Privacy Policy

1. Controller

The controller within the meaning of the revised Swiss Data Protection Act (revFADP) and — where users in the EU/EEA are concerned — the EU GDPR is: HRIT.ch GmbH (operator of the Connexxa platform), Ruhsitzweg 12, 9000 St. Gallen, Switzerland (UID CHE-439.819.869).

Contact for data protection matters: data@connexxa.ch.

2. Scope & legal framework

This policy applies to the Connexxa app (iOS/Android), the EMO platform for organizers, and the website. We serve primarily the Swiss market and process personal data under the revFADP (in force since 2023-09-01) and — where users in the EU/EEA are concerned — under the EU GDPR.

3. Swiss data-residency principle

The canonical data of the Connexxa app is stored in Switzerland (Supabase, Zürich region). The website and the EMO platform are delivered via Google Firebase Hosting (Zürich region); some event and registration data of the EMO platform is processed in Google Firebase services.

A few specialised processors are based in the EU or the US (Section 7). Switzerland holds an EU adequacy decision (GDPR Art. 45).

4. Legal bases for processing

Consent (GDPR Art. 6(1)(a) / Art. 31 revFADP): e.g. for AI features, location sharing, push notifications, or the use of sensitive signals in matching.

Contract performance (GDPR Art. 6(1)(b) / Art. 31(2)(a) revFADP): e.g. providing the account, profile/networking, event registration and check-in, chat, and billing.

Legitimate interest (GDPR Art. 6(1)(f) / Art. 31(1) revFADP): e.g. platform integrity and the reputation system, abuse/spam defense, k-anonymised product analytics, and the personal networking funnel.

Legal obligation (GDPR Art. 6(1)(c) / Art. 31(2)(b) revFADP): e.g. tax and commercial-law retention duties.

5. Processing activities & data categories

Account & sign-in: email, hashed password, user id, device/session data (contract). When registering via a third party (e.g. Google or LinkedIn login) we receive the profile data you release.

Profile & networking (app): name, photo, bio, company, industry, tags/offers/seeks, birth year (16+), languages, values, networking intents (contract; consent for sensitive intents).

Location: coordinates/geohash, home/office base, sharing tier for "near me" discovery (consent, opt-in).

Communities & events (app and EMO): memberships, roles, RSVPs, ticket and registration data, check-in timestamps (QR scan), agenda and organizer details (contract).

Chat/messaging: 1:1 and group messages, attachments, reactions, read/online status (contract).

Reputation/trust: server-computed reliability/Gentlemen-Score, reports, verification flags (legitimate interest in platform integrity).

Payments/subscriptions: Stripe customer/subscription id, plan, invoices. No card or bank data is held by us (contract).

AI features: profile/prompt text sent to the model and the consent timestamp (consent, server-enforced gate).

Push notifications: push token (device id), notification content (consent / contract).

Analytics: event type/domain and aggregates — k-anonymised (K≥5) (legitimate interest).

Anti-abuse: bot/spam defense at sign-up/waitlist via a Cloudflare Turnstile token and an IP-derived signal (legitimate interest).

Transactional email: auth and invite mails (email address, sender name, context; suppression list). Invited third parties are subject to a double opt-in (contract / consent).

Server log files: browser type/version, operating system, referrer URL, hostname, request time, and IP address. No merging with other data sources takes place.

Networking Funnel (personal CRM): relationship-keeping performed by users themselves — contact snapshot (name/avatar), private notes/labels, stage, and a warmth score (metadata only, such as frequency/recency — never message text) (legitimate interest; no automated decision about the subject).

6. AI, profiling and automated decisions

Matching/recommendations and reliability scores partly rely on automated evaluation. There is no solely-automated decision with significant effect without a human-review or objection option.

AI features are opt-in (consent gate). The AI processor in the current operating mode is Anthropic (Claude, US; no training on your data, per DPA). In the current mode an EU-only toggle fully disables the AI features. No training takes place on your data; prompts are not retained by us beyond the request. If we change the AI provider we update this policy and re-obtain your consent (versioned AI consent).

Sensitive signals (e.g. "dating" intent, or keywords that could imply health, religion, orientation or politics) are used for matching only with your explicit consent.

7. Processors & recipients

We use carefully selected processors under a data processing agreement (DPA):

Supabase — database, auth, storage, edge functions of the app (primary processor) — Switzerland (Zürich).

Google Firebase — hosting as well as auth/data services of the website and the EMO platform — Zürich/EU region; US transfers relying on SCC/DPF (Google is certified under the EU-U.S. Data Privacy Framework).

Google Workspace (Drive) — encrypted media backups — EU.

Anthropic — AI generation (only when AI is enabled) — US (SCC/DPF).

Stripe — payment processing (no card data held by us) — US/EU (SCC/DPF).

Expo (EAS) — push delivery — US (SCC).

Cloudflare (Turnstile) — bot/abuse defense — global (SCC).

Brevo — transactional/invite email — EU (France).

The current sub-processor list is available at data@connexxa.ch.

8. International data transfers

For transfers to the US or other third countries we rely on the European Commission's Standard Contractual Clauses (SCC) or the EU-U.S. Data Privacy Framework (DPF) and, where necessary, apply supplementary safeguards (GDPR Art. 46 / Art. 16 f. revFADP).

9. Retention and deletion

Principle: your personal data is fully removed on request via account deletion (server-side erasure cascade, incl. scrubbing your snapshots from other users' networking funnels).

Event data: check-in data and participation histories are retained for up to 12 months after the event and then anonymised or deleted.

Server logs: automatically deleted after a maximum of 90 days.

Retention exceptions: (a) invoice/payment data is kept to meet the Swiss Code of Obligations retention duty (~10 years), the rest pseudonymised; (b) a minimal hash of banned/abusive accounts to prevent re-registration; (c) legal holds during proceedings.

Content and attachments are additionally subject to container-specific retention.

10. Your rights

You have the right to access, rectification, erasure, restriction, objection and data portability, and to withdraw consent at any time (without retroactive effect).

Access and export are partly available directly in the app (profile export / account deletion). Contact data@connexxa.ch; we endeavour to answer requests within 30 days.

You may also lodge a complaint with the competent authority: the Swiss Federal Data Protection and Information Commissioner (FDPIC) or the competent EU authority.

11. Cookies and local storage

On the website we use technically necessary cookies and local-storage mechanisms (e.g. login/session token, DE/EN language preference, cookie consent). Non-essential tracking/marketing cookies are set only with your consent.

The app uses technically necessary session mechanisms. You can delete cookies and local storage at any time via your browser settings; this may limit functionality.

12. Data security

Access control is enforced via row-level security, encryption in transit (TLS) and at rest at the processor, and — optionally — multi-factor authentication.

13. Minimum age

Use requires a minimum age of 16 (age gate). We do not knowingly collect personal data from persons under 16; upon becoming aware, such data is deleted without delay.

14. Changes to this privacy policy

We may update this privacy policy, in particular when processing or processors change. The version published on this page applies; we communicate material changes appropriately. The version and date in the header of this document are authoritative.

15. Contact for data protection matters

For questions about data protection, exercising your rights, or access requests: HRIT.ch GmbH, Ruhsitzweg 12, 9000 St. Gallen, Switzerland — data@connexxa.ch.