1. General Note

Based on Article 13 of the Swiss Federal Constitution and the data protection provisions of the Federal Government (Data Protection Act, DSG), every individual is entitled to the protection of their privacy as well as protection against misuse of their personal data. The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations and this privacy policy.

In cooperation with our hosting providers, we strive to protect the databases as best as possible against unauthorized access, loss, misuse, or falsification.

We would like to point out that data transmission over the Internet (e.g., when communicating via email) may have security vulnerabilities. Complete protection of data from access by third parties is not possible.

By using this website, you agree to the collection, processing, and use of data as described below. This website can generally be visited without registration. In this process, data such as accessed pages or names of accessed files, date, and time are stored on the server for statistical purposes without these data being directly related to your person. Personal data, especially name, address, or email address, are collected on a voluntary basis whenever possible. Without your consent, the data will not be disclosed to third parties.

2. Processing of Personal Data

Personal data refers to any information relating to an identified or identifiable individual. A data subject is an individual about whom personal data is processed. Processing includes any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction of personal data.

We process personal data in accordance with Swiss data protection law. Furthermore, we process personal data in accordance with the following legal bases relating to Art. 6(1) GDPR to the extent and as long as the GDPR is applicable:

• Consent (Art. 6(1) lit. a. GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  
  
• Performance of a contract and pre-contractual inquiries (Art. 6(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.
  
  
• Legal obligation (Art. 6(1) lit. c. GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  
  
• Protection of vital interests (Art. 6(1) lit. d. GDPR) - Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  
  
• Legitimate interests (Art. 6(1) lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller 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.
  
  

We process personal data for the period necessary to fulfill the respective purpose or purposes. In cases of longer retention obligations due to legal or other obligations to which we are subject, we restrict processing accordingly.

Specifically, we process personal data in the following cases:

1. Visiting our website Each time transferly.swiss is accessed, the web server automatically stores a log file, which may include the name of the accessed URL, the visitor's IP address, date and time of access, the browser used, the amount of data transferred, the HTTP status code, and the requesting provider.
   
   Additionally, with each visit, if visitors have consented via cookie settings, anonymized visitor data such as date and time of access, origin, device, device type, operating system, browser, screen resolution, etc., are stored on the self-hosted open-source web analytics service Matomo.
   
   This data is solely evaluated for the purpose of ensuring smooth and secure operation of the site, improving the offering, and optimizing advertising.
   
   
2. Hosting services by third-party providers
   In the context of hosting services for representation, support, and operation of their service, transferly.swiss has commissioned Flow Swiss AG, Dufourstrasse 49, CH-8008 Zurich. Flow Swiss AG is an ISO-27001 certified cloud provider that stores all data in Switzerland in certified data centers.
   
   
3. Data collection and usage
   Collection and usage of personal data occur only in the following cases:
   1. When visiting our website or using our services through server logs, usage statistics, and web analytics
   2. When registering or logging into our website
   3. When ordering paid services and their invoicing
   4. When sending and requesting data if logged in
   5. When automaticly detecting abuse
   6. When contacting or reporting abuse
   7. In newsletter and information distribution

3. Security measures

In accordance with legal requirements and taking into account the state of the art, implementation costs, the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the threat 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.

4. Data transmission to third parties

1. Hosting Services
   In the context of hosting services for representation, support, and operation of their service, tranferly.swiss has commissioned Flow Swiss AG, Dufourstrasse 49, CH-8008 Zurich. Flow Swiss AG is an ISO-27001 certified cloud provider that stores all data in Switzerland in certified data centers.
   
   
2. Payment Provider
   For payment processing of paid services via credit card, the third-party provider Stripe Inc., 510 Townsend St., San Francisco, CA 94103, USA is utilized. Only the personal data necessary for payment processing and invoicing is transmitted.
   
   
3. Two-Factor Authentication (2FA)
   For two-factor authentication, SMS messages are sent, among other things. The mobile phone number of the affected individuals is transmitted to Twilio Inc., 101 Spear Street, 1st Floor, San Francisco, CA 94105, USA.
   
   
4. Identity Verification
   For optional identification of individuals using officially issued identification and a photograph, the third-party provider Stripe Inc., 510 Townsend St., San Francisco, CA 94103, USA is used.
   
   
5. Captcha Verification
   This website uses Friendly Captcha, a Proof-of-Work-based, privacy-friendly, and fully GDPR-compliant solution to block spam or abuse.
   
   Friendly Captcha generates a unique crypto puzzle for each user, which is automatically solved in the user's browser without storing their personal data.
   
   Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Germany
   
   
6. Display of Videos via Vimeo
   This website embeds videos from Vimeo.com. Vimeo.com is an online video streaming service that allows minimizing user tracking to a minimum.
   
   The data collected by Vimeo.com and its use are detailed in their Privacy Policy.
   
   Vimeo.com, Inc., Data Protection Officer, 330 West 34th Street, 10th Floor, New York, New York 10001, privacy@vimeo.com

5. Newsletter and online marketing distribution

If a user registers on transferly.swiss, they automatically agree to receive newsletter and online marketing emails. Unsubscribing from these emails is possible at any time via a link in the email. Re-subscribing can be done through the contact information provided in the imprint.

6. Cookies

To make the visit to our website attractive and to enable the use of certain functions, to display suitable products, or for market research, we use so-called cookies on various pages.

The user can decide for themselves about the use of cookies. We generally distinguish between two types of cookies:

1. Functional Cookies: These cookies are necessary for the proper functioning of our service and cannot be refused. When using transferly.swiss, a user implicitly accepts the storage of such cookies on their computer.
2. Analytics Cookies: These cookies are used for the anonymous recording of user behavior and analysis purposes to improve the service. The storage of analytics cookies is based on Art. 6 para. 1 lit. f DSGVO.

7. Use of Matomo

This website uses Matomo (formerly Piwik), an open-source software for statistical analysis of visitor traffic. Matomo uses so-called cookies, which are text files that are stored on your computer and enable an analysis of your use of the website.

The information generated by the cookie about your use of the Internet offering is stored on a server in Switzerland.

The IP address is anonymized immediately after processing and before storage. You have the option to prevent the installation of cookies by changing the settings of your browser software. We would like to point out that if you make corresponding settings, not all functions of this website may be available.

You can decide whether a unique web analysis cookie may be stored in your browser to enable the operator of the website to collect and analyze various statistical data.

8. Hyperlinks to other websites

The transferly.swiss service may contain links to other websites and social networks. We do not monitor these websites and are not responsible for their content or their handling of personal data. Our websites do not use social media plugins.

9. Rights, information and contacts

transferly.swiss has a responsible data protection officer who is available, in particular, for information and requests regarding personal data collected and processed, data corrections, objections to data collection and retention, and requests for data deletion in accordance with data protection legislation. The data protection officer can be contacted directly as follows:

transferly.swiss
c/o Digio AG
Birmensdorferstrasse 94
CH-8003 Zürich
+41 44 523 40 40
privacy@transferly.swiss

The competent data protection supervisory authority for Switzerland is the Federal Data Protection and Information Commissioner (EDÖB): www.edoeb.admin.ch.

10. Right to object

If personal data relating to the European Union (EU) is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, as defined in Art. 3 of the EU General Data Protection Regulation (GDPR), the data subject has the right, under Art. 21 GDPR, to object to the processing of such data if there are reasons arising from their particular situation or if the objection is directed against direct marketing measures. In the latter case, you have the option to object to the use of your data for marketing purposes (newsletter) at any time with effect for the future.

11. Retention and deletion

We keep personal data for as long as the data subject gives us their consent, it is necessary for the processing of the relevant legal relationship, and/or it is legally required. After that, personal data will be technically and appropriately deleted.