Privacy Policy

Effective date: August 29, 2025

Introduction

This Privacy Policy explains how smartTONi SA ("we", "us", "our") collects, uses, and protects personal information when you visit our website or use our contact form. We are committed to protecting your privacy and handling your data in an open and transparent manner.

Information We Collect

• Contact form data: When you use our contact form, we collect the name, email address, and the message you send us.
• Analytics data: We use Google Analytics 4 (GA4) to collect information about how you interact with our website. This includes your IP address, browser type, device type, pages visited, and time spent on the site. This data helps us understand website usage and improve our services.
• reCAPTCHA v3 data: We use reCAPTCHA v3 to protect our contact form from spam and abuse. This service collects hardware and software information, such as device and application data, and sends it to Google for analysis.

Legal Basis for Processing

Under GDPR (EU) and revDSG (CH), we must have a legal basis to process your personal data. Our legal bases are:

• Legitimate Interest: We process data from the contact form to respond to your inquiries. It is in our legitimate interest to communicate with you and provide the requested information.
• Consent: For analytics cookies (GA4), we rely on your explicit consent. You will be prompted to provide this consent via a cookie banner when you first visit our site.

How We Use Your Information

• To respond to messages sent through the contact form.
• To operate, maintain, and improve our website, including its functionality and user experience.
• To protect our website and services from spam and abuse using reCAPTCHA.
• To comply with legal obligations when required.

Sharing and Third Parties

We do not sell or rent your personal data. We share your data with the following third-party service providers who act as our data processors:

• Google (Gmail, Google Analytics, reCAPTCHA): Your contact form messages are delivered to our Gmail inbox. Analytics data and reCAPTCHA data are processed by Google.
• Amazon Web Services (AWS): Our website and data are hosted on AWS servers.

Please note that data may be transferred to third countries (e.g., the United States) where these service providers operate. We ensure that these transfers are protected by appropriate safeguards, such as Standard Contractual Clauses (SCCs), to guarantee an adequate level of data protection in line with GDPR (EU) and revDSG (CH) requirements.

Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the duration of our business relationship with you. When the data is no longer necessary, we will securely delete it, unless a longer retention period is required by law.

Cookies and Your Choices

Cookies are small text files stored on your device. We use essential cookies for the basic functioning of the website. With your consent, we also use analytics cookies (GA4) to understand how you use our site.

You have control over cookies. You can manage your preferences through a cookie consent tool or by adjusting your browser settings to reject cookies. However, disabling certain cookies may affect the functionality of the website.

Your Rights

Under GDPR (EU), you have the right to (similar under revDSG in CH):

• Request access to the personal data we hold about you.
• Request correction or deletion of your data.
• Request that we delete your personal data.
• Request to restrict the processing of your data.
• Receive your data in a structured, commonly used, machine-readable format.
• Object to the processing of your data, especially for direct marketing purposes or processing based on legitimate interests.

To exercise these rights or ask questions, contact us at: privacy@smarttoni.com.

Automated Decision-Making

We use reCAPTCHA v3, which involves automated processing to analyze user behavior and protect our contact form. This service may flag certain user actions as potentially fraudulent. However, this process does not result in a legally significant effect on you.

Security

We use reasonable technical and organizational measures to protect personal data. However, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective date above and post the updated policy on this page.

Contact

If you have questions about this policy, please contact: privacy@smarttoni.com

Last updated: September 1, 2025