Data Privacy has the highest priority at Visorway.ai

Date: January 1, 2025

Introduction

Protecting your personal data is a top priority for Visorway. This privacy policy explains in detail how Visorway processes the personal data of users and visitors to the website. It provides specific insights into the following areas:

1. What data we process, for what purposes, and on what legal basis
2. The use of AI at Visorway
3. Our cookie policy
4. Data recipients and possible transfers
5. Data security
6. Your rights

We are committed to:
Collecting only the data necessary to provide you with exceptional service,
Ensuring the confidentiality and security of your data, even when involving external service providers, and
Fully supporting your data protection rights.

These measures comply with applicable data protection laws in all countries where we operate, particularly the EU General Data Protection Regulation (GDPR) and the revised Swiss Federal Act on Data Protection (nLPD) of September 25, 2020. All terms follow the definitions outlined in Visorway’s Master Service Agreement (MSA), available at: Visorway.ai/legal.

Data Controller
The term “Visorway” or “we” refers to Appenzeller Ventures, registered in the commercial register of the Canton of Basel Land. The company is headquartered at Grienmattweg 7, 4410 Liestal, Switzerland. Visorway assumes responsibility for the data processing described in this privacy policy.

Contact Information for Our Data Protection Officer
For questions regarding the protection of your personal data or to exercise your rights (e.g., access, rectification, objection, deletion, restriction, portability, or posthumous data management), you can contact our Data Protection Officer:
Email: [email protected]
Mail: Visorway GmbH, Bleicherweg 10, 8002 Zürich, Switzerland

Implementation and Changes
This privacy policy automatically takes effect for all users on January 1, 2025. Visorway reserves the right to amend this privacy policy at any time. The latest version, governing how we use your data, is available at: Visorway.ai/legal. If significant changes are made, you will be informed via the email address provided during registration. Continued use of the platform or visits to our website after such changes will constitute acceptance of the updated terms.

1. What Data We Process and on What Legal Basis

We process your data to provide our services as defined in the MSA. The processing is based on your consent, our legitimate interest, or compliance with legal obligations.

Affected Group: Partners
We may process the following types of personal data about you:

Personal Information: Name, first name, phone number, email address, profile photo, preferred language.
Professional Information: Legal structure, VAT number, authorized company representatives, professional experience, resume, portfolio, project references, educational credentials, social media profiles.
Data Generated Through Platform Use: Emails and phone calls with our teams, cookies and browser data, transaction details, ratings and recommendations, communications via the integrated messenger, and information about completed projects.

Purpose(s)	Source	Category(ies)	Legal Basis	Retention Period
Verification of information provided by Visorway Approval for matching customer requests	Provided by partners	- Personal data - Professional information - Project details - Educational credentials	Performance of service agreement	Until account deletion and beyond, as required by legal retention obligations
Profile sharing with potential customers whose requirements match the partner's references and skills	Provided by partners	- Personal data - Professional information - Project details - Educational credentials - Customer ratings on Visorway platform	Performance of service agreement	Until account deletion and beyond, as required by legal retention obligations

Affected Group: Customers
We may process the following types of personal data about you:

Personal Information: Name, first name, email address, profile photo.
Professional Information: Company logo, industry, number of employees, billing and contact details, bank information.
Data Generated Through Platform Use: Emails and phone calls with our teams, cookies and browser data, transaction details, information about completed projects, ratings and recommendations, usage data of the integrated messenger (conversation content)

Purpose(s)	Source	Category(ies)	Legal Basis	Retention Period
Managing refunds and unpaid invoices	Generated through platform and provided by customer	- Personal data - Professional information - Project details	Performance of service agreement	Until account deletion or beyond in the case of legal disputes
Creation of consulting products on the platform	Provided by customer	- Current company challenges - Project details	Performance of service agreement	Until account deletion or beyond if legally required
Referral to partners	Provided by customer	- Personal data - Professional information - Company challenges - Project details	Performance of service agreement	Until account deletion or beyond if legally required

Affected Group: Users
*Reminder: User refer to partners and customers registered on the platform; the table below outlines data processing applicable to both partners and customers.

Purpose(s)	Source	Category(ies)	Legal Basis	Retention Period
General usage of services offered by Visorway	Provided by user and generated through platform usage	- Professional information - Project details	Performance of service agreement	Until account deletion or for 5 years after account inactivity
Providing project-related documents	Generated through platform usage	- Professional information - Project details	Performance of service agreement	Until account deletion or beyond, as legally required
Allowing feedback (ratings and comments) at the end of a project	Provided by user	- Project details	Performance of service agreement	Until account deletion or for 5 years after account inactivity
Sending relevant notifications directly related to platform services	Provided by user and generated through platform usage	- Personal data - Project details	Legitimate interest	Until account deletion, 5 years after inactivity, or upon objection
Notifying users of Visorway updates and events	Provided by user	- Personal data	Legitimate interest	Until account deletion, 5 years after inactivity, or upon objection
Support and dispute resolution via our support teams	Provided by user and generated through platform usage	- Personal and professional information - Messenger usage data - Transaction data	Legitimate interest	2 years
Providing a secure integrated messenger	Generated through platform usage	- Messenger usage data	Legitimate interest	Until account deletion or for 5 years after account inactivity
Service and feature improvements	Generated through platform usage	- Personal data - Professional information - Navigational data (anonymized where possible)	Legitimate interest and consent	Until account deletion or for 5 years after account inactivity
Participation in surveys (e.g., satisfaction and feedback, consulting studies)	Provided by user	- Personal data	Legitimate interest and consent	Duration of study or until objection
Recording sales team video conferences	Provided by user	- Personal data - Professional information	Legitimate interest	1 year
Reusing profile photos or event photos for internal and external promotional purposes	Provided by user	- Personal data	Consent	5 years or until withdrawal of consent
Recording Visorway Academy webinars	Provided by user	- Personal data	Legitimate interest	5 years or until objection
Responding to user requests to exercise their rights	Provided by user and generated through platform usage	All information processed as required by the user's request	Legal obligation	Until account deletion

Affected Group: Prospects and website visitors

Purpose(s)	Source	Category(ies)	Legal Basis	Retention Period
Notification about news and events at Visorway	Provided by the prospect or website visitor	Prospects	Consent	Until withdrawal of consent

2. The Use of AI at Visorway

Visorway's services rely on the use of advanced artificial intelligence (AI). Our AI technology is designed to create tailored solutions based on the data provided by customers.

How AI Works at Visorway:

Dedicated Assistants: Each customer is assigned an AI-powered assistant that analyzes the challenges shared by the customer and creates specific, AI-based solutions.
Matching with Partner Profiles: Our AI compares the analyzed information with the professional references and skills of Visorway's verified partners. Suitable partners are then recommended to the customer.
Customer Choice: The customer decides which partners to collaborate with and subsequently receives a prompt indicative offer.

Handling Customer Data in AI Use:

No Use for Training Purposes:
Customer data is exclusively used for providing services and is not utilized to train the underlying AI models.
Storage and Processing Locations:
o Company data is securely stored in Frankfurt, Germany.
o AI processing occurs in Gävle, Sweden.
Data Minimization and Purpose Limitation:
Visorway processes only the data necessary to deliver relevant outcomes and ensures that all data is used solely for its originally defined purposes.

Transparency and Accountability:

Decision-Making Explanation: We ensure that the results and recommendations provided by the AI are transparent and explainable. Customers can request additional information regarding AI-generated decisions.
Manual Review: Critical decisions or results generated by the AI can be reviewed and supplemented by human experts if necessary.

Security Measures for AI Data Processing:

Data Encryption: All data transmissions and storage locations are secured using advanced encryption technologies.
Access Rights: Data access is strictly limited to authorized personnel responsible for processing and managing the data.
Anonymization: Wherever possible, data is anonymized to further protect customer privacy.

With these measures, Visorway ensures the secure, transparent, and effective use of AI in delivering its services.

3. Our Cookie Policy

Like most online services, our website uses both first-party and third-party cookies for various purposes.

First-Party Cookies: These are typically essential for the website's functionality and do not collect personal data.
Third-Party Cookies: These cookies are primarily used to understand how the website functions, how you interact with it, maintain the security of our services, deliver relevant advertisements, and provide an overall improved user experience. Additionally, they help accelerate your future interactions with our website.

You can choose to accept, decline, or configure cookies during your initial login to the platform. You may also modify your preferences at any time by visiting the "Cookies" section on visorway.ai/legal.

A more detailed description of the cookies we use can also be found on this page.

4. Recipients of Data and Possible Transfers

Visorway is the recipient of the personal data collected through the platform and uses it exclusively for the purposes outlined above. Under no circumstances do we sell this information to third parties.

4.1 Transfers Between Users

We may share user information to:

Facilitate their interaction,
Provide business opportunities that align with the partners' skills and the customers' requirements, and
Enable the agreement of projects.

Certain clients may be located outside the EU. Some are based in countries covered by an adequacy decision of the European Commission. For other countries, measures have been taken in accordance with applicable data protection laws to ensure the transfer of data, such as the standard contractual clauses adopted by the European Commission.

4.2 Transfers Within Visorway

If a challenge cannot be matched with a suitable partner on the platform, Visorway may, upon the customer’s request, search for appropriate candidates outside the platform.

4.3 Transfers to Investors, Accountants, and Auditors

We may share user information to respond to information requests from our investors, accountants, and auditors, particularly in connection with potential capital fundraising or the verification of capital usage, in compliance with applicable regulations.

4.4 Transfers to Authorized Third Parties

We may retain or share your data if deemed necessary to:

Comply with legal or regulatory obligations,
Respond to requests from authorities or requirements in legal proceedings,
Protect the safety of an individual,
Address issues related to fraud, security, or technical matters, or
Protect the rights or property of our users.

4.5 Transfers to Trusted Partners and Service Providers

Data Storage Location:
All servers hosting your data are located in Europe.
In exceptional cases, some of our service providers, headquartered outside the EU, may need to transfer your data to their countries. In such instances, we ensure compliance with data protection obligations and implement tools such as standard contractual clauses to guarantee a level of data protection equivalent to that provided within the European Union.

Below is a list of Visorway’s partners and service providers, the purpose of their activities, the data storage location, and the applicable safeguards:

Service Provider	Purpose	Affected Individuals	Data Location
Microsoft Corp https://www.microsoft.com/privacy/privacystatement Contact: Privacy Support Requests	AI product generation from user inputs	Partners and customers	Sweden (EU)
Bubble.io https://bubble.io/privacy Contact: [email protected]	User interaction platform	Partners and customers	USA, signed Standard Contractual Clauses (SCC) and certified under the Data Privacy Framework (DPF)
Airtable https://www.airtable.com/company/privacy Contact: [email protected]	Data storage for inputs/outputs	Partners and customers	Germany (EU)
Loops https://loops.so/privacy Contact: [email protected]	Marketing, E-Mail	Partners and customers	USA, signed Standard Contractual Clauses (SCC) and certified under the Data Privacy Framework (DPF)
HubSpot https://legal.hubspot.com/privacy-policy	Marketing, E-Mail	Partners, customers, and prospects	USA, signed Standard Contractual Clauses (SCC) and certified under the Data Privacy Framework (DPF)

5. Data Security

Protecting the data of our users is a top priority for Visorway. We implement comprehensive technical and organizational measures to ensure the security, confidentiality, integrity, availability, and resilience of our information systems and your personal data. These measures safeguard the data we process against destruction, loss, alteration, disclosure, or unauthorized access.

Our Specific Security Measures Include:

Encryption Technologies: Most of our services are encrypted using SSL technology to ensure secure data transmission.
Account Verification: During account creation, we verify the user’s email address to ensure authenticity.
Regular Security Audits: Internal audits continuously review data collection, storage, processing, and physical security measures to prevent unauthorized access to our systems.
Strict Access Restrictions: Access to personal data is strictly limited to authorized employees and service providers who process the data in line with the principle of data minimization.

Commitments and Consequences:
All individuals with access to personal data are bound by strict confidentiality agreements. Violations of these agreements may result in disciplinary measures, including dismissal. With these measures, Visorway ensures that your data is always optimally protected.

6. Your Rights

Under applicable data protection laws, you have the following rights at Visorway.

6.1 Right of Access (Article 15 GDPR)

You have the right to access your personal data processed by Visorway. This includes:

Viewing stored data
Requesting a copy of the data

Third-party rights, whose personal data may be contained in your data, are respected.

6.2 Right to Rectification (Article 16 GDPR)

You can request the correction of your personal data if it is incorrect, incomplete, or outdated.

Changes can be made directly in your user account, where possible.
For further changes, you can contact us at [email protected].

6.3 Right to Deletion (Article 17 GDPR)

You have the right to request the immediate deletion of your personal data unless overriding legitimate interests or legal retention obligations exist.

To avoid unintended deletions, please send requests to [email protected].
Note that third parties, such as search engines, may retain publicly shared data for extended periods. Visorway is not responsible for such third-party processing.

6.4 Right to Restriction (Article 18 GDPR)

You can request the restriction of your data processing when:

You dispute the accuracy of your data (restriction during verification).
The processing is unlawful, but you oppose deletion.
Visorway no longer needs the data, but it is required to assert, exercise, or defend legal claims.
You have objected to processing, and a balancing of legitimate interests is underway.

If the restriction is lifted, we will notify you in advance.

6.5 Right to Object (Article 21 GDPR)

You may object to data processing if:

You provide reasons based on your specific situation, and
The processing is based on Visorway’s legitimate interest.

Visorway will cease processing unless there are compelling reasons that outweigh your interests or the data is required for legal claims.

Example: You can object to receiving marketing emails by using the unsubscribe link in our emails.

6.6 Right to Data Portability (Article 20 GDPR)

You can request your personal data in a machine-readable format. This includes data you provided or generated through your activity on the platform.

6.7 Right to Withdraw Consent (Article 7 GDPR)

If data processing is based on your consent, you may withdraw it at any time.

Withdrawal does not affect the lawfulness of processing conducted before the withdrawal.

These rights can be exercised through our data privacy center or by contacting our data protection team.

Privacy Policy