Privacy Policy

Preamble

With the following Privacy Policy, we would like to inform you about what types of your personal data (hereinafter also referred to simply as “data”) we process, for what purposes, and to what extent. This Privacy Policy applies to all processing of personal data carried out by us, both in the course of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Last updated: July 25, 2026

Table of contents

Controller

Stanislava Cabernard
Lumneins 19
7166 Trun

Email address:

Phone: +41 77 419 62 88

Overview of processing activities

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects concerned.

Types of data processed

  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication and procedural data.
  • Log data.

Categories of data subjects

  • Communication partners.
  • Users.

Purposes of processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or establishment. If, in individual cases, more specific legal bases are relevant, we will inform you of these in the Privacy Policy.

  • Consent (Art. 6(1) sentence 1 lit. a GDPR) – The data subject has given consent to the processing of personal data relating to them for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests, fundamental rights and freedoms of the data subject requiring the protection of personal data do not override those interests.

Relevant legal bases under the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss DPA”). Unlike, for example, the GDPR, the Swiss DPA generally does not require that a legal basis for processing personal data be stated, and processing of personal data is carried out in good faith, is lawful and proportionate (Art. 6(1) and (2) Swiss DPA). In addition, we only collect personal data for a specific purpose that is recognizable to the data subject and only process it in a manner compatible with that purpose (Art. 6(3) Swiss DPA).

Applicability of data protection requirements in the country of establishment: In the country in which the controller is established, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

Security measures

In accordance with the legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances and purposes of processing as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, ensuring availability and separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account already when developing or selecting hardware, software and procedures, in accordance with the principle of data protection by design and by privacy-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect users’ data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and in encrypted form.

Transfer of personal data

In the course of our processing of personal data, it may happen that it is transferred to other bodies, companies, legally independent organizational units or persons, or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, bodies or companies (which becomes apparent from the postal address of the respective provider or if the Privacy Policy explicitly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated 10/07/2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and set out contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur within the DPF, the Standard Contractual Clauses will take effect as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of political or legal changes.

For each service provider, we will inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information about the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission’s information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss DPA, we only disclose personal data abroad if adequate protection of the data subjects is ensured (Art. 16 Swiss DPA). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/de/schweizerische-anerkennung-von-staaten-die-einen-angemessenen-datenschutz-gewaehrleisten), we take alternative safeguards.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of Switzerland dated September 15, 2024. In addition, we have concluded standard data protection clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and set out contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard data protection clauses serve as additional security. Should changes occur within the DPF, the standard data protection clauses will take effect as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of political or legal changes.

For each service provider, we will inform you whether they are certified under the DPF and whether standard data protection clauses are in place. The list of certified companies as well as further information about the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, including international treaties, specific guarantees, standard data protection clauses approved by the FDPIC, or binding corporate rules recognized in advance by the FDPIC or a competent data protection authority of another country.

General information on data storage and deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consents are withdrawn or there are no other legal bases for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal enforcement or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

If multiple retention periods or deletion deadlines are specified for a set of data, the longest period always applies. Data that is no longer retained for the originally intended purpose but is kept due to legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply for retention and archiving under Swiss law:

  • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
  • 10 years – Data that is necessary to consider potential claims for damages or similar contractual claims and rights, as well as for processing related inquiries, based on previous business experience and customary industry practices, is stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 CO). After five years, claims for rent, lease and capital interest as well as other periodic services, from the delivery of food, for catering and for innkeepers’ debts, as well as from craft work, small retail sales of goods, medical services, professional work by attorneys, legal agents, procurators and notaries, and from the employment relationship of employees become time-barred (Art. 128 CO).

Start of the period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the time at which the termination becomes effective or the legal relationship otherwise ends.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6(1) lit. e or f GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted without undue delay or, alternatively, to request restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transfer to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the requirements of the Swiss DPA:

  • Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information required so that you can assert your rights under this Act and so that transparent data processing is ensured.
  • Right to data release or transfer: You have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the correction of inaccurate personal data concerning you.
  • Right to object, deletion and destruction: You have the right to object to the processing of your data and to request that personal data concerning you be deleted or destroyed.

Provision of the online offering and web hosting

We process users’ data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the users’ browser or device.

  • Types of data processed: Usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types used and operating systems, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.

Further information on processing operations, procedures and services:

  • Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a “web host”); Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, amounts of data transferred, message about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Use of cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies may also be used for various purposes, such as ensuring functionality, security and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies where storing and reading information is essential in order to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We clearly inform you about its scope and which cookies are used.

Notes on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, usage data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage period of cookies (e.g., as part of obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.

General notes on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to processing in accordance with the legal requirements, including via their browser’s privacy settings.

  • Types of data processed: Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution to obtain users’ consent for the use of cookies or for the procedures and providers named within the consent management solution. This procedure serves to obtain, log, manage and withdraw consent, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option to manage and withdraw their consent. The consent declarations are stored in order to avoid having to ask again and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information about the providers of consent management services is available, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information about the scope of consent (e.g., relevant categories of cookies and/or service providers) as well as information about the browser, the system and the device used; Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR).

Contact and inquiry management

When contacting us (e.g., by post, contact form, email, phone or via social media) as well as within existing user and business relationships, the information provided by the inquiring persons is processed insofar as this is necessary to respond to contact inquiries and any requested measures.

  • Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., text or image messages and posts and the information relating to them, such as information on authorship or time of creation). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.

Further information on processing operations, procedures and services:

  • Contact form: If you contact us via our contact form, by email or other communication channels, we process the personal data you provide to respond to and handle the respective request. This generally includes information such as name, contact details and, if applicable, other information you provide that is required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Changes and updates

We ask that you regularly inform yourself about the content of our Privacy Policy. We adapt the Privacy Policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this Privacy Policy, please note that the addresses may change over time and please check the information before contacting them.

Definitions

In this section, you will find an overview of the terms used in this Privacy Policy. Where the terms are legally defined, their legal definitions apply. The explanations below are intended primarily to aid understanding.

  • Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about how data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details such as file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email correspondence, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission channels. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they take through an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
  • Personal data: “Personal data” is any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person is considered identifiable if they 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 (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, monitor security or create performance reports.
  • Controller: The “controller” 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.
  • Processing: “Processing” is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collecting, evaluating, storing, transmitting or deleting it.

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