Legal
Privacy Policy
FitzleKey GmbH · revFADP (revised Swiss FADP) + GDPR
Data Controller
FitzleKey GmbH · Florastrasse 14, 4500 Solothurn · Switzerland Email: privacy@fitzlekey.com
Legal Basis
We process personal data in accordance with the revised Swiss Federal Act on Data Protection (revFADP, in force since 2023-09-01), the EU General Data Protection Regulation (GDPR), and applicable national implementations.
Data Collection
We collect only what operating the site and our services requires: • Provided directly: your email address and your message when you write to us (contact, waitlist — including language and interest if you state them) • Account and sign-in: when you create a FitzleKey account and use the web app — account data (email address, name), authentication and security data (including two-factor/passkey methods) and session data; plus technically necessary sign-in and security cookies (see the Cookie Notice) • Technically necessary: server log files on our Swiss infrastructure (IP address, timestamp, requested page) for operational security No analytics, no tracking, no advertising cookies — strictly necessary items only (see the Cookie Notice).
Purpose of Processing
• Operating and securing this website (legitimate interest) • Answering your inquiries and managing the waitlist (consent; one notification, no spam) • Account, sign-in and security of the web app (performance of contract and legitimate interest in secure operation) • Providing our services once available (Art. 6(1)(b) GDPR / revFADP Art. 6) • Compliance with legal obligations No marketing without consent, no usage analytics on this website.
Data Sharing
We share data only with processors bound by a data processing agreement (DPA): our Swiss hosting provider Infomaniak (website and product infrastructure) and a contracted business email provider for business email communication (contact and waitlist). No analytics tools, no ad networks, no payment or SSO providers. The current sub-processor list is available on request (privacy@fitzlekey.com); once our Trust page is published, it will also be available there.
International Transfers
Your content and data in our products, along with our website and our servers, are located in Switzerland. Our business email correspondence — which also carries contact, waitlist and contributor enquiries — runs with a contracted provider that holds data in Europe, safeguarded by adequacy decisions and Standard Contractual Clauses (SCCs). If further processors are added, we name them here and in the list under section 5.
Retention
Personal data is retained only as long as necessary for the stated purposes or as required by law (e.g. 10 years for accounting records under Swiss CO Art. 958f).
Your Rights
You have the right to: access (Art. 15 GDPR / revFADP Art. 25), rectification, erasure, restriction, data portability, objection, and withdrawal of consent. Contact: privacy@fitzlekey.com. You may lodge a complaint with the FDPIC (Switzerland) or a supervisory authority in the EU/EEA.
Data Security
We implement appropriate technical and organizational measures including encryption (TLS 1.3, AES-256), access controls, and ongoing security reviews and testing.
AI and Automated Decisions
This website makes no automated individual decisions (Art. 22 GDPR). Where our services use AI features: transparency per the GDPR and the EU AI Act; users are informed when interacting with AI-generated content, and no AI training happens on customer data.
Changes
Material changes will be communicated via email or in-app notification at least 30 days before taking effect.