Privacy Policy
1. Introduction
We take the protection of your personal data seriously. The following information explains which data we process, the purposes for which we process it and your rights.
We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the European Union's General Data Protection Regulation (GDPR).
2. Controller
Our website uses cookies, as well as Google Ads and Meta Pixel, to optimize our service. You can restrict or disable the use of cookies in your browser.
3. Principles and Legal Bases
3.1 We process personal data in good faith, proportionately and only for the purposes stated in this Privacy Policy.
3.2 Where the GDPR applies, we rely on the following legal bases for processing:
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Consent (Article 6(1)(a) GDPR), for example for marketing cookies and the newsletter
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Performance of a contract and steps taken prior to entering into a contract (Article 6(1)(b) GDPR), for example for reservations and enquiries
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Legal obligation (Article 6(1)(c) GDPR), for example statutory accounting retention requirements
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Legitimate interests (Article 6(1)(f) GDPR), for example the secure operation of the website
3.3 You may withdraw your consent at any time with effect for the future.
4. Personal Data We Process
Depending on how you contact us and use our services, we process the following data in particular:
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Basic data: name, first name and form of address
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Contact details: email address, telephone number and, where applicable, address
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Reservation data: date, time, number of guests, comments, allergies and intolerances, if you provide this information
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Communication data: the content of your enquiries by email, telephone or contact form
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Contract and payment data: for group bookings, invoicing or vouchers
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Technical data: IP address, browser type, device, operating system, pages accessed, referring page, and date and time of access
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Usage and marketing data: interactions with our website, advertisements and newsletter
Information about allergies and intolerances may constitute health data and therefore sensitive personal data. We process this information solely to fulfil your reservation and delete it after your visit.
5. Hosting and Operation of the Website
Our website is hosted by Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel. Wix stores and processes on our behalf all data generated when the website is visited, in particular access data, contact enquiries and reservation data.
We have a data processing agreement with Wix. The European Commission has adopted an adequacy decision for Israel, and Switzerland also recognises Israel as providing an adequate level of data protection. Any transfers to other countries are based on standard contractual clauses.
Further information: https://de.wix.com/about/privacy
6. Server Log Files
When you access our website, technical data is automatically recorded in log files (IP address, date and time, page accessed, browser, operating system and referrer). This processing is necessary for the secure and stable operation of the website and is based on our legitimate interest. The data is deleted or anonymised after [30] days unless it is required to investigate security incidents.
Your rights
7.1 Our website uses cookies and similar technologies. Cookies are small text files stored on your device.
7.2 We distinguish between:
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Essential cookies: required to operate the website, for example for security, language selection and the reservation tool. These cookies are set without consent.
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Functional cookies: improve convenience and usability.
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Analytics cookies: enable us to analyse how our website is used.
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Marketing cookies: enable the delivery and measurement of personalised advertising.
7.3 We use analytics and marketing cookies only if you have given your consent via our cookie banner. You can change or withdraw your selection at any time in the cookie settings on our website.
7.4 You can also block or delete cookies in your browser. Doing so may limit the functionality of our website.
8. Google Tag Manager
We use Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager is a tool used to manage website tags. It does not itself store personal data or set cookies, but it triggers other services that may collect data. If consent is declined in the cookie banner, the corresponding tags are not triggered.
9. Google Analytics
9.1 We use Google Analytics 4, an analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
9.2 Google Analytics helps us understand how our website is used, for example which pages are viewed, how long visits last and through which channels visitors find us. We use this information to optimise our content and advertising.
9.3 The data processed includes shortened IP addresses, device and browser information, approximate location at regional level and interactions with the website. Google Analytics 4 shortens IP addresses by default before storing them.
9.4 Processing is based exclusively on your consent. You can withdraw your consent at any time in the cookie settings.
9.5 Usage data is retained in Google Analytics for [14] months.
9.6 You can also prevent collection by installing Google's browser add-on: https://tools.google.com/dlpage/gaoptout
Google Privacy Policy: https://policies.google.com/privacy
10. Google Ads, Conversion Tracking and Remarketing
10.1 We advertise through Google Ads (Google Ireland Limited) and use Google conversion tracking to measure performance.
10.2 If you click one of our advertisements, a cookie is set. This allows us to determine whether a relevant action, such as a reservation, takes place after the click. We see only aggregated reports and no information that identifies individual persons.
10.3 We also use remarketing. After visiting our website, you may therefore see our advertisements on other websites and platforms in the Google advertising network.
10.4 [We use Enhanced Conversions. Before contact details such as your email address are transmitted to Google, they are hashed in your browser using a one-way process and used solely for matching with signed-in Google accounts.]
10.5 This processing is based exclusively on your consent.
10.6 You can manage your personalised advertising settings here: https://adssettings.google.com
11. Google Fonts
Our website uses Google Fonts. [The fonts are loaded from Google servers. In the process, your IP address is transmitted to Google.
12. Google Maps
You have the right to access, correct, or delete your personal data at any time. To do so, please contact us by email at info@sofreh-sg.ch.
13. Meta Pixel and Meta Ads (Facebook, Instagram)
13.1 We use technologies provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland, in particular the Meta Pixel.
13.2 We use them to measure the effectiveness of our advertising on Facebook and Instagram and to show you more relevant advertisements. The data collected includes pages visited, events such as starting or completing a reservation, device and browser information and your IP address.
13.3 [We also use Meta's Conversions API. Event data is transmitted to Meta on the server side. Contact details such as email addresses or telephone numbers are hashed before transmission.]
13.4 We and Meta are joint controllers within the meaning of Article 26 GDPR for the collection and transmission of data in connection with Custom Audiences. The relevant agreement is available at: https://www.facebook.com/legal/controller_addendum
13.5 Processing is based exclusively on your consent.
Meta Privacy Policy: https://www.facebook.com/privacy/policy
14. TikTok Pixel and TikTok Ads
14.1 We use the TikTok Pixel provided by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland.
14.2 We use it to measure the effectiveness of our advertising on TikTok and to create audiences for the delivery of further advertisements. The data collected includes your IP address, device and browser information, pages visited and events triggered.
14.3 Processing is based exclusively on your consent. Data may also be transferred to TikTok group companies outside Switzerland and the European Economic Area. Such transfers are based on standard contractual clauses.
TikTok Privacy Policy: https://www.tiktok.com/legal/privacy-policy-eea
15. Online Reservations
15.1 We use Wix Table Reservations and Google Reservations for table bookings.
15.2 In this context, we process your name, email address, telephone number, date and time, number of guests and any comments you provide. We need this information to process and confirm your reservation. Without it, we cannot accept a reservation.
15.3 The legal basis is the performance of a contract or steps taken prior to entering into a contract.
15.4 We use your contact details to confirm your reservation, send any reminders and contact you with questions about your visit. We use them for advertising purposes only with your consent.
16. Contacting Us
If you contact us by email, telephone, contact form or social media, we process the information you provide in order to respond to your enquiry.
17. Newsletter
17.1 You can subscribe to our newsletter. We require your email address for this purpose. Other information, such as your name, is voluntary and is used to address you personally.
17.2 Registration uses a double opt-in process. After registering, you will receive an email asking you to confirm your subscription. This ensures that subscriptions cannot be made using someone else's email address. The registration, confirmation and time are recorded.
17.3 We use [Wix Email Marketing / Brevo / Mailchimp: add provider and address] to distribute the newsletter. A data processing agreement is in place with the provider.
17.4 We analyse whether and when our newsletters are opened and which links are clicked. This analysis helps us improve our content and delivery times.
17.5 The legal basis is your consent. You can unsubscribe at any time using the unsubscribe link at the end of each message or by emailing info@capriotti.ch . After you unsubscribe, your email address will be deleted or placed on a suppression list so that you do not receive further messages.
18. Vouchers and Payments
When issuing vouchers and invoicing group bookings and events, we process the contract and payment data required for this purpose. If a purchase is made online, payments are processed via [add payment service provider]. We cannot view your full credit card details. We retain accounting records for ten years in accordance with the Swiss Code of Obligations.
19. Our Social Media Presence
We maintain profiles on social networks, currently on Instagram (@capriotti.sg). If you visit these profiles or interact with our content, the relevant platform processes data under its own responsibility and in accordance with its own terms. We have only limited influence over this processing. We receive statistics about our pages only in aggregated, anonymised form.
20. Disclosure of Data and Processing by Service Providers
20.1 We do not disclose your data to third parties unless this is necessary to provide our services, you have given your consent or we are legally required to do so.
20.2 We work with carefully selected service providers that process data on our behalf, particularly for hosting, reservations, newsletter distribution, analytics, advertising, payment processing and accounting. Appropriate data processing agreements are in place with these providers.
21. International Data Transfers
Some of the services we use process data outside Switzerland, particularly in the European Union, Israel and the United States. If data is transferred to a country without an adequate level of data protection, we rely on appropriate safeguards, in particular the European Commission's standard contractual clauses in the version recognised by the Federal Data Protection and Information Commissioner, certification under the Swiss–US Data Privacy Framework, or your explicit consent.
22. Retention Period
We retain personal data only for as long as necessary for the relevant purposes or for as long as statutory retention obligations apply. The data is then deleted or anonymised.
23. Data Security
We take appropriate technical and organisational measures to protect your data against unauthorised access, loss and misuse. Data transmitted via our website is encrypted (TLS). However, absolute security cannot be guaranteed when data is transmitted over the internet.
24. Your Rights
24.1 Subject to applicable law, you have the following rights in particular:
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Access to the personal data we process about you
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Correction of inaccurate data
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Deletion of your data
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Restriction of processing
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Provision or transfer of your data
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Objection to certain processing activities, particularly for advertising purposes
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Withdrawal of consent with effect for the future
24.2 To exercise your rights, simply send a message to info@capriotti.ch. We may request additional information to verify your identity.
24.3 You also have the right to lodge a complaint with a supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern. In the European Economic Area, the competent authority is the data protection authority of your country of residence.
25. Automated Decision-Making
We do not use automated individual decision-making, including profiling, that produces legal effects concerning you.
26. Amendments to this Privacy Policy
We may amend this Privacy Policy at any time, particularly if we change our services or the tools we use. The version published on www.capriotti.ch at the relevant time shall apply.
KAJA GmbH
Capriotti Restaurant, Schützengasse 8, CH-9000 St. Gallen info@capriotti.ch | +41 71 220 11 12 | www.capriotti.ch