Preambles

We believe that your personal data belongs to you. For that we create digital solutions that give you a simple way to take back control of your personal data, empowering you to decide the terms for responsible use by commercial entities. This privacy policy is meant to help you understand what information we process in order to provide our services and what your rights are.

In short, we do NOT store any personal data if you use our application or visit our website. We ONLY store your e-mail and optionally your name and feedback if you subscribe to our newsletter or contact us. NO other personal data is stored.

1. Scope

This privacy policy stipulates how FlecheTech Sàrl, Aarbergstrasse 46, 2502 Biel/Bienne, Switzerland (hereinafter “FlecheTech” or “we”) processes personal data of individuals (“you”) who provide personal data on its website, in its application or via other means.

2. Contact

You can contact us as follows:

FlecheTech Sàrl
46 Aarbergstrasse,
2502 Biel/Bienne
Switzerland
FlecheTech is represented
by Adrien Girod
[email protected]

In the European Union FlecheTech is represented by:

FlecheTech Sàrl
46 Aarbergstrasse,
2502 Biel/Bienne
Switzerland

You can contact our data protection officer as follows:

FlecheTech Sàrl
46 Aarbergstrasse,
2502 Biel/Bienne
Switzerland

3. General

FlecheTech aims, through the provision of services and the manufacture of products in the field of information and software technology and data protection, to protect the personal data and privacy of its customers and to enable them to control the use of their personal data and to decide in what form their personal data is used by third parties. For this purpose, FlecheTech allows you to manage your personal data rights given by applicable laws (e.g. GDPR in Europe). This includes but is not limited to the management of privacy settings of digital services such as social media, search engines, e-commerce etc. provided by companies and institutions

All personal data processed, which are protected either by the European General Data Protection Regulation (hereinafter “GDPR”) and/or by the Swiss Federal Act on Data Protection (hereinafter “FADP”), will be used exclusively for fulfilling our services to you; unless, in particular pursuant to this privacy policy, you have consented to further use of your personal data or the applicable law permits such further use (e.g. legal obligations or legitimate and vital interests).

4. What Personal Data is Collected for What Purpose

4.1. Users of our application

FlecheTech does NOT collect or process any personal data if you download and use our application.
All personal data used by our application to provide the service is only stored locally within our application on your device. It is not seen, known, used, or accessed by either FlecheTech or any third party. This data includes your privacy preferences, which third party services you manage via our application, and authentication tokens.

4.1.1 Testers of our application

You may decide to register and become a test user of our web application before it is officially released. To enroll you as test users, we need to collect your e-mail address and optionally other data like your name.

4.2. Visitors of our website

Traffic data is used to display our website correctly and optimized and to protect it against attacks or other infringements. It includes the IP address of the device you are using to access our website, information about which browser and browser version you are using, when you accessed our website, etc.

4.3 Subscriber of our newsletter and persons using our contact forms

You may decide to subscribe to our newsletter or contact us through our website. In this case we collect your e-mail address, and optionally your feedback and other contact data like your name, to send you our newsletter or to provide customer support.

4.4. Personal data received via other channels

We might receive and process personal information via other channels e.g., if you send us an e-mail, letter, or give us telephone call. In this case, we might store this personal data in our database.

4.5 Handling of your personal data

Input fields that are necessary are marked accordingly. The disclosure of personal data in non-marked or as optional marked input fields is voluntary.
We also might add other information to your personal data in our database for instance time stamps or our response to your request.
The personal data we collect and process from you is stored at cloud service providers, i.e., at third parties we instruct to do so (see sec. 6 hereinafter). Occasionally, we might download personal data to computers which FlecheTech operates, e.g. for providing customer support, for market research and for debugging purposes. In this case we anonymize and minimize the personal data used as far as possible.
You can inform us at any time that you no longer wish us to process your personal data (cf. section 11, Your Rights).

5. Retention Period

5.1. Users of our application

As no personal data is stored at FlecheTech but only on your device, your data is deleted once you delete our application.

5.2 Visitors of our website, subscribers of our newsletter or persons contacting us

We only process personal data until the purpose, for which it was collected, is fulfilled, as required by law, or as stipulated in the contracts with third parties operating our IT.
You can request the deletion of your personal data anytime (cf. section 11, Your Rights). We will delete your personal data unless we are required otherwise by applicable law.
To refuse further business contact with a data subject due to misuse or other legitimate reasons, we may store personal data for five years, or ten years in case of recurrence.

6. Processing of Personal Data

6.1 Processing by FlecheTech

As we process personal data electronically, we have taken appropriate IT organisational and technical measures to ensure that your personal data is protected (e.g., we rely on professional cloud service providers to store and process your personal data and do not operate our own servers for IT-security reasons).
Our employees are obliged to treat personal data confidentially. We also regularly educate our employees in data protection and information security.

6.2. Processing by third Parties and abroad

Within the purpose agreed herein, we may have personal data processed by our group entities or third parties. Such third parties are companies that operate our servers and information technology (cloud service providers for our hosting, office tools, our continuous integration and deployment systems, and other), payment service providers, or attorneys and government bodies. If we commission group companies or third parties with the processing of personal data, the third party will be carefully selected and must take appropriate security measures to guarantee the confidentiality and security of your personal data.

We or the third parties may process personal data abroad, i.e. in European or non-European countries. We represent that the third parties will only use personal data according to the law and exclusively in the interest of FlecheTech. These necessary contractual guarantees provided by the third parties are based on the standards of the European Commission (also recognised in Switzerland). You have the right to inspect the guarantees in these contracts (or parts thereof).

We have engaged the following third parties as sub-processors:

7. Anonymized usage and survey data

We collect anonymized usage data (e.g., error messages or which buttons are clicked) when you access our website. The application collects anonymized usage data only if you explicitly opted in. If you participate in surveys on our website or in our application, we only process anonymized results. Hence, we do not and cannot draw any conclusions about you as a person from this usage or survey data. We merely use them to optimize our services or market research purposes.

8. Inclusion of Third Party Elements on Our Web Site

We do NOT embed any third party elements (e.g. YouTube player, social media buttons) on our website. We only use hyperlinks to external content in order to protect your privacy.

10. Legal Bases of Processing

The legal justification, upon which we base our processing of personal data, is stipulated in article 6(1)(b) GDPR (performance of contract) and in article 6(1)(a) GDPR (consent). For Switzerland this corresponds to article 13(2)(a)/31(2)(a) FADP/revised FADP, article 13(1)/31(1) FADP/revised FADP (consent of the data subject or obligation to process by law), respectively. If we are required to process your personal data by law, the legal basis lies in art. 6(1)(c) DSGVO or article 13(1)/31(1) FADP/revised FADP or the respective legal basis for our obligation to process data.

We reserve the right to store contact data (e.g. first name and surname, e-mail address, IP-address) of a data subject pursuant to article 6(1)(f) GDPR (legitimate interest) – corresponding to 13(1)/31(1) FADP/revised FADP for Switzerland – if, based on misuse or similar legitimate reasons, we refuse to conclude any future contracts with data subjects or to protect our IT.

11. Your Rights

Upon request, we will inform you about and – if so – which personal data we process about you (right of confirmation, right of access).

At your request:

we will cease processing personal data, in part or in full (right to withdraw your consent to the processing of personal data for one or more specific purposes; right to erasure (right “to be forgotten”)). Your request to be forgotten will also be communicated to third parties to whom we have previously forwarded your personal data.
we will correct the relevant personal data (right to rectification);
we will restrict the processing of the relevant personal data (right to restriction of processing; in this case we will only store or use your personal data to protect our own legal claims or the third party rights;
you will receive the relevant personal data in a structured, commonly used and machine-readable format (right to data portability).

To request any of the rights described in this section, for example if you no longer wish to receive our e-mail newsletters or if you wish to delete your account, please use the appropriate function on our website, send us an e-mail, or contact our data protection officer or an employee as described in section 2 (Contact).

If we do not comply with your request, we will inform you of the reasons for our non-compliance. For example, we may legally refuse to delete your personal data if we still need it to fulfil the purpose, for which it was originally provided (for example if we continue providing our services to you), if the processing is based on mandatory law (for example mandatory accounting regulations), or if we have a predominant interest of our own (for example in the case of a lawsuit against the data subject).

If we assert a predominant interest in the processing of personal data, you have nevertheless the right to object to the processing; provided, however, that your individual situation compares differently to that of other data subjects (right to object). This could be the case, for example, if you are a person of public interest, or if processing increases the risk of you being harmed by third parties.

If you disagree with our response to your request, you have the right to file a complaint with a competent supervisory authority, for example, in your country of residence or at the registered seat of FlecheTech (right to appeal).

12. Severability and Changes

If any provision of this Agreement is held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions will in no way be affected or impaired as long as the intent of the Parties can be preserved.

Due to the further development of our website and offers or due to changed legal or official requirements, it may become necessary to change this privacy policy. Any changes will be communicated through our application, through our website, and by e-mail (for registered users only).

13. Applicable Law and Place of Jurisdiction

This privacy policy and any agreements concluded based on, or in connection with, this privacy policy, as the case may be, are governed by Swiss law, unless the applicable law of another country applies mandatorily. The place of jurisdiction is the registered seat of the headquarter of FlecheTech in Biel/Bienne, Switzerland, unless a different place of jurisdiction applies mandatorily.

Privacy Policy