Privacy Policy

1. Introduction

At eProfiler Solutions AG ("eProfiler," "we," "us," or "our"), we are committed to protecting your privacy and handling your personal data with transparency and care. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, use our bioelectronic sensing platforms and services, or interact with us.

This Privacy Policy is designed to comply with:

  • The General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679

  • The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

  • The Swiss Federal Act on Data Protection (FADP)

  • Other applicable data protection laws

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller Information

Data Controller:
eProfiler Solutions AG
[Company Address]
Switzerland

Data Protection Officer (DPO):
Email: privacy@eprofiler.com

If you have any questions about this Privacy Policy or our data practices, please contact our DPO using the details above.

3. Personal Data We Collect

3.1 Categories of Personal Data

We collect and process the following categories of personal data:

3.1.1 Identity and Contact Data

  • Full name

  • Job title and organization

  • Professional contact information (email address, phone number, postal address)

  • Account login credentials (username, encrypted password)

3.1.2 Technical and Usage Data

  • IP address and device identifiers

  • Browser type, version, and language

  • Operating system and platform

  • Time zone setting and location data

  • Pages visited and navigation patterns

  • Referral source and exit pages

  • Date and time of visits

  • Device information (hardware model, unique device identifiers)

3.1.3 Research and Scientific Data

  • Research institution affiliation

  • Scientific research data (where applicable and with consent)

  • Equipment usage logs and performance data

  • Calibration and maintenance records

  • Study protocols and experimental parameters (anonymized where possible)

3.1.4 Communication Data

  • Correspondence records (emails, chat logs, support tickets)

  • Meeting notes and call recordings (with prior notice)

  • Feedback and survey responses

  • Marketing preferences and consent records

3.1.5 Transaction and Financial Data

  • Billing address and payment information (processed via secure third-party processors)

  • Purchase history and service usage records

  • Contract and agreement details

3.2 Special Categories of Data

We do not generally collect special categories of personal data as defined under GDPR Article 9 (such as health data, biometric data, or genetic data). However, if our bioelectronic research services involve processing such data on your behalf, we will only do so:

  • With your explicit consent

  • Under a valid data processing agreement

  • With appropriate technical and organizational safeguards in place

3.3 Children's Data

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@eprofiler.com.

4. How We Collect Your Personal Data

4.1 Direct Collection

We collect personal data directly from you when you:

  • Create an account or register for our Services

  • Fill out forms on our Website

  • Subscribe to newsletters or marketing communications

  • Contact our support or sales teams

  • Participate in surveys, research studies, or events

  • Submit feedback or request information

4.2 Automated Collection

We automatically collect certain data through:

  • Cookies and similar technologies (see our Cookies Policy for details)

  • Server logs recording your interactions with our Website

  • Analytics tools (e.g., Google Analytics) tracking usage patterns

  • Device information transmitted by your browser or device

4.3 Third-Party Sources

We may receive personal data from:

  • Your employer or research institution (with proper authorization)

  • Business partners and distributors

  • Publicly available sources (professional directories, scientific publications)

  • Referral programs

Under the GDPR, we process your personal data based on the following legal grounds:

| Purpose | Legal Basis | | --- | --- | | Providing our Services and fulfilling contracts | Performance of a contract (Article 6(1)(b)) | | Complying with legal obligations | Legal obligation (Article 6(1)(c)) | | Marketing communications (with consent) | Consent (Article 6(1)(a)) | | Improving our Services and Website | Legitimate interests (Article 6(1)(f)) | | Fraud prevention and security | Legitimate interests (Article 6(1)(f)) | | Research and development (anonymized data) | Legitimate interests (Article 6(1)(f)) |

Our legitimate interests include:

  • Maintaining and improving the quality of our Services

  • Ensuring network and information security

  • Conducting scientific research to advance bioelectronic technology

  • Marketing our products to existing customers

Where we rely on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6. How We Use Your Personal Data

6.1 Primary Purposes

We use your personal data for the following purposes:

Service Provision:

  • Creating and managing your account

  • Providing access to our bioelectronic sensing platforms and tools

  • Processing transactions and delivering purchased services

  • Providing customer and technical support

  • Sending service-related notifications and updates

Research and Development:

  • Improving our bioelectronic technologies and algorithms

  • Conducting scientific research and data analysis (with anonymization)

  • Developing new products and features

  • Quality assurance and testing

Communication:

  • Responding to inquiries and support requests

  • Sending administrative information

  • Providing information about products, services, and events (with consent)

  • Conducting customer satisfaction surveys

Security and Compliance:

  • Protecting against fraud, unauthorized access, and security threats

  • Complying with legal and regulatory obligations

  • Enforcing our Terms and Conditions

  • Establishing, exercising, or defending legal claims

6.2 Marketing Communications

With your consent (where required by law), we may use your contact information to send you:

  • Newsletters and industry updates

  • Information about new products, features, or services

  • Invitations to webinars, conferences, and events

  • Scientific publications and research findings

You can opt-out of marketing communications at any time by:

  • Clicking the "unsubscribe" link in our emails

  • Updating your preferences in your account settings

  • Contacting us at privacy@eprofiler.com

7. Data Sharing and Recipients

7.1 Categories of Recipients

We may share your personal data with:

Service Providers and Processors:

  • Cloud hosting providers (e.g., AWS, Azure)

  • Customer relationship management platforms

  • Payment processors

  • Analytics providers

  • Email and communication service providers

  • IT support and maintenance providers

All processors are bound by data processing agreements requiring them to process data only on our instructions and maintain appropriate security measures.

Professional Advisers:

  • Legal counsel

  • Accountants and auditors

  • Insurance providers

  • Consultants

Business Partners:

  • Authorized distributors and resellers

  • Research collaboration partners (with appropriate agreements)

  • Scientific institutions (for joint research projects)

Legal and Regulatory Authorities:

  • Courts, tribunals, and regulatory bodies

  • Law enforcement agencies (when legally required)

  • Government authorities (for compliance with applicable laws)

7.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your personal data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.

7.3 No Sale of Personal Data

We do not sell your personal data to third parties for monetary consideration. Under the CCPA, certain transfers may be considered "sales" or "sharing" for cross-context behavioral advertising. We do not engage in such practices without your consent.

8. International Data Transfers

8.1 Transfer Mechanisms

As a Swiss company with global operations, your personal data may be transferred to and processed in countries outside your jurisdiction, including:

  • Switzerland (our headquarters)

  • European Economic Area (EEA) countries

  • United States (for cloud hosting and service providers)

  • Other countries where our service providers operate

When transferring personal data outside the EEA or Switzerland, we ensure appropriate safeguards are in place:

For EU/EEA data:

  • Standard Contractual Clauses (SCCs) approved by the European Commission

  • Adequacy decisions (for countries recognized as providing adequate protection)

  • Binding Corporate Rules (where applicable)

For Swiss data:

  • Swiss Federal Act on Data Protection requirements

  • Adequacy assessments for recipient countries

8.2 Transparency

You can request a copy of the safeguards we use for international transfers by contacting us at privacy@eprofiler.com.

9. Data Retention

9.1 Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

| Data Category | Retention Period | | --- | --- | | Account and contact data | Duration of account + 3 years after closure | | Transaction records | 10 years (legal requirement) | | Communication records | 3 years from last contact | | Website logs and analytics | 26 months | | Marketing consent records | Duration of consent + 2 years | | Scientific research data | As specified in research agreements |

9.2 Retention Criteria

Retention periods may be extended where necessary to:

  • Comply with legal, accounting, or reporting requirements

  • Establish, exercise, or defend legal claims

  • Maintain scientific research integrity and reproducibility

  • Protect against fraud or security threats

9.3 Secure Deletion

When personal data is no longer required, we securely delete or anonymize it in accordance with our data retention policies.

10. Your Data Protection Rights

Depending on your location, you have the following rights regarding your personal data:

10.1 GDPR Rights (EU/EEA/UK Residents)

Right to Access (Article 15):
You have the right to request a copy of the personal data we hold about you and information about how we process it.

Right to Rectification (Article 16):
You have the right to request correction of inaccurate or incomplete personal data.

Right to Erasure / "Right to be Forgotten" (Article 17):
You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

Right to Restrict Processing (Article 18):
You have the right to request that we limit the processing of your personal data in certain circumstances.

Right to Data Portability (Article 20):
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

Right to Object (Article 21):
You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent (Article 7):
Where we rely on consent, you have the right to withdraw consent at any time.

Right to Lodge a Complaint (Article 77):
You have the right to complain to a data protection authority if you believe we have violated your rights.

10.2 CCPA/CPRA Rights (California Residents)

If you are a California resident, you have the following rights:

Right to Know:
You have the right to request disclosure of:

  • Categories of personal information we collect

  • Categories of sources from which personal information is collected

  • Business or commercial purposes for collecting personal information

  • Categories of third parties with whom we share personal information

  • Specific pieces of personal information we hold about you

Right to Delete:
You have the right to request deletion of your personal information, subject to certain exceptions.

Right to Correct:
You have the right to request correction of inaccurate personal information.

Right to Opt-Out of Sale/Sharing:
While we do not sell personal information, you have the right to opt-out of any future sale or sharing for cross-context behavioral advertising.

Right to Limit Use of Sensitive Personal Information:
You have the right to limit our use and disclosure of sensitive personal information.

Right to Non-Discrimination:
We will not discriminate against you for exercising your privacy rights.

10.3 How to Exercise Your Rights

To exercise any of your rights, please contact us:

We will respond to your request within:

  • GDPR: 30 days (extendable to 60 days for complex requests)

  • CCPA: 45 days (extendable by 45 days with notice)

10.4 Verification

To protect your privacy, we will verify your identity before processing your request. We may request:

  • Government-issued identification

  • Account credentials

  • Other information to confirm your identity

10.5 Authorized Agents

You may designate an authorized agent to make requests on your behalf. The agent must provide written authorization signed by you.

11. CCPA-Specific Disclosures

11.1 Categories of Personal Information Collected (Past 12 Months)

| Category (Cal. Civ. Code § 1798.140) | Collected? | Source | Purpose | | --- | --- | --- | --- | | Identifiers (A) | Yes | Direct, automated | Service provision, communication | | Personal records (B) | Yes | Direct | Contract fulfillment | | Protected characteristics (C) | No | - | - | | Commercial information (D) | Yes | Direct | Transaction processing | | Biometric information (E) | No | - | - | | Internet activity (F) | Yes | Automated | Analytics, security | | Geolocation data (G) | Limited | Automated | Security, localization | | Audio/visual data (H) | Limited | Direct | Support calls (with notice) | | Professional information (I) | Yes | Direct, third parties | Service provision | | Non-public education (J) | No | - | - | | Inferences (K) | Yes | Automated | Service improvement |

11.2 Disclosure for Business Purposes

We disclose personal information to the following categories of service providers for business purposes:

  • Cloud storage providers

  • Analytics providers

  • Customer support platforms

  • Payment processors

  • Marketing platforms

11.3 Financial Incentive Programs

We do not currently offer financial incentive programs that require the collection of personal information.

12. Data Security

12.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

Technical Measures:

  • Encryption in transit (TLS 1.3) and at rest (AES-256)

  • Multi-factor authentication for systems access

  • Regular security assessments and penetration testing

  • Intrusion detection and prevention systems

  • Secure development practices

  • Regular security patching and updates

Organizational Measures:

  • Role-based access controls

  • Employee training on data protection

  • Confidentiality agreements with staff and contractors

  • Incident response procedures

  • Business continuity and disaster recovery plans

12.2 Breach Notification

In the event of a personal data breach, we will:

  • Notify the relevant supervisory authority within 72 hours (GDPR)

  • Notify affected individuals without undue delay when the breach poses a high risk

  • Cooperate fully with regulatory investigations

12.3 No Absolute Security

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

13. Cookies and Tracking Technologies

For detailed information about the cookies and similar technologies we use, including:

  • Types of cookies

  • Purposes of cookies

  • Cookie duration

  • How to manage cookie preferences

Please see our Cookies Policy.

14. Automated Decision-Making and Profiling

We do not currently engage in automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.

If we implement such processing in the future, we will:

  • Provide meaningful information about the logic involved

  • Explain the significance and envisaged consequences

  • Implement appropriate safeguards

  • Obtain explicit consent where required

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • Changes in our data practices

  • Changes in applicable laws and regulations

  • New products or services

  • Security enhancements

We will notify you of material changes by:

  • Posting the updated Privacy Policy on our Website

  • Updating the "Last Updated" date at the top of this page

  • Sending an email notification (for registered users)

For significant changes, we will provide at least 30 days' notice before the changes take effect.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Data Protection Officer:
Email: privacy@eprofiler.com
Address: [Company Address], Switzerland

General Inquiries:
Email: info@eprofiler.com
Phone: [Phone Number]

17. Data Protection Authorities

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with a data protection authority:

For EU/EEA residents:
Contact the supervisory authority in your country of residence or place of work.

For Swiss residents:
Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
CH-3003 Bern
Switzerland
Website: https://www.edoeb.admin.ch

For UK residents:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
United Kingdom