Data processing agreement (DPA)

Privacy policy and consent to data usage on by vengo GmbH


vengo GmbH (hereinafter also "we", "us") collects and processes personal data that concerns you or other persons (so-called "third parties"). We use the term "data" here synonymously with "personal data".

In this privacy policy we describe what we do with your data when you use, other websites of ours or our apps (hereinafter collectively referred to as "website"), purchase our services or products, otherwise contact us under a contract, communicate with us or otherwise deal with us. If necessary, we will inform you in writing of additional processing activities not mentioned in this privacy policy in a timely manner. In addition, we may inform you separately about the processing of your data, e.g. in declarations of consent, contractual terms, additional privacy statements, forms and notices.

If you send us or disclose data about other people, such as family members, work colleagues, etc., we assume that you are authorized to do so and that this data is correct. By sending data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

This privacy policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DSG”) and the Swiss Data Protection Act (“DSG”). However, whether and to what extent these laws are applicable depends on the individual case.


For the data processing of described in this data protection declaration, vengo GmbH in St. Moritz is responsible under data protection law, unless otherwise communicated in individual cases, e.g. in further data protection declarations, on forms or in contracts.

You can contact our data protection officer for your data protection concerns and to exercise your rights in accordance with section 11 as follows:

Data protection officer according to Art. 37 ff. GDPR, Art. 10 revDSG, EU according to Art. 27 GDPR, Switzerland according to Art. 14 revDSG, United Kingdom (UK) according to Art. 27 UK GDPR:

vengo GmbH
Data Protection Officer
Via San Gian 44
7500 St. Moritz


We process different categories of data about you. The main categories are as follows:

Technical data

When you use our website or other electronic services, we collect technical data from your device to ensure the functionality and security of these services. This data also includes logs that record the use of our systems. We generally store technical data for [1-14] months. To ensure the functionality of these services, we can also assign you or your device an individual code (e.g. in the form of a cookie, see section 12). The technical data itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, it can be linked to other data categories (and thus possibly to you personally).


Certain offers, e.g. competitions and services (e.g. login areas of our website, newsletter dispatch, free WiFi access, etc.) can usually only be used with a user account or registration, which can be done directly with us or through our external login service providers. You must provide us with certain data and we collect data about the use of the offer or service. We usually keep registration data for [1-14] months after the end of use of the service or the closure of the user account. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. This data is usually kept for at least [10] years.


If you contact us via the contact form, by email, telephone or chat, by letter or by other means of communication, we record the data exchanged between you and us, including your contact details and the peripheral data of the communication. If we record or listen in on telephone conversations or video conferences, e.g. for training and quality assurance purposes, we will draw your attention to this. Such recordings may only be made and used in accordance with our internal guidelines. You will be informed whether and when such recordings take place, e.g. by a display during the video conference in question. If you do not want a recording, please let us know or end your participation. If you simply do not want your image to be recorded, please switch off your camera. If we want or need to establish your identity, e.g. if you make a request for information, apply for media access, etc., we collect data to identify you (e.g. a copy of an ID card). We generally keep this data for [1-14] months from the last exchange with you. This period may be longer if necessary for evidentiary reasons or to comply with legal or contractual requirements or for technical reasons. Emails in personal mailboxes and written correspondence are generally kept for at least [10] years.

base data

We refer to master data as the basic data that we need in addition to the contract data (see below) for the processing of our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details and information, e.g. about your role and function, your bank details, your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (e.g. as a contact person for the business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. in the context of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you yourself (e.g. when making a purchase or as part of a registration), from bodies for which you work, or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.). We can also process health data and information about third parties as part of master data. We may also collect master data from our shareholders and investors. We generally retain this data for [10] years from the last exchange with you, but at least from the end of the contract. This period may be longer if necessary for evidentiary reasons or to comply with legal or contractual requirements, or for technical reasons. For purely marketing and advertising contacts, the period is normally much shorter, usually no more than [2] years since the last contact.


This is data that arises in connection with the conclusion or processing of a contract, e.g. information about contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information about reactions (e.g. complaints or information on satisfaction, etc.). We usually collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third-party sources (e.g. providers of credit data) and from publicly accessible sources. We generally keep this data for [10] years from the last contractual activity, but at least from the end of the contract. This period may be longer if this is necessary for reasons of evidence or to comply with legal or contractual requirements or for technical reasons.


Depending on the relationship we have with you, we try to get to know you and tailor our products, services and offers to you better. To do this, we collect and use data about your behavior and preferences. We do this by evaluating information about your behavior in our area, and we can also supplement this information with information from third parties - including from publicly accessible sources. Based on this, we can calculate the probability that you will use certain services or behave in a certain way. Some of the data processed for this purpose is already known to us (e.g. if you use our services), or we obtain this data by recording your behavior (e.g. how you navigate our website or our social media portals). We anonymize or delete this data when it is no longer meaningful for the purposes pursued, which can be between [2-3] weeks and [24] months (for product and service preferences), depending on the type of data. This period can be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in section 12.


We also collect data from you in other situations. In connection with official or legal proceedings, for example, data arises (such as files, evidence, etc.) that may also relate to you. We may also collect data for reasons of health protection (e.g. as part of protection concepts). We may receive or create photos, videos and sound recordings in which you may be recognizable (e.g. at events, through security cameras, etc.). We may also collect data on who enters certain buildings and when or has corresponding access rights (including during access controls, based on registration data or visitor lists, etc.), who takes part in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems and when. Finally, we collect and process data about our shareholders and other investors; in addition to master data, this includes information for the relevant registers, regarding the exercise of their rights and the holding of events (e.g. general meetings). The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and typically a few weeks for contact tracing data, to visitor data which is typically retained for [3] months, to event reports with images which may be retained for several years or longer.

You provide us with much of the data mentioned in this section 3 yourself (e.g. via forms, when communicating with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, with the exception of individual cases, e.g. within the framework of binding protection concepts (legal obligations). If you wish to conclude contracts with us or claim services, you must also provide us with data as part of your contractual obligation in accordance with the relevant contract, in particular master, contract and registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data.

Unless this is prohibited, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the Internet including social media) or receive data from other companies within our group, from authorities and from other third parties (such as credit agencies, address dealers, associations, contractual partners, Internet analysis services, etc.).


We process your data for the purposes that we explain below. You can find further information for the online area in sections 12 and 13. These purposes or the objectives underlying them represent legitimate interests of ours and, where applicable, of third parties. You can find further information on the legal basis for our processing in section 5.

We process your data for purposes related to communication with you, in particular to answer inquiries and assert your rights (Section 11) and to contact you if you have any questions. For this purpose, we use communication data and master data in particular and, in connection with offers and services you use, also registration data. We store this data in order to document our communication with you, for training purposes, for quality assurance and for inquiries. We process data for the establishment, administration and processing of contractual relationships.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalized advertising about products and services from us and third parties (e.g. from advertising contractual partners). This can, for example, take the form of newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions, etc.) and also include free services (e.g. invitations, vouchers, etc.). You can reject such contacts at any time (see the end of this section 4) or refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the Internet more specifically to you (see section 12). We also process your data for market research, to improve our services and operations, and for product development. We can also process your data for security purposes and for access control. We process personal data to comply with laws, instructions and recommendations from authorities and internal regulations ("compliance"). We also process data for the purposes of our risk management and as part of prudent company management, including operational organization and company development.


If we ask for your consent for certain processing, we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with effect for the future by sending us a written notification (by post) or, unless otherwise stated or agreed, by email; our contact details can be found in section 2. To revoke your consent for online tracking, see section 12. If you have a user account, you can revoke your consent or contact us via the relevant website or other service. As soon as we have received notification of the revocation of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The revocation of your consent does not affect the legality of the processing carried out on the basis of the consent up to the time of revocation.

Where we do not ask for your consent to process data, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, in particular in order to pursue the purposes and associated objectives described above under section 4 and to be able to carry out appropriate measures. Our legitimate interests also include compliance with statutory provisions, insofar as these are not already recognized as a legal basis by the applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and Switzerland).

If we receive sensitive data, we may also process your data based on other legal bases, e.g. in the event of disputes due to the need to process the data for a possible legal process or to enforce or defend against legal claims. In individual cases, other legal grounds may apply, which we will communicate to you separately if necessary.


We may automatically evaluate certain of your personal characteristics for the purposes stated in section 4 using your data (section 3) ("profiling") if we want to determine preference data, but also to determine misuse and security risks, to carry out statistical evaluations or for operational planning purposes. For the same purposes, we may also create profiles, i.e. we may combine behavioral and preference data, but also master and contract data and technical data assigned to you in order to better understand you as a person with your different interests and other characteristics.

If you are one of our customers, we can, for example, use "profiling" to determine which other products you are likely to be interested in based on your purchases. We can also use this to check your creditworthiness before we offer you a purchase on account. An automated evaluation of data can also, for your protection, check the probability that a certain transaction was fraudulent. This allows us to stop the transaction for clarification. A distinction must be made between these and "profiles". This means the linking of different data in order to gain clues about essential aspects of your personality from the totality of this data (e.g. what you like or how you behave in certain situations). Profiles can also be used for marketing, for example, but also for security purposes.

We use anonymous movement profiles in a non-personal way, for example to give our contractual partners recommendations for avoiding peak times. For personalized movement profiles, we use personal data, for example to point out interesting offers and products in your area, to draw conclusions about your interests from the location data (length of stay) and to inform you which products and services other contractual partners with similar interests have used.

In both cases, we ensure that the results are proportionate and reliable and take measures to prevent any misuse of these profiles or profiling. If these could have legal consequences or significant disadvantages for you, we generally carry out a manual review.


In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes listed in section 4, we also transmit your personal data to third parties, in particular to the following categories of recipients:


We work with service providers in Germany and abroad who process data about you on our behalf or under joint responsibility with us, or who receive data about you from us under their own responsibility.

In order to provide our products and services efficiently and to be able to concentrate on our core competencies, we obtain services from third parties in numerous areas. These services include, for example, IT services, the sending of information, marketing, sales, communication or printing services, building management, security and cleaning, the organization and implementation of events and receptions, debt collection, credit agencies, address checkers (e.g. to update address lists when moving), anti-fraud measures and services from consulting firms, lawyers, banks, insurers and telecommunications companies. We provide these service providers with the data required for their services, which may also concern you. These service providers can also use such data for their own purposes, e.g. information about outstanding debts and your payment history in the case of credit agencies or anonymized information to improve services. In addition, we conclude contracts with these service providers that contain provisions for the protection of data, unless such provisions arise from the law. Our service providers may process data on how their services are used and other data that arise in the context of the use of their services as independent controllers for their own legitimate interests (e.g. for statistical evaluations or billing). Service providers provide information about their independent data processing in their own privacy statements.


This primarily refers to our customers (e.g. service recipients) and other contractual partners, because this data transfer results from these contracts. For example, they receive registration data for vouchers issued and redeemed, invitations, etc. If you work for such a contractual partner yourself, we can also transfer data about you to them in this context.


We may pass on personal data to offices, courts and other authorities at home and abroad if we are legally obliged or authorized to do so or if this appears necessary to protect our interests. The authorities process data about you that they receive from us under their own responsibility.


This refers to other cases where the involvement of third parties results from the purposes set out in paragraph 4.

All of these categories of recipients can in turn involve third parties, so that your data can also be accessed by them. We can restrict processing by certain third parties (e.g. IT providers), but not that of other third parties (e.g. authorities, banks, etc.).


As explained in section 7, we also disclose data to other entities. These are not only located in Switzerland. Your data may therefore be processed in Europe; in exceptional cases, however, in any country in the world.

If a recipient is located in a country without adequate legal data protection, we will contractually oblige the recipient to comply with the applicable data protection (for this purpose we use the revised standard contractual clauses of the European Commission, which can be accessed here:, unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply in particular in legal proceedings abroad, but also in cases of overriding public interests or if the execution of a contract requires such disclosure, if you have consented or if the data concerned has been made generally accessible by you and you have not objected to its processing.

Please also note that data exchanged over the Internet is often routed via third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.


We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require it, or if storage is technically necessary. Further information on the respective storage and processing periods can be found in the individual data categories in section 3 or in the cookie categories in section 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymize your data after the storage or processing period has expired as part of our usual procedures.

Documentation and evidentiary purposes include our interest in documenting processes, interactions and other facts in the event of legal claims, discrepancies, IT and infrastructure security purposes and proof of good corporate governance and compliance. Retention may be necessary for technical reasons if certain data cannot be separated from other data and we therefore have to store it with them (e.g. in the case of backups or document management systems).


We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorized or unlawful processing and to counteract the risks of loss, accidental alteration, unwanted disclosure or unauthorized access.

Security measures of a technical and organizational nature may include measures such as encryption (e.g. SSL, TLS) and pseudonymization of data, logging, access restrictions, storage of backup copies, instructions to our employees, confidentiality agreements and controls. We protect your data transmitted via our website during transport using suitable encryption mechanisms. However, we can only secure areas that we control. We also require our contract processors to take appropriate security measures. However, security risks cannot generally be completely ruled out; residual risks are unavoidable.


Applicable data protection law grants you the right to object to the processing of your data, in particular for direct marketing purposes, profiling for direct marketing purposes and other legitimate interests in processing, under certain circumstances.

To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and which data we process about you;
  • the right to have us correct data if it is inaccurate;
  • the right to request the erasure of data;
  • the right to request that we provide you with certain personal data in a common electronic format or to transmit them to another controller;
  • the right to withdraw consent where our processing is based on your consent;
  • the right to obtain, upon request, further information necessary to exercise these rights;
  • the right to express your point of view in the case of automated individual decisions (point 6) and to request that the decision be reviewed by a natural person.

If you wish to exercise the above-mentioned rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; our contact details can be found in section 2. In order to rule out misuse, we must identify you (e.g. with a copy of your ID card, if this is not possible otherwise).

Please note that these rights are subject to conditions, exceptions or restrictions under applicable data protection law (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary.

If you do not agree with the way we handle your rights or data protection, please let us or our data protection officer (Section 2) know. In particular, if you are located in the EEA, the United Kingdom or Switzerland, you also have the right to complain to the data protection supervisory authority in your country.


We use various technologies on our website with which we and third parties we engage can recognize you when you use the website and, under certain circumstances, track you across multiple visits. We will inform you about this in this section.

Essentially, it is about being able to distinguish your access (via your system) from that of other users, so that we can ensure the functionality of the website and carry out evaluations and personalization. We do not want to draw any conclusions about your identity, even if we can do so if we or third parties we engage can identify you by combining you with registration data. Even without registration data, the technology used is designed in such a way that you are recognized as an individual visitor every time you visit a page, for example by our server (or the third party servers) assigning you or your browser a specific identification number (so-called "cookie").

Cookies are individual codes (e.g. a serial number) that our server or a server of our service provider or advertising partner transmits to your system when you connect to our website and that your system (browser, mobile) receives and stores until the programmed expiry date. With each subsequent access, your system transmits these codes to our server or the third party server. This way, you are recognized even if your identity is unknown.

Other techniques can also be used to recognise you with a greater or lesser degree of probability (ie to distinguish you from other users), eg fingerprinting. Fingerprinting combines the browser you use, the screen resolution, the language you choose and other information that your system sends to each server, resulting in a more or less unique fingerprint. Cookies can therefore be dispensed with.

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated into an email), your visits can be tracked. If we integrate offers from an advertising contract partner or provider of an analysis tool on our website, they can track you in the same way, even if you cannot be identified in individual cases.

We use such techniques on our website and allow certain third parties to do the same.

You can program your browser to block or spoof certain cookies or alternative technologies, or to delete existing cookies. You can also extend your browser with software that blocks tracking by certain third parties. For more information, see your browser's help pages (usually under the heading "privacy") or the websites of the third parties we list below.

The following cookies are distinguished (techniques with comparable functionality such as fingerprinting are included here):


Some cookies are necessary for the website to work as such or for certain functions to work. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies only exist temporarily ("session cookies"). If you block them, the website may not work. Other cookies are necessary so that the server can store decisions or entries you make beyond a session (i.e. a visit to the website) if you use this function (e.g. selected language, consent given, the function for automatic login, etc.). These cookies have an expiry date of up to [24] months.


In order to optimize our website and related offers and to better tailor them to the needs of users, we use cookies to record and analyze the use of our website, possibly even beyond the session. We do this by using third-party analysis services. We have listed these below. Performance cookies also have an expiry date of up to [24] months. Details can be found on the third-party websites.


We and our advertising partners have an interest in targeting advertising to specific groups, i.e. only showing it to those we want to address. We have listed our advertising partners below. For this purpose, we and our advertising partners also use cookies that can record the content accessed or contracts concluded. This enables us and our advertising partners to display advertising that we can assume will be of interest to you, on our website, but also on other websites that display advertising from us or our advertising partners. Depending on the situation, these cookies have an expiration period of a few days to [12] months.

In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we can transmit the email addresses of our users, customers and other people to whom we want to display advertising to operators of advertising platforms (e.g. social media). If these people are registered there with the same email address (which the advertising platforms determine by comparing), the operators will show the advertising we have placed to these people in a targeted manner. The operators do not receive personal email addresses of people they do not already know. However, if the email addresses are known, they will find out that these people are connected to us and what content they have accessed.

We can also integrate other third-party offers on our website, in particular those from social media providers. If you have an account with the social media provider, they can assign this information to you and thus track your use of online offers. These social media providers process this data under their own responsibility.

We currently use offers from the following service providers and advertising partners:


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


Google Ireland (based in Ireland) is the provider of the service and acts as our data processor. Google Ireland relies on Google LLC (based in the USA) as its data processor (both "Google"). Information on data protection can be found here [].


OneSignal, Inc. (based in the USA) is the provider of the service and acts as our data processor. Information on data protection can be found here [].


We may operate pages and other online presences on social networks and other platforms operated by third parties ("fan pages", "channels", "profiles", etc.) and collect the data about you there as described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. about your behavior and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalize advertising) and to control their platforms (e.g. which content they show you).

We process this data for the purposes described in section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see section 12) and for market research. Information on the relevant legal bases can be found in section 5. We may further distribute content published by you (e.g. comments on an announcement) (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further information on the processing carried out by the platform operators, please refer to the platform's data protection notices. There you will also find out in which countries they process your data, what information, deletion and other data subject rights you have and how you can exercise these or obtain further information.

We currently do not use any platforms.


This privacy policy is not part of a contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: April 2024