Privacy statement

Version dated 1 December 2024

This Privacy Statement describes the collection and further processing of personal data by companies of the V-ZUG Group and its affiliates (collectively V-ZUG) as far as they are not covered by other data protection policies or are evident from the circumstances or are provided for by applicable law. The term “personal data” shall include all information relating to an identified or identifiable person.

This Privacy Statement describes in Section I the processing of personal data by V-ZUG in general. Section II contains specific provisions for different applications (e.g. online shops, newsletter, etc.) and for data processing in connection with the use of the V-ZUG apps.

Every website (including online shops and mini sites for special offers), every presence on social media, multimedia portals, chatbots and every app of V-ZUG (each a “website”) has a controller – where personal data is collected – within V-ZUG according to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) (or comparable provisions according to applicable data protection laws). Unless provided otherwise on the website (according to the legal notice, the terms of use, etc.) or under section II, the controller is: V-ZUG Ltd, Industriestrasse 66, 6300 Zug, Switzerland. The respective V-ZUG subsidiary or affiliate is the controller in case V-ZUG communicates through other means of communication (e-mail, letter, telephone, audio or video conferencing, etc.) and the communication does arise in the course of an activity for which V-ZUG has appointed a specific controller within this Privacy Statement or otherwise. Should a V-ZUG company or affiliate disclose personal data to another V-ZUG company or affiliate for certain purposes of the receiving company or affiliate, such company or affiliate is the controller according to Art. 4 (7) GDPR. A comprehensive list of companies and affiliates of V-ZUG can be found here. V-ZUG has not appointed a data protection officer according to Art. 37 GDPR (or comparable provisions according to applicable data protection laws), except for V-ZUG Deutschland GmbH. Any enquiry, claim or concern regarding data protection at V-ZUG can be addressed to the following contact unit: [email protected], or concerning V-ZUG Deutschland GmbH: [email protected]. In cases where a V-ZUG company that is processing personal data is not located in the EU or the EEA and the data is being processed in conjunction with an offer of goods or services to data subjects in the EU or the EEA, and in cases in which the behaviour of data subjects in the EU or the EEA is being observed, the following representative within the Union has been designated in accordance with Art. 27 GDPR: V-ZUG Europe BV, Evolis 102, 8530 Harelbeke-Kortrijk, Belgium. In cases where a V-ZUG company processing personal data is not located in the United Kingdom and the data is being processed in conjunction with an offer of goods or services to data subjects in the United Kingdom, as well as in cases where the behaviour of data subjects in the United Kingdom is being observed, the following representative within the United Kingdom has been designated in accordance with Art. 27 UK GDPR: V-ZUG UK Ltd., 27 Wigmore St, London W1U 1PN, United Kingdom.

V-ZUG collects and processes personal data of:

• visitors of its websites registered or not registered with V-ZUG;

• contact persons and employees of service providers, suppliers, retailers, vendors and providers of V-ZUG products and parts of products;

• customers, buyers, recipients and beneficiaries or prospective customers of products and services (including warranty, repair and maintenance services) of V-ZUG or its contact persons and employees;

• contact persons and employees of business partners and associated companies, personnel providers and employment agencies (as well as brokered employees/workers) and further commercial and economic partners;

• shareholders and beneficiaries of other rights to shares of V-ZUG Holding AG as well as respective interested parties;

• recipients of ad hoc-information and newsletters of V-ZUG;

• participants in competitions, market research campaigns and opinion surveys conducted by V-ZUG;

• participants in courses, seminars and other training organized by V-ZUG;

• users of Wi-Fi provided at V-ZUG stores, showrooms, business premises and other locations;

• individuals ordering or using V-ZUG customer loyalty programmes; and

• registered participants of V-ZUG customer loyalty programmes (business partner programme)

(collectively “business partners”).

The personal data of business partners is generally collected directly during the course of using the website, upon demand for or use of products or services, upon submission of reviews or reports, participation in competitions, market research or other surveys, in stores, sales offices or at events of V-ZUG or V-ZUG approved retailers or during direct communication with V-ZUG via e-mail, telephone, audio or video conferencing or in any other way. However, personal data can also be collected indirectly, namely when the business partner engages in a commercial activity which does not correspond with the person benefiting from the commercial activity or if a purchase is shipped to a different person (e.g. warranty, repair or service work), based on the recommendation of a third party (e.g. recommendation by friends and acquaintances of the business partner) or through further obtaining or acquisition of supplementary information from third party data sources (e.g. social media, address brokers, providers of commercial information, etc.).

In particular, the following categories of personal data are processed by V-ZUG:

• Personal data and contact information: including but not limited to first and last name, address, residence, telephone number, e-mail address, age, date of birth, gender, marital status, relatives, details of secondary contact, where applicable, photos, information about function within the company, information about business relationships with this data subject, information about commercial transactions, enquiries, offers, quotes, stipulations and contracts, statements about work or other interests of the data subject, etc.;

• Data pertaining to deliveries and sales as well as orders and purchases: including but not limited to payment information, credit card details and other payment details, billing and shipping address, products and services delivered and sold as well as ordered and purchased, information connected to queries, complaints and disagreements relating to products and services or respective contracts entered into such as warranty claims, rescissions and disputes, information regarding business partners blacklisted by V-ZUG, etc.;

• Data in connection with the marketing of products and services: including but not limited to information about marketing activities such as the receipt of newsletters, newsletter opt-ins and opt-outs, documents received, invitations to and participations at events and special activities (as far as they are not part of a customer loyalty programme), personal preferences and interests, etc.;

• Data concerning the use of the website: including but not limited to the IP address and other identification (e.g. social media username, MAC address of smartphones or computers, cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies) or other technologies, with which personal data is collected), date and time of website visits, visited sites and contents, referring websites, etc.;

• Data of shareholders and beneficiaries of shares and related communication: including but not limited to number of shares, share transfers, entitlement, security deposit account, bank account for dividends, preferred means of communication, correspondence, correspondence language and communication with V-ZUG (including records of the communication), etc.;

• Data that was collected in connection with a customer programme: such as membership number, access details (including passwords), preferred language, gift certificate number, date and duration of the membership, payment information of the customer or third party, where applicable, information concerning recipients of gifts, number of visits of the website, purchase history, products acquired, etc. (besides traditional customer loyalty programmes, all website accounts, activities and events for which a business partner must register with his personal data and thus enter into a contract with V-ZUG shall be deemed a customer programme for the purposes of this policy);

(collectively “business partner data”).

In accordance with applicable law, V-ZUG may process business partner data namely for, but not limited to, the following purposes:

• In connection with products and services offered, conclusion of contracts (in particular purchases and sales of products and services), execution of contracts (in particular purchase and supply agreements and contracts regarding participation in customer programmes and events) or other business relationships, maintenance and development of relations with business partners and shareholders or other beneficiaries or prospective shareholders of V-ZUG Holding Ltd (in particular invitations to and staging of events, activities and campaigns on behalf of and with business partners), communication, customer service and support (in particular orders and enquiries), marketing, promotion and advertising activities (including newsletters and promotions);

• Management of the users and visitors of the website and other activities in which business partners participate; operation and enhancement of the website (including the provision of functions that require identifiers or other personal data) and further IT systems, identity verifications;

• Quality control, market research, enhancement of products and services, creation of statistics, budgets, records and management information as well as further reports on business partners, transactions and activities, offers and other commercial aspects of V-ZUG for the purposes of company management and development of the company, its range of products and services, its activities and project management;

• protection of business partners, employees and other individuals and protection of data, secrets and assets of and entrusted to V-ZUG, security of systems and premises of V-ZUG;

• compliance with legal and regulatory requirements (in particular company law and stock exchange law and rules, ad hoc information etc.) and internal rules of V-ZUG, pursuit and enforcement of various rights, defence against legal claims, litigation, complaints, combating fraud and abusive conduct, engaging in legal investigations and proceedings and responding to enquiries from public authorities;

• sale or acquisition of business divisions, companies or parts of companies and other corporate transactions and the transfer of business partner data associated therewith;

• for other purposes as far as a legal obligation requires processing and such processing was evident from the circumstances or indicated at the time of the collection;

(collectively the “purpose of processing”).

V-ZUG uses the business partner data for the purpose of processing based on the following legal grounds:

• performance of contracts;

• compliance with legal obligations of V-ZUG;

• consent of the business partner (only insofar as the processing is based on a specific query from V-ZUG and can be withdrawn by the business partner at any time, namely the receipt of newsletters for which the client has registered);

• legitimate interests of V-ZUG, including but not limited to

  • purchase and shipment of products and services, also in connection with individuals who are not direct contractual partners (e.g. individuals receiving gifts);

  • carrying out advertisement and marketing activities;

  • efficient and effective customer support, maintenance of contacts and other communication with business partners outside of the processing of contracts;

  • understanding customer behaviour, activities and needs, market research;

  • efficient and effective improvement of existing products and services and development of new products and services;

  • efficient and effective protection of business partners and other individuals as well as protection of data, secrets and assets of or entrusted to V-ZUG, security of systems and premises of V-ZUG;

  • maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further development of the website and other IT systems;

  • reasonable corporate governance and development;

  • successful sale and acquisition of business units, companies or parts of companies and other corporate transactions;

  • compliance with legal and regulatory requirements and internal rules of V-ZUG;

  • concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of legal claims and actions against V-ZUG, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defence against legal actions.

Where applicable data protection laws permit, V-ZUG may process the data of registered and non-registered website visitors for the purposes of maintaining and developing the website (including the provision of functions that require identifiers or other personal data), for statistical analysis regarding the use of the website as well as for combating abusive conduct, for purposes of legal investigations or proceedings and for responding to enquiries from public authorities. The visitor data shall be processed in accordance with the principles set out for business partner data above.

All the purposes of processing shall be applicable for the whole of the V-ZUG Group, i.e. not only for the company which initially collected the personal data. All personal data of business partners is collected for the purposes of all V-ZUG companies.

Personal data is only processed or used for purposes other than those for which the personal data was collected in compliance with the applicable mandatory provisions or where necessary with the consent of the data subject.

Where applicable laws permit, V-ZUG may disclose business partner data to the following categories of third parties who process business partner data in accordance with the purpose of data processing on behalf of V-ZUG or for their own purposes:

• Service providers (within V-ZUG as well as external, for example for share registers, support and service), including processors;

• Distributors, suppliers and other business partners;

• Customers and buyers of V-ZUG products and services;

• Local, national and foreign authorities as well as stock exchanges and related supervisory and enforcement bodies (including SIX Exchange Regulation AG, the Swiss Financial Market Supervisory Authority FINMA, law enforcement authorities and courts);

• Media and private reporters and journalists;

• The general public, including visitors to V-ZUG websites and social media channels;

• Industry organizations, associations, organizations and other committees;

• Competitors;

• Acquirers or parties interested in acquiring business units, companies or other parts of V-ZUG;

• Other parties in potential or actual legal proceedings;

• Other companies of V-ZUG

(collectively “third parties”).

V-ZUG may disclose business partner data within the V-ZUG Group as well as to third parties and in every country worldwide, including all countries in which V-ZUG is represented by companies, affiliates, exhibition and other sales premises and representatives or distributors as well as to countries in which service providers of V-ZUG process their data. If data is disclosed to countries that do not guarantee adequate protection, V-ZUG will ensure adequate protection of data by way of technical and organizational measures and putting adequate contractual guarantees in place, namely on the basis of an international treaty; the data protection clauses in a contract between V-ZUG and a processor which have been notified in advance to the Federal Data Protection and Information Commissioner (FDPIC); the currently valid EU standard clauses; standard contractual clauses approved, issued or recognized in advance by the FDPIC; binding internal company data protection rules approved in advance by the FDPIC or by another competent supervisory authority of a state that ensures adequate protection; or other suitable guarantees under applicable data protection law. In the absence of such guarantees, V-ZUG relies on the exception of consent, the performance of the contract, the establishment, exercise or enforcement of legal claims, overriding public interests, the data published by the business partner or the grounds that it is necessary to protect the integrity of such persons. The business partner can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact unit named in Section I, para. 1. V-ZUG reserves the right to redact such copies for reasons of data protection or secrecy reasons.

As a rule, V-ZUG retains contract-related business partner data as long as the contractual relationship is ongoing and for ten years after the termination of the contractual relationship unless a longer statutory store obligation is applicable on a case-by-case basis, this is required for reasons of proof or another valid reason for an exception is pertinent based on applicable law, or the deleting of the data is required earlier (namely because the data is no longer required or V-ZUG is obligated to delete the data). As a rule, shorter retention periods are applicable for operational data containing business partner data (e.g. protocols, logs). Business records, including communications, will be retained as long as V-ZUG has an interest in them (namely an interest in reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis) or is obligated to do so (by way of contract, law or other provisions). Deviating legal obligations are reserved namely with respect to anonymization or pseudonymization.

V-ZUG may use personal data of business partners with their consent (if such consent is required under applicable law), or based on other grounds recognized under data protection law, in order to provide them with information about goods or services (promotions, e.g. marketing communications, competitions or campaigns). The promotions may be carried out in compliance with the relevant applicable law, in particular on the websites of V-ZUG, third-party websites, via newsletters, by e-mail and by post (see Section II. para. 4) and/or on social networks. Further information can be found in the details on the individual promotions.

Any data subject may request information from V-ZUG as to whether data concerning them is being processed. In addition, they have the right to request the correction, deletion or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on consent, the data subject may withdraw consent at any time. In countries of the EU and EEA the data subject may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable/electronic format which allows for further use and transfer. Requests in connection with these rights shall be submitted to the data protection officer or contact unit (see Section I, para. 1). V-ZUG reserves the right to restrict the rights of the data subject in accordance with applicable law and, for instance, not to disclose comprehensive information or delete data. 

Should V-ZUG make an automated decision with respect to a certain individual which may have a legal effect for the data subject or seriously affect them in a similar way, the data subject shall have, in accordance with applicable law, the right to communicate with a responsible person of V-ZUG and to request a reconsideration of the decision or to request the prior evaluation by a person. In this case, the data subject might no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance. 

Any data subject may also file a complaint with the competent data protection authority.

V-ZUG is entitled to amend this Privacy Statement at any time and without prior notice or announcement. The latest version according to the website shall be applicable. Should the Privacy Statement form part of an agreement with business partners, V-ZUG may inform them of an update by e-mail or in another appropriate manner. The new Privacy Statement shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection, V-ZUG shall be free to terminate the agreement exceptionally and with immediate effect.

The following provisions shall supplement the provisions of the general part for certain activities of V-ZUG. In the event of any inconsistency, the following provisions shall prevail over the provisions of the general part.

In V-ZUG online shops, the creditworthiness of business partners placing orders is evaluated automatically in order to offer the purchase on account based on this decision as far as this payment option is offered at all. In this case the credit rating is evaluated on the basis of information from an external credit rating agency, which will provide V-ZUG with a credit score of the respective individual. The agency will calculate the score of the business partner based on data on the business partner’s payment, debt and insolvency history and possible limitations of his legal capacity. Should the score be below a certain threshold, no payment by invoice will be offered. If a business partner disagrees with this, he can contact the following contact unit [email protected]. V-ZUG online shops may automatically decide whether to enter into purchase agreements. However, V-ZUG does not deem this an automated individual decision within the meaning of the applicable Swiss or European data protection legislation. In the event that the business partner does not wish for a contract to be concluded automatically, they have the option of purchasing V-ZUG products and services at physical stores operated by V-ZUG and its retailers.

The term physical store includes but is not limited to exhibition stands, physical shops, sales points, outlets, shopping centres, permanent establishments, production plants, where goods and services of V-ZUG are displayed, exhibited, presented, marketed, sold or where there is information, advice and guidance on such goods and services. Stores and salespoints of business partners (including distributors) are also deemed to be physical stores. Within the scope of visits to such physical stores V-ZUG can collect personal data directly or indirectly via its business partners. Personal data includes, but is not limited to name, address, phone number, e-mail address, etc.

V-ZUG processes personal data in order to fulfil obligations arising out of or in connection with orders, deliveries, installations, fittings, calibration, acceptance (FAT/SAT), warranty claims, service and support, care and maintenance, further enquiries or transfer of information material (newsletters, product information, events, etc.). Personal data includes, but is not limited to, name, address, phone number, e-mail address, etc. The data is processed for product, customer and quality control purposes.

V-ZUG may send newsletters or other commercial communications in connection with its products and services to business partners. In accordance with applicable law V-ZUG reserves the right to do so without prior consent of existing business partners. However, these business partners may object to further mailings at any time. In other cases, V-ZUG will send such communications only upon previous request of the business partner (e.g. newsletter opt-in via a website-account, double opt-in). As part of a newsletter mailing, V-ZUG may use measuring instruments and other identifiers, e.g. tracking pixels or web beacons, to the extent permitted by applicable law. V-ZUG measures whether and when an e-mail has been opened and which linked content has been clicked on or downloaded (known as newsletter tracking). However, the business partner may block this application in his/her e-mail application. The following personal data is processed: e-mail address, IP address. This data is processed to determine the effectiveness of the newsletter and to prepare content for business partners on a more targeted basis. 

However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective website or through the link indicated in every mailing. However, the termination of one newsletter does not necessarily terminate the mailing of other newsletters. It is possible that personalized advertisements are placed during the visit to the website. Every banner advertisement displayed to the business partner contains products offered on websites which have previously been visited by the business partner. The advertisement is generated by V-ZUG by means of cookies (see Section I para. 6).

When first selecting the GuidedCooking app (the “application”), each user has the option of receiving a matching HOTPAN® Comfort 2 Litre with Bluetooth from Kuhn Rikon as a gift from V-ZUG; this option is available only once per serial number or hob, and the action is time-limited. A form must be completed for this purpose to obtain a voucher code that can then be used in the Kuhn Rikon web shop. By completing the form and then confirming the details in the e-mail link sent (double opt-in), the following personal data will be processed if the corresponding field has been filled in: title, first and last name, address and e-mail address (mandatory field).

At the same time users have the option, by placing a cross in the appropriate box, of notifying V-ZUG whether they agree to their data being collected for marketing purposes (in particular the sending of newsletters: see Section II para. 4). V-ZUG processes the data solely on the legal basis of user consent. Users may withdraw their consent at any time (see Section II para. 4). Existing data processing operations will not be affected by such withdrawal.

Users of the application may send voluntary feedback to V-ZUG. When sending feedback, users may also voluntarily submit their name and e-mail address (optional fields). If these optional input fields are not completed it will not be possible to make any inference regarding the user’s person or behaviour. The serial number of the hob will not be sent. The same procedure applies if the application crashes: in this case V-ZUG will receive a crash report but will not be able to make any inference regarding the relevant person or their behaviour.

V-ZUG collects anonymous usage data on the application by means of Google Firebase, a product of Google Inc., USA. Google Firebase uses tracking technologies that permit the use of the application by users to be analysed, e.g. for performance monitoring, error logs or to analyse user behaviour. The purpose of Google Firebase is to enable the use of the application to be analysed, regularly improved and thus made more economical to operate. The statistics collected allow V-ZUG to improve its offering and make it more attractive to users. The anonymised data is transmitted to a Google server in Ireland or the USA. Further information about Google Firebase can be found at https://firebase.google.com/ and https://policies.google.com/privacy?hl=en.

Once the user registration process has been completed in the V-Kitchen app (the application), V-ZUG will store the following personal data: last name, first name, username, user UID, e-mail address and password (collectively "user data"). Registration is confirmed by e-mail and completed by creation of a user account (double opt-in). User data is processed for the purpose of user authentication. In connection with use of the application, the following personal data is also processed and stored as log files: IP address and UID of the mobile device (smartphone or tablet). This data is processed

• to enable and simplify communication with users,

• to notify users of changes in the content of the terms and conditions of use,

• to prepare information on recipes, products, services and other offers,

• to enable use of the latest version of the app,

• to enable use of the latest version of the app,to enable use of the latest version of the app,

• to guarantee system security and stability as well as

• in aggregated and anonymized form – for statistical and analytical purposes.

For these purposes, the data can also be passed on exclusively in anonymized form to third parties. An evaluation of IP addresses is carried out only in the event of attacks on V-ZUG systems. Log files are automatically and irretrievably deleted after 3 months. The legal basis on which V-ZUG processes this data is that of fulfilment of a contract or the protection of legitimate interests.

Via their personal user account settings, users can choose to upload profile pictures and provide information on dietary preferences, intolerances and allergies. This information may be modified or removed at any time. V-ZUG processes such data on the legal basis of consent.

Within the application, a user may post, share, flag, like, report as inappropriate, rate and/or comment on contributions, recipes, including photos of dishes, stories, background information, videos, menu plans and other content (collectively "V-Kitchen content) as well as follow other users and third parties or invite these to follow them (collectively "actions"). When an action is performed, the user's username and profile picture (if provided) are displayed for other users to see. The user may themselves remove their actions from the application, making them invisible to all users. The following actions cannot be removed or undone: sharing content, inviting a user to follow, or reporting inappropriate content. The user can also activate and at any time deactivate push notifications via their personal settings. A user may select ingredients of recipes and link them with quantities ("virtual shopping basket"). The user subsequently has the option of forwarding the virtual shopping basket to a business partner of V-ZUG ("V-Kitchen partner") and there, if required, to expand their selection and make a purchase. None of the user's personal data will be passed on to V-Kitchen partners or third parties. Within the scope of the application, V-ZUG may use plug-ins (and add-ons) from social networks as well as integrate RSS feeds, graphics from other websites or links from business partners. V-ZUG does so in accordance with the principles set out in Section 1, para. 6 for social plug-ins. Processing of the user's personal data by the operator of the social network, the business partner or the V-Kitchen partner is performed under the responsibility of and in accordance with the data protection regulations of said operator or business partner. The user may uninstall the application at any time. Uninstalling the application does not automatically delete the user's personal data. A request for deletion must be sent to [email protected].

After informing users in advance, V-ZUG may record and store audio and video conferences in compliance with the statutory provisions and internal company directives. In particular, but not exclusively, the following personal data is processed: first name, last name, e-mail address, telephone number (for telephone dial-up), profile picture (optional). This personal data is processed for the purpose of know-how management or for business-related documentation or preservation of evidence in the context of legal transactions with business partners.