Waggle Solutions – Privacy Notice
1. What is this Privacy Notice about?
This Privacy Notice explains how we process personal data, primarily in relation with our business and our website. If you would like more information, please feel free to contact us (sec. 2). “Personal data” means any information relating to an identified or identifiable natural person, and “processing” means any handling of personal data, such as collecting, storing, using, and sharing it.
2. Who is responsible for processing your data?
For the data processing, the following organization is the “controller”, i.e., the party that is primarily responsible to ensure compliance with data protection laws (also “we”), unless otherwise communicated in individual cases (e.g., in further privacy notices):
Waggle Solutions Sàrl
Route de Champ-Colin 12
1260 Nyon
Switzerland
If you have any questions regarding data protection, please feel free to contact us at support@waggle-solutions.com.
You may provide us with data that relates to other individuals as well (e.g., work colleagues). In this case, we understand that this data is correct and that you act within your rights when sharing it with us. We may not be in direct contact with these individuals and cannot inform them directly about our data processing, but we ask that you to inform these individuals about our data processing (e.g., by pointing them to this Privacy Notice).
3. How do we process data in relation with our activities?
When you use our products and services (collectively “services”), we process data for onboarding of conclusion of a service agreement and for its performance and management:
We may advertise our services, e.g., through newsletters. More details are set out in sec. 4.
If we are in contact with you in view of an agreement, we process data, for example if you register an account on our website or submit an onboarding application. This is mostly data you provide to us, e.g., your name, contact details or date of birth, information about your professional background, financial status, approximate net worth, additional information collected through applications and forms, details of services requested and the date of agreement.
Where required in view of an agreement, we may also obtain further data from public registers (e.g. the commercial register), the media and the internet.
If we enter into an agreement with you, we process the data from the onboarding, information on the agreement (e.g. the date and the content of the agreement), and data required to offer our services that is usually provided by you, including financial data.
We also process personal data during and after the agreement. Examples are information on the purchase of services, payments, financial data, contacts with customer service, claims, complaints, account access data, data on the termination of the agreement and – if there ever should be disputes in relation with the agreement – also on these and related proceedings. Without these data processing operations, we would not be able to perform agreements.
When you communicate with us, e.g. by submitting an inquiry or request through our website, by e-mail, over the phone, by letter, or other means of communication, we collect the personal data you provide, such as your name, contact details, and any relevant information you include in your message, as well as information about the nature and time of the communication. For your identification, we may also process information about proof of identity. We use this data to manage and respond to your requests in a timely and efficient manner and address any concerns, provide the information you seek, or resolve issues related to our activities. Telephone conversations with us may be recorded; we will inform you of such recordings at the beginning of each conversation. If you do not want us to record such conversations, you have the option at any time to terminate the conversation and contact us by other means (e.g. by e‑mail).
We also process the data set out above for statistical purposes (e.g. in which regions and at what times our services are used, etc.). These statistics support the improvement and development of products and business strategy generally. We may also use them on a personally identifiable basis for marketing purposes; for more information, please see sec. 4.
In the context of recruitment, we process personal data provided by individuals applying for positions within our organization. This data may include your name, contact information, education and employment history, qualifications, references, and any other information you choose to share in your application or CV. We use this data for the purposes of evaluating your suitability for the position, managing the recruitment process, and, where applicable, contacting you for interviews or further discussions. In some cases, we may also conduct background checks or request additional information in accordance with applicable laws.
For corporate partners we process less personal data because data protection law only applies to data of individuals. However, we process data of individuals with whom we are in contact, e.g. name, contact details, professional details and details from communications, and details about management persons, etc. as part of the general information about partners with which we cooperate.
4. How do we process data in relation with advertising?
We also process personal data to advertise our services:
Newsletter: We send out electronic information and newsletters, which may include advertising for our services. We will ask for your consent before sending out electronic marketing, except for certain offers to existing customers. In addition to your name and e-mail address, we also process information about which services you have used, whether you open newsletters, and which links you click on. For this purpose, a service provider we use includes invisible images that are loaded from a server via a coded link and transmits related information. This is a common method that helps us assess the effect of newsletters and optimize them. You can object by setting your email program accordingly (e.g. by switching off automatic loading of images).
Online advertising: We may process personal data to display personalized content and advertisements on our website (cf. section 5) and social media (cf. section 6).
Advertising calls: We may conduct advertising calls to inform potential customers about our services. In this context, we process contact details such as phone numbers, information about previous interactions with us, and user preferences and interests where available. You may opt out of advertising calls at any time by informing us through the details provided in section 2.
Market research: We also process data to improve and develop new services, e.g., information about purchases made or reactions to newsletters or information from customer surveys and polls or from social media, media monitoring services and public sources.
5. How do we process data in relation with our website?
For technical reasons, every time you use our website, some data is collected that is temporarily stored in log files (log data), in particular the IP address of the device, information about the internet service provider and the operating system of your device, information about the referring URL, information about the browser used, date and time of access, and content accessed when visiting the website. We use this data to provide our website, to ensure security and stability, to optimize our website and for statistical purposes.
Our website also uses cookies. These are small files that your browser saves on your device. This allows us to separate individual visitors from others, but usually without identifying visitors. Cookies may also include information about content accessed and the duration of the visit. Certain cookies (“session cookies”) are deleted when the browser is closed. Others (“persistent cookies”) are stored for a certain period of time so that we can recognize recurring visitors.
You can configure your browser in the settings so that it blocks or deletes certain cookies and other stored data. You can find out more about this in the help pages of your browser (usually under “privacy”).
Cookies and other technologies may also be used by third parties that provide services to us. These may be located outside of Switzerland and the EEA (for more information, see sec. 9). For example, we use analytics services so that we can optimize and personalize our website. Cookies and similar technologies from third-party providers also enable them to target you with individualized advertising on our websites or on other websites as well as on social networks that also work with this third party and to measure how effective advertisements are (e.g., whether you arrived at our website via an advertisement and what actions you then take on our website). The relevant third-party vendors may record website usage for this purpose and combine their records with other information from other websites. They can record user behavior across multiple websites and devices to provide us with statistical data. The providers may also use this information for their own purposes, e.g. for personalized advertising on their own website or other websites. If a user is registered with the provider, the provider can assign the usage data to the relevant person.
6. How do we process data via social media?
We operate our own presences on social networks and other platforms (Facebook, LinkedIn, X/Twitter, YouTube). If you communicate with us there or comment on or redistribute content, we collect information about such interaction which we use primarily for communication with you, for marketing purposes and for statistical evaluations (see sec. 4 and 7). Please note that the provider of the platform themself also collects and uses data (e.g. on user behavior), possibly together with other data available to them (e.g. for marketing purposes or to personalize the platform content). Insofar as we are jointly responsible with the provider, we enter into a corresponding agreement, about which you can obtain information from the provider.
7. What are other processing purposes?
Typical (though not necessarily frequent) cases are as follows:
Compliance with legal requirements: We may disclose information to authorities as required by law or to comply with internal regulations.
Prevention: We process data to prevent crime and other misuse, for example fraud prevention or for internal investigations.
Legal proceedings: Where we are involved in legal proceedings (e.g. court or administrative proceedings), we process data such as information about other parties to the proceedings and individuals involved such as witnesses and disclose data to such parties, courts, and authorities, possibly also abroad.
IT security: We also process data for monitoring, controlling, analyzing, securing, and assessing our IT infrastructure, as well as for backups and archives.
Competition: We process data about our competitors and the market environment in general (e.g. the political situation, the association landscape, etc.). We may also process data about key persons, such as their name, contact details, role or function and public statements.
Transactions: If we sell or acquire assets, business units or companies, we process data to prepare and execute transactions, e.g. information about partners or their contact persons or employees, and we may also disclose such information to potential buyers or sellers.
Other purposes: We process data to the extent necessary for other purposes such as training and education, administration (e.g. accounting), enforcement and defense of claims, evaluation and improvement of internal processes, acquisition or sale of receivables, and safeguarding other legitimate interests.
8. How do we work with service providers?
We may share personal data with various third-party providers from whom we receive services, especially IT services (examples are providers of hosting or data analysis services), shipping and logistics services and services from banks, the post office, consultants and advisors, travel agencies, hotels, airlines, event managers, conferencing services, interpreters, caterers, security services, etc. In relation with service providers for our website, please see sec. 5.
9. Can we disclose data abroad?
The recipients of data are not all located in Switzerland, in particular certain service providers (especially in IT). These providers may have locations within the EU or the EEA, but also in other countries worldwide, e.g., in the USA. We may also share data with authorities abroad if we are legally compelled to do so or, for example in relation with legal proceedings (see sec. 7). Not all these countries have an adequate level of data protection. We therefore use appropriate safeguards, in particular the EU standard contractual clauses, which can be found here. In certain cases, we may share data abroad without such safeguards, as permitted under applicable data protection law, e.g., with your consent or where the disclosure is necessary for the performance of the contract, for the establishment, exercise, or enforcement of legal claims or for overriding public interests.
10. How long do we process personal data?
We process your personal data as long as it is necessary for the purpose of processing (in the case of contracts, usually for the duration of the contractual relationship), as long as we have a legitimate interest in storing it (e.g. if in order to enforce legal claims, for archiving and or to ensure IT security) and as long as data is subject to a statutory retention obligation (for certain data, for example, a ten-year retention period applies). After these periods have expired, we delete or anonymize your personal data.
11. What else should be considered?
Depending on the applicable law, data may only be processed based on legal grounds. This does not apply under the Swiss Data Protection Act, but it does under the European General Data Protection Regulation (GDPR) to the extent it is applicable. In this case, our processing is based on a necessity to prepare for and perform contracts (sec. 3), to safeguard legitimate interests of us or third parties, e.g. statistical evaluations (sec. 3) or for marketing purposes (sec. 4), that it is required or permitted by law, or that you have provided separate consent. The relevant provisions are article 6 and 9 GDPR.
You are not under an obligation to provide data to us, except in some cases such as when it is required to comply with a contractual obligation). However, we must process data for legal and other reasons when we conclude and execute contracts. The use of our website would also not be possible without some data processing (see sec. 5).
12. What are your rights?
You have certain rights, subject to conditions and restrictions under applicable law:
You may request a copy of your personal data and further information about our data processing.
You may object to our data processing, especially in relation with our newsletter.
You may have incorrect or incomplete personal data corrected or completed or supplemented by a note of dispute.
You may request receipt of the personal data that you have provided to us in a structured, common and machine-readable format.
You may revoke your consent at any time if we process data based on your consent. The revocation is only valid for the future, and we reserve the right to continue to process data based on another basis in the event of a revocation.
If you wish to exercise such a right, please feel free to contact us (cf. sec. 2). We will usually have to verify your identity (e.g. by means of a copy of your ID card). You are also free to file a complaint against our processing of your data with the competent supervisory authority, in Switzerland the Federal Data Protection and Information Commissioner (FDPIC).
13. Changes to this Privacy Notice
We may update this Privacy Notice from time to time. Any updates will be published on our website, and the revised version will specify the effective date. We encourage you to review the Privacy Notice periodically.
Last update: March 2025