1. Name and contact details of the data processor responsible, the data protection officer and the location of the server

The controller in accordance with Article 4 (7) of the EU General Data Protection Regulation (GDPR) is

BERNINA International AG
Seestrasse 161
8266 Steckborn
Switzerland

Email: [email protected]
Telephone: +41 (0) 52 762 11 11 (see our legal notice)
 
You can contact our Data Protection Officer Mr. Denkinger by email at [email protected] or at the above postal address, addressing any correspondence to „the Data Protection Officer“.
  
Furthermore, you can also contact the appropriate market organization if you wish to discuss the processing of your data: [email protected]

At BERNINA, the personal data is saved at on servers in the EU.

2. Collection and storage of personal data; type and purpose of its use

When visiting the website and using the BERNINA app

When you access our website, information is automatically transferred to us via the browser on your device. When using the app, via which you can access the content of our websites bernina.com, inspiration.bernina.com and blog.bernina.com, we collect the following personal data described below in order to enable the convenient use of the functions. When you visit our website or use our app, the following data – without any action on your part – will be collected and temporarily stored in a log file:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Contents of the request (specific page)
• Access status/HTTP status code
• the amount of data transferred
• the website from which the request was received
• Browser used
• Language and version of the browser software
• Operating system and its interface
• App version

The specified data will be processed by us for the following purposes:
 

• To ensure the smooth establishment of a connection to the website or app
• To ensure convenient operation of our website or app
• To evaluate the system security and stability
• For determining the correct country site
• Other administrative purposes 

The legal basis for data processing is Art. 6 para. 1 clause lit a (if and insofar as you have given your consent to the processing of your personal data), lit. b (purchase, conclusion of contract) and lit. f GDPR (technical administration, IT security), whereby our legitimate interest consists of the aforementioned purposes for data collection.

Your data will be deleted as soon as it is no longer required and provided there are no statutory retention obligations to the contrary.
 
When you visit our website and use our app, we also use analytical services, social media bookmarks/plug-ins and website cookies. Further information on cookies and analytical services can be found under sections 4 and 5 of this privacy policy and information about social media bookmarks/plug-ins can be found under section 6. Sections 7 and 8 provide information about the integration of YouTube Videos and Google Maps.

Please note: BERNINA's websites are aimed at users all over the world. If you display content via the browser or app which is not aimed at European customers, this content is not subject to the provisions of the General Data Protection Regulation. This applies in particular to the content on www.bernina.com, www.bernette.com and the WeAllSew blog of our US branch.

Further data processing activities when using the app

When you download the app, the required information is transferred to the app store, in particular username, email address and customer number of your account, time of the download, payment information and the unique ID number of your device. We have no influence over this data collection and are not responsible for it. We process the data only to the extent that this is necessary for the mobile app to be downloaded to your mobile device.  

To use the services, we also need your device ID, the unique number of the device (IMEI = International Mobile Equipment Identity), the unique number of the network subscriber (IMSI = International Mobile Subscriber Identity), the mobile phone number (MSISDN), the MAC address for WLAN use, the name of your mobile device, your email address.

When you log in to the customer portal via the app, we process the following information that is required from you in order to clearly identify you: Customer name and password. 

Your personal data is processed for the purpose of access management based on our legitimate interests in accordance with Article 6(1f) GDPR. The legitimate interest includes but is not limited to enabling you to log in to the customer portal via the app. Once a password is assigned, there is an option to log in via touch ID/face ID (iOS) or fingerprint/face recognition (Android). This data is stored by the respective service provider. BERNINA has no influence on this data processing.
   
For the app to be used, access to the network functions (WLAN or mobile Internet/ mobile data) of your device is required. You can configure this yourself using the settings on your device (look for „settings/data protection“). This network access is necessary because the app can only be used when the device is in online mode.

We use the push service of the operating system vendors Apple Inc. and Google LLC to send you messages (hereinafter referred to as messages, push notifications or push notices). After installing the app, you will be asked by Apple Inc., as the provider, if you consent to the sending of messages. You are free to decide whether or not you want to receive push notifications. If you give your consent, a device token will be assigned by Apple Inc. The only purpose of processing the device token is to provide the push service. The device token is an encrypted device ID. Google LLC considers push notifications as a "normal" authorization. When the app is started for the first time, the Android Push Notification feature permission.notifications_enabled will be set to the value TRUE. You can revoke this authorization on the page with the app settings by setting the value to FALSE. 

Your data are deleted as soon as they are no longer required to achieve the purpose for which they were collected. Your data are therefore stored for as long as the consent to receive push notifications is active.
We evaluate push messages statistically and can therefore identify whether and when push notifications have been displayed and clicked on. This enables us to determine which push notifications interest the recipients so that we can tailor future notifications to the presumable interests of all or individual recipients and thereby increase interest in our services.
You can deactivate push notifications at any time via the settings on your device. Instructions are available from the following links:

• https://support.google.com/messages/answer/6080337?hl=en
• https://support.apple.com/en-us/HT201925

The legal basis for data processing in connection with push notifications is Art. 6 para. 1 lit. b GDPR. 

The app includes the option of geolocalization (location data – GPS data) of the user. This enables the location of the user to be indicated. These data are not sent anywhere by the software but remain on the user's device. The location data are discarded after 18 months.
The legal basis for using the user's location data is Article 6(1a) GDPR.
If the application is not to process location data, access can be denied either to the geolocation function of the mobile device altogether or – provided the relevant operating system supports this – only in respect of this application. Further information on this is available here:

• Apple iOS operating system: https://support.apple.com/en-gb/HT207092
• Android operating system: https://support.google.com/accounts/answer/6179507?hl=en

When using a contact form or contacting us via email
Applies to all websites mentioned and the BERNINA app

When using our online contact form, certain personal data is collected, the scope of which can be seen from the respective input mask. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. If necessary due to your request, the data may also be transmitted to companies affiliated with BERNINA or to independent market organizations and specialist dealers and processed by them.

The processing of data for the purpose of contacting us is made according to Article 6 para. 1 clause 1 lit. a GDPR on the basis of your voluntarily provided consent. If you contact us by email, , the data processing is based on our legitimate interest according to Art. 6 para. 1 clause 1 lit. f GDPR. If your contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted or anonymized after final processing of your request. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

When downloading free downloads from www.bernina.com and BERNINA app

On our website and app, we provide you with the option of free downloads (e.g. for test versions of embroidery software or upgrades of already purchased software). Before you can start downloading, you are required to complete a form, including providing your name, your email address, your post/zip code and your location. With your consent, we store and share this data with the respective sales organization or dealer in your area. The purpose of the processing is to create a statistical record of the downloads carried out as well as promotions and advertising on the part of BERNIINA, the respective sales organization or a dealer in your area. The legal basis for this is Article 6(1a) GDPR.
  
In addition, if you have consented to the use of your data for the purposes of sending newsletters, we will process the data for direct marketing purposes and combine it in a customer profile with other information that BERNINA has saved about you. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR.

When signing up for our newsletter
Applies to all websites mentioned and the BERNINA app

You can sign up for our newsletter to receive information about the latest trends in sewing, quilting, and embroidery as well as attractive offers from BERNINA.

When registering for our newsletter, we use the double opt-in procedure. This means that we send an email to the specified email address in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be automatically deleted.

In addition to your email address, we store the IP addresses you use and the times of registration and confirmation. The purpose of the procedure is to verify your registration and, if necessary, to investigate any possible misuse of your personal data.

In addition to your email address, on some forms, your name and/or your zip code are mandatory information for sending the newsletter. We want to send our users high-quality newsletters that are customized to their needs. In order to address you personally in the newsletter, and to tailor the newsletter to your needs, we also require your name, and in some cases your zip code, when you subscribe to the newsletter. You are neither legally nor contractually obligated to provide information. However, the use of our newsletter service is only possible if the aforementioned mandatory information is provided.

If you sign up for the BERNINA newsletter, the data you enter when registering (name, email address, interests, zip code, and additional information where appropriate) is stored for the purpose of direct marketing (including the delivery of personalized content within the newsletters but also on the BERNINA website) and may be linked to other data that BERNINA has saved about you.

Please note that we use our newsletter to evaluate your user behavior. This may be done using an algorithm or manually. If you click on a link in a newsletter, you will be directed to one of our websites via a Salesforce Marketing Cloud server. Salesforce Marketing Cloud evaluates various parameters, e.g. when you click which links in the newsletter and which of our pages you visit. To evaluate user behavior, we link the data generated in this way with other user data, in particular data collected via a Salesforce Marketing Cloud cookie (for more information, see Section 5 "Salesforce.com, Inc." of this privacy policy below). We use the aforementioned data to create a user profile in order to tailor our digital offers such as the newsletter or websites to your individual interests.

For sending newsletters and the subsequent evaluation of your user behavior, we use solutions from the external service provider Salesforce.com, Inc., Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA. This may result in Salesforce.com, Inc. having access to your personal data. The collected data is stored on Salesforce.com, Inc. servers.

In addition to the aforementioned user analysis by Salesforce Marketing Cloud services, some of the services offered by Email on Acid, 5500 Greenwood Plaza Blvd, Suite 220, Greenwood Village, CO 8011174112 18 , USA, a company of Sinch Sweden AB, Lindhagensgatan 74, 112 18 Stockholm, Sweden, are also used, whereby the above statements on data collection/processing and user analysis by Salesforce Marketing Cloud apply accordingly to Email on Acid's analysis and tracking services.

In addition, we use the services of Email on Acid to test the presentation of newsletters on different email platforms and on different mobile devices. In isolated cases, this can result in the transmission of personal data to Email on Acid.

Email on Acid processes this data exclusively on behalf of and in accordance with the instructions of BERNINA.

For sending newsletters and the subsequent evaluation of your user behavior, we use solutions from the external service provider MailChimp, The Rocket Science Group, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. This may result in MailChimp having access to your personal data.

The legal basis for the aforementioned data processing is Art. 6 para. 1 clause 1 a) of the GDPR or, insofar as consent has not been granted in individual cases, Art. 6 para. 1 clause 1 f) of the GDPR.

You can revoke your consent to receiving the newsletter and unsubscribe from the newsletter at any time. You can declare that you revoke your consent by clicking on the link provided in each newsletter email, by sending an email to [email protected] or by sending a message to the contact details given in the imprint. This applies equally to an objection against commercial use in the event that you have not given consent to the sending of newsletters.

The data collected in relation to this will be stored until the consent is revoked.

When creating a BERNINA account
Applies to bernina.com, blog.bernina.com, inspiration.bernina.com and the BERNINA app

In order to use services such as the BERNINA customer portal or the Accessories Organizer on the BERNINA app, you must first register by providing your email address and a password of your choosing. The username (= email address) and the encrypted password are stored in the Azure cloud service provided by the Microsoft Corporation, One Microsoft Way Redmond, WA 98052-6399, USA, on servers in the EU. For this registration, we use what is known as an «invitation code», which means your registration is not complete until you confirm the registration using a code sent to you by email. 
 
We send this email using the Mailjet program. Mailjet is operated by Mailgun Technologies, Inc., 112 E Pecan St #1135, San Antonio, TX 78205, USA - a company of Sinch Sweden AB, Lindhagensgatan 74, 112 18 Stockholm, Sweden - with which we have concluded an appropriate data processing agreement. Mailjet's data centers are located in the EU exclusively. Mailjet processes your email address for the fulfillment of its contractual obligations and stores it only for the period necessary for the provision of the services. Through its certification in accordance with ISO 27001 (https://www.mailjet.com/resources/learn/gdpr/mailjet-first-esp-iso-27001-and-gdpr-certified/), Mailjet, as a GDPR-compliant email service provider, guarantees compliance with the data protection regulations of the EU. In addition, Mailjet provides further information regarding data protection at https://www.mailjet.com/security-privacy/.

Alternatively, you can log in using a federated login via your Google, Apple or Facebook account. By registering with Google, Apple or Facebook, data is exchanged with these providers. For the registration, we receive only the information absolutely necessary for this purpose from the service providers:

Facebook
The following data is transmitted from Facebook to BERNINA: 

Category «Public Profile»
The Public Profile authorization makes it possible to read standard public profile fields. The permissible use of this authorization is to authenticate users and provide you with a personalized experience. This authorization is automatically granted by Facebook and is not used by BERNINA. 
 
Category «Email»
The email authorization allows you to read a person's primary email address. The permitted use for this authorization is to allow users to log in with the email address that is linked to their Facebook profile. This authorization is granted automatically by Facebook.

Google
The following data is transmitted from Google to BERNINA:

Google sends an ID token to BERNINA. Access to the token is reduced to the required minimum. BERNINA only uses the "email" and "sub" information for the authentication.  

 

• Email: The user's email address. This value may not be unique for this user and cannot be used as a primary key.
• Sub: An identifier for the user that is unique in all Google accounts and is never reused. A Google account can have multiple email addresses at various points in time. However, the sub value remains unchanged.

Apple
Sign in with Apple is a preconfigured service provided by Apple Inc. over whose function BERNINA has no influence. The service is designed to process personal data in accordance with the applicable Apple data protection regulations. 

Further information about Sign in with Apple can be found here: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/

When using our customer portal and product registration at www.bernina.com or via the BERNINA app

If you wish to use our customer portal, you must register, see section 2, "When creating a BERNINA account". 

In our customer portal, you can view, change, and add to the personal information that we have on record for you at any time. We use this information for customer data management and, if necessary, to process any warranty claims as well as to personalize advertising. Additionally, you can register your BERNINA products, upload your own products with an image, sign up for the BERNINA newsletter, and identify topics that you are particularly interested in.
 
When you register a product, we store the data you provide: Serial number, date of purchase, selected retailer and the product. If you also complete the optional questionnaire as part of the product registration process, we store this information as well and link it to your product registration, see also section 2 below "When participating in online surveys". We use this data for the purpose of customer data management and, if necessary, to provide any services resulting from product registration (depending on the country) and for personalized direct marketing. 

You can find more information about data protection when using the newsletter service in "When registering for our newsletter" above in this privacy policy.
 
Information that you provide in the customer portal may be linked to other information we have saved about you in a customer profile. In doing so, we comply with the principle of purpose limitation and only link data that has been collected for the same purposes (e.g. for personalized advertising). BERNINA can provide dealers, suppliers, or service providers with information from your customer profile if you have given your consent, which is revocable at any time, to this submission or if the transmission of this information is necessary in order to process your request. BERNINA will only transmit your data to third parties to the extent required. These third parties are obligated to adequately protect your data and to use it in conformity with the law.
 
The legal basis for the processing of your data when using the customer portal is Article 6(1a) (consent) and 6(1b) (performance of a contract). The customer portal is freely available, but only on provision of mandatory information, including last name and first name. Any country-specific services arising from product registration can only be provided once the product has been registered.
 
Users can delete their account themselves by going to «My Account» in the customer portal. In this case, the login (see section 2, "When creating a BERNINA account") will be deleted and access to the customer portal will be terminated. If, by means of this deletion, the purpose for which the data is stored ceases to apply, the entire profile is deleted automatically. Alternatively, you can also erase individual items of your personal data stored in the customer portal at any time.

All of your stored data may be deleted upon request. More information about your information and consent revocation rights is available in Section 10 of this privacy policy. In all other respects, your data will be deleted when the purpose for which the data was collected no longer exists.

When using the Accessories Organizer in the BERNINA app

You must register in order to use the Accessories Organizer in the BERNINA app, see section 2 "When creating a BERNINA account". 
 
If you want to register products on the Accessories Organizer lists in the app, we will save the information you provide and use it for the purposes of customer data administration and for personalized direct advertising
.
If you upload your own product via the BERNINA App, we store the data you provide (name of the product and image / photograph) and use it for the purpose of customer data management and personalized direct advertising. The upload function is to be used exclusively for product information. In principle, you are the author of the photographs you have taken yourself. It is expressly forbidden to store particularly sensitive personal data or inappropriate or illegal content. This includes, among other things, images and photographs in which persons can be recognized whose consent cannot be proven or for which you have no right of use. Random samples of uploads are checked manually and illegal content is removed immediately. 

Information that you provide in the Accessories Organizer in the BERNINA app may be linked to other information we have saved about you in a customer profile. In doing so, we comply with the principle of purpose limitation and only link data that has been collected for the same purposes (e.g. for personalized advertising). BERNINA can provide dealers, suppliers, or service providers with information from your customer profile if you have given your consent, which is revocable at any time, to this submission or if the transmission of this information is necessary in order to process your request. BERNINA will only transmit your data to third parties to the extent required. Our service providers are obligated to adequately protect your data and to use it in conformity with the law.

When using our blog blog.bernina.com (also possible via the BERNINA app) 

In order to use certain functions of the BERNINA blog, such as creating a community profile or a personal project watch list, you must register – see section 2, "When creating a BERNINA account". Once successfully logged in, the mandatory information specified by you when registering (name, email address, country) as well as any additional data you provide to supplement your profile, are saved for the purpose of the blog and for direct marketing purposes and, where appropriate, are linked to other data that BERNINA has saved about you.

Using your blog profile, you can share topics, posts, links, comments, photos, sketches, instructions, etc. If you carry out such an action, we will save this internally, publish your action in the BERNINA blog and use these activities, where appropriate, to provide personalized content. Based on your uploaded projects (number of articles written, categories, participation in interactive campaigns, tags used to describe articles, first/last entry) we will try to draw conclusions about your interests and use this information for direct marketing purposes. 
 
We require your name so that we can indicate you as the author of projects/comments and address you personally, and we require your country for assignment to a market organization. You are neither legally nor contractually obligated to provide information. Use of our blog, however, is only possible if the required information specified above has been provided.
 
If you want to leave a comment in the blog, a spam check is carried out in order to prevent misuse of our blogs. As part of this, your email address and your IP address will be saved and compared against a local blacklist. In addition, we use the "Anti Spam Bee" plug-in to help detect spam. All of the checks noted above are carried out locally on our servers. No personal data is transferred to third parties. Once the above tests have taken place, your comment, along with your first name and last name, will be published. In addition, the author of the post you commented on receives an alert about your comment which also includes your first and last name.
 
The photos you upload to the blog must first be compressed. We use the Optimus image optimizer from the external service provider proinity GmbH, Rümikerstrasse 60, 8409 Winterthur, Switzerland, to perform this image compression. proinity GmbH compresses the photos and then, after the transfer process has been completed, immediately erases all cached data. No personal data remains on the service provider's servers. Your data is processed by proinity GmbH exclusively on behalf of and in accordance with the instructions of BERNINA subject to these data protection regulations.

You can also sign up for our special blog newsletter. The  instructions under "When registering for our newsletter" above shall apply for the blog newsletter.
 
We use the Mailjet program to send emails generated by the blog (e.g. information about a new comment). Mailjet is operated by Mailgun Technologies, Inc., 112 E Pecan St #1135, San Antonio, TX 78205, USA - a company of Sinch Sweden AB, Lindhagensgatan 74, 112 18 Stockholm, Sweden - with which we have concluded an appropriate data processing agreement. Mailjet's datacenters are located in the EU exclusively. Mailjet processes your email address for the delivery of emails to you. Mailjet collects personal data for the fulfillment of its contractual obligations and stores these data only for the period necessary for provision of the services. Through its certification in accordance with ISO 27001 (https://www.mailjet.com/resources/learn/gdpr/mailjet-first-esp-iso-27001-and-gdpr-certified/) Mailjet, as a GDPR-compliant email service provider, guarantees compliance with the data protection regulations of the EU. In addition, Mailjet provides further information regarding data protection at https://www.mailjet.com/security-privacy/. 

The legal basis for the processing of your data in the BERNINA blog is Article 6(1a) GDPR (consent).
 
The data collected in the context of our blog will be stored until the consent is withdrawn.

Please refer to the special terms and conditions of use of the BERNINA-Blog. For information about your rights under  the EU Digital Services Act and the contact points and procedures provided by BERNINA, please visit  https://www.bernina.com/digital-services-act.

When using our webshop inspiration.com (also possible via the BERNINA app)

If you wish to order something from our web shop, in order to conclude the contract, you are required to provide the personal data necessary to process your order (mandatory information). The mandatory information required to process the order is marked separately. We process the data you provide for the purpose of processing your order.
 
Customers who wish to purchase a subscription can do so after registering or logging in with their customer account. This ensures that subscription customers have access to their subscription at all times and can manage it independently. For example, credit card details can be updated in the personal customer account, or the subscription can be canceled or extended before it expires. In addition, customers of the digital subscription have 24/7 access to the downloads (patterns, instructions, embroidery designs) of the individual issues included in the subscription. Customers of a single issue or single pattern can also create a customer account, giving them access to their order history and any purchased downloads whenever they need them.

Before you can create a customer account, you must first authenticate yourself, see section 2, "When creating a BERNINA account". The personal data you have provided, alongside your previous purchases, will be stored in this customer account unless consent is withdrawn. The data specified above may be linked to other information we have saved about you in a customer profile. In doing so, we comply with the principle of purpose limitation and only link data that has been collected for the same purposes (e.g. for personalized advertising).

If you order print media, we will pass on your data to our logistics partner, Medienwerkstatt AG, Steinackerstrasse 8, 8583 Sulgen, Switzerland.  They are responsible for shipping single issues ordered and issues covered by a subscription. If you pay by credit card or PayPal, we will pass on your payment details to the payment service provider Worldline Schweiz AG, Hardturmstrasse 201, 8005 Zürich, Switzerland. Credit card and PayPal data are stored and processed exclusively by Worldline Schweiz AG. BERNINA does not save or process your payment data.
 
Due to commercial and tax regulations, we are obliged to save your address and order data for a period of ten years. If you have ordered as a guest, your data will be deleted when the purpose for which the data was collected no longer applies and there is no legal basis for its continued storage. As a registered customer, your order data is also available in your customer account until consent is withdrawn. 

In your customer account, you can edit or erase all optional data yourself under „Addresses“ or „Profile data“. Your entire customer account can be deleted on request (which you can send to [email protected] for example). More information about your information and consent revocation rights is available in Section 10 of this privacy policy.

The legal basis for the processing of your data is Article 6(1b) (purchase, conclusion of contract), and additionally, when creating a customer account and making a purchase as a registered customer, Article 6(1a) (consent).
 
We use the Mailjet program to send emails generated by the web shop (e.g. order confirmation or invoice). Mailjet is operated by Mailgun Technologies, Inc., 112 E Pecan St #1135, San Antonio, TX 78205, USA - a company of Sinch Sweden AB, Lindhagensgatan 74, 112 18 Stockholm, Sweden - with which we have concluded an appropriate data processing agreement. Mailjet's data centers are located in the EU exclusively. Mailjet collects and processes the following data: Your email address for the delivery of every email. In addition, your title, first name, last name, billing and (if different) delivery address (street and house number, postal code, town, country, state) as well as any company name given by you, if you have provided all of these data, are processed and stored by Mailjet in the context of an order for the purpose of delivering an order confirmation and invoice. Mailjet collects personal data for the fulfillment of its contractual obligations and stores these data only for the period necessary for provision of the services. Through its certification in accordance with ISO 27001 (https://www.mailjet.com/resources/learn/gdpr/mailjet-first-esp-iso-27001-and-gdpr-certified/) Mailjet, as a GDPR-compliant email service provider, guarantees compliance with the data protection regulations of the EU. In addition, Mailjet provides further information regarding data protection at https://www.mailjet.com/security-privacy/.

The legal basis for sending these notifications is our legitimate interest pursuant to Article 6(1f).

When participating in online surveys
The following applies for www.bernina.com and the BERNINA app

Online surveys can be carried out on our websites and in the app. As a rule, these surveys are anonymous and are therefore not subject to data protection. 

An exception to this is the online survey as part of product registration, where a personal reference is established. Legal basis for this survey is the consent of the user (Art. 6 para. 1 clause 1 lit. a), as the survey relates directly to the previously registered product. The information provided in this online survey will be evaluated by BERNINA . The subsequent use of the data is described in Section 2 of this privacy policy «When using our customer portal and product registration at www.bernina.com». 

If you delete a registered product yourself, the answers to the survey will be retained. Only the reference to the registered product is deleted. All of your stored data may be deleted upon request. More information about your information and consent revocation rights is available in Section 10 of this privacy policy. In all other respects, your data will be deleted when the purpose for which the data was collected no longer exists.

The system used for the online surveys is "Customer Voice" from Microsoft. Further information on data protection can be found here: https://learn.microsoft.com/en-gb/dynamics365/customer-voice/privacy

3. Use of service providers, communication of data

BERNINA uses selected external service providers to provide support and administrative tasks for our web store. These service providers have access to your personal data. The service provider processes your data solely on behalf of and in accordance with the instructions of BERNINA and in compliance with this privacy policy and the applicable laws.

We currently use the following service providers:
 

In order to ensure the technical implementation and security of the systems and to enable delivery to customers, other service providers are also given access to the systems as part of their fulfillment purpose. These service providers are checked and compliance with data protection is ensured through appropriate certifications and contracts. At the customer's request, a corresponding order data processing list can be requested from the data protection officer.

Your personal data will only be transferred to third parties to the extent that the lawfulness of the processing fulfills one of the following conditions:

• You have given your explicit consent in accordance with Art. 6 para. 1 clause 1 lit. a of the GDPR.
• In accordance with Art. 6 para. 1 clause 1 lit. f of the GDPR, the disclosure is required in relation to the assertion, exercise or defense of legal claims, or for the delivery of our website or app and there is no reason to believe that you have an overriding legitimate interest in the non-disclosure of your information
• In the event that the disclosure is a legal obligation in accordance with Art. 6 para. 1 clause 1 lit. c of the GDPR
• The disclosure is permitted by law and is required to conclude a contractual relationship with you in accordance with article 6 para. 1 clause 1 lit. b of the GDPR.

4. Cookies

BERNINA uses cookies on this website or app. Cookies are small pieces of text information, which are stored by your browser (e.g. Internet Explorer or Mozilla Firefox) on your computer's hard drive or by your app in the device memory of your mobile device and which allow the flow of specific information to us. This does not mean, however, that we can immediately determine your identity.
 
On the one hand, the use of cookies serves to make using our website and app more convenient for you. This is why we use so-called session cookies, to recognize that you have already visited individual pages of our website or app. These are automatically deleted after leaving our site or app.
 
In addition, we also use temporary cookies to enhance the user experience; these are stored for a specific length of time on your device. Should you revisit our site or app to make use of our services, it will automatically detect that you previously visited, what you entered, and which settings you selected so that you do not have to enter them again.
 
We also make use of cookies to capture statistical data on the use of our site or app and to evaluate it in order to optimize our website and app tto you (see sections 5 and 6 of this privacy policy). When visiting again, these cookies allow our website or app to automatically detect that you have previously visited us. These cookies are automatically deleted after each defined period of time.
 
The data processed by the cookies is necessary to protect our legitimate interests for the aforementioned purposes as well as those of third parties in accordance with Article 6(1f) GDPR.

You can configure your browser settings or the settings of your mobile operating system and the app according to your wishes and refuse, for example, to accept third-party cookies or all cookies. If you opt out of the use of cookies, your ability to use every function on this website or app to its fullest extent could be limited.
 
The legal basis for the use of cookies is Article 6(1a) GDPR based on your consent. Strictly necessary cookies shall be set based on Article 6(1f) GDPR.

Overview of cookies used

You can find more information about the cookies we use on the respective websites and the option to change your cookie settings in our cookie lists:
 

• www.bernina.com
• blog.bernina.com blog.bernina.com blog.bernina.com blog.bernina.com
• inspiration.bernina.com inspiration.bernina.com inspiration.bernina.com inspiration.bernina.com inspiration.bernina.com inspiration.bernina.com
• www.bernette.com

5. Web and app analysis

Google Analytics
Applies to all websites mentioned and BERNINA App

If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The controller for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland („Google“). 

Type and purpose of the processing
Google Analytics uses cookies that enable your use of our website to be analyzed. The information generated by the cookie about your use of the website is usually transmitted to and stored on a Google server in the USA.

Google Analytics collects additional information about users who have activated personalized adverts (interests and demographic data) and adverts can be delivered to these users in remarketing campaigns.

With Google Analytics 4, IP addresses are anonymized by default. Owing to IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. 

While you are visiting our website, your user behavior is being recorded in the form of „events“. Events may include: 

• Page views 
• First visit to the website 
• Start of the session 
• Websites visited
• Your „click path“, interaction with the website 
• Scrolls 
• Clicks on external links
• Internal search queries 
• Interaction with videos 
• File downloads 
• Adverts viewed/clicked on
• Language setting 

The following is also recorded: 

• Your approximate location (region) 
• Date and time of your visit
• Your IP address (in shortened form) 
• Technical information about your browser and the end devices you use (e.g. language setting, screen resolution) 
• Your Internet provider 
• The referrer URL (the website/advertisement via which you accessed this website)

Purposes of the processing
On behalf of the operator of this website, Google will use this information to analyze your pseudonymized use of the website and to compile reports on website activity. The reports prepared by Google Analytics are used to analyze the performance of our website and the success of our marketing campaigns. 

Recipients
Recipients of the data are/may be 

• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as data processor pursuant to Article 28 GDPR) 
• Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA 
• Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Third-country transfer
The European Commission adopted its adequacy decision for the USA on July 10, 2023. Google LLC is certified under the EU-US Privacy Framework. Since Google servers are distributed around the world and data transfer to third countries (for example, Singapore) cannot be ruled out completely, we have also concluded the EU standard contractual clauses with the provider. 

Storage period
The data sent by us and linked to cookies is erased automatically after 14 months. The maximum lifespan of Google Analytics cookies is two years. Once per month, any data that has reached the end of its retention period is automatically erased. 

Legal basis
The legal basis for this data processing is your consent in accordance with Article 6(1a) GDPR. 

Withdrawal of consent
You can withdraw your consent at any time with effect for the future by accessing the Cookie settings and changing your selection there. This does not affect the lawfulness of the processing conducted on the basis of the consent before the consent was withdrawn.

As well as deactivating cookies in general (see Section 4 of this privacy policy), you can prevent Google from collecting and processing the data generated by the cookie and related to your use of the website (including your IP address) by
 

1. not giving your consent to cookies being placed on your device or withdrawing such consent, or
2. downloading and installing the browser add-on to deactivate Google Analytics .

You can find more detailed information on the terms of use of Google Analytics and data protection at Google by visiting https://marketingplatform.google.com/about/analytics/terms/gb/ and at https://policies.google.com/?hl=en.
 

Google Tag Manager
Applies to all websites mentioned and BERNINA app

BERNINA uses Google Tag Manager, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Using this service, website tags (tags are small code elements on the website that among other things, are used to measure traffic and visitor behaviors) can be managed via one interface. Google Tag Manager itself captures aggregated data for monitoring the stability and performance of the system. However, this data does not include IP addresses or other user-specific identifiers that could be assigned to a specific individual (see https://support.google.com/tagmanager/answer/9323295?hl=en). Its sole purpose is to trigger other tags, which in turn may capture data. Google Tag Manager does not, however, have access to this data. If disabled at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. 
 
The information under Item 5. "Google Analytics" with respect to Google as a third-party provider shall apply mutatis mutandis.

Salesforce.com, Inc.
Applies to www.bernina.com, blog.bernina.com and BERNINA app

BERNINA uses the Marketing Cloud service of Salesforce.com, Inc, Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA, which uses cookies to analyze user behavior on the website. We use them to analyze which of our websites are visited by users and which products users are interested in so that we can present content tailored to their needs and for direct advertising purposes. The data from the analysis of user behavior is recorded anonymously or, if possible, in user profiles. User behavior may be evaluated using an algorithm or manually. 

For the evaluation of user behavior, the information about the use of the website is linked to an individually generated customer ID and, if necessary, to other data, e.g. with information that we generate about the use of our newsletter (see section 2. "above when registering for our newsletter"), with information about actions taken by the user on our website and with other data that may already be stored in a customer profile about the respective user. User behavior is recorded in a user profile and evaluated if the corresponding consent has been given. If such consent has not been provided, the cookie only records anonymous data of the user.
 
The use of Salesforce.com, Inc. services may result in Salesforce.com, Inc. having access to your personal data. Salesforce.com, Inc. processes your data exclusively on behalf of and in accordance with the instructions of BERNINA. The collected data is stored on Salesforce.com, Inc. servers. 

Further information on data protection at Salesforce can be found at https://www.salesforce.com/privacy/products/.
 
The cookies used by Salesforce are classified as "cookies for marketing purposes". You can disable "cookies for marketing purposes" at any time via our cookie lists.

The legal basis for this is Article 6(1a) GDPR, insofar and to the extent that consent is given.

Bryj Technologies, Inc.
Applies to the BERNINA App

Our app and website use a web analysis service provided by Bryj Technologies, Inc., 5 Third Street, Suite 520, San Francisco, CA 94103, USA („Bryj“). By using Bryj we want to ensure a needs-based design and the continuous optimization of our website and to analytically record the use of our website in order to optimize our service for you. The legal basis for this is Article 6(1a) GDPR, insofar and to the extent that consent is given. Where technically necessary and/or this is required in order to protect our legitimate interests: Article 6(1f) GDPR. When downloading the app from the Google and Apple app stores, anonymous data from the relevant app store is transferred to Bryj. 

Bryj collects personal data for the fulfillment of its contractual obligations and stores these data only for the period necessary for provision of the services. We have concluded an order processing agreement with Bryj.

You can specify the extent of the data collection and storage when you give consent to the enabling of "performance cookies". You can disable this setting at any time via our cookie lists . 

If you have consented to the enabling of "performance cookies", the data collected by Bryj includes the following:

• Device ID
• Application ID
• Push Token
• Notification Authorization Status
• SDK Platform
• Public Key
• Authentication Secret
• Device Type
• Application Version and Build Number
• Country Code
• Device Model
• Language
• Mobile Network Code
• Mobile Country Code
• Time Zone
• Time Zone Name
• Operating System Version
• Is Device Jailbroken
• Interface Ideom
• SDK Version
• Session Timeout
• … 

If you objected to the storage of "performance cookies", Bryj still collects the following data (minimal data collection):

• Device ID
• Application ID
• Push Token
• Notification Authorization Status
• SDK Platform
• Public Key
• Authentication Secret

Bryj will use this information on our behalf to evaluate your use of the app/website, to compile reports about app/website activities and to provide other services associated with use of the app/website.

Third-party information: Bryj, 5 Third Street, Suite 520, San Francisco, CA 94103, USA, Privacy Policy: https://bryj.ai/privacy.

6. Use of social media links and plug-ins

Social Media Links on www.bernina.com, blog.bernina.com, inspiration.bernina.com and BERNINA app

On our website and/or app, we use links to our social media profiles on Facebook, Instagram, X (Ex Twitter) Flickr as well as YouTube in order to raise the awareness of the profiles of BERNINA.
 
These services are only included as links to the relevant social networks. No data can be transferred to the providers of the social networks if you do not click on the respective links. After clicking on the embedded links, you will be redirected to the page of the respective provider. Only then will user information be transmitted to the respective provider.
 
Addresses of the relevant providers and URLs with their privacy policies:
 
a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; https://www.facebook.com/policy.php. , for further information on data collection on websites, use the "Like" button: https://www.facebook.com/help/186325668085084.

b) Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA. Further information on data collection: https://help.instagram.com/155833707900388.

c) X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Further information on data collection: https://twitter.com/en/privacy. 

d) Flickr: Oath, Inc., Oath, Inc. 770 Broadway Fl 4 New York, NY 10003-9558, USA. Further information on data collection: https://policies.oath.com/ie/en/oath/privacy/products/flickr/index.html.

e) YouTube LLC., 901 Cherry Ave., San Bruno, CA 94066, USA. Further information on data collection: https://policies.google.com/privacy?hl=en. 

Social media plug-ins on www.bernina.com, blog.bernina.com and BERNINA app
 
On the basis of Article 6(1f) GDPR, we use a social media plug-in from the Pinterest social network on the article pages on our blog to raise the awareness of BERNINA and to allow our users to share content with friends and acquaintances. The underlying purpose of advertising is considered a legitimate interest within the meaning of the GDPR.
 
If you access a page that contains a social media plug-in from Pinterest, no personal data will be initially passed on to Pinterest. Only when you click on the social button of the Pinterest plug-in provider will you establish a connection to the Pinterest server. By creating a connection to the Pinterest server, log data will be transferred to Pinterest. This log data may include your IP address, the address of sites you have visited that also contain Pinterest features, the type of browser and its settings, the date and time of the request, how you use Pinterest and cookies. Personal data may therefore be transmitted to Pinterest and stored (possibly in the USA).
 
We have no control over the data collected and the data processing operations, nor are we aware of the full scope of the data collected by Pinterest, the purposes of the processing, and the retention periods. We also have no information with respect to deleting the data collected by Pinterest. Responsibility for operations that comply with data protection is to be guaranteed by Pinterest.
 
Pinterest stores the data collected about you as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged-in) for the presentation of demand-oriented advertising and to inform other Pinterest users about your activities on our website or app. You have the right to object to the creation of this user profile and you must contact Pinterest to exercise this.
 
The data transfer takes place irrespective of whether you have an account with Pinterest and are logged in. If you are logged in to Pinterest, your data that is collected from us will be associated directly with your Pinterest account. If you press the button and, for example, link to the page, Pinterest also saves this information in your user account and communicates this to your contacts publicly.
 
For more information on the purpose and scope of the data collection and its processing by Pinterest, please read the privacy policy of Pinterest which is linked below. You will also find further information about your rights and settings options pertaining to the protection of your privacy:
 
Pinterest Europe Ltd. Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Irland, https://policy.pinterest.com/en/privacy-policy.

7. Integration of YouTube videos

Applies to www.bernina.com, blog.bernina.com, www.bernette.com and BERNINA App

We have integrated YouTube-Videos from YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA („YouTube“), in our online website and app, which are stored on https://www.youtube.com and can be dsiplayed driectly from our website or app. The YouTube videos are integrated for the purpose of ensuring a comfortable user experience of the website or app. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR (consent).

The YouTube videos on our website and app are all embedded in „enhanced privacy mode“, which means that no data about you as a user is transferred to YouTube if you are not playing videos. Only when you play a video, will the following data will be transmitted to YouTube. There is nothing we can do about this data transfer.
 
By playing a video, YouTube receives information showing that you have accessed the corresponding subpage of our website or app. Log data as per section 2 of this policy is also transferred. This happens regardless of whether YouTube provides a user account that you are logged in to, or if there is no user account. If you are logged in to Google, your data will be associated directly to your account. If you do not want this to be associated with your profile on YouTube, you must log out before visiting our website or app. YouTube stores your data as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged in) for the delivery of demand-oriented advertising and to inform users of other social networks about your activities on our website or app. You have the right to object to the creation of this user profile and you must contact YouTube to exercise this.
 
YouTube is an affiliated company of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For more information on the purpose and scope of the data collection and its processing by YouTube, please look at the Google Privacy Policy. You will also find further information about your rights and settings options pertaining to the protection of your privacy: https://policies.google.com/privacy?hl=en Google operates data centres worldwide (inside and outside the EU, USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

8. Google Maps

Applies to www.bernina.com, blog.bernina.com, www.bernette.com and BERNINA app

On this website or app we use a service from Google Maps by Google LLC., 1600 Amphitheater Parkway, Mountainview, California 94043, USA („Google“). This allows us to show you interactive maps directly on the website or app and allows you to conveniently use the map feature. The legal basis for this is Art. 6 para. 1 clause 1 lit. a of the GDPR (consent).

By visiting the website or app, Google receives the information that you have accessed the corresponding sub-page of our website or app. In addition, the data specified under Section 2 of this declaration is transmitted to Google. This happens regardless of whether Google provides a user account that you are logged in to, or if there is no user account. If you are logged in to Google, your data will be associated directly to your account. If you do not want this to be associated with your Google profile, you must log out before visiting our website or app. Google stores your data as a user profile and uses it for the purposes of advertising, market research and/or tailor-made website design. Such an assessment is carried out in particular (also for users who are not logged in) for the delivery of demand-oriented advertising. You have the right to object to the creation of this user profile and you must contact Google to exercise this.
 
To best protect your data, we have signed a contract processing agreement with Google
.
More information on the purpose and scope of the data collection and its processing by Google can be found in the Google data protection policy. You will also find further information about your rights and settings options pertaining to the protection of your privacy: https://policies.google.com/privacy?hl=en. Google operates data centers worldwide (inside and outside the EU and USA). We do not know whether your data may also be transmitted by Google to servers outside the EU and USA.

9. Data security

When you visit the website, we use the widely used TLS (Transport Layer Security) protocol in conjunction with the highest encryption level supported by your browser. We also take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. However, BERNINA cannot guarantee the security of the data transmitted by you as a user. Any transmission of data is undertaken at your own risk.

10. Your rights

You have the right:

• In accordance with Article 15 GDPR, to request information about your personal data processed by us. In particular, you can request information on the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the planned storage period, the right to modifications, deletion, limitation of processing or contradiction, the existence of the right to appeal, the origin of the data insofar as it was not collected from us, and the existence of automated decision-making, including profiling and, where appropriate, descriptive information about the details thereof
• in accordance with Art. 16 of the GDPR to immediately request the correction of inaccurate or the completion of personal data stored by us
• in accordance with Art. 17 of the GDPR to request the deletion of your personal data stored by us, insofar as the processing is not required for the exercise of the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal rights
• in accordance with Art. 18 of the GDPR to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you reject its deletion and we no longer need the data, yet you need this to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 of the GDPR
• in accordance with Art. 20 of the GDPR, to receive your personal data, which you have provided to us, in a structured, common and machine-readable format or to request its transmission to another responsible person
• in accordance with Art. 7 para. 3 of the GDPR, to revoke the consent granted to us at any time. The consequence is that we are no longer allowed to continue data processing, based on this consent, in the future.

To exercise the aforementioned rights, please send an email to  [email protected] or send us a message to the contact details given in the Legal notice

Right to object
If we process your personal data to protect legitimate interests as defined in Article 6(1f) GDPR, you have the right to object to this processing on grounds relating to your particular situation in accordance with Article 21(1) GDPR. You can object to the processing of your data for direct marketing purposes at any time and without reason, in accordance with Article 21(2) GDPR. In order to exercise your right to object, it is sufficient to send us an informal notification, e.g. via email to info@bernina.
 
Right to lodge a complaint:
If you believe that the processing of personal data concerning you is in breach of the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority in accordance with Article 77 GDPR.

11. Currency of and amendments to this privacy policy

This privacy policy is currently valid and was last updated on July 11, 2024.
  
As a result of the further development of our website or app and offerings, or due to amended statutory or regulatory requirements, it may be necessary to modify this privacy policy. The respective current privacy policy can be consulted at any time on our website https://www.bernina.com/privacy or in our app and can be printed out.