Welcome to Freename (the “Platform”), which is operated by Freename AG, Samstagernstrasse 41, Wollerau, Switzerland (hereinafter “freename” or “We”, “Us”, “Our”). We are committed to protecting and respecting your privacy.

By accessing or using our Platform, you acknowledge that you have read this policy and that you understand your rights in relation to the personal data you provide and how we will collect, use and process it. If you do not agree with this policy in general or any part of it, you should refrain from visiting our Platform. 

Our offer is subject to Federal Act on Data Protection and any applicable foreign data protection law, in particular General Data Protection Regulation of the European Union (EU) (hereinafter “GDPR”).

1. Data controller

Freename AG.

Samstagernstrasse 41
Wollerau
Switzerland

[email protected]

In some instances, there may be other persons responsible for the processing of personal data. In such a case, we inform you.

2. Processing of personal data

2.1. Terms

Personal data: all information that relates to an identified or identifiable person;

Data subject: natural or legal person whose data is processed;

Processing: any operation with personal data, irrespective of the means applied and the procedure, and in particular the collection, storage, use, revision, disclosure, archiving or destruction of data;

European Economic Area (EEA) comprises the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. 

2.2. Extent of personal data processing 

In principle, we process personal data of our users only to the extent necessary to provide a functional Platform and present our content. The processing of personal data of our users generally occurs only with the consent of the user. An exception applies to cases in which prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

2.3. Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (FATP) and the Ordinance to the Federal Act on Data Protection (OFATP).

We process personal data – if and insofar as GDPR is applicable – in accordance with at least one of the following legal bases:

• Art. 6 para. 1 letter b GDPR for the processing of personal data necessary for the performance of a contract with the data subject and for the implementation of precontractual measures.
• Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject outweigh the data subject. Legitimate interests are in particular our interest in being able to permanently provide our offer in a safe and reliable way and to advertise it user-friendly, to offer protection against misuse and unauthorized use and compliance with Swiss law.
• Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data for the fulfilment of a legal obligation to which we are subject according to any applicable law of member states of the European Economic Area (EEA).
• Art. 6 para. 1 letter e GDPR for the processing of personal data necessary for the performance of a task carried out in the public interest.
• Art. 6 para. 1 letter a GDPR for the processing of personal data with the consent of the data subject.
• Art. 6 para. 1 letter d GDPR for the processing of personal data necessary to protect vital interests of the data subject or of another natural person.

2.4 Type, scope and purpose

We process those personal data that are necessaryto provide our services in a permanent, user-friendly, secure and reliable manner. Such personal data can fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data.

We process personal data for the period of timerequired for the respective purpose or purposes or as required by law. Personal data whose processing is no longer required will be made anonymous or deleted. Persons whose data we process have a right to deletion.

In line of principle, we process personal data only with the consent of the data subject, unless the processing is permitted for other legal reasons. In this context, we process in particular information that a person concerned voluntarily and personallysubmits to us when contacting us – for example by letter post, e-mail, contact form, social media or telephone. We may store such information in an address book or with comparable tools. If you transmit personal data about third parties to us, you are obliged to guarantee data protection against such third parties and to ensure the accuracy of such personal data.

We also process personal data that we receive from third parties, obtain from publicly accessible sources or collect when providing our services, if and to the extent that such processing is permitted by law.

2.5 Processing of personal data by third parties, also abroad

We may have personal data processed by commissioned third parties or process it together with third parties or with the help of third parties or transfer it to third parties. Such third parties are in particular providers whose services we make use of. We also guarantee appropriate data protection for such third parties.

Such third parties are generally locatedin England and in the European Economic Area (EEA). However, such third parties may also be located in other states and territories, provided that their data protection law guarantees adequate data protection in the opinion of the Federal Data Protection and Information Commissioner (FDPIC) and – if and insofar as the GDPR is applicable – in the opinion of the European Commission, or if adequate data protection is guaranteed for other reasons, such as by a corresponding contractual agreement, in particular on the basis of standard contractual clauses, or by appropriate certification. Exceptionally, such a third party may be located in a country without adequate data protection, provided that the conditions under data protection law are met, such as the express consent of the data subject.

3. Rights of data subjects

Data subjects whose personal data we process have the rights granted by Swiss data protection law. This includes the right to information and the right to correct, delete or block the processed personal data.

Data subjects whose personal data we process may – if and to the extent that the GDPR is applicable – obtain free of charge confirmation as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data transferability, and have their personal data corrected, deleted, blocked or completed.

Data subjects whose personal data we process may – if and to the extent that the GDPR is applicable – revoke their consent at any time with effect for the future and object to the processing of their personal data at any time.

Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in England is the Federal Data Protection and Information Commissioner (FDPIC).

4. Data security

We take appropriate and suitable technical and organizational measures to ensure data protection and in particular data security. However, despite such measures, the processing of personal data on the internet can always have security gaps. We can therefore not guarantee absolute data security.

The access to our online offer is carried out by means of transport encryption (SSL /TLS, especially with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

Access to our online offer is subject – as basically all internet traffic – to mass surveillance without cause or suspicion and other monitoring by security authorities in England, in the European Union (EU), in the United States of America (USA) and in other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces and other security authorities.

5. Use of the Platform

5.1 Cookies

We may use cookies for our website. Cookies – both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) – are data that is stored in your browser. Such stored data does not need be limited to traditional cookies in text form. Cookies cannot execute programs or transmit malware such as Trojans and viruses.

When you visit our website, cookies can be stored temporarily in your browser as “session cookies” or for a certain period of time as so-called permanent cookies. “Session cookies” are automatically deleted when you close your browser. Permanent cookies have a certain storage period. In particular, they make it possible to recognize your browser the next time you visit our Platform and thus to measure the range of our Platform. Permanent cookies can also be used for online marketing purposes.

You can deactivate or delete cookies in your browser settings at any time, either in whole or in part. Without cookies, our website may no longer be fully available. We actively ask you – if and to the extent necessary – for your express consent to the use of cookies.

For cookies that are used to measure success and reach or for advertising, a general optout is possible for many services via the YourAdChoices (Digital Advertising Alliance), the Network Advertising Initiative (NAI), or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

5.2 Server log files

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (IP) address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-pages of our website called up including transferred data volume, last website called up in the same browser window.

We store such information, which may also represent personal data, in server log files. This information is required to provide our online services in a permanent, user-friendly and reliable manner and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.

6. Notifications and messages

We send notifications and communications, such as newsletters, by e-mail and through other communication channels such as instant messaging.

6.1 Measurement of success and range

Notifications and messages can contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and messages on a personalized basis. We need this statistical recording of usage to measure success and reach in order to provide notifications and messages in an effective, user-friendly, permanent, secure and reliable manner based on the needs and reading habits of the recipients.

6.2 Consent and objection

You expressly consent to the use of your e-mail address and other contact addresses when you submit this information to us. Use of your e-mail address and other contact addresses may also be permitted for other legal reasons. 

You can unsubscribe from notifications and communications such as newsletters at any time. However, we reserve the right to send you notifications and messages that are absolutely necessary for our offer. By unsubscribing, you may in particular object to the statistical recording of usage for the measurement of success and reach.

6.3 Service provider for notifications and messages

We send notifications and communications about third party services or with the help of service providers. Cookies may also be used in this process. We also guarantee appropriate data protection for such services.

7. Social media

We are present on social media platforms and other online platforms to communicate with interested people and to inform them about our offer. Personal data may also be processed outside England and the European Economic Area (EEA). The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such online platforms also apply in each case. These provisions provide information in particular about the rights of affected persons, which includes the right to information.

8. Success and reach metrics

8.1 Google Analytics

We use Google Analytics to analyze how our website is used, and we can also measure the reach of our website and the success of links from third parties to our website, for example. This is a service provided by  Google LLC, an American company. The Irish Google Ireland Limited is responsible for users in the European Economic Area (EEA) and England.

Google also tries to track individual visitors to our website when they use different browsers or devices (cross-device tracking). Cookies are also used for this purpose. Your Internet Protocol (IP) address is required for Google Analytics, but is not combined with other data from Google.

In any case, we will have your Internet Protocol (IP) address anonymized by Google before the analysis. As aresult, your complete IP address will not be transmitted to Google in the USA.

Further information on the type, scope and purpose of data processing can be found here:

• Our Privacy and Security Principle;
• Google privacy policy;
• Google product privacy guide;
• How Google uses information from sites or apps that use our services;
• How Google uses cookies.

You also have the following options:

• Deactivate Google Analytics with a browser add-on; 
• Object to personalized advertising.

8.2 ActiveCampaign

Our marketing automation application of choice is Active Campaign. This database system stores data of both individuals and companies. Personal data stored may contain name, job title, company name, e-mail address, phone number, website, and address. When a user accepts cookies, the website will also keeps track of pages visited by the user and will forward it to Active Campaign. This provides us a way to offer you personal and relevant content.We also send our newsletters and email campaigns via Active Campaign. We keep track of links clicked by individuals, to know which type of content gains the most attention.

You can find more information in the privacy policy of ActiveCampaign.

9. Services of third parties

We use third party services to provide our services in a stable, user-friendly, secure and reliable manner. Such services also serve to embed content into our website. Such services – such as hosting and storage services, video services and payment services – require your Internet Protocol (IP) address, otherwise such services cannot transmit the corresponding content. Such services may be located outside England and the European Economic Area (EEA), provided that adequate data protection is guaranteed.

For their own security, statistical and technical purposes, third parties whose services we use may also process data in connection with our offer and from other sources – including cookies, log files and counting pixels – in aggregated, anonymized or pseudonymized form.

All our payments are processed by Stripe or Coinbase Commerce. For more information, please see https://stripe.com/gb/privacy and https://commerce.coinbase.com/legal/privacy-policy/.

9.1 Digital Infrastructure

We use services of third parties in order to be able to make use of the digital infrastructure required for our services. These include in particular hosting and storage services from specialized providers. Such providers process – usually exclusively on our behalf – the data required to operate this infrastructure. This includes in particular your Internet Protocol (IP) address. We also guarantee appropriate data protection with such providers.

WordPress.com: Website construction kit; Provider: Automattic Inc. (USA) / Aut O’Mattic A8C Ireland Ltd. (Ireland) for users on the European mainland, among others; Information on data protection: Automattic’s Privacy Policy.

9.2 Entertainment

We use YouTube to embed videos into our website. Cookies are also used for this purpose. YouTube is a service of the Google LLC. Google Ireland Limited is responsible for users in the European Economic Area (EEA) and England.

Further information about the nature, extent and purpose of data processing can be found:

• Our Privacy and Security Principle;
• Google privacy policy;
• Google product privacy guide;
• How Google uses information from sites or apps that use our services;
• How Google uses cookies.

You also have the following option:

• Object to personalized advertising.

10. Final provisions

We may amend and supplement this privacy policy at any time. We will provide information about such adaptations and additions in a suitable form, in particular by publishing the respective current data protection declaration on our Platform.