1. What is this privacy policy about?
2. Who is responsible for processing your data?
3. What personal data do we process?
4. For what purposes and how do we process your personal data?
5. With whom do we share your salary information?
6. Do we disclose salary data abroad?
7. How long do we process salary data?
8. What are the legal bases for data processing?
9. What rights do you have?
10. Changes

1. What is this privacy policy about?

Matto-Group AG, General-Guisan-Str. 6, 6300 Zug, processes personal data that concerns you or other people in different ways and for different purposes. As far as we refer to “Matto-Group” or “we” below, this refers to Matto-Group AG (see section 2).

“Personal data” is all information that can be associated with a specific person, and “processing” means any handling of it, e.g. obtaining, using, and disclosing it.

This data protection declaration explains our processing of personal data (hereinafter data) if

• you carry out our salary analysis (subsequently salary check) on our website https://lohncheck.ch/de or other platforms,
• you register for our newsletter,
• we or third parties carry out direct marketing activities based on the data you enter as part of the salary check.

Please also note our general data protection declaration, which contains additional information, for example for the general use of our website or if you are in business contact with us. The general data protection declaration is available here.

To make it easier to read, this data protection declaration does not mention multiple genders, but we do mean to address people of all genders.

Please take the time to read this privacy policy to learn how and why Matto-Group processes your personal data in connection with the salary check and how Matto-Group protects your personal data and what rights you have in this context. If you have any questions or would like further information about our data processing, we will be happy to help you (Section 2).

We have aligned this data protection declaration with both the Swiss Data Protection Act (DSG) and the European General Data Protection Regulation (GDPR). If “personal data” is mentioned in the data protection declaration, this also includes “personal data” in accordance with the GDPR. Whether and to what extent the GDPR is applicable depends on the individual case

2. Who is responsible for processing your data?

The following company is the “responsible party” for data processing in accordance with this data protection declaration, i.e. the body primarily responsible for data protection law, unless otherwise communicated in individual cases (e.g. in further data protection declarations or on forms):

Matto-Group AG
General-Guisan-Str. 6
6300 Zug
Switzerland

If you have any questions about data protection, please feel free to contact the following address so that we can process your request as quickly as possible:

[email protected]

If you have any questions about the GDPR, you can also contact our EU representative in accordance with Art. 27 GDPR:

DP-Dock GmbH
Attn. Matto-Group AG
Ballindamm 39
20095 Hamburg
Germany

If you have any questions about the UK GDPR, you can also contact our UK representative:

DP Data Protection Services UK Ltd.
Attn: Matto-Group AG
16 Great Queen Street
Covent Garden
London, WC2B 5AH
United Kingdom

The email address for inquiries to our local representatives in the EU and UK is: matto‑group@gdpr‑rep.com

3. What personal data do we process?

For the purposes of the salary check and the advertising measures based on it, we process the following personal data, although this list is not exhaustive. We process the data you enter on our website to carry out the salary check. This data is only personal if you also provide your name or email address. You are not required to identify yourself or enter any data, but without the relevant data the salary check cannot be carried out or it will produce an inferior result. We primarily collect the following data (hereinafter collectively: wage check data):

• Information about yourself (e.g. gender, year of birth, nationality, place of residence, marital status, year of birth of children)
• Contact details such as email address or post address
• Information about your profession and education (e.g. diplomas, educational institution, highest level of education)
• Information about your professional experience (e.g. career level, work experience, management span, etc.)
• Information about your employer (e.g. company, industry, number of employees, orientation, legal form, country)
• Information about your job, salary, and income situation (e.g. gross income, workload, job title)
• Further information that you provide to us, for example, via the career coach

We may also automatically and with the use of artificial intelligence extract relevant data from the CV and other documents you provide to us so that we can use this data to make more precise salary comparisons.

To the extent that the data disclosed to us contains particularly sensitive personal data (also “special categories of personal data”), such as health data or information about political or trade union activities, we use this data for the purposes specified in this data protection declaration. In this case, we rely on your express consent through your disclosure (Art. 9 Para. 2 lit. a GDPR). With your separate consent, we can also collect comprehensive data from your LinkedIn profile, which LinkedIn makes available to us. This includes:

• Information about your account (e.g. when you opened your account and when you logged in, history of email addresses associated with the account, phone numbers associated with your account, information about calendars synced with LinkedIn)
• Information about activities on LinkedIn (e.g. which ads you have clicked on, who or which hashtags you follow, which photos, videos or documents you have shared, what or who you searched for and when, conclusions that LinkedIn draws from your profile or your activities on LinkedIn, comments made, updates liked, posts and articles written, contacts imported, events attended and other purchases related to your account, ratings and reviews of products, service providers and learning reviews, groups in which you participate, Invitations you have received or sent, jobs you have posted and positions you have applied for, preferred jobs, locations, industries and companies, learning videos you have watched, messages sent and received, job information saved, job alerts, recommendations that you have received or submitted)
• Information about your profile (e.g. publications, projects, volunteer activities, organizations, languages, awards, courses, certifications and other profile information, biographical information and skills, positions with companies and locations, schools and degrees, confirmations of your skills by other people) and
• Information about your connections (e.g. name, position, company and date of connection of the first-degree connections).

We may receive additional personal information from third parties when they conduct a payroll check for someone else. If you provide us with information about other people, we will assume that you are authorized to do so and that the information is accurate. Please ensure that these third parties have been informed about this data protection declaration (e.g. through a reference to this data protection declaration)..

4. For what purposes and how do we process your personal data?

4.1. Carrying out the wage check and other online services

We use the wage check data we collect primarily to provide our online services, i.e. in particular to carry out wage calculations and analyses on our websites or platforms and to display relevant job advertisements on our pages.You may then have the option of forwarding your details to an appropriate recruiting partner (Section 5.3).

4.2. Personalized self- and third-party advertising

Based on your separate consent, the wage check data you provide on our website or platform may be used for advertising and marketing purposes. We ourselves may analyze your wage check data to show you personalized offers on our website or on third-party websites, as part of a specific target group (e.g. income, professional or age group). These offers may relate to goods or services from us or from partners. We may also share your wage check information with third parties for them to run related advertising campaigns. As a rule, this takes place without disclosing any personal data - this means that these third parties only receive your data pseudonymously (i.e. conclusions about your person are only possible if you are already known to these third parties, for example due to a login). We can also send your wage check data to our partners on a personal basis, in particular publishers, who can use your data under their own responsibility, for the purposes of personalized advertising for themselves and third parties. Further information can be found in section 5.

or the purposes of personalizing advertising campaigns, we can compare your email addresses with the address database of the recipients named under Section 5 so that your wage check data from these recipients is in turn linked to other identifiers they have, such as UID2, EUID tokens or OneID and can be used accordingly. A UID2 or EUID token is a persistent, encrypted digital advertising identifier provided and controlled by the website user. The OneID is an encrypted, digital advertising ID that is created using an identifier such as your email address and allows us to recognize and specifically address you across different websites.

You can object to our use of your wage check data for advertising purposes at any time by sending an email to: [email protected] or using the unsubscribe link in our newsletters and communications with effect for the future.

It is also possible for us to link your wage check data with further information about you for the purposes of personalized advertising, both internally and externally, for example with data from publicly accessible sources such as public registers or from the Internet (website, social media, etc.). For further information on these data categories, please see our general data protection declaration.

4.3. Newsletter

Based on your separate consent, we may send you information about personalized products and services as well as job offers from our advertising partners via newsletter. We use your wage check data for this, but we may also use your behavioral and preference data. Further information about these categories of personal data can be found in our general data protection declaration, available here. You can object to this sending at any time by sending an email to [email protected] or by clicking on the unsubscribe link in the respective message.

4.4. Other purposes

Finally, we may also process your wage check data for other purposes, such as optimizing our website, optimizing our statistical model for calculating pay and avoiding redundancies in our training data, enforcing the law and preventing crimes. Information about these additional purposes can be found in our general data protection declaration, which is available here; However, the corresponding explanations for further purposes also apply here. However, the corresponding explanations for further purposes also apply here.

5. Who do we share your wage check details with?

5.1. General

In connection with personalization and the display of advertising campaigns, we may also disclose your data to third parties based on your separate consent. These can be publishers (e.g. online publishing houses) or our advertising technology partners, who process the data either for us (if we run the advertising campaigns) or for their own purposes and therefore under their own responsibility (for in the event that they play out the advertising campaigns themselves).

5.2. Processing by third parties for their own purposes

In cases where we pass on your data to our partners, such as publishers, for processing for their own purposes, they are responsible for the further processing of your data themselves. You can find information about your data processing in the relevant data protection declaration of our partners. We and our partners may also be jointly responsible for collecting the data. In these cases, we will make a corresponding agreement, which you can find out about at the address given in section 2.

5.3. Announcement to recruiting partners

If you give us your consent, we will pass on your application information to our recruiting partners. This includes all career-relevant data from your resume or LinkedIn profile, such as name, contact information, education, qualifications, skills, professional experience and further training.

5.4. Announcement to advertising technology partners

We also share your information with our advertising technology partners so that we or they can show you personalized offers from us or our partners on our website or on other websites. These announcements are made to the following recipients. However, the following list is not exhaustive. We may also work with other advertising technology partners who offer the same or similar services to those listed below:

• Meta: Facebook Custom Audiences is a remarketing campaign in which the advertiser encrypts the email addresses of its customers collected and collected for this purpose using an algorithm and sends these non-personal identifiers (hash values) to Facebook transmitted. Facebook can compare this data with its inventory of user IDs and advertise the matches in a targeted manner. After the comparison, the transmitted hash values are deleted. This means that no email addresses are transmitted that were not already known to Facebook. In addition, Facebook can also address similar customers with similar interests based on the uploaded user lists. Further information about the scope of the collection and the further processing and use of the data by Facebook Custom Audiences can be found in Facebook's data protection guidelines, which are listed, among others, at https://www.facebook.com/privacy/explanation The terms and conditions for Custom Audiences can be found at https://www.facebook.com/ads/manage/customaudiences/tos.php .You can object to the collection and use of information for online advertising aimed at specific target groups using the following: https://www.facebook.com/ads/website_custom_audiences/ .
• Google: Google Customer Match essentially works like Facebook Custom Audiences (see above). Unlike Facebook Custom Audiences, we can also provide your data to Google in unencrypted form. In this case, Google takes care of the encryption (hashing) on our behalf before it compares the data. Based on the data comparison, Google can advertise to users of Google Search, YouTube and Gmail in a targeted manner and independently optimize advertising campaigns. The guidelines for the “Customer Match” function apply to the data provided by the advertiser: https://support.google.com/adwordspolicy/answer/6299717?hl=de

For further information, please see Google's privacy policy at: https://www.google.com/intl/de/policies/privacy/. You can edit your personal data and privacy settings under Google “My Account”: https://myaccount.google.com/intro?hl=de.

• The Trade Desk: With The Trade Desk we use a platform that makes it possible to compare data with ID solutions such as Unified ID 2.0 or EUID (encrypted User ID) or OneID. When you use the ID solutions, certain identifiers (such as your email address) are assigned to an encrypted ID. Using Trade Desk, we can assign your ID to specific target groups, display personalized advertising on our website and third-party websites and synchronize them across devices, thereby maximizing the reach of advertising campaigns on different media types (mobile devices, stationary devices, TV).
• OneID: We can compare your wage check data with the data you have stored with OneID (e.g. email address) and thereby receive the OneID assigned to you. We can link this ID with other wage check data in order to recognize you on our website and third-party websites and to address you across devices by showing you personalized offers from us or our advertising partners.

5.5. Other announcements

We also provide other service providers with the wage check data required for their services. This particularly affects our IT service providers.This also includes providers of data evaluation and analysis services, including OpenAI for extracting data from your CV and other documents provided to us using artificial intelligence. To the extent that these service providers process personal data as processors, they are obliged to process personal data exclusively in accordance with our instructions and to take measures to ensure data security.

Data can also be disclosed to other recipients, e.g. to courts and authorities as part of procedures and legal information and cooperation obligations, to buyers of companies and assets, to financing companies for securitizations and to debt collection companies.

6. Do we disclose wage check data abroad?

The recipients of data mentioned above are not only located in Switzerland. They may also be in the European Economic Area (EEA) (for example in Ireland), but also in other countries around the world (particularly the USA). Not all these states currently guarantee a level of data protection that corresponds to Swiss law. We compensate for the lower level of protection through appropriate contracts, in particular the standard contractual clauses issued by the European Commission and recognized by the Swiss Data Protection and Information Commissioner (FDPIC). Further details and a copy of these clauses can be found here.

In certain cases, we can transmit data in accordance with data protection regulations even without such contracts, e.g. if you have consented to the corresponding disclosure or if the disclosure is necessary for the execution of the contract, for the establishment, exercise, or enforcement of legal claims or for overriding public interests.

Please note that data exchange over the Internet is often routed via third countries. In this case, your data can therefore end up abroad even if the sender and recipient are in the same country.

7. How long do we process wage check data?

We store and process your wage check data as long as it is necessary for the purpose of processing, as long as you do not revoke your consent or as long as we have a legitimate interest in storing it (e.g. to enforce legal claims, for archiving or to improve IT to ensure security) and as long as data is subject to a legal retention obligation. If there are no legal or contractual obligations to the contrary, we will destroy or anonymize your data after the storage or processing period has expired as part of our usual processes.

8. What are the legal bases for data processing?

Depending on the applicable law, data processing is only permitted if the applicable law specifically allows it. This does not apply under the Swiss Data Protection Act, but, for example, under the European General Data Protection Regulation (GDPR), to the extent that this applies. In this case, we base the processing of your wage check data on the following legal bases:

• Article 6, (1) (a) GDPR for processing that we carry out with your separate consent, in particular the procurement and processing mentioned in paragraphs 3 and 4.2 and the disclosure of data mentioned in paragraph 5.3;
• Article 6, (1) (a) GDPR for processing that we carry out with your separate consent, in particular the processing mentioned under Section 4.2;
• Aricle 6, (1) (b) GDPR for processing that is necessary for the preparation and implementation of our online services (in particular the implementation of wage analyzes and the other purposes mentioned in Section 4.1), if you decide to use these services gain weight;
• Article 6, (1) (f) GDPR for processing that is necessary to protect the legitimate interests of us or third parties, unless the fundamental freedoms and rights as well as the interests of the data subject outweigh this. This applies in particular to compliance with Swiss or European law, our interest in carrying out our activities and activities in a permanent, user-friendly, safe and reliable manner and the purposes according to section 4.4;
• Article 6 (1) (c) GDPR for processing that is necessary to fulfil a legal obligation under the law of a member state of the European Economic Area (EEA). The EEA includes the EU states and Iceland, Norway and Liechtenstein.

9. What rights do you have?

You have certain rights within the scope and subject to the conditions or limitations of applicable data protection law so that you can obtain further information about and influence our data processing. These are the following rights:

• Right to information: You can request further information about our data processing. We are at your disposal for this. You can also submit a so-called information request if you would like further information and a copy of your data.
• Objection and deletion: You can object to our data processing with effect for the future and request that we delete your wage check data at any time. You can object to the processing of data for the purposes of direct advertising and the newsletter at any time. https://lohncheck.ch/de/daten-loeschen
• Correction and restriction: You can correct or complete incorrect or incomplete wage check data and have the processing of your data restricted.
• Transfer: You also have the right to receive the wage check data that you have provided to us in a structured, common, and machine-readable format or to have it transferred to a third party, provided that the corresponding data processing is based on your consent or is necessary to fulfil the contract is.
• Revocation: If we process data based on your consent, you can revoke your consent at any time. The revocation only applies for the future, and we reserve the right to continue to process data in the event of a revocation based on another basis.

Please note that these rights are subject to legal requirements and restrictions and are therefore not fully available in every case. We may need to further process and store your personal data to protect our own legitimate interests, such as the assertion, exercise, or defense of legal claims, or to comply with legal obligations. To the extent legally permissible, to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we can therefore reject a data subject's request in whole or in part (e.g. by blacking out certain content that concerns third parties or our business secrets).

If you would like to exercise your rights against us, please contact us in writing. You can find our contact details in section 2. As a rule, we must check your identity (e.g. through a copy of your ID). You are also free to lodge a complaint against our processing of your data with the responsible supervisory authority. The responsible supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC). Within the scope of the GDPR, you can contact the relevant national supervisory authorities.

10. Changes

We can adapt this data protection declaration at any time if necessary. The current version published on our website applies.

As of: May 22, 2024