Privacy

Who is responsible

The controller is the operator named in the imprint. Write to the contact address there for anything on this page; it reaches a person, not a queue.

Whether an EU representative under Art. 27 GDPR is required here is an open question for counsel. It is named rather than omitted so that its absence is a known gap and not an oversight.

What is processed, and why

Only what a purpose needs. There is no profiling, no advertising, and no automated decision with a legal effect.

• —Waitlist: the email address you enter, and a company name if you choose to give one, so we can write to you when a place opens. Consent, withdrawable at any time by replying and asking.
• —Account and assessment data: what you enter into the product, so the product can compute and store your assessments. Performance of the contract.
• —Security and operations: sign-in events, audit records and server logs, so misuse can be detected and an account can be recovered. Legitimate interest in running the service safely.
• —Setting up your account: your name and, if you choose, the area you work in; the name of the organisation you create or join, its country and, if you give it, its size; and, if we ask how you heard about us, your answer, which is optional. So the product can address you and show your colleagues who you are: performance of the contract. The organisation’s country and size, and your answer about how you heard about us, so that we can understand where our users are: legitimate interest. The size and the answer are yours to leave empty.
• —What you accepted: which version of the Terms of Use, the Privacy Policy and the Data Processing Addendum you accepted, when, and a fingerprint of the text, so that what you agreed to can be shown. Legitimate interest in being able to show what you agreed to.
• —Product news by email: only if you tick the optional box, which is separate from accepting the terms and never ticked for you. We record that you consented, and each time you withdraw it. Nothing is sent on the strength of it yet. Consent.

Who else sees it

Processors, each under a written agreement that limits them to acting on the operator’s instructions. Nothing is sold, and nothing is shared for anyone else’s purposes.

• —The hosting and deployment provider, which runs the application and its logs.
• —The managed database provider, which stores the data at rest.
• —The transactional mail provider, which delivers sign-in, invitation and notification mail.
• —Platform staff, through the operator console: the country and size of an organisation, and, if we ask, how people heard about us.

Where it goes

Processing is intended to stay within Switzerland and the European Economic Area. Where a provider processes data elsewhere, a transfer mechanism is required, and naming the right one for each provider is an open question for counsel.

This section will name each provider, each country and each mechanism before these pages are published. Until it does, treat it as incomplete rather than as a statement that no transfer happens.

How long it is kept

Until the purpose ends, and then not longer because deleting is inconvenient.

• —Waitlist entries: until a place is offered and declined, or until you ask for removal.
• —Account and assessment data: for as long as the account exists, and then through the deletion process the account settings describe.
• —Security and audit records: kept for a limited retention window, because a record that can be deleted on request is not a record of anything. The exact window is set in the operator’s retention policy.
• —Server logs: a short operational window measured in days.
• —Records of what you accepted, and of your product-news consent and its withdrawal: ten years, and beyond the deletion of your account, because they are evidence of what was agreed; once the account is gone they are kept without any link to you.

What you can ask for

Write to the contact address in the imprint. You will get an answer from a person, and you do not have to give a reason.

• —A copy of the data held about you, and information about how it is processed.
• —Correction of anything inaccurate.
• —Deletion, where no obligation requires the record to be kept.
• —Restriction of processing, and objection to processing based on a legitimate interest.
• —Your data in a portable form.
• —Withdrawal of any consent you gave, as easily as you gave it — the waitlist one is a reply to any mail, and the product-news one is a switch on your account page.
• —A complaint to the Federal Data Protection and Information Commissioner in Switzerland, or to your own supervisory authority in the European Economic Area.