Privacy Policy
This English translation is provided for convenience. Only the German version is legally binding.
1. Controller
The controller within the meaning of the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR) is:
2. Scope
This privacy policy applies to the website www.tw-p.ch and all related offerings of TW Projects GmbH. The websites www.tw-services.ch and www.memora-moments.ch have their own privacy policies, available on the respective websites.
3. Purpose of data processing
TW Projects GmbH processes personal data exclusively for the following purposes:
- Provision and technical operation of the website
- Answering enquiries received by email or through the contact form
- Audience measurement in pseudonymised form to improve our offering
- Compliance with statutory retention and cooperation obligations
No processing takes place for advertising purposes, profiling or automated individual decision-making.
4. Categories of data processed
4.1 Server log files
When this website is accessed, our hosting provider Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA records technically necessary data in log files:
- IP address of the requesting device (shortened)
- Date and time of access
- URL requested and HTTP status code
- Amount of data transferred
- User agent (browser and operating system information)
- Referrer URL
Content is delivered through Vercel's edge network; for visitors from Europe primarily through servers in Frankfurt and Dublin. The legal basis is our legitimate interest in a stable, secure and functional website (Art. 31 para. 2 lit. d FADP, Art. 6 para. 1 lit. f GDPR). Log files are deleted automatically after 30 days at most, unless there are concrete indications of a security incident.
4.2 Vercel Analytics (audience measurement)
This website uses Vercel Analytics for statistical analysis of visitor behaviour. Vercel Analytics works without cookies: no cookies are set, no cross-device identifiers are created and no personal profiles are built. Only aggregated data is processed, such as page views, referrers, approximate geographic region (country/city) and device type. To recognise a visitor within a session, an anonymised hash is created, which expires after 24 hours.
As no personal data within the meaning of Art. 4 No. 1 GDPR is processed, no consent is required. The legal basis for audience measurement is our legitimate interest in a privacy-friendly analysis of website usage (Art. 31 para. 2 lit. d FADP, Art. 6 para. 1 lit. f GDPR).
Further information: vercel.com/docs/analytics/privacy-policy
4.3 Fonts and software libraries
The fonts used (Geist, Geist Mono) and the software libraries for rendering and animations are stored on this website's web server and loaded from there. No connection to third parties (e.g. Google Fonts) is established for this purpose when the website is accessed.
4.4 Email contact
If you contact us by email at kontakt@tw-p.ch, the information you send (sender address, name, content of the message and any other data you provide voluntarily) is stored for the purpose of handling your enquiry and any follow-up communication.
Emails are processed and stored via Google Workspace (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). A data processing agreement under Art. 28 GDPR is in place with Google.
The legal basis is Art. 31 para. 2 lit. a FADP and Art. 6 para. 1 lit. b and f GDPR. The data is deleted in accordance with section 9 (Retention period), unless statutory retention obligations prevent this.
4.5 Contact form
When you use the contact form, the information you enter (email address and message) is transmitted together with the time of the enquiry and stored for the purpose of handling your enquiry and any follow-up communication.
Transmission is encrypted to Google Apps Script; the information is stored in a spreadsheet (Google Sheets) in our Google Workspace account (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). A data processing agreement under Art. 28 GDPR is in place with Google.
The legal basis is Art. 31 para. 2 lit. a FADP and Art. 6 para. 1 lit. b and f GDPR. The data is deleted in accordance with section 9 (Retention period), unless statutory retention obligations prevent this.
4.6 Online appointment booking
To book an appointment, this website links to our booking page termin.tw-p.ch. There, the chosen appointment, name and email address, and optionally company and message, are recorded and stored for the purpose of preparing and holding the conversation and any follow-up communication.
The information is stored in our customer database with Supabase (storage in the EU, Frankfurt). The appointment is entered in Google Calendar (Google Workspace) and confirmed by email with a Google Meet link.
The legal basis is Art. 31 para. 2 lit. a FADP and Art. 6 para. 1 lit. b and f GDPR. The data is deleted in accordance with section 9 (Retention period), unless statutory retention obligations prevent this.
5. Processors and recipients
To operate this website and handle enquiries, we use the following processors, with each of which a data processing agreement under Art. 9 FADP / Art. 28 GDPR is in place:
| Provider | Purpose | Registered office | Data transfer |
|---|---|---|---|
| Vercel Inc. | Website hosting, edge delivery, audience measurement | USA, delivery via EU servers | EU (Frankfurt, Dublin), USA if required |
| Google Ireland Limited | Email, contact form, calendar (Google Workspace) | Ireland (EU) | EU, USA if required |
| Supabase Inc. | Database for appointment booking | Singapore, storage in EU region | EU (Frankfurt) |
6. Transfers abroad
Personal data is transferred to the USA or other third countries in the context of the processing described above. The lawfulness of these transfers is ensured by the following mechanisms:
- EU Standard Contractual Clauses (SCC) with all US-based service providers
- EU-U.S. Data Privacy Framework for certified US companies (including Vercel and Google)
- Recognition by Switzerland of the USA as a country with an adequate level of data protection for DPF-certified companies (Swiss-U.S. Data Privacy Framework)
7. Cookies
This website sets no cookies. If users choose the light or dark display with the switch in the header, this setting is stored locally in the browser (localStorage). It is not transmitted to us and can be deleted at any time through the browser settings. No other information is stored on the end device.
8. Tracking, profiling, advertising
This website uses:
- no Google Analytics
- no Meta Pixel (Facebook/Instagram)
- no LinkedIn Insight Tag
- no other marketing or conversion tags
No usage profiles are created and no data is transmitted to advertising networks.
9. Retention period
Personal data is stored only for as long as necessary for the stated purposes or as required by statutory retention periods. In particular:
| Data category | Retention period |
|---|---|
| Server log files | 30 days |
| Vercel Analytics (aggregated) | 12 months |
| Enquiries, appointment bookings and contacts without a contractual relationship (email, contact form, appointment booking) | Up to 24 months after the last contact |
| Email correspondence relating to a contract | 10 years (Art. 958f CO) |
| Invoices and business records | 10 years (Art. 958f CO) |
10. Rights of data subjects
Under the FADP and the GDPR, you have the following rights:
- Access to the data stored about you (Art. 25 FADP, Art. 15 GDPR)
- Rectification of inaccurate data (Art. 32 para. 1 FADP, Art. 16 GDPR)
- Erasure or restriction of processing (Art. 32 para. 2 FADP, Art. 17, 18 GDPR)
- Objection to processing (Art. 30 para. 2 lit. b FADP, Art. 21 GDPR)
- Data portability in a structured format (Art. 28 FADP, Art. 20 GDPR)
- Withdrawal of consent given with effect for the future (Art. 6 para. 6 FADP, Art. 7 para. 3 GDPR)
- Right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) or the competent EU supervisory authority
You can exercise these rights informally by email to kontakt@tw-p.ch. We handle requests within 30 days. To verify your identity, we may request suitable proof.
11. Data security
The website is delivered exclusively in encrypted form via HTTPS (TLS). We take technical and organisational measures in line with the current state of the art to protect personal data against unauthorised access, loss and manipulation. These include in particular access controls with multi-factor authentication, encrypted storage and regular security audits.
12. No EU representative
TW Projects GmbH has currently not designated a representative in the EU within the meaning of Art. 27 GDPR, as personal data of EU citizens is processed only occasionally and does not pose a high risk to the rights and freedoms of the data subjects. This assessment is reviewed on an ongoing basis.
13. Changes
TW Projects GmbH reserves the right to amend this privacy policy to adapt it to changes in the legal situation or in the services offered. The version published at the time of your visit to the website applies.