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Privacy policy

Privacy policy Diction Ltd.
Diction Ltd, Bahnhofstrasse 32, 9470 Buchs (SG) – Switzerland (Diction)

We are delighted that you are interested in our company and the services we offer. Diction Ltd (hereinafter referred to as Diction) takes the protection of your personal data very seriously. Data protection is of considerable importance to Diction’s management team. Our employees and the carefully selected individuals we commission are familiar with data protection requirements. They implement these with the necessary care and in accordance with our high quality standards.

1. Name and address of the controller and the data protection advisor or data protection officer
The controller within the meaning of the Swiss Data Protection Act (DSG; Art. 10) and the General Data Protection Regulation (Art. 4(7) GDPR) and other data protection laws applicable in the Member States of the European Union, as well as other provisions of a data protection nature, is:
Diction Ltd, headquartered at Bahnhofstrasse 32, P.O. Box 249, 9471 Buchs (SG) – Switzerland
Managing Director: Patrick Fassbender
Telephone: +41 81 750 53 33
Email: beratung@diction.ch
Website: www.diction.ch

UID: CHE-114.124.005 (registered in the commercial register; see www.zefix.ch)
Diction Ltd, Bahnhofstrasse 32, 9471 Buchs (SG) – Switzerland

Data Protection Officer (hereinafter referred to as DPO):
PROLIANCE Ltd.
www.datenschutzexperte.de
Leopold Street 21
80802 Munich
Email: datenschutz@diction.ch

Position of the DPO
In its additional role as DPO, Diction ensures that the DPO is properly and promptly involved in all questions relating to the protection of personal data and is supported by the controller in the performance of its duties.
The independence of the DPO and his or her professional qualifications and expertise in the field of data protection law and practice necessary to perform his or her duties are guaranteed.

2. Definitions
Our privacy policy should be simple and understandable for everyone. This privacy policy generally uses the official terms of the General Data Protection Regulation (GDPR). The official definitions are explained in Article 4 of the GDPR.

3. Data protection – General information
We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy, in particular in accordance with the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (2016/679) of 27 April 2016 (GDPR).

The use of www.diction.ch, other websites belonging to us or our apps (hereinafter referred to as “website”) is generally possible without providing personal data. However, if a data subject wishes to use special services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

We would like to point out that data transmission over the Internet (e.g. when communicating by e-mail) may be subject to security vulnerabilities despite the high security standards we have implemented.

It is not possible to completely protect data from access by third parties.

As the affected (natural) person, it is in your personal interest to secure the system(s) you use (PC, laptop, etc.) against unauthorised access by third parties, to provide them with adequate password protection and not to disclose the password to third parties, as well as to install and update a recognised virus protection programme (Internet Security).

4. Collection of general data and information
The Diction website collects a range of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files.
The following data may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (known as the referrer), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serves to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Diction does not draw any conclusions about the data subject. This information is required in order to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Diction for statistical purposes and with the aim of increasing data protection and data security in our company, ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

Cookies
Some websites, including Diction’s, use cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our quote more user-friendly, effective, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called session cookies. They will be automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognise your browser the next time you visit.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. Deactivating cookies may limit the functionality of this website.

Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • browser type and browser version
  • operating system used
  • referrer URL
  • host name of the accessing computer
  • time of server request

This data cannot be attributed to specific individuals. This data is not merged with other data sources. We reserve the right to subsequently check this data if we become aware of specific indications of unlawful use.

Contact option via the website
If you send us enquiries via the contact form or email, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We will not disclose this data without your consent.

Newsletter subscription, data and cancellation
If you would like to subscribe to the newsletter offered on the website, we require a valid email address that you can access directly, as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter (known as a confirmation email in the double opt-in process). No further data is collected. We use this data exclusively for sending the requested information and do not pass it on to third parties.
 You may revoke your consent to the storage of data, your email address and its use for sending the newsletter at any time, for example via the unsubscribe link in the newsletter.

Newsletter tracking (tracking pixels)
Diction newsletters contain tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails sent in HTML format to enable log file recording and analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Using the embedded tracking pixel, Diction can detect whether and when an email has been opened by a data subject and which links in the email have been clicked on by the data subject.
Such personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimise the newsletter dispatch and to change the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties or used for purposes other than those specified above.
In the event of revocation by the data subject, this personal data will be deleted by the controller. Diction automatically interprets unsubscribing from the newsletter as a revocation. She is thus unilaterally initiating the above measures.

Data protection in job applications and during the application process
The controller collects and processes applicants’ personal data for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits the relevant application documents electronically, for example by email with PDF files or other file types as attachments or via links integrated into the website of the onlyfy Application Manager (provided by NEW Work SE, Am Strandkai 1, 20457 Hamburg, Germany) to the controller.
If the controller enters into an employment contract with an applicant, the data transmitted will be stored by Diction for the purpose of processing the employment relationship, in compliance with legal requirements and ensuring that unauthorised employees and third parties cannot access it.
If the controller does not conclude an employment contract with the applicant as the data subject, the application documents will be deleted automatically and without further notice to the applicant two months after notification of the rejection decision if they were sent by email, provided that no other legitimate interests of the controller prevent deletion. Other legitimate interests in this sense include, for example, the burden of proof in proceedings under the (General) Equal Treatment Act (GlG or AGG). When transmitting data via the onlyfy Application Manager, we refer you to the information on data processing by the manufacturer – onlyfy information on data processing.

Web analytics
Diction analyses the use of its websites with third-party analysis tools such as Google Analytics (hereinafter referred to as ‘analysis service providers’). Diction accepts no responsibility or liability for any data processing carried out by the providers of the tools.


Marketing automation
For the purposes of marketing automation, newsletter distribution and certain contact forms (website), we use HubSpot software as our solution. Only necessary data is stored at HubSpot in Frankfurt. HubSpot offers data protection in accordance with the GDPR – see: https://legal.hubspot.com/de/privacy-policy

5. Google Analytics
This website uses functions of the web analytics service Google Analytics. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.


Google Analytics uses so-called cookies. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.

Google Analytics cookies are stored on the basis of Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.

IP anonymisation
We have activated the IP anonymisation function on this website. This means that your IP address will be truncated by Google within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area before being transmitted to the United States. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On order of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plug-in
You may prevent the storage of cookies by adjusting your browser software settings accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Objection to data collection
You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie is set to prevent your data from being collected on future visits to this website: Disable Google Analytics.

For more information on how Google Analytics handles user data, please refer to Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Order data processing
We have concluded a contract with Google for commissioned data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics. The retention period for data linked to cookies, user IDs or advertising IDs is 26 months on Google Analytics for Diction.

Demographic characteristics in Google Analytics
This website uses the “demographic characteristics” feature of Google Analytics. This allows reports to be generated that contain information about the age, gender and interests of visitors to the site. This data comes from interest-based advertising by Google and visitor data from third-party providers. This data cannot be attributed to any specific person. You can deactivate this function at any time via the display settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the section “Objection to data collection”.

Google reCAPTCHA
We use the reCAPTCHA service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) on our website. This serves the purpose of distinguishing between input by a human being and automated, machine processing. In the background, Google collects and analyses usage data, which is used by reCaptcha to distinguish regular users from bots. To this end, your input will be transmitted to Google and reused there. In addition, the IP address and, if applicable, other data required by Google for the reCAPTCHA service will be transmitted to Google. This data is processed by Google within the European Union and, where applicable, also in the United States. Processing is carried out on the basis of Art. 6(1)(f) GDPR from the legitimate interest of protecting our website from automated spying, misuse and spam. You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you based on Article 6(1)(f) GDPR. Further information about Google reCAPTCHA and the associated privacy policy can be found at: https://www.google.com/recaptcha/intro/android.html and https://www.google.com/privacy.

6. Social media
Third-party functions (plug-ins) and social media platforms (LinkedIn, YouTube, etc.) are integrated into Diction’s websites. These plug-ins enable users to share content on the aforementioned social networks. When accessing the website, the buttons are disabled by default. This means that no personal data is transferred to the respective third-party providers without the user’s intervention. After the user has activated the buttons, the plug-ins automatically transmit data, including personal data, to the relevant third-party provider. If the user is logged into the network of the respective third-party provider at the same time as visiting the website, the provider can assign the visit to the user’s network account. Diction has no influence over this. The purpose and scope of this data collection and the further processing and use of personal data are set out in the data protection information provided by the respective social networks. Users can also find information there about their rights and settings options regarding privacy protection.

LinkedIn
Our website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn servers is established. LinkedIn will be informed that you have visited our website with your IP address. If you click on the LinkedIn Recommend button and are logged into your LinkedIn account, LinkedIn can associate your visit to our website with you and your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or its use by LinkedIn.
Further information on this can be found in LinkedIn’s privacy policy at: www.linkedin.com/legal/privacy-policy

YouTube
We use the YouTube.com platform to upload our own videos and make them publicly accessible. YouTube is used for public relations purposes and to present Diction’s online offerings in an appealing manner.
YouTube is a quote provided by a third party not affiliated with us, namely YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA; YouTube is a subsidiary of Google Inc.

In general, we are not responsible for the content of linked websites. However, if you follow a link to YouTube, we would like to point out that YouTube stores its users’ data (e.g. personal information, IP address) in accordance with its own data usage guidelines and uses it for business purposes. Further information on this and on data protection at YouTube can be found in their privacy policy at:

  • https://policies.google.com/privacy?hl=de&gl=de
  • https://www.datenschutz.org/youtube/
  • https://support.google.com/youtube/answer/171780?hl=de

We only embed YouTube on our website in extended data protection mode. This is provided by YouTube, which guarantees that no cookies will be set or used initially. As soon as you start playing an embedded video by clicking on it, YouTube will only store cookies on your device that do not contain any personally identifiable information, unless you are currently logged into a Google service. This may also lead to a connection being established with the Google “DoubleClick Network” (formerly Internet Advertising Network), which offers online marketing solutions. These cookies can be prevented by adjusting your browser settings and extensions. YouTube uses cookies to collect information about visitors to its website, to compile statistics, to prevent fraud and to improve user-friendliness. Starting the video may trigger further data processing operations. We have no influence over this. Data processing is carried out under YouTube’s own responsibility.

7. DeepL/DeepL Pro
Diction uses DeepL as a processor in accordance with Article 28 of the GDPR. DeepL is a company that specialises in the development of artificial intelligence for languages. DeepL collects and uses personal data exclusively within the framework of legal provisions, in particular the European General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).
The person responsible for data processing within the meaning of the EU GDPR, BDSG, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

  • DeepL GmbH, Maarweg 165, 50825 Cologne, Germany

Diction uses the DeepL Pro product for this purpose. DeepL Pro is a subscription service that provides access to the full capacity of DeepL’s AI translation technology and is particularly useful for professional translators who need DeepL translations to efficiently handle their business processes.

DeepL Pro does not store the texts from requests or their translations. In the event of error corrections, DeepL may store data in encrypted form, with automatic deletion after 72 hours. Only metadata about the request (e.g. time of request, IP address or number of translated characters) is stored for billing and statistical purposes. Only metadata is temporarily stored during the translation of documents. In particular, the following data is stored for each translation process:

  • Status/progress of the translation process
  • File type of the document
  • Selected language pair for translation
  • Estimates of the time required for translation
  • Reference to the glossary used (when using DeepL Pro)
  • Content of the glossary used (when using the free translator)
  • Number of characters calculated
  • Errors that occurred during the translation process.

Further information: https://www.deepl.com/de/pro-faq.html and https://www.deepl.com/de/privacy/ (data protection).

8. Globalese by memoQ
Diction uses Globalese as a processor in accordance with Article 28 of the GDPR. Globalese by memoQ is a product of memoQ Zrt., which specialises in the development of artificial intelligence for languages. Globalese collects and uses personal data exclusively within the framework of legal provisions, in particular the European General Data Protection Regulation (GDPR).
The controller responsible for data processing within the meaning of the EU GDPR, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

  • memoQ Ltd. (memoQ), 1074 Budapest, Rákóczi út 70-72, II. floor

Diction uses the product Globalese by memoQ for this purpose. Globalese by memoQ is a subscription service that provides access to the full capacity of memoQ’s AI translation technology and is particularly useful for professional translators who need Globalese translations to handle their business processes efficiently.
Globalese by memoQ does not store the texts from enquiries or their translations. In the event of error corrections, however, Globalese may store data in encrypted form, with automatic deletion after 72 hours. Only metadata about the request (e.g. time of request, IP address or number of translated characters) is stored for billing and statistical purposes. Only metadata is temporarily stored during the translation of documents. In particular, the following data is stored for each translation process:

  • Status/progress of the translation process
  • File type of the document
  • Selected language pair for translation
  • Estimates of the time required for translation
  • Reference to the glossary used (when using DeepL Pro)
  • Content of the glossary used (when using the free translator)
  • Number of characters calculated
  • Errors that occurred during the translation process.

Further information: https://www.memoq.com/product/globalese/ and https://www.memoq.com/legal/privacy-policy/ (data protection).

9. This website uses the open source web analytics service Matomo.
With the help of Matomo, we are able to collect and analyse data about how visitors use our website. This enables us to find out, among other things, when which page views were made and from which region they originate. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).
The use of this analysis tool is based on Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent may be revoked at any time.

IP anonymisation
We use IP anonymisation when analysing with Matomo. In this case, your IP address is shortened before analysis so that it can no longer be clearly assigned to you.
Cookie-free analysis
We have configured Matomo so that it does not store any cookies in your browser.

Hosting
We host in the Matomo Cloud within the European Union. All data is stored in full compliance with the GDPR.

10. SSL encryption
This site uses SSL encryption for security reasons and to protect the transmission of confidential content, such as enquiries you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from http:// to https:// and by the lock symbol in your browser line.
When SSL encryption is activated, the data you transmit to us cannot be read by third parties.

11. Your rights
Below you will find information on the rights that applicable data protection law grants you with regard to the controller in relation to the processing of your personal data:
The right to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can obtain information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it was not collected by us, and the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details.

The right to request the immediate correction of inaccurate or incomplete personal data stored by us in accordance with Art. 16 GDPR.
The right to request the erasure of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defence of legal claims.

The right to request the restriction of the processing of your personal data in accordance with Art. 18 GDPR, insofar as you dispute the accuracy of the data, the processing is unlawful, but you refuse to have it deleted and we no longer need the data, but you need it to assert, exercise or defend legal claims, or you have objected to the processing pursuant to Article 21 GDPR.

The right, pursuant to Article 20 of the GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transfer to another controller.

The right to lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR. As a rule, you can contact the supervisory authority of the federal state of our registered office as stated above or, if applicable, that of your usual place of residence or workplace.

The right to withdraw consent granted in accordance with Art. 7(3) GDPR: You have the right to revoke your consent to the processing of data at any time with future effect. In the event of revocation, we will delete the affected data immediately, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right of objection
If we process your personal data on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that this is done for reasons arising from your particular situation. Insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the need to specify a particular situation.
If you wish to exercise your right of withdrawal or objection, simply send an email to datenschutz@diction.ch.

12. Legal obligations
The provision of personal data for the decision on concluding a contract, the fulfilment of the contract or for the implementation of pre-contractual measures is voluntary. However, we can only make the decision within the framework of contractual measures if you provide personal data that is necessary for the conclusion of the contract, the fulfilment of the contract or pre-contractual measures.

13. Automated decision-making
Automated decision-making or profiling in accordance with Article 22 of the GDPR does not take place.

14. Right to make changes
We reserve the right to make changes or update this privacy policy as necessary in accordance with applicable data protection regulations. This allows us to adapt them to current legal requirements and take into account changes to our services, e.g. when introducing new services. The current version applies to your visit.

Last update: 15 December 2025