Notice under legal review.

HighOnDigital privacy notice

Version 1.3 · 29.09.2026

Version register

The earlier versions (from 0.1 of 18.09.2026 to 0.9 of 28.09.2026) covered only the Social Boost pages; HighOnDigital keeps their text.

This notice explains which personal data we collect, why, who we share it with, how long we keep it and what rights you have. It applies to every place listed in §2. Where we use a technical word, we explain it in brackets the first time.

What we store in your browser (cookies and similar) is explained in the cookie policy.

1. Controller

The controller (meaning who decides why and how your data is used) is:

HighOnDigital di Peter Ishiodu & Veronica Motta
Via Canova 15, 6900 Lugano, Switzerland
Email: info@highondigital.net · Phone: +41 76 604 11 36

We have not appointed a data protection advisor: it is not mandatory for us.

2. Where this notice applies

3. What we collect, why and on what basis

Each row is one processing (meaning one use of your data). The «Where» column says on which site or at which moment. The «Legal basis» column says why we are allowed to: if you are in the European Union, the General Data Protection Regulation (GDPR), Article 6, applies; if you are in Switzerland, the Federal Act on Data Protection (FADP) applies, which requires the purpose to be recognisable and that you can say no.

Before you answer the cookie banner. Today, on the Social Boost pages, if you have not yet answered the banner, the statistics and advertising tools start straight away, as if you had accepted. The banner still asks for your choice, and from the moment you answer your answer applies (§4).

On the application pages no measurement starts until you answer the banner: no count, not even an anonymous one, no cookie and no data about your visit to our CRM, apart from the technical request that shows you the banner (row «Operation and security»). The answers you write in the questionnaire stay, as always, only in your browser (§3.3). After your answer the rows below apply; in any case there are no Google or Meta tools there.

3.1 On all our pages

3.2 Social Boost pages (agenzia.highondigital.net)

3.3 Job applications (jobs.highondigital.net)

3.4 Our emails

What we do not do. We take no automated decisions with legal effects on you: for applications too, a person always decides. We do not ask for sensitive data (for example health, religion, political opinions): you can leave photos and such details out of your CV, we do not need them. We do not sell your data. We do not link the hod_vid code to your name.

Giving your data is optional. If you refuse cookies, the pages still work. To book we need your name and email: without them Calendly cannot set the appointment. To apply we need your CV, portfolio and test: without them we cannot assess the application.

4. The cookie banner: how your choice works

The banner appears on the pages of agenzia.highondigital.net and jobs.highondigital.net. It has three buttons of equal weight, Accept · Refuse · Customise, and two separate permissions. The choice applies to the site where you make it: if you answer on one of the two sites, the banner asks again on the other.

• Statistics («counting visits»): on the Social Boost pages the CRM code, Google Analytics 4, the hod_vid code and Google Ads measurement without advertising cookies; on the application pages the CRM code.
• Marketing and personalisation («recognising you»): together with «Statistics», personal recognition in the CRM and, on the Social Boost pages, the Meta pixel with sending from our server, Google Ads cookies and lists and the encrypted email of people who book.

If you have not answered yet, today on the Social Boost pages the tools start straight away, as if you had given both permissions (§3). One thing always waits for your yes: after a booking, your encrypted email to Google. On the application pages, instead, no measurement starts until you answer (§3).

If you refuse, even after the tools have started, from that moment and for later visits the page no longer loads Google and Meta tools and deletes the Google Analytics and Meta cookies, the hod_vid code and the CRM code. The refusal is recorded and we do not ask again at every visit. Some Google Ads and Meta cookies and storage remain in the browser, listed in the cookie policy: these pages no longer send them to Google or Meta, and you can delete them in your browser settings. What was already sent before your answer stays where it arrived, with the durations in §8; for what is in our CRM you can ask us to delete it (§9).

You can change your mind at any time from «Your cookie choices» at the bottom of every page. Withdrawing a yes works like a refusal.

5. Our emails: how to say no, and your latest choice

• Do not measure opens and clicks. Write to info@highondigital.net: from then on we write to you only from our mailbox, which does not measure opens and clicks. You can also turn off automatic image loading in your email software: opens are then not counted, clicks on links still are.
• Stop the emails about the call. At the bottom of the email with the prices and of the email after the call, a line explains how: open «Preferenze e tracciamento» (Preferences and tracking) and press «Conferma» (Confirm). From then on you no longer receive the reminder the day before or the email after the call. Calendly's emails and SMS do not depend on this choice: for SMS reply STOP.
• Unsubscribe from marketing emails. At the bottom of each one there is the «Non ricevere più queste email» (Stop receiving these emails) link: you open it and confirm with a button, no password needed.
• Object to direct marketing. You can ask us at any time not to use your data to offer you our services, including by replying to one of our emails.

If you change your mind, your latest choice applies. If you give us different choices at different times (in the cookie banner, in the booking-form box, from the link at the bottom of our emails), the latest always applies, and only to what that choice concerns. For example: if you refused cookies on the page and then, when booking, you tick the marketing email box, we write to you now and then, but cookies stay refused; if you then unsubscribe from the link in an email, we stop; if later you tick the box again, we start again.

6. Who we share data with

Within HighOnDigital, the data is seen by the people who work with the CRM. Outside, these providers receive it:

7. Data outside Switzerland and the European Union

The CRM, with the applications and their files, has its database in Switzerland (Zurich region). Google, Meta, Calendly, Vercel and Resend have their seat or servers in the United States.

The United States is recognised as a country with adequate protection only for companies certified under the Data Privacy Framework (Federal Council, decision of 14.08.2024 in force since 15.09.2024; European Commission, decision of 10.07.2023).

• Google LLC and Meta Platforms, Inc.: certified under the Swiss-U.S. and EU-U.S. Data Privacy Framework.
• Calendly, LLC and Vercel Inc.: state in their privacy notice that they are certified under the Swiss-U.S. and EU-U.S. Data Privacy Framework.
• Resend and Supabase: the safeguard is the standard contractual clauses approved by the European Commission (decision 2021/914), with the adjustments for transfers from Switzerland written in their data processing agreements.

8. How long we keep data

9. Your rights

You can ask at any time for:

• access to the data we hold about you (FADP Art. 25; GDPR Art. 15);
• correction of inaccurate data (FADP Art. 32; GDPR Art. 16);
• deletion (FADP Art. 32; GDPR Art. 17);
• restriction of processing (GDPR Art. 18);
• portability, meaning receiving the data you gave us in a readable format (FADP Art. 28; GDPR Art. 20);
• objection to processing based on legitimate interest (GDPR Art. 21).

Direct marketing. You can object at any time to the use of your data for direct marketing (GDPR Art. 21(2)). If you object, we stop (§5).

Withdrawing consent. You withdraw the banner consent from «Your cookie choices», as easily as you gave it; consent to marketing emails from the «Non ricevere più queste email» link. Withdrawal does not make unlawful what was done before.

How to exercise them: write to info@highondigital.net. We answer within 30 days. We may ask for proof of identity if we cannot attribute the requested data to you with certainty.

Complaint. You can contact the Federal Data Protection and Information Commissioner (FDPIC, Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch). If you are in the European Union, the authority of your country; for Italy the Garante per la protezione dei dati personali (www.garanteprivacy.it).

10. Security

The pages are served only over an encrypted connection (https). Our cookies are marked Secure and SameSite=Lax. The register of choices can only be added to: no one can change or delete it. Visits in the CRM do not record the IP address. The links in our emails and on the price page use long random codes that cannot be guessed. Application files are in a private area: only people who work with the CRM open them, with links that expire after 15 minutes.

11. Changes

When we start processing data in a new way, we add it here and raise the version. The register at the top of this page says what changed and when.