Privacy Policy

Privacy Policy

The protection of your personal data is a matter of great importance to me. In this Privacy Policy, I inform you about how I process personal data when you visit my website, use my services, or contact me.

This Privacy Policy applies to all data processing in connection with my online offer, my services, and my external online presences (e.g., social media). The terms used apply equally to all genders.

Note on the Applicability of the Swiss DPA and the GDPR
This Privacy Policy fulfills the information obligations under both the Swiss Federal Act on Data Protection (revDSG/nFADP) and the General Data Protection Regulation (GDPR).

The GDPR applies insofar as this offer is directed at persons in the European Economic Area (EEA) (Art. 3 Para. 2 GDPR), in particular through the provision of information, appointment bookings, or services for persons residing in the EU. For better comprehensibility, terms of the GDPR are partially used (e.g., “processing”, “personal data”). However, the legal assessment is always based on the respectively applicable data protection law.

1. Controller
Agni Witt Consulting (Sole Proprietorship)
Owner: Agni Witt
6340 Baar
Switzerland
Email: [email protected]

2. General Information on Data Processing
I process personal data confidentially and in accordance with statutory data protection regulations. The provision of personal data is generally voluntary. However, without certain information (e.g., contact or payment data), I cannot provide my services or conclude contracts.

Legal Basis under Swiss Law (revDSG): The processing of personal data is carried out in accordance with Art. 6 revDSG based on the principles of lawfulness, proportionality, purpose limitation, transparency, and data security. Consent is obtained where necessary (e.g., marketing, profiling).

Legal Basis under GDPR (for EU Data Subjects):
– Performance of a contract and pre-contractual measures (Art. 6 para. 1 lit. b GDPR)
– Consent (Art. 6 para. 1 lit. a GDPR)
– Legitimate interests (Art. 6 para. 1 lit. f GDPR)
– Legal obligation (Art. 6 para. 1 lit. c GDPR)

3. Overview of Data Processing
– Data Subjects: Website visitors, clients, participants in offers, interested parties, business and contractual partners.
– Types of Data: Inventory data, contact data, contractual and billing data, payment data, content data, usage and access data, as well as meta and communication data (e.g., IP address).

4. Hosting and Server Log Files
My website is hosted by Infomaniak Network SA (Switzerland). When you access the website, the following are recorded: IP address, date/time, browser type, and referrer URL.
– Retention: Maximum 30 days.
– Legal Basis: Legitimate interest (Art. 6 para. 1 lit. f GDPR / Art. 31 para. 1 revDSG).

5. Contacting Me
When contacting me via email or form, your details are stored for processing the inquiry and deleted after completion, provided there are no statutory retention obligations.

6. Appointment Booking and Payment Processing
– Setmore (USA): Appointment organization. Transfer via Swiss-U.S. Data Privacy Framework (DPF). Privacy: https://www.setmore.com/privacy

– Stripe (USA): Payment processing. Retention up to 10 years. Transfer basis: Swiss-U.S. DPF. Privacy: https://stripe.com/privacy

7. Newsletter
Sent via MailerLite (EU/Lithuania) using the double opt-in procedure. Consent can be revoked at any time via the unsubscribe link. Retention: Until unsubscription + max. 3 years proof period.

8. Video Conferencing
I use kMeet / Infomaniak (Switzerland) for online appointments. Data processing primarily in Switzerland/EU.

9. Messenger Communication
ManyChat (USA): For automated communication. Transfer via Standard Contractual Clauses (SCCs) and Swiss-U.S. DPF. There is no automated decision-making with legal effect within the meaning of Art. 22 GDPR.

10. Cloud, Project & Design Tools
– Apple iCloud (USA): DPF certified. Privacy
– Google Drive (USA): DPF certified. Privacy
– kDrive (Switzerland): Data location Switzerland.
– Canva (Australia/USA): Secured via Standard Contractual Clauses (SCCs). Privacy
– Notion (USA): Secured via SCCs and DPF. Privacy

11. Accounting
CashCtrl (Switzerland): Invoicing and accounting. Retention: 10 years.

12. VIA Character Strengths Assessment
Conducted by the VIA Institute on Character (USA).

Note: This does not constitute a medical diagnosis. It involves personality profiling with increased protection requirements. Participation only with explicit consent.

13. Use of Artificial Intelligence (AI)
I use tools such as ChatGPT, Claude, and Google Gemini for internal support. Personal client data is generally not transmitted. In exceptional cases, this is only done anonymously or with prior consent (e.g., with training mode deactivated).

14. Cookies & Tracking
Analysis and marketing cookies are only set after consent via Complianz.
– Google Analytics / Ads: Privacy
– Facebook Pixel: Privacy

15. Social Networks
Profiles on Facebook and Instagram (Meta). For Page Insights, there is a joint controller-ship according to Art. 26 GDPR. Details: Facebook Page Insights Terms.

16. International Data Transfers
Disclosure of personal data abroad takes place according to Art. 16 revDSG only with adequate protection (adequacy decisions, DPF, or SCCs). Transfers to the USA are based on the Swiss-U.S. Data Privacy Framework.

17. Retention Period
Contract data: 10 years. Server log files: 30 days. Newsletter: Until unsubscription. VIA results: Until revocation.

18. Rights of Data Subjects
You have the right to:
– Information, correction, deletion, and destruction.
– Restriction of processing & objection.
– Data portability (handover in a common format).
– Revocation of consent. Contact: [email protected]

19. Right to Lodge a Complaint
Switzerland: FDPIC (EDÖB).
EU: Competent supervisory authority in your member state of residence.

20. Data Security
Use of SSL/TLS encryption, access restrictions, and regular backups/updates.

21. Changes
I reserve the right to adapt this Privacy Policy occasionally so that it always complies with current legal requirements or to implement changes to my services. The current version published here applies to your visit.