Last updated: 04 January 2024

Welcome to SINAPS GmbH. We value your privacy and take the security of your personal data very seriously. To provide you with our range of services, such as coaching, using our website, attending events or masterclasses, and receiving our newsletter ("Services") we need to collect some of your personal data. This Privacy Policy is here to help you understand what information we collect, how we use it, and your rights. Whether you’re visiting our website: www.sinaps.ch and any sub-domains of this site, or providing your personal data through other means, this Policy applies.

Before you use our Services or access to our website, please take time to read this Privacy Policy carefully. If you disagree with this Policy, you should not provide any personal data and refrain from using our Services or the website.

If you have any questions about how we handle your personal data, please get in touch using the contact details in Section 16 “How to contact us” below.

1.  Identification of the Data Controller

SINAPS GmbH (hereafter referred to as “SINAPS”, “we” “us” or “our”) acts as a Data Controller for the personal data we process about you when you use our Services. We recognize that you, as a Data Subject, have certain rights regarding your personal data. We take our best efforts to handle your personal data responsibly and in a manner that aims to comply with the General Data Protection Regulation (GDPR) and all other relevant privacy laws, including the revised Swiss Federal Act on Data Protection (FADP).

2.   What Personal Data Do We Process About You:

The collection and processing of personal data depends on the context of our interactions with you. We collect and process personal data that may include, but is not limited to:

o  Name

o  Date of birth

o  Contact information such as email address, telephone number, and physical mailing address

o  Gender

o  Job Title

o  Profession

o  Income level

o  Demographic information, including religion, ethnicity, and marital status

o  Details relevant to our Service delivery, such as partner preferences, lifestyle choices, values, goals, dreams, aspirations, availability and travel schedules

o  Payment and invoicing information

o  Anonymized data that doesn’t identify you

o  IP address (automatically collected)

o  Web browser type and version (automatically collected)

o  Operating system (automatically collected)

o  A list of URLs including the referring site, your activity on our website and the site you exit to (automatically collected

 3.     How Do We Collect Your Personal Data

 o   Information You Provide Directly: this includes information you share during in-person interactions, over the phone, or through electronic communication while scheduling a call or undergoing the application process; when you inquire about or purchase our Services; as part of newsletter subscriptions; and during registration or participation in events and masterclasses. It also encompasses personal data collected automatically when you visit or use our website/software applications or engage with us via social media.

o   Information We Collect from Other Sources: we may also obtain your personal data indirectly. For instance, from comments you make on blog posts, interactions on social media platforms like LinkedIn, or followings and comments on SINAPS's social media profiles. Even if you later remove your information from social media sites, SINAPS retains data from previous interactions. Additional sources include referrals, data gleaned from Google Analytics on our website, and information collected through social media widgets like contact forms, as well as from tracking and statistical tools that may be utilized by SINAPS.

4.     Why Do We Collect Your Personal Data

We collect your personal data to interact with you and to provide our Services. We use this information for several purposes:

o   To provide and manage our Services;

o   To communicate with you about our Services, answer your inquiries, and send administrative and informational content;

o   With your consent, and where permitted by law, we may use your personal data for marketing, including contact via email, social media, or text with information, offers, and news about our Services;

o   To share important updates about SINAPS’s terms and conditions, policies or any emergency communications (e.g. last-minute cancellation of a date);

o   To fulfill legal, regulatory, and contractual obligations;

o   For crime prevention, fraud detection, and that no one misuses our Services;

o   To address legal claims or disputes;

o   For operational reasons such as financial transactions, procurement, security, and unauthorized use preventions, backup storage, and to protect our business interests;

o   To develop, adapt, and enhance our Services and troubleshoot problems;

o   For internal data analysis;

o   To address your questions or requests;

o   To protect the vital interests of you or another person;

o   When you allow us to post testimonials;

o   To conduct market research through various channels, which helps us tailor and improve our Services and your online experiences;

o   To comply with applicable laws and regulations.

If you contact us directly via email, the personal data you transmit is automatically stored for processing or to get back to you.

5.     The Legal Basis For Processing Your Personal Data

 o  With Your Consent:

We may request your permission to process your personal data for specific purposes. You have the right to withdraw your consent at any time, though this will not affect the processing that has already occurred. For instance, we need your consent to provide you with personalized coaching services or to create your profile for matchmaking.

Please be aware that as the data controller, we reserve the right to object to withdrawal requests if we determine that compelling legitimate grounds or legal obligations for the processing override the interests, rights, and freedoms of the individual, or for the establishment, exercise, or defense of legal claims.

SINAPS does not actively request sensitive personal data such as information about your health, ethnicity, or religious beliefs. However, you may choose to provide this information if you believe it could be beneficial in optimizing the Services, we provide to you. We will take all reasonable steps to protect this data. The provision of such information is entirely voluntary, and not providing it will not limit your access to most of our Services. Should you choose to provide sensitive personal data, you retain the right to withdraw your consent for its use at any time, without impacting your access to our other Services.

Non-mandatory information is optional, and you may opt-out of non-essential communications by unsubscribing at: info@sinaps.ch

o   Pursuing Legitimate Interests

We process your personal data when it is in our legitimate interests to do so and when these interests are not overridden by your data protection rights. Our legitimate interests include:

·       Enhancing, maintaining, and improving our Services to meet our clients’ needs;

·       Marketing to inform you about our Services;

·       Addressing fraud, security, or technical issues ;

·       Protecting the rights, property, or safety of SINAPS, our clients, or the public;

·       Conducting research that improves our Services for our clients;

·       Fulfilling obligations to our services providers we may engage with;

·       To address legal claims or disputes;

o   Based on Contractual Obligations

We process certain personal data to fulfill our contractual obligations, such as payment information for invoicing or providing contact details for contract setup and onboarding.

o   Compliance with Legal Obligations

We are limited in the level of privacy we can assure. We may need to process certain personal data in response to legal processes or enforceable governmental requests. Compliance with the law requires us to process personal data for statutory obligations, like tax or accounting record-keeping. SINAPS restricts access to personal data and limits processing as much as possible, taking reasonable steps to protect it.

6.     How We Share Your Personal Data

The disclosure of your personal data depends on the situation and is only carried out with parties who have a legitimate need to access it for Services provided by or through SINAPS.

We may share your personal data, to the extent permitted by law and on a need-to-know basis, with:

o    Internal employees at SINAPS;

o    Coaches, therapists, doctors and psychologists, but only with your permission;

o    Third party service providers with whom SINAPS has partnered, whose services complement, facilitate and enhance our own. These include providers for billing and payment processing, session recording, virtual conference services, content, legal and financial advice, event organization, administrative tasks, client onboarding, contract setup, testimonial editing, web hosting, search engine optimization, advertising, and marketing.

o    SINAPS may also disclose or allow access to your personal data in response to a legal request, such as a subpoena, legal proceedings, search warrant, or court order, or to comply with applicable laws if there is a good faith belief that the law requires it, with or without notice to you.

In cases where SINAPS must share your data with third parties, we will take reasonable steps to ensure that your personal data is handled securely and in accordance with your rights, our obligations, and the third parties’ obligations under the law.

Our website is hosted by Squarespace, which also hosts and owns our consultation booking form (Acuity scheduling). As our data processor, Squarespace plays a key role in managing our online presence. For more information about Squarespace, you can read Squarespace Terms of Service, Squarespace Privacy Policy and their Data Processing Addendum.

7.     International Data Transfers 

Some of SINAPS’s service providers or collaborators may be based outside of EEA and Switzerland. If you are based in Europe or Switzerland, we may transfer your personal data outside of these regions. When we do, we ensure that: (i) the European Commission or Swiss Data Protection Authorities recognize the receiving country as providing an adequate level of data protection; (ii) the appropriate Standard Contractual Clauses are in place, such as the Regulation (EU) 2016/679 of the European Parliament and of the Council from June 4, 2021, or (iii) we have obtained your explicit consent for the transfer.

8.      Cookies And Their Use

Cookies are small text files placed on your computer when you visit our website. We use cookies to recognize your computer, which make it possible for us to determine the frequency of use and the number of users of the pages of our website, and to analyze behavior of our website users.

You will be asked for consent to set cookies on your computer or device before they are used. By consenting to our use of cookies, you enable us to provide you with an optimal service and user experience.

You have the option to refuse cookies, but please be aware that this may impair some of the website's functionality.

You can also delete cookies. If you are in Europe, you can learn more about how to delete cookies on this website: www.youronlinechoices.com

Please be aware that if you delete cookies, it could negatively affect the functionality of many websites.

Additionally, our website allows you to share pages with social networks such as Facebook. Please note that our website does not share any personal data with these third-party social networks.

9.     Use of Google Analytics

Our website utilizes Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics employs "cookies", which are text files placed on your computer, to help the website analyze how users engage with the site. The information generated by the cookie about your use of the website (including your IP address) may be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

We use the data from Google Analytics to gain insights into how our website is used, to improve user experience, and to tailor our Services better to our visitors' needs. By using our website and accepting the cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If you wish to opt-out of Google Analytics tracking, you can download and install the Google Analytics Opt-out Browser Add-on for your current web browser. This provides you with more control over what data relating to your website visits is collected by Google Analytics.

For more information on terms of use and data privacy, please visit Google Analytics Terms of Services or the Google Privacy Policy. We also use reports provided by Google Analytics to help understand website traffic and webpage usage.

10.  Your Data Protection Rights

Under the GDPR and revised Swiss FADP, you as a Data Subject, have certain rights:

o    The Right to Access: this means you may request access to and obtain a copy of your personal data;

o    The Right of Rectification: you may also request that any personal data that is inaccurate or incomplete be rectified or completed;

o    The Right to be Forgotten: you may request that your personal data be erased under certain legal conditions (for example, where the personal data is no longer needed to achieve the purposes for which the information was initially collected);

o    Data Portability: receive your personal data in a machine-readable format and send it to another data controller;

o    The Right to Object and The Right to Restriction of Processing: this means you may object to the processing of your personal data and ask us to restrict the processing of your personal data;

o    Opt-out: if applicable, you have the right to opt-out of electronic marketing communications we send you at any time and free of charge;

o    Automated Decision-Making: request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.

We will respond to your request without undue delay and at the latest within one (1) month. That period may be extended by two (2) further months where necessary, considering the complexity and number of the requests. Please note that to exercise your rights, you may be asked to confirm your identity. This could involve providing identity document or other details. There is no fee for this service, and we will provide the information you request free of charge.

You may exercise any of the rights above at any time by contacting us as described under Section 16 « How to Contact Us” below.

11.  Retention of Personal Data:

We are committed to only retaining personal data for as long as necessary to fulfill the purposes for which it was collected. This may include the duration of your relationship with us, as well as any legal, regulatory, and financial reporting obligations.

How Long We Keep Your Data:

o    Service Provision: For the duration of your active engagement with our Services, and for a reasonable period thereafter in case you decide to re-engage with our Services.

o    Legal Compliance: As required by tax laws, anti-fraud regulations, and other legal requirements, which may necessitate holding your personal data for specific periods as defined by law.

o    Contractual Necessity: For the length of any contractual relationship and after its termination, as necessary to enforce or defend against legal claims.

o    Consent-Based Processing: Where processing is based on your consent, such as for marketing purposes, until such time as you withdraw that consent.

o    Analytical and Improvement Purposes: For as long as required to carry out analytical work or to improve our Services, which may include anonymization of personal data so that it no longer relates to an identifiable individual.

When we no longer need your personal data, we will securely delete or anonymize it. If this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

12. Supervisory Authority

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

Contact details for data protection authorities in the European Economic Area available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

and Switzerland are available here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

13.  Security and Protection

We have taken all reasonable steps to protect your personal data from being lost, modified, misused, unauthorized access, or breaches.

Information Regarding Personal Data Breaches:

A personal data breach happens when there is a failure in security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. In such an event, we may have to notify the supervisory authority without undue delay. If the personal data breach is likely to pose a high risk to your rights and freedoms and the risk has not been mitigated, we will also notify you directly.

Please keep in mind:

1. No method of electronic transmission or storage is 100% secure, and therefore, we cannot guarantee absolute security of your personal data.

2. Similarly, we cannot assure the security of any personal data you send to us via postal services or other physical delivery methods.

3. You should keep your passwords confidential and never share them with anyone. SINAPS will never request your password from you.

Links to External Sites:

Links on our website may lead to third-party resources, over which SINAPS has no control. The processing of personal data on these third-party websites including by use of cookies is subject to these third-party notices and terms of use. Please review the notices and terms of use of each website you visit.

14.  Changes in Business Ownership

Our business may evolve over time, which could include expanding, downsizing, or selling parts or all our operations. In such cases, the transfer of ownership or control may involve the transfer of personal data held by SINAPS to the new owner or newly controlling party. This data will be transferred only if relevant to the part of the business being sold or transferred.

According to this Privacy Policy, the new owner or party in control will be allowed to use your personal data solely for the purposes for which it was originally obtained by us.

Should any such change occur, we will ensure that you are notified in advance and informed about the implications for your personal data.

15.  Changes To Our Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in law or our privacy practices. Any updates will be promptly posted on our website. By using our site after these updates are posted, you agree to the revised policy. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal data we collect.

16.  How To Contact Us

Please contact us if you:

o    Have any questions or comments in relation to this Privacy Policy;

o    Would like to withdraw/revoke your consent to SINAPS processing your personal data;

o    Would like to object to SINAPS processing your personal data; 

o    Would like to review, amend or limit the processing of your personal data, including deleting your personal data;

o    Opt-out of certain non-essential communications such as promotional communication;

o    Have further questions pertaining to the legal basis for processing of your personal data.

SINAPS GmbH:

Kelly Brändli

phone: +41 79 333 2924

 E-mail:

info@sinaps.ch

Postal Address:

SINAPS GmbH

Hofstrasse 105        

8623 Wetzikon

Switzerland