Effective Date: August 30, 2025
Last Updated: August 30, 2025
1. Data Controller
Salfati Group GmbH
Zählerweg 12
6300 Zug
Switzerland
Email: legal@salfati.group
Data Protection Representative: Elon Salfati, CEO
2. Scope and Application
This Privacy Policy applies to all data processing activities conducted by Salfati Group GmbH through our website, services, and AI solutions. We process personal data in strict compliance with the Swiss Federal Act on Data Protection (nDSG/FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
3. Data We Collect
3.1 Information You Provide Directly
- Identity Data: Name, job title, company affiliation
- Contact Data: Business email address, company address
- Professional Data: Industry sector, company size, business requirements
- Communication Data: Inquiries, project specifications, feedback
3.2 Automatically Collected Information
- Technical Data: IP address (anonymized), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
- Usage Data: Information about how you use our website and services via Google Analytics, including:
- Pages visited and interaction patterns
- Access times and duration
- Traffic sources and navigation paths
- Geographic location (country/city level only)
3.3 Client Project Data
- Project Data: Data provided for AI development and implementation
- Output Data: AI-generated results and analyses
Important: Client data processed through our AI systems remains the exclusive property of the client. We do not use client data to train our AI models or for any purpose other than providing the contracted services.
4. Legal Basis for Processing
We process personal data based on the following legal grounds under Swiss law:
- Contractual Necessity: To perform our AI consulting and development services
- Consent: For analytics cookies and marketing communications
- Legitimate Interests: To improve our services, ensure security, and protect our intellectual property rights
- Legal Obligations: To comply with Swiss federal law and regulatory requirements
5. How We Use Your Data
5.1 Service Delivery
- Provide AI consulting and development services
- Manage client relationships and projects
- Process service inquiries and proposals
- Deliver technical support and maintenance
5.2 Business Operations
- Analyze website usage to improve user experience
- Ensure network and information security
- Protect our intellectual property rights
- Comply with legal and regulatory obligations
5.3 Communications
- Respond to inquiries and requests
- Send service-related notifications
- Provide technical updates and security alerts
- Share relevant industry insights (with consent)
6. Data Sharing and Transfers
6.1 Categories of Recipients
We may share your data with:
- Service Providers: Google Analytics (USA) for website analytics
- Professional Advisors: Legal counsel, auditors (bound by professional secrecy under Swiss law)
- Authorities: When required by Swiss law, court order, or regulatory requirements
- Business Transfers: In connection with any merger, acquisition, or asset sale
6.2 International Data Transfers
When transferring data outside Switzerland:
- EU/EEA: Transfers are made based on adequacy decisions
- USA: We rely on Standard Contractual Clauses for Google Analytics
- Other Countries: Appropriate safeguards per Article 16-17 nDSG are implemented
7. Data Security
We implement appropriate technical and organizational measures (TOMs) pursuant to Article 8 nDSG, including:
- End-to-end encryption for data transmission (TLS 1.3)
- Access controls and multi-factor authentication
- Regular security assessments and penetration testing
- Incident response and data breach procedures
- Employee confidentiality agreements and training
- Secure development lifecycle for AI systems
- Infrastructure hardening and monitoring
8. Data Retention
We retain personal data only as long as necessary:
- Contact Data: 5 years after last business interaction
- Project Data: Duration of project plus 10 years for legal compliance
- Analytics Data: 14 months
- Financial Records: 10 years per Swiss CO Art. 958f
- Legal Claims: Until expiration of applicable limitation periods
9. Your Rights
Under the Swiss Federal Act on Data Protection, you have the right to:
- Access: Request information about your personal data we process
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data ("right to be forgotten")
- Restriction: Limit processing of your data
- Data Portability: Receive your data in a structured format
- Objection: Object to processing based on legitimate interests
- Consent Withdrawal: Withdraw consent at any time without affecting prior processing
- Automated Decision-Making: Not be subject to purely automated decisions
To exercise these rights, contact: legal@salfati.group
10. Client Data and AI Training
10.1 Client Data Ownership
All data provided by clients for processing through our systems remains the exclusive property of the respective client.
10.2 AI Model Training
We explicitly do not use client data to train, improve, or develop our AI models. Our AI systems are trained exclusively on:
- Licensed datasets
- Public domain information
- Synthetic data
- Our proprietary research data
10.3 Data Isolation
Client data is processed in isolated environments with strict access controls and is permanently deleted according to contractual terms.
11. Cookies and Tracking Technologies
We use cookies as described in our Cookie Notice. You can manage your cookie preferences through your browser settings or our cookie consent tool.
12. Children's Privacy
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors.
13. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be notified via our website or email.
14. Contact and Complaints
For privacy-related inquiries or concerns:
Salfati Group GmbH
Attn: Data Protection
Zählerweg 12
6300 Zug, Switzerland
Email: legal@salfati.group
Supervisory Authority
You have the right to lodge a complaint with:
Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
CH-3003 Bern
Switzerland
Website: www.edoeb.admin.ch
© 2025 Salfati Group GmbH. All rights reserved.