Skip to main content Skip to search

Privacy Policy

Who we are

We are very delighted that you have shown interest in Thortax. Data protection is of a particular importance for the management of Thortax. The use of the Internet pages of Thortax is possible without any indication of personal data; however, if a person wants to use special services via our website, personal data processing may be required. If the processing of personal data is required and there is no legal basis for such processing, we generally seek the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Thortax. By means of this data protection declaration, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the Controller, Thortax has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of Thortax is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

  1. Personal data. Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  2. Data subject. Data subject is any identified or identifiable natural person, whose personal data is processed by the Controller responsible for the processing.
  3. Processing. Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  4. Restriction of processing. Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
  5. Profiling. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  6. Pseudonymisation. Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  7. Controller or Controller responsible for the processing. Controller or Controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  8. Processor. Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
  9. Recipient. Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
  10. Third party. Third party is a natural or legal person, public authority, agency or body other than the data subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorized to process personal data.
  11. Consent. Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Thortax
Website: thortax.ch

3. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

We may use Customer Data and Technical Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you about relevant products and services, such as online courses; books; live broadcast trainings such as webinars; live events and conferences; coaching and mentoring services. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

4. Cookies

The Internet pages of Thortax use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual’s browser from other internet browsers that contain other cookies. A particular web browser can be recognized and identified by the unique cookie ID.

By using cookies, Thortax can provide users of this website with more user-friendly services that would not be possible without cookies.

By means of a cookie the information and offers on our website can be optimized in the sense of the user. Cookies allow us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies need not reenter their credentials each time they visit the website, as this is done by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently contradict the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

5. Contact possibility via the website

The website of Thortax contains information that enables a quick electronic contact to the Consortium, as well as direct communication with the Controller, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the Controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the Controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

6. Routine erasure and blocking of personal data

The Controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the Controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. Rights of the data subject

  1. Right of confirmation. Each data subject shall have the right granted by the European legislator to obtain from the Controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the controller.
  2. Right of access. Each data subject shall have the right granted by the European legislator to obtain from the Controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
    • the purposes of the processing;
    • the categories of personal data concerned;
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • the existence of the right to request from the Controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
    • the existence of the right to lodge a complaint with a supervisory authority;
    • where the personal data are not collected from the data subject, any available information as to their source;
    • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.If a data subject wishes to avail himself of this right of access, he or she may at any time contact the controller.
  3. Right to rectification. Each data subject shall have the right granted by the European legislator to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact the controller.
  4. Right to erasure (Right to be forgotten). Each data subject shall have the right granted by the European legislator to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
    • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
    • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
    • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
    • The personal data have been unlawfully processed.
    • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject.
    • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Thortax, he or she may at any time contact the controller. The Controller shall promptly ensure that the erasure request is complied with immediately.
      Where the Controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other Controllers processing the personal data that the data subject has requested erasure by such Controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Controller will arrange the necessary measures in individual cases.
  5. Right of restriction of processing. Each data subject shall have the right granted by the European legislator to obtain from the Controller restriction of processing where one of the following applies:
    • The accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data.
    • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
    • The Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
    • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller override those of the data subject.If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Thortax, he or she may at any time contact the Controller. The Controller will arrange the restriction of the processing.
  6. Right to data portability. Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a Controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
    Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
    In order to assert the right to data portability, the data subject may at any time contact the Controller.
  7. Right to object. Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
    The Controller shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
    If the Controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Controller to the processing for direct marketing purposes, the Controller will no longer process the personal data for these purposes.
    In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Controller for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    In order to exercise the right to object, the data subject may directly contact the Controller. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
  8. Automated individual decision-making, including profiling. Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data Controller, or (2) is not authorized by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
    If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data Controller, or (2) it is based on the data subject’s explicit consent, the Controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and contest the decision.
    If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact the Controller.
  9. Right to withdraw data protection consent. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the Controller.

8. Data protection for applications and the application procedures

The Controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the Controller. If the data Controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the Controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the Controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

9. Privacy Policy on Use and Use of Facebook

The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is an Internet-based social meeting place, an online community that typically allows users to communicate with each other and interact in virtual space. A social network can serve as a platform to exchange views and experiences, or allows the Internet community to provide personal or business information. Facebook allows social network users to create private profiles, upload photos and socialize via friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Persons responsible for the processing of personal data, if an affected person lives outside the US or Canada, are Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.

Each visit to one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the person concerned automatically by the respective Facebook Component causes a representation of the corresponding Facebook component of Facebook to download. An overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=en_US. As part of this technical process, Facebook receives information about which specific underside of our website is visited by the person concerned.

If the data subject is simultaneously logged into Facebook, Facebook recognizes with each visit to our website by the data subject and during the entire duration of the respective stay on our website, which specific underside of our website the data subject visits. This information is collected through the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the person concerned activates one of the Facebook buttons integrated on our website, for example the “Like” button, or if the person concerned makes a comment, Facebook assigns this information to the personal Facebook user account of the person concerned and saves this personal data ,

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged in to Facebook at the same time as accessing our website; this happens regardless of whether the person clicks on the Facebook component or not. If such a transfer of this information to Facebook is not wanted by the data subject, it can prevent the transfer by logging out of their Facebook account before calling our website.

The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information on the collection, processing and use of personal data by Facebook. It also explains which options Facebook offers to protect the privacy of the data subject. In addition, different applications are available, which make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

10. Privacy Policy for Use and Use of Instagram

The controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform, allowing users to share photos and videos, and also disseminate such data to other social networks.

Instagram’s operating company is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

Each visit to one of the pages of this website operated by the controller and on which an Instagram component (Insta-Button) has been integrated automatically causes the internet browser on the information technology system of the person concerned through the respective Instagram component causes to download a representation of the corresponding component of Instagram. As part of this technical process, Instagram is aware of which specific bottom of our website is visited by the person concerned.

If the data subject is logged in to Instagram at the same time, Instagram recognizes with each visit to our website by the data subject and during the entire duration of the respective stay on our website which specific subpage the affected person visits. This information is collected through the Instagram component and assigned through Instagram to the affected person’s Instagram account. If the person concerned activates one of the Instagram buttons integrated on our website, the data and information transferred with it are assigned to the personal Instagram user account of the person concerned and saved and processed by Instagram.

Through the Instagram component, Instagram always receives information that the person concerned has visited our website if the person concerned is simultaneously logged into Instagram at the time of accessing our website; this happens regardless of whether the person clicks on the Instagram component or not. If the affected person does not want to transmit this information to Instagram, the latter can prevent the transmission from logging out of their Instagram account before calling our website.

Additional information and Instagram’s privacy policy can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

11. Method of Payment: Privacy Policy to PayPal as payment

The controller has integrated components from PayPal on this website. PayPal is an online payment service provider. Payments are made through so-called PayPal accounts, which are virtual private or business accounts. In addition, PayPal has the ability to process virtual payments through credit cards if a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there is no classic account number. PayPal makes it possible to initiate online payments to third parties or to receive payments. PayPal also takes on trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.rl & Cie. SCA, 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

If the data subject selects “PayPal” as a payment option during the order process in our online shop, data of the data subject will be automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transfer of personal data required for payment processing.

The personal data sent to PayPal are usually first name, last name, address, email address, IP address, telephone number, mobile phone number or other data required for payment processing. For the execution of the purchase contract, also such personal data are necessary, which are in connection with the respective order.

The purpose of the transmission of the data is payment processing and fraud prevention. The controller will provide PayPal with personally identifiable information, in particular if there is a legitimate interest in the transfer. The personal data exchanged between PayPal and the controller may be transferred by PayPal to credit reporting agencies. This transmission aims at the identity and credit check.

PayPal may disclose personal information to affiliates and service providers or subcontractors, to the extent necessary to fulfill its contractual obligations or to process the data on behalf of.

The data subject has the option to revoke the consent to the handling of personal data against PayPal at any time. A revocation has no effect on personal data which must be processed, used or transmitted for (contractual) payment processing.

PayPal’s applicable privacy policy is available at https://www.paypal.com/webapps/mpp/ua/privacy-full.

12. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the Controller (Recital 47 Sentence 2 GDPR).

13. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

15. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact the Controller.

The Controller clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.