Privacy Policy

1. Introduction

This Privacy Policy explains how 21 Analytics AG ("21 Analytics", "we", "us", or "our") collects, uses, shares, and protects your personal data when you interact with our websites, products, and services (collectively, the "Services").

We are committed to safeguarding your privacy and processing your personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).

If you have any questions or concerns about this notice or our practices, please contact us at [email protected]

2. Scope of this Policy

This policy applies when you:

• Visit our website at https://www.21analytics.ch, or any website that links to this notice;
• Engage with us in relation to our software solutions or other services;
• Participate in our events, marketing, or communications, including (but not limited to) signing up for our emails, downloading or sharing our content, or interacting with our digital materials; or
• Contact us for information or support.

If you do not agree with this policy, please discontinue the use of our Services.

3. Information We Collect

3.1 Information You Provide

We collect personal information that you voluntarily provide when you:

• Request information about our products or services;
• Subscribe to our marketing communications;
• Engage in sales or demo processes; or
• Contact us directly.

Depending on the context, this information may include:

• Identity data, such as your name and organisation;
• Contact data, such as your email address and other contact details.

We do not collect or process sensitive personal data.

All information you provide must be true, accurate, and kept up to date.

3.2 Information Automatically Collected

When you access our Services, we automatically collect limited technical data, such as:

Log and Usage Data

Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.

Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

Device Data

We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.

Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data

We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).

You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

This information does not reveal your specific identity (like your name or contact information), but helps us ensure security, improve performance, and analyse usage trends.

We may use cookies and similar technologies (e.g. pixels) for analytics and functionality. You can manage your preferences through your browser or via our Cookie Policy.

3.3 Data from Third Parties

We may receive information from trusted third-party sources, such as:

• Analytics and marketing partners;
• Publicly available sources; or
• Event registration platforms.

We only collect such data if it is necessary and lawful to do so.

4. How and Why We Use Your Data

We process your personal data to:

• Provide and maintain our Services (performance of a contract);
• Respond to your enquiries or provide customer support (legitimate interest);
• Send marketing and promotional communications, if you have opted in (consent);
• Improve our Services through analytics and usage insights (legitimate interest);
• Comply with legal obligations, including anti-fraud or regulatory requirements;
• Protect your or another person's vital interests when necessary.

We never sell your personal data.

5. Legal Bases for Processing (GDPR & FADP)

Depending on your location, we rely on one or more of the following legal bases:

Consent

When you have given clear permission which you can withdraw your consent at any time;

Contract

We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request, prior to entering into a contract with you to fulfil or prepare a contract with you;

Legal Obligation

We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved;

Legitimate Interest

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.

For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services;
• Develop and display personalised and relevant advertising content for our users;
• Analyse how our Services are used so we can improve them to engage and retain users;
• Support our marketing activities.

Vital Interest

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

6. How We Share Your Data

We may share personal data with trusted service providers who assist us in operating our business, including:

• Data analytics and performance tools;
• CRM and email communication providers;
• Website hosting and IT security providers.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do so.

They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We may also share data in specific situations:

• Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Legal obligations: when required by law or competent authorities.

We use Google Analytics to understand website usage. You can opt out via https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

7. International Data Transfers

As a Swiss company, we may transfer your personal data outside Switzerland or the EEA. When we do so, we ensure adequate protection through:

• The use of Standard Contractual Clauses (SCCs); or
• Transfers to countries recognised by the Swiss FDPIC or the European Commission as having adequate data protection laws.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy, or as required by law.

For example:

• Marketing contact data: up to 24 months after last interaction;
• Contractual or transaction data: as long as required for legal recordkeeping.

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

9. Data Security

We apply technical and organisational measures to protect your data from unauthorised access, alteration, or disclosure.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. Your Rights

Under the GDPR and FADP, you have the right to:

• Access and obtain a copy of your personal data;
• Request correction or deletion of inaccurate data;
• Restrict or object to processing;
• Withdraw consent at any time*;
• Request data portability, where applicable;
• Lodge a complaint with a supervisory authority.

To exercise these rights, please email [email protected].

If you are in:

• EEA/UK: You may contact your local Data Protection Authority.
• Switzerland: contact the Federal Data Protection and Information Commissioner (FDPIC).

Withdrawing Your Consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting [email protected].

11. Cookies and Tracking

Our website uses cookies for functionality, analytics, and performance purposes.

You can adjust your cookie settings at any time. For details, please refer to our Cookie Policy.

12. Children's Privacy

Our Services are not intended for children under 18. We do not knowingly collect data from minors.

If you believe a child has provided us with personal information, contact [email protected] and we will delete it promptly.

13. Disclaimer Regarding Our Content

All materials made available by 21 Analytics AG, including but not limited to LinkedIn articles, articles, reports, blogs, webinars, guides, and downloadable resources ("Content"), are provided solely for educational and informational purposes.

The Content does not constitute legal, tax, financial, or investment advice. You should always seek guidance from qualified professionals before making any business or compliance-related decisions.

We remind users to remain vigilant against fraudulent communications. Always ensure you are engaging directly with your verified service providers or exchanges. 21 Analytics will never request confidential information, account access, or payments through unofficial channels.

While we strive to ensure the accuracy and relevance of our Content, 21 Analytics assumes no responsibility or liability for any decisions made, or actions taken, based on the information provided. We do not guarantee the accuracy, completeness, timeliness, suitability, or validity of the Content and shall not be liable for any claims, losses, or damages arising from errors, omissions, or reliance upon such information.

Use of our Content is at your own discretion and risk.

14. Do-Not-Track Signals

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be published on this page with a revised date.

Material changes will be clearly communicated through the website or by direct notification. You can request a copy of previous versions of this policy at any time.

16. Contact Information

Data Controller

Data Protection Officer (DPO)

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