General HOPPE Privacy Policy

1. Subject matter and scope

We take the protection of your personal data very seriously. With this Privacy Policy, we would like to inform you about which personal data we collect and how and for what purposes it is processed.

This Privacy Policy applies to visits to our website and to various other data processing operations, for example when you visit our social media pages, when you contact us, when we work with you as a customer or as a supplier or when you apply to work for us as an employee or other third party.

We always treat your personal data in accordance with the statutory data protection regulations and this Privacy Policy.

2. Data controller and data protection officer

2.1 Data Controller:

HOPPE Holding AG
Via Friedrich Hoppe 6
7537 Müstair
Switzerland
privacy@hoppe.com

For processing activities that concern the entire HOPPE Group, HOPPE Holding AG is the data controller. However, for processing activities that concern only individual companies within the HOPPE Group, responsibility for data processing lies with the respective company. This is the case, for example, with job applications.

2.2 Data Protection Officer for the HOPPE Group:

Christian Schmoll, lawyer, IT law specialist, CIPP/E, CIPM, FIP, DSB (TÜV)
LUCID Compliance GmbH
Ledererstrasse 19
80331 Munich
Germany
E-mail: schmoll@lucid-compliance.com

3. Visiting our website

Each time you visit our website, our system automatically collects data and information from the computer system of the accessing computer. In order for the pages to be displayed in your browser, the IP address of the end device you are using must be processed. In addition, there is further information about the browser of your end device.

Ensuring the confidentiality and integrity of the personal data processed with our IT systems is of great importance to us. The data is also used to correct errors on websites.

For these purposes, the following data is logged:

• IP address of the calling computer
• Operating system of the calling computer
• Browser version of the calling computer
• Name of the retrieved file
• Date and time of the retrieval
• Amount of data transferred
• Referring URL

This data is regularly deleted automatically after a few days.

Our websites are hosted by a data processor on the basis of a data processing pursuant to Art. 28 GDPR.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation of this website and the implementation of the protection goals of confidentiality, integrity and availability of the data.

4. Content Delivery Network

We use the Content Delivery Network (CDN) of the service provider Cloudflare Germany GmbH in Germany (hereinafter “Cloudflare”) to increase the security and delivery speed of the website and the platform. A CDN is a network of servers distributed worldwide that is capable of delivering optimized content to users. For this purpose, personal data may be processed in server log files by Cloudflare.

Cloudflare acts as a data processor for us on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Since a CDN represents a network of servers distributed worldwide, the use of a CDN may result in the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (EU Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is to increase the security and delivery speed of the website and the platform.

5. Contacting us

If you contact us to request information or documents, the information you provide will be stored for the purpose of processing your request.

We need the information requested in a contact form on the website to process your enquiry, to address you correctly and to send you a reply.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is communication with interested parties, visitors and customers as well as our interest in marketing our products.

If the contact or communication is aimed at the conclusion of a contract or takes place within the context of an existing contractual relationship, the legal basis for the processing is Art. 6 (1) lit. b) GDPR.

Enquiries and orders are stored in our CRM system for as long as this is necessary to achieve the above stated purposes or as stipulated by the storage periods provided for by law.

6. Customer and supplier data

We process the data of our prospective customers, customers, service providers and suppliers within the framework of the provision of our contractual services. In doing so, we may process master data (such as name and address), contact data (such as e-mail address and telephone number), content data (such as photos and videos), contract data (such as subject matter of the contract and term), payment data and data collected in the course of providing the service and/or processed to provide the service. This data is regularly stored in our CRM system (see also above under “Contacting us”).

The legal basis for this storage and processing is the fulfilment of the contract or the implementation of pre-contractual measures pursuant to Art. 6 (1) lit. b) GDPR.

7. Cookies and third-party tools/functions

Our website uses cookies and implements third-party tools and functions.

Cookies are pieces of information that are transferred from our web server or third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Information is stored in cookies that is related to the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that we gain immediate knowledge of your identity.

We also use third-party tools and functions, for example, to expand the functional scope of the website, to analyze the use of the website, and to optimize the content accordingly.

When integrating tools and functions from third-party providers, personal data may be transmitted to the providers of the integrated tools and functions in order to be able to provide the tools and functions.

Cookies and third-party tools and functions are hereinafter uniformly referred to as “cookies” for the sake of simplicity.

7.1 Essential and Non-Essential Cookies

When visiting our website, cookies are set that are absolutely necessary for the operation of the website. These essential cookies may be, for example, cookies that are required for the display of the website with a content management system, which are used to recognize language settings, or which are used to document whether you have consented to the setting of further (non-essential) cookies or whether you have rejected them.

The technically necessary cookies, including their purpose and storage period or deletion period, are explained to you in our cookie banner, which is displayed when you access the website.

The legal basis for the processing of personal data using essential cookies is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation and provision of our website.

We also use non-essential cookies, for example to collect additional information about the interests of visitors to our websites or about their usage behavior, to analyze and optimize our website and generally our customer interactions on this basis.

Non-essential cookies, including their purpose and storage period or deletion period, are also explained to you in our cookie banner, which is displayed when you access the website.

Non-essential cookies are only set if you have expressly consented to the setting of non-essential cookies. You can also select different categories of non-essential cookies that you wish to allow in the cookie banner.

7.2 Consent Management

On our website, we use the cookie consent management tool Borlabs to obtain your consent to store certain cookies in your browser and to document this in accordance with the relevant data protection law. The provider is Borlabs GmbH, Hamburger Str. 11, 22083 Hamburg, Germany (hereinafter Borlabs).

When you access our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are being stored. This data is not shared with the Borlabs provider. You can change the Borlabs settings here:

[borlabs-cookie type=“btn-cookie-preference“ title=“Cookie preferences“/]

The collected data will be stored until you request us to delete it or until you delete these Borlabs or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on data processing by Borlabs can be found at: What data does Borlabs cookie store?

The legal basis for this data processing is initially Art. 6 (1) lit. f) GDPR, the provision of our website and ensuring the possibility to obtain consent for non-essential cookies. If you give consent, the legal basis for the processing of the data relating to your consent is Art. 7 (1) and 6 (1) lit c) GDPR.

8. Recipients of data

Within our company, your data will be received by those internal areas that need it to fulfil their tasks, where applicable to fulfil contracts with you, to process data with your consent or to protect our (overriding) legitimate interests.

Data will only be passed on to third parties within the framework of legal requirements. We only pass on your data to third parties if this is necessary, e. g. on the basis of Art. 6 (1) lit. b) GDPR for contractual purposes or to protect our overriding legitimate interest in accordance with Art. 6 (1) lit. f) GDPR in the effective performance of our business operations.

Insofar as we use service providers or third-party providers in the context of providing the website and/or providing our services, we take appropriate legal precautions as well as corresponding technical and organizational measures to ensure the protection of your personal data.

If, in the course of providing the website and/or our services, we use content or tools from service providers or third-party providers whose registered office is in a third country, data is regularly transferred to a third country. Third countries are countries in which the GDPR is not directly applicable law, i. e. countries outside the EU or the European Economic Area. The transfer of data to third countries only takes place if either an adequate level of data protection, consent or other legal permission, in particular appropriate safeguards in accordance with Art. 46 GDPR, exists.

9. Your rights

You have the right to free information about your stored personal data, its origin and recipient and the purpose of the data processing and a right to correction, blocking or deletion of this data. You also have the right to restrict processing and to object to processing.

You also have the right to have your data that we process, automatically handed over to you or to a third party in a common, machine-readable format.

To exercise your rights, please contact us using the contact details above.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

10. Withdrawal of consent

Some data processing operations are only possible with your express consent. You can withdraw your consent at any time. To do so, it is sufficient to send us an informal message by e-mail using the contact details provided above. The legality of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

11. Right to object

INSOFAR AS YOUR DATA IS PROCESSED TO PROTECT OUR OVERRIDING LEGITIMATE INTERESTS, AS EXPLAINED IN THIS PRIVACY POLICY, YOU MAY OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE. TO DO SO, PLEASE CONTACT US USING THE CONTACT DETAILS PROVIDED ABOVE.

IN PRINCIPLE, YOU ONLY HAVE THIS RIGHT TO OBJECT IF THERE ARE GROUNDS ARISING FROM YOUR PARTICULAR SITUATION (ART. 21 (1) GDPR). AFTER EXERCISING YOUR RIGHT TO OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE PROCESSED FOR THESE PURPOSES UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF THE PROCESSING IS FOR THE PURPOSES OF DIRECT MARKETING, YOU MAY EXERCISE YOUR RIGHT TO OBJECT AT ANY TIME (ART. 21 (2) GDPR) AND YOUR PERSONAL DATA WILL THEN NO LONGER BE PROCESSED FOR THE PURPOSES OF DIRECT MARKETING, REGARDLESS OF THE GROUNDS FOR THE OBJECTION.

12. Automated decision-making

We do not use automated decision-making including profiling.

13. Retention and deletion

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as stipulated by the storage periods provided for by law.

If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

14. Data security

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, enquiries or payment data that you send to us.

15. Changes to this privacy policy

We reserve the right to amend this Privacy Policy from time to time so that it always complies with the current legal requirements or in order to implement changes to our services in the Privacy Policy, e. g. when introducing new services. The new Privacy Policy will then apply to your next visit.

Version: June 2026