HighOnDigital Privacy Policy
Version 2.0 · 20.10.2026
| Version | Date | Changes |
|---|---|---|
| 2.0 | 20.10.2026 | New wording of the policy, organised by purpose. The dedicated policy for clients, partners and collaborators is now separate (section 13). Clarified what is erased and what is retained in the event of an erasure request, withdrawal of consent or objection to marketing (section 12). Extended to the main website highondigital.net (sections 2, 6.2, 6.13 and 7). Clarified the retention of application data and of the tracking linked to applicants (section 9). |
Previous versions are kept by the Controller and are available on request.
This policy describes how HighOnDigital processes the Personal Data of people who visit its websites, book an appointment, submit an application, contact the Controller or receive its communications, pursuant to Art. 19 of the Federal Act on Data Protection (FADP) and, where applicable, Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR). Capitalised terms are defined in section 16. The use of cookies and similar technologies is described in the Cookie Policy, which forms an integral part of this policy.
1. Data Controller
HighOnDigital di Peter Ishiodu & Veronica Motta
Via Canova 15, 6900 Lugano, Switzerland
Email: hello [at] highondigital [dot] net · Phone: +41 76 604 11 36
The Controller has not appointed a data protection advisor, as it is not required to do so.
2. Scope
This policy applies to processing carried out through:
| Scope | Description |
|---|---|
| highondigital.net and its subdomains | The Controller's pages, including: the main website highondigital.net (presentation of the agency, case studies and articles); the pages of the agency's services for Ticino and for the rest of Switzerland (in Italian, German and English), with the booking confirmation pages and the confidential pricing pages reachable through a personal link; the pages for the selection of collaborators; the technical services linked to the pages and communications (cookie consent banner, links contained in emails, communication preferences page) |
| Communications | Emails sent by the Controller, messages received at the email address from which communications are sent, contacts by phone and WhatsApp |
| Third-party services | Calendly (appointment booking) and Google Meet (video calls). Processing carried out on their pages is also governed by their own privacy policies |
For Personal Data processed in the context of a contractual or collaboration relationship with the Controller (clients and their contact persons, partners, collaborators), the dedicated policy referred to in section 13 also applies.
3. Types of Data collected
Depending on the case, the Controller processes the following categories of Personal Data:
| Category | Examples |
|---|---|
| Contact data | First name, last name, email address, phone number |
| Data relating to the Data Subject's business | Name and location of the business, website, information provided in the booking form |
| Application data | Area of residence, professional situation, VAT number, experience, languages, availability, equipment, curriculum vitae, links to the portfolio and to published work, uploaded video files, notes from the interview and the practical test |
| Usage Data | IP address, browser and device type, pages visited, events on the page, referring page, date and time, campaign parameters (utm_*) and ad click identifiers (fbclid, gclid) |
| Trackers | Cookies, browser local and session storage, pixels and random codes, described in the Cookie Policy |
| Communication data | Content of messages and emails exchanged with the Controller, attachments, data on delivery, opening and clicks of emails |
| Consent data | Choices made in the cookie banner and in the communication preferences, with date, time, text version and language |
The Controller does not request sensitive personal data within the meaning of Art. 5(c) FADP and Art. 9 GDPR. The Data Subject is asked not to include such data in the curriculum vitae or in messages.
Unless otherwise indicated, Data is collected from the Data Subject. Usage Data and Trackers are collected automatically during browsing.
4. Methods and place of processing
Methods. Processing is carried out using IT and telematic tools, following procedures strictly related to the purposes indicated, by means of the Controller's proprietary management software and the services of the providers listed in section 7. The Controller adopts technical and organisational measures appropriate to the risk (Art. 8 FADP; Art. 32 GDPR) to protect the Data against unauthorised access, disclosure, alteration or destruction (section 10).
Access to the Data. Within the Controller, only authorised persons who need the Data to perform their tasks have access to it. Externally, the Data is disclosed to the providers listed in section 7.
Place. The database of the proprietary management software and its backups are kept in Switzerland (Zurich region). Some providers have their registered office or servers outside Switzerland and the European Union: see section 8.
5. Purposes and legal bases: overview
| Purpose | Legal basis (GDPR, where applicable) | Switzerland (FADP) |
|---|---|---|
| Operation and security of the websites (6.1) | Legitimate interest, Art. 6(1)(f) | Overriding interest, Art. 31(1) |
| Management of cookie consent (6.2) | Legal obligation, point (c), and legitimate interest in demonstrating consent, Art. 7(1) | Art. 31(1) |
| Statistics (6.3) | Consent, point (a); for anonymous measurement: no personal data | Information and right to refuse, Art. 45c TCA; Arts. 6 and 31 |
| Advertising and ad measurement (6.4) | Consent, point (a) | Art. 45c TCA; Arts. 6 and 31 |
| Booking and holding the appointment (6.5) | Pre-contractual measures at the Data Subject's request, point (b); legitimate interest, point (f) | Art. 31(2)(a) |
| Direct contact (6.6) | Pre-contractual measures, point (b); legitimate interest, point (f) | Art. 31(1) and (2)(a) |
| Selection of collaborators (6.7) | Pre-contractual measures, point (b); consent for the archive, point (a) | Art. 31(2)(a); Art. 6(6) |
| Email communications (6.8) | Pre-contractual measures, point (b); consent for marketing, point (a) | Art. 3(1)(o) UCA; for the measurement of opens and clicks, Art. 45c TCA and Arts. 30–31 FADP |
| Management of incoming correspondence (6.8.4) | Legitimate interest, point (f) | Art. 31(1) |
| Contact records and business relationships (6.9) | Legitimate interest, point (f); pre-contractual measures, point (b) | Art. 31(1) and (2)(a) |
| Use of artificial intelligence systems (6.10) | The same basis as the purpose served; legitimate interest, point (f) | Art. 31(1) |
| Backups (6.12) | Legitimate interest, point (f); security measure within the meaning of Art. 32(1)(c) | Art. 8 FADP; Art. 3 DPO |
| Reviews and protected pages of the main website (6.13) | Legitimate interest, point (f); for the protected page, the function requested by the User | Art. 31(1); Art. 45c TCA |
The following sections describe each processing activity in detail.
6. Details of the processing
6.1 Operation and security
Personal Data processed: Usage Data contained in the technical logs of the hosting provider (IP address, requested page, address parameters, browser, date and time, network region); truncated IP address, used by the proprietary management software to limit abuse of the public pages.
Purpose: serving the pages, protecting them from abuse, detecting errors, excluding the Controller's own connections and automated visits from the statistics.
Place of processing and providers: Vercel and, for the main website, SiteGround (section 7); Switzerland for the proprietary management software.
Retention: section 9.
6.2 Management of cookie consent
On the pages of highondigital.net and its subdomains, a banner asks the User for consent to two categories of Trackers, «Statistics» and «Marketing and personalisation», with three buttons of equal prominence: Accept, Refuse, Customise. The choice applies to the subdomain on which it is made.
Personal Data processed: a cookie containing the choice, the text version, the time and a random identifier of the choice; in the register of choices of the proprietary management software: identifier of the choice, website, categories accepted or refused, version and language of the text, button pressed, page, date and time. The register does not contain the IP address or the browser type, and also keeps the choices relating to communications (section 6.8).
Purpose: not repeating the request and being able to demonstrate the choice made.
Before the User's response. On the pages of the agency's services, until the User has responded to the banner, the statistics and advertising tools are activated as if the User had accepted both categories; the exception is the transmission to Google of the hashed email of the person booking, which takes place only with consent. From the moment of the response, the User's choice applies. For this processing, in the absence of a response, the basis is the information provided in this policy and the right to refuse at any time (Art. 45c(b) TCA). On the main website highondigital.net and on the pages for the selection of collaborators, before the response, no tool that recognises the User and no third-party statistics or advertising tool is activated: only the anonymous totals are collected (section 6.3.3).
Refusal and withdrawal. Refusal or withdrawal, possible at any time through the «Your cookie choices» link at the bottom of every page, stop the activation of the tools from that moment and cause the related cookies to be deleted, as described in the Cookie Policy. Data already transmitted before withdrawal remains with the recipients for the periods indicated in section 9; for the data held in the proprietary management software, the Data Subject may request its erasure (section 12).
6.3 Statistics
6.3.1 The Controller's own statistics
Personal Data processed: a random code in the browser (nx_v); pages viewed, clicks and events on the page, referring page, campaign parameters; on the pages for the selection of collaborators, the steps of the questionnaire with the time (never the content of the answers).
Purpose: counting visits and assessing the effectiveness of the pages.
Legal basis: consent to the «Statistics» category; on the pages of the agency's services, before the response, as indicated in section 6.2.
6.3.2 Linking visits to the Data Subject's record
Personal Data processed: the link between the nx_v code and the Data Subject's data in the proprietary management software, when the Data Subject arrives through a personal link contained in an email from the Controller or provides their data by booking or applying.
Purpose: recognising the visits of people already in contact with the Controller.
Legal basis: consent to both categories («Statistics» and «Marketing and personalisation»); on the pages of the agency's services, before the response, as indicated in section 6.2.
6.3.3 Anonymous measurement
On all pages the Controller collects, even in the event of refusal, anonymous daily totals: page openings, display of the banner and the response given, scrolling, sections viewed, clicks, time on the page in bands, screen type, channel of origin; on the pages for the selection of collaborators, progress through the questionnaire and submission. No cookies or codes that recognise the User are used, and the IP address is not recorded. These totals are not Personal Data; the Controller does not combine them with other data and does not disclose them to third parties.
6.3.4 Google Analytics 4 (Google Ireland Limited / Google LLC)
Google Analytics 4 is a web traffic analysis service. It is used on the pages of the agency's services and on the main website (the same property) and is linked to the Controller's Google Ads account, so that visit data contributes to the remarketing lists (section 6.4.2).
Personal Data processed: Usage Data; Trackers (_ga, _ga_*); a random identifier of the Controller (hod_vid), never linked to name or email.
Place of processing: Ireland, United States. Privacy policy.
Legal basis: consent to the «Statistics» category; before the response, as indicated in section 6.2.
6.3.5 Recognition of repeat visits
Personal Data processed: random code hod_vid, number of visits, the Controller's pages already visited, first and last campaign of origin. Never linked to name or email.
Purpose: knowing whether the User returns and through which channel they first arrived.
Legal basis: as in section 6.3.4.
6.4 Advertising and ad measurement
These services allow the Controller to measure the effectiveness of its ads and to show them to people who have already visited its pages. The Meta Pixel is used only on the pages of the agency's services; Google Ads also on the main website. The Controller may use similar services of other advertising platforms, for example TikTok; this policy is updated before they are activated.
6.4.1 Meta Pixel and Conversions API (Meta Platforms Ireland Limited / Meta Platforms, Inc.)
Personal Data processed: Trackers (_fbp, _fbc); page address without personal data; events of visit, click on the booking button, click on the WhatsApp button and completed booking; click identifier (fbclid). The same events are also transmitted to Meta from the Controller's server, with IP address and browser and device type. Name, email or booking code are never transmitted to Meta.
Role: joint controllership for the collection and transmission of events; Meta is an independent controller for subsequent processing.
Place of processing: Ireland, United States. Privacy policy.
Legal basis: consent to both categories; before the response, as indicated in section 6.2.
6.4.2 Google Ads: conversion tracking, remarketing and enhanced conversions (Google Ireland Limited / Google LLC)
Personal Data processed: Trackers (_gcl_au, _gcl_aw, _gcl_ls); click identifier (gclid); visit data for the remarketing lists; only on the confirmation page and only with consent to the «Marketing and personalisation» category, the email address of the person booking, hashed with a hash function, which Google matches against its own data.
Role: Google acts as processor for the hashed email and as independent controller for Google Ads measurements.
Place of processing: Ireland, United States. Privacy policy · Information on advertising services.
Legal basis: with the «Statistics» category alone, measurement without advertising cookies, without lists and without email; everything else with both categories; before the response, as indicated in section 6.2 (without email).
6.5 Booking and holding the appointment
6.5.1 Booking (Calendly, LLC)
Personal Data processed: first name, last name, email, phone number, answers to the form, day and time; for the rest of Switzerland, the language of the appointment; optionally, the number for SMS reminders sent by Calendly (to stop them, simply reply STOP).
Purpose: setting and confirming the appointment. The phone number is used to contact the Data Subject again if necessary and is not used for promotional communications.
Place of processing: United States. Privacy policy.
Legal basis: pre-contractual measures at the Data Subject's request.
6.5.2 Confirmation page
For appointments booked from the pages of the agency's services, at the end of the booking Calendly returns the Data Subject to the Controller's confirmation page, transmitting name, email and time in the address. The page shows them only to the Data Subject, removes them from the address immediately and does not save them. The completed-booking event is transmitted to Google and Meta with weekday, time and campaign parameters; the hashed email only as indicated in section 6.4.2.
Legal basis: pre-contractual measures; legitimate interest for the technical logs.
6.5.3 Analysis of information about the business
Personal Data processed: the answers in the form relating to the Data Subject's business and, if indicated, the text of the public pages of their website. The information may be processed with artificial intelligence systems (section 6.10). No data about individuals is searched for.
Purpose: preparing the appointment and the proposal with the business data.
Legal basis: pre-contractual measures at the Data Subject's request.
6.5.4 Service communications about the appointment
Personal Data processed: name, email, day and time of the appointment; links to join, reschedule or cancel; outcome of the video call.
Purpose: confirming the appointment, sending the confidential pricing page, reminding of the appointment and following up on the video call. These communications do not subscribe the Data Subject to any list; the Data Subject may ask to stop receiving them (section 12.2).
Legal basis: pre-contractual measures.
6.5.5 Video call (Google Meet)
Personal Data processed: data on participation in the meeting made available by Google (start and end, display name of the participants and type of connection). The Controller does not record audio, video or chat and does not read the participants' email address.
Purpose: holding the video call and verifying that it took place before contacting the Data Subject again.
Place of processing: Ireland, United States. Privacy policy.
Legal basis: pre-contractual measures; legitimate interest.
6.5.6 Confidential pricing page
Personal Data processed: a random personal code contained in the link sent by email; the Data Subject's name, name and town of the business, day and time of the appointment, if provided; number of openings of the page and time of the last opening. For this count, neither the IP address nor the browser type is recorded and no cookies are used.
Purpose: showing the prices with the Data Subject's data and preparing for the appointment.
Legal basis: pre-contractual measures for the display; legitimate interest for counting the openings.
6.6 Direct contact
Personal Data processed: the contact data and the content of the messages that the Data Subject sends to the Controller by email, phone or WhatsApp, including through the button on the pages of the agency's services.
Purpose: answering requests and, if the Data Subject so requests, setting an appointment.
Providers: for WhatsApp messages, WhatsApp Ireland Limited, which processes the data of the messaging service according to its own policy (privacy policy); for email, the providers in section 7.
Legal basis: pre-contractual measures at the Data Subject's request; legitimate interest in responding.
6.7 Selection of collaborators
6.7.1 Filling in the questionnaire
Personal Data processed: the answers, saved only in the User's browser until submission (local storage, deleted 24 hours after the last save or on submission); the links to the portfolio and to published work, which the Controller's server opens with a single request, without cookies and without an account, to check that they are accessible, without keeping their content. Whoever hosts the link receives the request from the Controller's server and not from the User's browser. The links are saved only when the application is submitted. The curriculum vitae and video files are uploaded to a temporary private area and deleted if the application is not submitted within 24 hours.
Purpose: allowing the questionnaire to be interrupted and resumed; preventing an application from being lost because of an inaccessible link.
6.7.2 Application and assessment
Personal Data processed: the Application data (section 3); the channel of origin, the page and, if present, the nx_v code; the result of the link check; the interview notes and, for searches that provide for it, the assessment of the practical test.
Purpose: assessing the application, examining the work, inviting to the interview and communicating the outcome. The Controller does not measure the opening of emails relating to the application or clicks on their links. The practical tests requested are free of charge, the same for all applicants and are not published. The data needed for any subsequent assignment is processed according to the agreement concluded with the collaborator.
Preliminary automated assessment: see section 11.
Legal basis: pre-contractual measures at the Data Subject's request (GDPR Art. 6(1)(b); FADP Art. 31(2)(a)).
6.7.3 Application archive
Personal Data processed: the application data.
Purpose: considering the application also for future searches.
Legal basis: consent, given through the dedicated checkbox before submission and revocable at any time.
6.7.4 Questionnaire measurement
The anonymous totals described in section 6.3.3 are collected for everyone from the first moment. The individual person's path through the questionnaire is recorded only with consent to the «Statistics» category and linked to the application only with consent to both categories.
6.8 Email communications
6.8.1 Sending and delivery (Resend)
Personal Data processed: address, subject and text of the email; result of delivery, bounce or report as unwanted.
Purpose: sending emails and checking their delivery.
Legal basis: the same as that of the communication sent.
6.8.2 Measurement of opens and clicks
In emails relating to the appointment and in marketing emails (not in those relating to applications), the Controller uses an invisible image and links that pass through its own servers.
Personal Data processed: which email, date and time of the open or click, link clicked, program or device, truncated IP address. Location is not derived. Automatic opens by email programs are kept separate.
Purpose: checking that emails arrive and are read, and which content is of interest. These measurements are not used for automated decisions.
Legal basis: in Switzerland, information provided in this policy and the right to object at any time (Art. 45c(b) TCA; Arts. 30–31 FADP). The Controller does not request prior consent; the Data Subject may object as indicated in section 12.2.
6.8.3 Marketing emails
Personal Data processed: name, email; the answer to the consent checkbox with date and text of the question.
Purpose: periodically sending content and offers about the Controller's services. Without consent the Data Subject does not receive marketing emails, and service communications remain unchanged. Consent to emails does not change the choices on cookies.
Legal basis: consent (GDPR Art. 6(1)(a); Art. 3(1)(o) UCA), revocable through the link in every email.
6.8.4 Management of incoming correspondence
Personal Data processed: sender, subject and text of the emails received at the address from which the Controller's communications are sent, including replies to them, and any attachments.
Purpose: classifying and summarising messages, including with artificial intelligence systems (section 6.10), in order to reply in an orderly way; recognising and deleting unwanted mail; recording as a new contact anyone who writes with a request. In case of doubt, the message is examined by a person.
Legal basis: legitimate interest in managing correspondence and in protecting against unwanted mail.
6.9 Contact records and business relationships
The data of people who book, apply, write to the Controller or become clients is kept in the Controller's proprietary management software as contact records, with the history of business relationships (appointments, offers, purchases, status of the relationship).
Purpose: managing and documenting business relationships and being able to contact the Data Subject again, in compliance with their choices on marketing communications.
Legal basis: legitimate interest; pre-contractual measures.
6.10 Use of artificial intelligence systems
The Controller may process the Data held in its proprietary management software with artificial intelligence models from third-party providers (section 7), to search for and summarise information, classify correspondence and prepare communications. The models are accessed through Vercel; the providers do not use the Data to train their models. No communication to the Data Subject is sent without a person's confirmation, and no automated decisions producing legal effects on the Data Subject are taken.
Legal basis: the same as that of the purpose served; legitimate interest in efficient work organisation.
6.11 Legal defence
The Data may be processed to establish, exercise or defend a right of the Controller in court or in preparatory phases, including enforcement proceedings.
6.12 Backups
Personal Data processed: a copy of the database of the proprietary management software, with all the Data it contains at the time of the copy; uploaded files are not included.
Purpose: restoring the Data in the event of failure, error or attack. The copies are not used for other purposes; they may be temporarily restored in an environment of the Controller to check that they work, and the test copy is deleted at the end of the check.
Place of processing and providers: Google Cloud EMEA Limited, Zurich region, Switzerland (section 7).
Legal basis: legitimate interest in not losing the Data and security measure (Art. 8 FADP; Art. 3 DPO; Art. 32(1)(c) GDPR).
6.13 Reviews and protected pages of the main website
Personal Data processed: to display the reviews left by clients on Google, the review box on some pages of the main website sends the User's IP address and browser type to Trustindex, which provides the box, and to Google, from which the reviewers' photos are loaded; no cookies are used. For password-protected pages, a technical cookie remembers that the password has been entered (Cookie Policy, section 3.1).
Purpose: showing clients' reviews; allowing access to protected pages without asking for the password each time.
Place of processing and providers: Trustindex and Google (section 7); SiteGround for hosting the website.
Legal basis: legitimate interest in presenting the reviews received (Art. 31(1) FADP; Art. 6(1)(f) GDPR); for the protected page, the cookie is necessary for the function requested by the User (Art. 45c TCA).
7. Recipients of the Data
Within the Controller, the Data is accessible to authorised staff. Externally, it is disclosed to the following providers:
| Provider | Registered office | Role | Service | Privacy policy |
|---|---|---|---|---|
| Vercel Inc. | 440 N Barranca Avenue #4133, Covina, CA 91723, USA | Processor | Hosting of the websites and of the proprietary management software; technical logs; checking of application links; connection to the artificial intelligence models | vercel.com/legal/privacy-policy |
| Supabase Pte. Ltd. | 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513; data in the Zurich region, Switzerland | Processor | Database of the proprietary management software and private file archive | supabase.com/privacy |
| Resend (Plus Five Five, Inc.) | 2261 Market Street #5039, San Francisco, CA 94114, USA; sending from the Ireland region (EU) | Processor | Sending of emails and delivery results | resend.com/legal/privacy-policy |
| Calendly, LLC | 115 E Main St., Ste A1B, Buford, GA 30518, USA | Processor | Appointment booking, confirmations, SMS reminders | calendly.com/legal/privacy-notice |
| Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC (USA) | Ireland, USA | Processor for Google Analytics 4 and for the hashed email; independent controller for Google Ads measurements | Statistics, advertising, video calls (Google Meet), also on the main website; reviewers' photos in the review box | policies.google.com/privacy |
| Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) and Meta Platforms, Inc. (USA) | Ireland, USA | Joint controller for the collection and transmission of events; independent controller for subsequent processing | Ad measurement and campaign audiences | facebook.com/privacy/policy |
| Anthropic PBC (548 Market Street, PMB 90375, San Francisco, CA 94104, USA) and Anthropic Ireland, Limited (South Bank House, Barrow Street, Dublin 4, Ireland) | USA, Ireland | Sub-processor, on behalf of Vercel; the model may also be run, on behalf of Vercel, on Amazon Web Services or Google Cloud servers | Artificial intelligence models (section 6.10) | anthropic.com/legal/privacy |
| Google Cloud EMEA Limited | 70 Sir John Rogerson's Quay, Dublin 2, Ireland; data in the Zurich region, Switzerland | Processor | Database backups | cloud.google.com/terms/data-processing-addendum |
| WhatsApp Ireland Limited | Merrion Road, Dublin 4, Ireland | Independent controller for the messaging service | WhatsApp messages | whatsapp.com/legal/privacy-policy-eea |
| SiteGround Spain S.L. | Calle de Prim 19, 28004 Madrid, Spain; servers in the European Union (Germany) | Processor | Hosting of the main website; server logs, cache, protection | eu.siteground.com/privacy.htm |
| Trustindex Ltd | Nyári Pál utca 15, 2724 Újlengyel, Hungary | Processor | Google reviews box on the main website | trustindex.io/privacy-policy |
When the Controller checks the links of an application (section 6.7.1), the service hosting the link receives a request from the Controller's server. That service is not a provider of the Controller and processes the request according to its own policy.
The Data may also be disclosed to authorities and advisors (for example lawyers and fiduciaries) where necessary to comply with legal obligations or for legal defence.
8. Transfers abroad
The database of the proprietary management software and the backups are located in Switzerland. The Data may be disclosed to countries of the European Union (including Ireland, Germany, Spain and Hungary) and to the United States, where Google, Meta, Calendly, Vercel, Resend, Anthropic and Amazon Web Services have their registered office or servers.
| Recipient | Safeguard (Art. 16 FADP; Arts. 45–46 GDPR) |
|---|---|
| Ireland and the European Union | Countries with adequate protection according to the Federal Council |
| Google LLC, Meta Platforms, Inc. | Certification under the Swiss-U.S. and EU-U.S. Data Privacy Framework (decision of the Federal Council of 14.08.2024, in force since 15.09.2024; decision of the European Commission of 10.07.2023) |
| Calendly, LLC, Vercel Inc. | Certification under the Swiss-U.S. and EU-U.S. Data Privacy Framework stated in their policy |
| Resend, Supabase | Standard contractual clauses approved by the European Commission (Decision 2021/914), with the adaptations for transfers from Switzerland |
| Anthropic and, when they run the model, Amazon Web Services or Google Cloud | Data processing agreement with Vercel, with standard contractual clauses (Decision 2021/914) also valid for transfers from Switzerland |
| SiteGround Spain S.L. | Registered office and servers in the European Union; for any access from other countries, the safeguards of its data processing agreement apply |
| Google Cloud EMEA Limited | Data kept only in Switzerland; for any access from other countries, the safeguards of its data processing agreement apply (Data Privacy Framework towards the United States, standard contractual clauses towards other countries) |
9. Retention period
The Data is kept for as long as necessary for the purposes for which it is collected, according to the following table. At the end of the period, the Data is erased or anonymised (Art. 6(4) FADP).
| Data | Period |
|---|---|
| Contact records and history of business relationships (section 6.9), including the data of people who book and the emails sent | No fixed term; in the event of an erasure request, section 12.1 applies |
| Application data (answers, curriculum vitae, links, uploaded files, notes from the interview and the test) | No fixed term, until the Data Subject requests erasure or withdraws consent to the archive |
Tracking data linked to an applicant (nx_v code, visits and path through the questionnaire) | Three months from submission of the application; thereafter only anonymous totals |
| Accounting records | Ten years from the end of the financial year (Art. 958f CO) |
| Register of choices (cookies, communications, consents and their withdrawal) | No fixed term: it serves to demonstrate the choices and, in the event of objection, not to contact the Data Subject again |
| Visits and events not linked to a Data Subject | 180 days for each individual item; thereafter only daily totals without codes |
| Visits and events linked to a Data Subject; opens and clicks of emails; openings of the pricing page | Up to 24 months for each individual item; thereafter only totals. For applicants, the three-month term indicated above applies |
| Anonymous totals (section 6.3.3) | No term: they are not Personal Data |
| Personal link to the pricing page | Valid until 14 days after the appointment, or 30 days if no appointment is set |
| Received emails recognised as unwanted or deleted | 30 days from deletion |
| Truncated IP address against abuse | One day |
| Uploaded files and unsubmitted application | 24 hours |
| Data transmitted to artificial intelligence models | Not kept by Vercel after the response; deleted by Anthropic within 30 days, except for security checks (up to 2 years) or legal obligations |
| Backups | 30 days from their creation; an erased item remains in existing copies until they expire |
| Vercel technical logs | From 1 hour to 30 days, depending on the service plan |
| Server logs of the main website (SiteGround) | For as long as necessary for the security of the service and the analysis of any improper access, according to the provider's data processing agreement |
| Data held by Google, Meta and Calendly | According to the Controller's settings and the providers' policies: Google Analytics data 2 or 14 months; Google Ads remarketing lists up to 540 days; Meta audiences 180 days |
| Cookies and similar technologies | As indicated in the Cookie Policy |
The application data is collected to assess the application and to consider it also in future searches (sections 6.7.2 and 6.7.3): it remains necessary for that purpose until the Data Subject requests its erasure or withdraws consent to the archive, and therefore has no fixed term (Art. 6(3) and (4) FADP; Art. 5(1)(e) GDPR). Tracking data linked to an applicant is not necessary for that purpose beyond the first three months and is therefore erased at that point.
10. Security
The pages are served exclusively over an encrypted connection (HTTPS), and the Controller's cookies are set with the Secure and SameSite=Lax attributes. The register of choices cannot be modified or deleted. Personal links use unpredictable random codes. Application files are kept in a private area accessible only to authorised staff, with expiring links. Backups are transmitted and stored in encrypted form, in an archive not accessible to the public.
11. Automated decisions
The Controller does not take decisions based solely on automated processing that produce legal effects or significant consequences for the Data Subject (Art. 21 FADP; Art. 22 GDPR).
For applications, the proprietary management software assigns each application an order of priority, based on some answers and on the result of the link check. An application that does not meet a stated requirement of the search (for example area, VAT number, language or equipment) is flagged as such. Final decisions are never automated: the system indicates whether an application meets the requirements, but does not exclude it; the decision to proceed with, accept or close an application is always taken by a person of the Controller, who can reopen it. The Data Subject may express their point of view and request that the decision be reviewed by a person (section 12).
12. Rights of the Data Subject
12.1 Rights
The Data Subject may at any time exercise the following rights:
| Right | Reference |
|---|---|
| Access to their Data and to information about the processing | Art. 25 FADP; Art. 15 GDPR |
| Rectification of inaccurate Data | Art. 32(1) FADP; Art. 16 GDPR |
| Erasure | Art. 32(2) FADP; Art. 17 GDPR |
| Restriction of processing | Art. 18 GDPR |
| Delivery or transfer of the Data in a commonly used electronic format | Art. 28 FADP; Art. 20 GDPR |
| Objection to processing based on legitimate interest, and in any case to direct marketing | Art. 21 GDPR |
| Withdrawal of consent, without affecting the lawfulness of prior processing | Art. 30(2)(b) FADP; Art. 7(3) GDPR |
| Expressing a point of view and review by a person in the case of an automated decision | Art. 21(2) FADP; Art. 22(3) GDPR |
Erasure of Personal Data. An erasure request has different effects depending on the relationship between the Data Subject and the Controller. In all cases, the Controller keeps proof of consents and objections and a hashed fingerprint of the email address, solely in order not to enter the Data Subject's Data again and not to contact them against their will; information without reference to the Data Subject may be kept in anonymised form.
Data Subjects without a business relationship with the Controller (no appointment, no offer, no contract): the Controller erases their Data, including the content of communications and the related attachments.
Data Subjects with whom the Controller has had a pre-contractual relationship (for example an appointment or an offer): the Controller keeps the name, the business and the business history (appointments, offers and communications sent), to document the relationship and defend its rights, for no more than ten years (Art. 31 FADP; Art. 17(3)(e) GDPR), and erases the other contact data. From that moment, such Data is not used for marketing communications.
Clients and former clients: the dedicated policy applies (section 13).
Applications: without a request, the application data, including uploaded files, is kept with no fixed term (sections 6.7.3 and 9). Upon an erasure request or withdrawal of consent to the archive, the application is erased. Tracking data linked to the applicant is in any case erased three months after the application is submitted (section 9).
Usage Data. Upon an erasure request, the Usage Data linked to the Data Subject is erased in all cases. Withdrawal of consent to Trackers stops the collection; Data already collected remains until it expires (section 9), unless erasure is requested.
Withdrawal and objection to marketing are not erasure. Withdrawing consent to marketing emails or objecting to direct marketing stops the related communications, without erasing the contact records and the history of the relationship.
Data already present in backups remains there until they expire (section 9). In its reply, the Controller indicates which Data it has kept, for what reason and until when.
12.2 Choices about communications
The Data Subject may at any time: disable the measurement of opens and clicks by writing to hello [at] highondigital [dot] net (from that moment, the Controller writes to them only from its own mailbox, which does not measure opens and clicks); ask to stop receiving service communications relating to the appointment, from the «Preferenze e tracciamento» (Preferences and tracking) page reachable through the link at the bottom of the emails; withdraw consent to marketing emails through the «Non ricevere più queste email» (Stop receiving these emails) link in each of them; object to direct marketing also by replying to an email. Calendly SMS messages stop by replying STOP.
If the Data Subject makes different choices at different times (in the cookie banner, in the checkbox of the booking form, through the links at the bottom of the emails), the most recent choice applies, limited to what it concerns.
12.3 How to exercise the rights
Requests should be sent to hello [at] highondigital [dot] net. The Controller replies within 30 days and may request proof of identity where the Data cannot be attributed to the requester with certainty.
12.4 Complaint
The Data Subject may contact the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch. If they are in the European Union, they may lodge a complaint with the supervisory authority of their State; for Italy, the Garante per la protezione dei dati personali, www.garanteprivacy.it.
13. Clients, partners and collaborators
If the Data Subject is a client of the Controller or one of its contact persons, a partner or a collaborator, the Data processed in the context of the relationship is also governed by the dedicated policy, which the Controller makes available at the start of the relationship.
14. Whether providing Data is mandatory
Providing the Data is optional. Refusing cookies does not prevent the pages from being consulted. To book an appointment, name and email are required; to apply, the mandatory answers of the questionnaire, the curriculum vitae and the link to the portfolio are required. Without them, the appointment cannot be set or the application cannot be assessed.
15. Changes to this policy
The Controller updates this policy when it introduces a new processing activity or changes an existing one, indicating the version, the date and the changes in the table at the top of the document.
16. Definitions and legal references
Personal Data (or Data): any information relating to an identified or identifiable natural person (Art. 5(a) FADP; Art. 4(1) GDPR).
Usage Data: information collected automatically during the use of the websites.
Data Subject: the natural person to whom the Personal Data refers.
User: the person who uses the Controller's websites.
Data Controller (or Controller): HighOnDigital, as indicated in section 1.
Processor: the person or company that processes Personal Data on behalf of the Controller (Art. 9 FADP; Art. 28 GDPR).
Proprietary management software: the Controller's IT system for managing contacts, appointments, applications and communications.
Trackers: cookies, browser storage, pixels and similar technologies.
Legal references: Federal Act on Data Protection of 25 September 2020 (FADP, SR 235.1) and its Ordinance (Data Protection Ordinance, DPO, SR 235.11); Telecommunications Act (TCA, SR 784.10), Art. 45c; Federal Act against Unfair Competition (UCA, SR 241), Art. 3(1)(o); Code of Obligations (CO, SR 220), Art. 958f; Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC, Art. 5(3), for Data Subjects located in the European Union.