletter is a service of SECO’s SME portal (www.kmu.admin.ch). If you subscribe to the SME newsletter via EasyGov, you will be asked to provide SECO with the following data:

• your first name and surname;
• your email address; and
• your preferred language.

If you wish, you can provide SECO with additional data. SECO uses these data to send you information that is as personalised as possible, relevant to you and in line with your interests.

By subscribing to the SME newsletter, you give SECO permission to process the data collected for the regular dispatch of the SME newsletter.

At the end of each SME newsletter, you will find a link that allows you to unsubscribe at any time. If you unsubscribe from the newsletter, your data in connection with sending the newsletter will be deleted immediately.

At this point it should be noted that the Privacy Policy of the SME Portal applies when subscribing to the SME newsletter.

7.4 Registration and use

When you register on EasyGov, you accept that SECO, as the operator of EasyGov, may process the following data:

• your first name(s) and surname, your postal and email address and your telephone number;
• the information used to identify you on EasyGov, including your user name (email address), your password and any details you provide to SECO;
• technical data, in particular the IP (Internet Protocol) address used to connect your digital device to the Internet, the type of mobile device used, a unique device ID (e.g. the IMEI number of the phone, the MAC address of the wireless network interface or the mobile phone number used by the device); and
• your location information.

When using EasyGov, additional data must also be collected in certain cases (e.g. when establishing a business or when additional partners or shareholders are added). In this context, you may have to disclose data relating to third parties. If this is the case, you must guarantee to SECO that you are authorised to do so and that the data subject has consented in advance to the disclosure of the data. Furthermore, you must undertake to provide SECO only with correct and up-to-date data.

These personal data are collected so that you can access EasyGov and use the services provided by the partner authorities. When you request a public service, you consent to your personal data being forwarded to the relevant EasyGov partner authorities for which SECO acts as a supplier.

Your identification on EasyGov takes place via the eIAM (eGovernment Identity and Access Management) services of the Federal Office of Information Technology, Systems and Telecommunication (FOITT). When registering, you agree to use the eIAM services in order to use the application. When you connect to EasyGov, your data will be processed by eIAM, subject to the relevant eIAM terms of use. The eIAM Terms of Use apply.

7.5 Payment function

As an EasyGov user, for certain public service processes you have the option of using a payment module (Payrexx AG, Burgstrasse 20, CH-3600 Thun) to pay the fees via EasyGov for a public service. The money is then transferred directly to the relevant partner authority.

The following personal data will be processed with your consent:

• your first name(s) and surname;
• your email address;
• details of your business, including the UID;
• your postal address;
• your means of payment;
• your payment details (e.g. credit card number); and
• the public service you have obtained through EasyGov.

In all other respects the privacy policy of Payrexx AG applies.

8. What happens if you do not want to disclose your personal data to us?

If you do not wish to disclose your personal data to us, you will only be able to use EasyGov to a limited extent or may not be able to use it at all, and you will no longer be able to receive the SME Newsletter.

9. References and links

References and links to third-party websites are outside SECO’s sphere of responsibility. You access and use such websites at your own risk. As the operator of EasyGov, SECO has no influence whatsoever over the design, content and offers of the linked sites. Accordingly, it cannot guarantee that the information contained on such sites is accurate or free of malware (such as viruses). Information and services provided by linked websites or web services are entirely the responsibility of the respective third party. SECO excludes any responsibility for such websites.

10. Social media networks

If you authorise a third-party social media network (such as Facebook, LinkedIn, etc.) to share personal data with SECO as the operator of EasyGov, SECO will have access to any personal data you publish on that social media network that are part of your profile or that you allow the social media network to share (e.g. your name, email address, gender, profile picture, list of friends or contacts, preferences).

If you use a function of a social media network that is accessible via the website www.easygov.swiss or interact with SECO via a social media network, SECO will also receive personal data on your profile.

Personal data from social media networks are collected to personalise and optimise your experience as a user and to inform you of offers and news that may interest you. The processing of your personal data is based on your consent.

SECO has no influence over the collection of data and their further use by the operators of these social media networks. The extent to which the data are stored, where they are stored and for how long, the extent to which social media operators comply with any existing deletion obligations, what evaluations and links they make with the data and to whom they pass on the data is not apparent to SECO as the operator of EasyGov. The privacy policies of the social media networks concerned apply.

11. Duration of storage

Your data will only be kept until you delete them. EasyGov users can delete their UID entity[2] (e.g. company or foundation) with all its data at any time in the EasyGov Cockpit. Of course, you can also request us to delete your personal data. To do this, you must send us a request for deletion. For more information, please refer to Section 14.3.

Furthermore, SECO, as the operator of EasyGov, deletes your data at the latest one year after a UID entity has ceased its economic activity and two years after SECO has become aware of the death of an individual, unless a legal successor has given notice of his or her rights during these two years.

12. To whom does SECO forward your personal data?

12.1 To partner authorities

If you use a public service from a partner authority, SECO, as the operator of EasyGov, acts as its data supplier. With your consent, SECO may also disclose further personal data to partner authorities if this is necessary for the partner authorities to provide a specific service.

12.2 To SECO processors

Under data protection law, the processing of personal data may be entrusted by contract or by legislation to a processor, i.e. a private person or a federal body that processes personal data on behalf of the data controller.

Within the scope of the support services, personal data are processed by the following processors:

The processors may only process the personal data in the same way as SECO is permitted to do as the controller. Furthermore, SECO as the controller must ensure that the abovementioned processors take appropriate technical and organisational measures to guarantee adequate data security. SECO reviews implementation and compliance with these measures on an ongoing basis. Furthermore, the processors are subject to a duty of confidentiality.

In all other respects, the respective privacy policies of the abovementioned three processors apply.

Use of remote support software (ISL Online) as part of the 1^stlevel support by Callpoint AG employees:

In order to be able to help EasyGov users as quickly as possible in the event of problems, the1st level support staff of Callpoint AG have the option of using remote support software. This is an application that is used to establish a connection with the digital device of the EasyGov user. The1st level support staff of Callpoint AG can then operate the digital device of the person requesting support as if it were physically in front of them. The 1st level support staff are specially trained to use the remote support software.

The EasyGov user must in each case give his or her express verbal consent in advance to the use of the remote support software.

12.3 To third parties

If permitted or required by law, SECO as the operator of EasyGov may forward your personal data to third parties subject to the conditions provided for in the relevant legislation or with your consent. As described in Section 13, data may also be collected directly from third parties through the use of cookies and similar technologies.

13. Cookies and similar technologies

The EasyGov website uses cookies to make your visit more attractive and to permit the use of certain functions. Cookies are small text files that are stored on your digital device. Most of the cookies used (session cookies) are deleted from your hard disk at the end of the browser session. Other cookies remain on your digital device and enable us to recognise you on your next visit (permanent cookies) and thus facilitate the login process.

You can stop cookies from being stored on your browser by restricting or deactivating the storage and reading of cookies. Please note that you will not be able to use certain functions of the website without cookies.

13.1 SECO cookies

The types of cookies SECO uses on the EasyGov website and their purposes are:

Category 1: Strictly necessary cookies

These cookies are essential to enable you to navigate the EasyGov website and use its features. Without these cookies, several elements of the EasyGov website may be blocked and/or may not function properly. SECO uses these cookies to enable you to access the services offered on the EasyGov website.

Category 2: Performance cookies

These cookies collect information about how you use the www.easygov.swiss website (e.g. which pages you consult most often and whether you receive error messages from certain pages). SECO may use such cookies to improve the efficiency and usability of the EasyGov website and to understand how it is used. However, these cookies do not collect any personal data.

Category 3: Functional cookies

These cookies are used on the EasyGov website to store the information you have entered (e.g. your username, language or region). They may also be used to provide the public services that you have requested. SECO may use such cookies to improve the efficiency and usability of the EasyGov website and to provide you with an optimal navigation experience.

Category 4: Targeting and advertising cookies

These cookies are used to learn more about you as a user of the EasyGov website, to customise its content, to compile statistics on its use, and to display advertising tailored to you on third-party websites based on your expressed interest in our services. In certain cases, these cookies enable SECO to show you advertising that is tailored to you and your interests.

13.2 Third-party cookies

13.2.1 General notes

We use cookies from third parties so that they can collect the information required for their services; we do not transmit any personal data to these third-party providers. However, the third-party providers collect information about your use of the EasyGov website in order to provide their services. This primarily involves statistical evaluations of the use of the EasyGov website. Third-party providers may combine the information they collect from you with information from other websites you have visited that work with those third parties, and may use that information for their own purposes (e.g., to target advertising on these providers’ partner sites). If you have registered with the relevant provider, the provider can identify you. Such processing of your personal data is the sole responsibility of the provider in accordance with its privacy policy.

13.2.2 Cookies from Google Analytics, Google Tag Manager, Google Adwords Conversions and DoubleClick

The following cookies are used on the EasyGov website:

The creation and use of cookies by the third parties mentioned above is subject to the privacy policies of those third parties. SECO has no control over these cookies. Please refer to the respective privacy policies of these third-party providers for information on how their cookies work.

13.2.3 Cookies from CookieYes

We use the consent management tool “CookieYes” from the following company on the EasyGov website:

CookieYes Limited
3 Warren Yard Warren Park
Wolverton Mill
Milton Keynes
MK12 5NW, United Kingdom
support@cookieyes.com

With the help of CookieYes, you will be shown a ‘cookie banner’ when you first access the EasyGov website, in which you can manage your consent to the setting of cookies or the use of cookie categories. The settings you make are stored in separate cookies, whereby personal data is also transmitted to CookieYes. These are the following categories of data:

• anonymised IP address;
• date and time of consent;
• browser details;
• the URL of the website;
• an anonymous, random and encrypted key;
• the consent status, which serves as proof of your consent.

Cookie consents given using CookieYes are stored for 12 months. Further information can be found in the Privacy Policy – CookieYes.

14. Your rights

Under the current data protection law, you have the following rights in particular:

14.1 Right to information

You can request information from SECO at any time about whether data about you are being processed. If you wish to exercise your right to information, please proceed as described in Section 14.6.

Information is usually provided within 30 days of receipt of your request. If the information cannot be provided within 30 days, we will inform you of this and tell you when the information will be provided.

If your request for information concerns one of our partner authorities, please send the request directly to the relevant partner authority.

14.2 Right to correction

As a user, you have the right to request the correction of your stored data at any time. If you wish to exercise your right to correction, please proceed as described in Section 14.6.

If your correction request concerns one of our partner authorities, please send the request directly to the relevant partner authority.

14.3 Right to deletion

As an EasyGov user, you can delete your UID entity (e.g. your business or foundation) and all related data at any time in the EasyGov Cockpit. Of course, you can also contact us and request us to delete specific data or all of your data. As the operator of EasyGov, SECO will comply with this request for deletion unless there are legal grounds that prevent it from doing so. Should you wish to exercise your right to deletion, please proceed as described in section 14.6.

If your deletion request concerns one of our partner authorities, please send the request directly to the relevant partner authority.

14.4 Right to data portability

You can request the data controller to hand over the personal data that you have disclosed to it. The data must be provided in a common electronic format (e.g.: HTML, XLS, CSV, XML or JSON). Should you wish to exercise the right to have the data handed over, please proceed as described in Section 14.6.

Under Article 28 FADP, you also have the right to request the controller to transfer your personal data to another controller. Should you wish to exercise your right to transfer data, please proceed as described in Section 14.6.

Normally the data will be handed over or transferred within 30 days of receipt of your request. If this is not possible within 30 days, we will inform you and let you know when the data handover or transfer will take place.

14.5 Right of revocation

If you have given us permission to process personal data when using the EasyGov website, you can revoke this permission at any time. If you wish to exercise your right of revocation, please proceed as described in Section 14.6.

The effects of revocation are limited to the processing of personal data that may not already be processed without your consent by law. Furthermore, revocation has no effect on the previous processing operations that were carried out on the basis of the consent.

14.6 Procedure for asserting your rights

To assert your rights, please contact us in writing by sending a letter or email enclosing a copy of an official identification document (e. g.: identity card, passport or driving licence) to the data protection officer named in Section 5.

Please note that your rights will be restricted to the extent provided for by law or that is necessary due to overriding public or private interests.

15. Data security

Data security is a high priority for SECO as the operator of EasyGov. We use the widespread SSL / TLS procedure for EasyGov in conjunction with the encryption level supported by your browser. You can see that a page on our website is being transmitted in encrypted form when a closed lock symbol is displayed in the status bar of your browser.

In accordance with the applicable data protection legislation, SECO, as the operator of EasyGov, uses appropriate technical and organisational security measures for data processing in order to protect your data against accidental or wilful manipulation, partial or complete loss, destruction or against unauthorised access by third parties. The Federal Administration’s security measures correspond to the current state of the art.

16. How will you be informed about changes to this Privacy Policy?

We reserve the right to amend this Privacy Policy at any time. As part of the procedure for EasyGov platform updates in accordance with Section 7.2, we will inform you of any amendments to the Privacy Policy.

The current version published on our EasyGov website applies.

17. Final provisions

This Privacy Policy has been translated into several languages. In the event of any contradictions between the different language versions, the German version takes precedence.

[1] The abbreviation “UID” stands for company identification number. See also: Federal Act of 18 June 2010 on the Business Identification Number (UIDG; SR 431.03).

[2] For the term UID entity, see Art. 3 para. 1 let. c UIDG.