Privacy policy

Disclaimer: This statement has been automatically translated into English. In the event of any ambiguity, please refer to the German version.

The protection of personal data of the users of our websites (educaswiss.ch, bildungsdarlehen.ch and educaplan.ch) is of central importance to EDUCA SWISS.

We collect, process and use personal data only in compliance with the applicable data protection law. We also work continuously to ensure that personal data is protected by technical and organisational measures and is inaccessible to third parties.

This data protection declaration provides information on which data EDUCA SWISS collects during your visit to our website (see list above) and how we use this data. Some of the data we store on our server is data that you have voluntarily provided to us by filling in forms, while other data has been collected automatically. EDUCA SWISS does not collect any data from which the identity of individual visitors can be deduced, unless you yourself provide us with your personal data. Furthermore, EDUCA SWISS does not use any technological tools aimed at identifying visitors.

General notes

The following information provides a simple overview of what happens to your personal data when you visit our websites. Personal data is any data with which you can be personally identified. Which specific data is processed in detail and how it is used depends largely on the specific circumstances.

Who are we?

EDUCA SWISS is the Swiss foundation for education promotion and financing. We support motivated people in the implementation of their educational project, on the one hand by providing free guidance in the planning and budgeting of their work-related educational project, and on the other hand by arranging educational loans at favourable interest rates.

To whom does this privacy notice apply?

When we process personal data, this means that we collect, store, use, transmit or delete it, for example. This privacy notice applies to personal data of the following natural persons in connection with our websites: Interested parties, borrowers, coaches, lenders and donors who are natural persons. Until a possible change in the legal situation in the Data Protection Act of the Swiss Confederation and the Ordinance to the Data Protection Act of the Canton of Lucerne, this data protection notice also applies to legal entities, insofar as these are applicable.

What data do we use?

We process the data that arise in the context of using our websites or the data that you provide (e.g. in the context of mailings, registrations on educaplan, filling out web forms or other).

We collect your personal data in particular when you contact us, for example via our websites, as a prospective customer, borrower, lender, coach, donor, etc. We process personal data that we receive from our borrowers in the course of our activities. In addition, we process – to the extent necessary for the provision of our services – personal data that we permissibly obtain from publicly accessible sources. Furthermore, we process the data that arise in the course of using our websites or the data that are provided by you (e.g. in the course of mailings or registrations for events or in other web forms).

Relevant personal data are personal details (name, address and other contact details, date and place of birth and nationality, educational details, etc.) and identification data (e.g. ID card data). In addition, this may also be order data, data from the fulfilment of our contractual obligations, advertising data, documentation data and other data comparable with the categories mentioned.

We do not collect any personal data when you use our website for information purposes only, i.e. if you do not fill in any web forms or send us any other information. Data is transmitted to us anonymously by your browser, for example: browser type and version, operating system used, referring website, domain and host, visitor path through the website, date and time of the website visit, masked IP address, type of terminal device, etc. This data cannot be used to identify you.  No identification is possible on the basis of this data.

What do we process your data for and on what legal basis?

We process personal data in accordance with the Swiss Federal Data Protection Act (FADP), the Ordinance of the Canton of Lucerne on the Data Protection Act, and the European General Data Protection Regulation (GDPR), in each case insofar as the relevant regulations are applicable. As the GDPR requires us to list these individually, the legal bases on which we base our processing, insofar as the GDPR applies, are listed below. In the case of processing of personal data in accordance with cantonal ordinances or the DPA, we rely in each case on the comparable legal bases in these laws:

1. For the performance of contractual obligations (Art. 6 para. 1 b DSGVO). Personal data is processed for the provision of services by EDUCA SWISS in the context of the performance of our contracts with borrowers or lenders and for the performance of pre-contractual measures that take place upon request. The purposes of the data processing depend primarily on the specific service and may include activities such as telephone clarifications, mail clarifications or consultations. The contractual documents and terms and conditions may contain further details on the data processing purposes.
2. Within the framework of the balancing of interests (Art. 6 para. 1 f DSGVO). Where necessary, we process your data beyond the actual performance of the contract to protect legitimate interests on our part or on the part of third parties. Examples:
   • Anonymised statistical surveys
   • Screening of borrowers, coaches and lenders within our office and with the help of external service providers
   • Mediation between lenders, coaches and borrowers
   • Advertising if you have not objected to the use of your data
   • Assertion of legal claims and defence in legal disputes
   • Mailings, event registrations and orders for advertising materials
   • Ensuring IT security, IT programming and IT operation in the contractual relationship
   • Analysis of internet traffic on our websites, to improve the functionality of our websites
   • Prevention and investigation of criminal offences
   • Measures for business management and further development of services and products
3. Based on your consent (Art. 6 para. 1 a DSGVO). Insofar as you have given us consent to process personal data for certain purposes (e.g. forwarding data to coaches, mailings), the lawfulness of this processing is based on your consent. Consent given can be revoked at any time. This also applies to the revocation of declarations of consent given to us prior to the application of the GDPR, i.e. prior to 25 May 2018. The revocation of consent does not affect the lawfulness of the data processed until the revocation.
4. Due to legal requirements (Art. 6 para. 1 c DSGVO) or in the public interest (Art. 6 para. 1 e DSGVO). In addition, we are subject to the other legal requirements of the Swiss legislator, so that personal data may also be processed if this is required by law or if the processing is in the public interest.

Confidentiality/Security

The personal data you enter in a form is password-protected by the user. They are also stored on our servers, kept with all due care and protected from access by third parties. Only those employees and volunteers have access to your data who need it to fulfil their tasks. EDUCA SWISS will only pass on your data to third parties if this has been expressly stated elsewhere or to external service providers who process this data for EDUCA SWISS on the basis of an order processing contract. With the consent to the loan placement process (after completion of the coaching), the personal data is transferred to the verified lenders. This process can be stopped again at any time upon request. The collected data will only be collected for the declared purpose and will not be passed on.

Mailings

We would be pleased to inform you about current topics concerning EDUCA SWISS in our mailings. In order to send a mailing, we need at least your e-mail address, usually your name and gender and, if applicable, your address (in order to be able to determine the applicable legal basis). After you deposit your e-mail address and other details on our website or on educaplan, you will receive an e-mail from us to the e-mail address you have provided, in which you must click on a confirmation link to verify the e-mail address you have provided. By registering on educaplan, you automatically agree to receive regular informational mailings and service-related mailings. You can unsubscribe from the information mailings at any time. We use the list provider MailChimp to send our mailings. MailChimp is a service provided by The Rocket Science Group, LLC, 512 Means Street, Ste 404 Atlanta, GA 30318. You can find more information about their privacy policy here.

Who receives my data?

Within EDUCA SWISS, access to your data is granted to those persons who need it to fulfil our contractual obligations. Service providers employed by us may also receive data for these purposes. These include companies in the categories of IT, accounting, auditing, credit assessment and marketing services. Recipients of personal data may be, for example: public bodies and institutions (e.g. law enforcement agencies) if there is a legal or official obligation.

Other data recipients may be those bodies for which you have given us your consent to transfer data or for which you have released us from the obligation of confidentiality in accordance with the agreement or consent.

Is data transferred to a third country or to an international organisation?

Data transfer to bodies in states outside the European Union and Switzerland (so-called third countries) takes place by means of mailing service providers (Mailchimp) and online payment interfaces (Payrexx), among others. Service providers (analogous to the list above) may process the data provided by us via international organisations. The self-serving use of the data, apart from anonymous statistical surveys, is strictly prohibited by the service providers.

How long will my data be stored?

We process and store your personal data as long as it is necessary for the fulfilment of our contractual and legal obligations or as long as we consider it necessary for the purposes for which they are processed or our legitimate interests exist or your consent has not been revoked. You can request at any time that we make your data unrecognisable, whereupon we will anonymise your profile and remove any files.

What data protection rights do I have?

You have different rights depending on the applicable legal basis. If the DPA and the Ordinance of the Canton of Lucerne are applicable, your rights are governed by these enactments.

If the GDPR is applicable, the following applies: Every data subject has the right to information under Article 15 of the GDPR, the right to rectification under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to object under Article 21 of the GDPR and the right to data portability under Article 20 of the GDPR. In addition, there is a right of appeal to a competent data protection supervisory authority (Article 77 DSGVO).

You may revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent given to us before the applicability of the General Data Protection Regulation, i.e. before 25 May 2018. Please note that the revocation only takes effect for the future. Processing that took place before the revocation is not affected.

Is there an obligation for me to provide data?

Within the scope of our business relationship, you must provide those personal data that are necessary for the establishment and performance of a business relationship and the fulfilment of the associated contractual obligations or which we are legally obliged to collect. Without this data, we will generally not be able to enter into or execute a contract with you.

To what extent is there automated decision-making?

As a matter of principle, we do not use fully automated decision-making pursuant to Article 22 DSGVO to establish and implement the business relationship. Should we use these procedures in individual cases, we will inform you of this separately, insofar as this is required by law.

Does “profiling” take place?

We process your data partly automatically with the aim of evaluating certain personal aspects (profiling). In order to be able to inform and advise you in a targeted manner about services and news, we use evaluation tools. These enable us to provide needs-based communication and advertising. EDUCA SWISS may use cookies and web storage on its website.

1. Cookies
   Cookies are files that are filed and stored on a computer system via an internet browser. The data subject can prevent the storage of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time using an internet browser or other software programmes. You will find help for the most common browsers below:
   • Microsoft Explorer
   • Firefox
   • Google Chrome
   • Safari
   • Opera
2. Web-Storage
   Web storage (also called DOM storage or supercookies) is a technique for web applications that stores data in a web browser. DOM storage supports permanent data storage, similar to cookies, i.e. also local, session-dependent storage. In contrast to cookies, which can be accessed by both servers and clients (browsers), DOM storage is completely controlled by the client (browser). Data is not transferred to the server with every HTTP request and a web server cannot write data directly in the DOM storage. Access is exclusively via scripts on the website. This data is automatically deleted immediately when the browser window is closed and is therefore no longer available in later browser sessions. The saving of data in web storage can also be prevented by not accepting cookies. However, we would like to point out that the rejection of web storage can lead to restrictions in the function of accessed EDUCA SWISS websites.
3. Facebook Remarketing (Custom Audiences, Lookalike Audiences, Pixels)
   No plugins of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA are integrated on the website educaswiss.ch. However, in our mailings and on bildungsdarlehen.ch. You can recognise the Facebook plugins by the Facebook logo or the “Like” button on our pages and in the mailings. When you visit our pages and have agreed to the Facebook service via the cookie personalisation, a direct connection is established between your browser and the Facebook server via the plugin. Facebook thereby receives the information that you have visited our site with your IP address. If you click on the Facebook “Like” button on our website or in our mailings while logged into your Facebook account, you can link the content of our pages on your Facebook profile or follow us on Facebook. This allows Facebook to associate your visit to our pages with your user account. Pixels of the social network Facebook are used on our website. This enables Facebook to associate the visit to our pages with your user account. We would like to point out that we, as the provider of this website, have no knowledge of the content of the transmitted data or its use by Facebook. For more information, please see Facebook’s privacy policy here. We also use the Lookalike Audience service. Using Facebook Pixel data, Facebook determines commonalities in this, such as demographic data or interests. EDUCA SWISS uses this Facebook service by targeting similar groups of people with advertising. However, only Facebook can identify this data. If you do not want Facebook to be able to assign your visit to our pages to your Facebook user account, please log out of your Facebook user account and/or deactivate cookies in your browser.
4. Crisp
   We use Crisp on our pages. This pop-up chat box allows visitors to contact us personally directly on the websites. You can find more information about Crisp’s data protection here.
5. Statistic
   Our websites use web analytics software (Google Analytics, the web analytics service of Google, Inc.). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. This so-called tracking can be prevented by the Do-Not-Track setting in common internet browsers. This setting has the effect that the “Do-Not-Track” tag is sent in the header block of the browser request and the visitor’s actions are not evaluated. However, we would like to point out that in this case you may not be able to use all the functions of our websites to their full extent. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Further information on Google Analytics data protection.
6. IT system protocols
   Every time you use the Internet, e.g. when calling up websites and sending e-mails, data is automatically transmitted, some of which could be classified as personal data and is stored by us in so-called system logs. The system logs are stored by EDUCA SWISS to identify faults and for security reasons. If the data is no longer required for the fulfilment of operational or legal obligations, it will be deleted.
7. External contents
   Iframes are used on our websites (YouTube, donation form, etc.). In the process, the IP address is transmitted and the content providers can set cookies etc.. If the website visitor is simultaneously logged into the network of the respective third-party provider, the visit to the website can be assigned to his/her user account, depending on the provider. EDUCA SWISS has no influence on the type and manner of data transmission and has a legitimate interest in the integration of this external content. You can find the privacy policy of YouTube here and that of Payrexx here. We exclude any liability on the part of EDUCA SWISS due to misuse of data by the third-party providers.

Changes to the privacy notice

We reserve the right to change this privacy policy at any time. The date of the last update can be found at the end of the data protection notice.

Who is responsible for data processing and whom can I contact?

Simon Merki
Managing Director & Data Protection Officer
simon.merki@educaswiss.ch

EDUCA SWISS
Swiss Foundation for the Promotion and Financing of Education
6003 Luzern

mail@educaswiss.ch
Phone: 041 558 57 88 (Mo-Fr from 9am to 5pm)

Last updated: 15 May 2020