Privacy
Below we inform you about the type, scope and purposes of processing personal data on this website.
Cookies & Consent
We use essential cookies. Additional categories (statistics, marketing, functional) are only activated with your consent.
Google Analytics / Hotjar / Matomo
Analytics services are loaded only after consent. Where available, IP anonymisation is enabled.
Contact form
Your details are processed to handle your request and then deleted unless statutory retention applies.
1. Controller
new work composer GmbH
Alpenstrasse 14, 6300 Zug, Schweiz
Authorised representative: Sabine Rasch
Phone: +41 762 238938
Email: contact@newworkcomposer.com
(hereinafter: “we”, “us”).
2. Data Protection Officer (if appointed)
Name: [Name, if available]
Contact: [DPO email], [Address]
3. Purposes and legal bases of processing
We process personal data under Art. 6 GDPR only to the extent necessary. Possible purposes:
• Provision of the website/IT security (Art. 6(1)(f) GDPR – legitimate interests)
• Contract performance/order handling/support (Art. 6(1)(b) GDPR)
• Compliance with legal obligations (Art. 6(1)(c) GDPR)
• Communication/enquiries (Art. 6(1)(f) or (b) GDPR)
• Newsletter/marketing (Art. 6(1)(a) GDPR – consent)
• Reach measurement/statistics/marketing cookies (Art. 6(1)(a) GDPR in conjunction with Sec. 25(1) TTDSG)
• Necessary cookies (Art. 6(1)(f) GDPR in conjunction with Sec. 25(2) TTDSG).
4. Hosting and server log files
We use hosting services from [hosting provider], with whom a data processing agreement (Art. 28 GDPR) exists. When you access this website, the server automatically processes log data: IP address, date/time, time zone, pages/files visited, data volume transferred, referrer URL, user agent. Legal basis: Art. 6(1)(f) GDPR (operation of the website, IT security). Log files are generally deleted after 14 days.
5. Contact (email, phone, forms)
When you contact us, we process the data you provide (e.g., name, email, content of the enquiry) to handle the request (Art. 6(1)(b) or (f) GDPR). Data are deleted after completion and expiry of statutory retention periods.
6. Orders, customer account (if available)
To perform orders, we process master, payment and delivery data (Art. 6(1)(b) GDPR). For a customer account, we process the registration data provided by you. Deletion takes place after contract end and expiry of statutory retention periods. Payment data are processed by payment service providers depending on the payment method (see “Payment service providers”).
7. Newsletter (if available)
Registration takes place using a double opt-in procedure. Legal basis: Art. 6(1)(a) GDPR. Unsubscribe at any time, e.g., via the unsubscribe link. We log subscriptions, changes and unsubscribe actions for evidence purposes (Art. 6(1)(f) GDPR).
8. Cookies, consent management
We use cookies and similar technologies. Non-essential technologies are only set with your consent (Sec. 25(1) TTDSG, Art. 6(1)(a) GDPR). Technically necessary cookies can be set without consent (Sec. 25(2) TTDSG, Art. 6(1)(f) GDPR). We manage your consents via a consent management tool, with whom a data processing agreement exists. You can change your selection at any time in the “Cookie settings” and withdraw consent with effect for the future.
9. Reach measurement & analytics
• Google Analytics (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). IP anonymisation enabled. Legal basis: Art. 6(1)(a) GDPR in conjunction with Sec. 25(1) TTDSG. Withdrawal at any time via cookie settings. Transfers to the USA may occur. Basis: EU Standard Contractual Clauses (Art. 46 GDPR).\n• Alternatively/additionally: Matomo (self-hosted). Processing on own server, possibly without cookies. Legal basis: Art. 6(1)(f) GDPR (legitimate interests) or Art. 6(1)(a) GDPR (with cookies).
10. Marketing/tracking services
• Google Ads/Conversion Tracking, Google Ireland Limited – only with consent (Art. 6(1)(a) GDPR; Sec. 25(1) TTDSG). US transfer based on EU Standard Contractual Clauses.\n• Meta Pixel (Meta Platforms Ireland Ltd.) – only with consent; joint controllership may apply (Art. 26 GDPR); US transfer based on EU Standard Contractual Clauses.
11. Embedded content & third parties
• YouTube/Vimeo, maps (e.g., Google Maps), CDNs, web fonts (local hosting recommended). When content is loaded externally, the IP address may be transmitted to third parties. Non-essential embeds only after consent. For providers in third countries, transfers occur on the basis of Art. 46 GDPR (Standard Contractual Clauses) or the derogations of Art. 49 GDPR.
12. Payment service providers
• PayPal (Europe) S.à r.l. et Cie, S.C.A. – legal basis: Art. 6(1)(b) GDPR.\n• Stripe Payments Europe Limited – legal basis: Art. 6(1)(b) GDPR.\nFor further details please refer to the privacy notices of the respective providers.
13. Processors & recipients
We use service providers (e.g., hosting, IT, newsletter, consent management) as processors under Art. 28 GDPR. Data are only disclosed to further recipients where a legal basis exists.
14. Third-country transfers
Where data are transferred to countries outside the EEA, this is done in compliance with Art. 44 et seq. GDPR (in particular Standard Contractual Clauses) and, where necessary, additional measures.
15. Storage periods
We delete personal data as soon as the purpose ceases to apply and there are no statutory retention obligations. Statutory periods may follow from commercial and tax law (typically 6 or 10 years).
16. Security of processing
We implement appropriate technical and organisational measures (Art. 32 GDPR), e.g., access restrictions, encryption, backup/recovery processes, pseudonymisation, confidentiality agreements.
17. Obligation to provide data
Providing certain data may be required for contract conclusion/execution. Without these data, a service may not be possible.
18. Automated decision-making/profiling
No solely automated decision-making including profiling takes place. [Or: it does – with description and logic, Art. 22 GDPR].
19. Minors
Our offer is not directed at persons under 16 years of age. Personal data of minors are not knowingly processed without consent of the legal guardians.
20. Your rights
• Access (Art. 15 GDPR)\n• Rectification (Art. 16 GDPR)\n• Erasure (Art. 17 GDPR)\n• Restriction (Art. 18 GDPR)\n• Data portability (Art. 20 GDPR)\n• Objection to processing based on legitimate interests (Art. 21 GDPR)\n• Withdrawal of consent (Art. 7(3) GDPR) with effect for the future\n• Complaint to a data protection supervisory authority, e.g., the authority responsible for your place of residence.
21. Exercising your rights
Please contact the above contact details or: contact@newworkcomposer.com.
22. Changes to this Privacy Policy
We adapt this policy where necessary, e.g., if legal situation, processing or services change. Valid in the current version (status: 2025-11-12).
Last updated: 2026-01-24