Privacy policy

This Privacy Policy (“Statement”) describes how MindMetrix AG (“we”, “us” or “our”) collects, uses and discloses information about your use of our products and of this website, www.mindmetrix.ch. You should not use our services if you do not agree with this Privacy Policy.

This Privacy Policy applies to all our Services, including your use of our products, worldwide.

By using our services, you expressly agree that your personal data provided directly or collected through your use of our services, including our products, may be processed in accordance with this Privacy Policy and may be stored in Switzerland or another country of the European Economic Area.

MindMetrix AG is a company registered under Swiss law and subject to Swiss data protection regulations, such as the Swiss Federal Data Protection Act (“DPA”). As an internationally active company, the EU General Data Protection Regulation (“GDPR”) is also relevant. In this Privacy Policy, “process” or “processing” and “personal information” are used synonymously with “edit” or “editing” and “personal data”.

We are the controller within the meaning of the DPA/GDPR, which determines the purposes and means of processing personal data. This Privacy Policy does not apply to individuals if our client uses our services with an agreement regarding the use of our products and personal data processing; the client controls collected data and their privacy policy applies.

This website

The numbered sections below describe our products. This section describes this website, which works differently and collects far less.

Cookies and analytics. We use Google Analytics 4, a service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), to understand how this website is used: which pages are read, how visitors find us, and whether the contact and application forms are sent. Google processes this data on our behalf. On your first visit we ask whether you allow analytics cookies. The analytics option is ticked when the question appears; you can untick it, or choose “Reject all cookies”, before you continue.

• If you allow them, Google Analytics stores two cookies, _ga and _ga_<ID>, for up to two years, so that it recognises your browser on later visits.
• If you do not, nothing is stored on your device. Google Analytics still receives a signal for each page you view and each form you send, with the page address, the time, your browser and device type, and your IP address. The signal carries no identifier and cannot be linked to your other visits; Google uses your IP address only to estimate your country and region and does not store it.

Google may process this data in the United States; Google LLC is certified under the Swiss-U.S. and EU-U.S. Data Privacy Frameworks. We keep analytics data for 14 months, and Google’s advertising features and data sharing are switched off. Analytics cookies are set only with your consent; the cookieless signals rely on our legitimate interest in knowing how our website is used. You can change your choice at any time under “Cookie preferences” at the bottom of every page; withdrawing your consent deletes the analytics cookies.

Storage on your device. We store one thing in your browser: your cookie choice, for one year. When you switch language, your browser also notes how far down the page you were, so that the translated page opens at the same place; that note is gone when you close the tab. Both stay on your device, are never sent to us, and can be removed at any time through your browser settings.

Server logs. Our hosting provider records standard access data, as described in Section 1: the date and time, the file requested, the amount of data transferred, your browser and its language, and your IP address.

Embedded services. The typefaces, the software libraries that render the pages and the three-dimensional graphics are all served from our own domain, so loading them tells no third party about your visit. Three exceptions remain:

• Google Analytics — on every page, as described under “Cookies and analytics” above.
• OpenStreetMap — the map, on the contact page only. When your browser loads it, it sends your IP address to the OpenStreetMap Foundation, which is unavoidable for any embedded map. We set no cookies through it and receive no reporting back from it.
• Photon — address suggestions, on the job application form only, as described under “Address suggestions” below.

No advertising. This website carries no advertising and no tracking pixels. We do not profile visitors, and we do not share anything about your visit with advertisers.

Contact form. If you write to us through the form, we receive your name, your email address, your message and the language of the page you wrote from. The form delivers them by email to contact@mindmetrix.ch; the website itself keeps no copy. We use them to answer you, as described in Section 2. The same applies if you write to us by email.

Job applications. If you apply through the application form, we receive your first name and surname, your email address and telephone number, your town and country, your street address if you give it, the position you apply for, and the résumé and cover letter you upload. Your browser packs the documents into one file, and the form delivers everything by email to job@mindmetrix.ch; an application that is not for an advertised position also goes to contact@mindmetrix.ch. The website itself keeps no copy. These mailboxes are part of our Microsoft 365 environment, which Microsoft operates on our behalf. We use your application only to assess you for the position, or for other suitable openings if you applied without naming one, and only the people involved in hiring at MindMetrix read it.

Address suggestions. When you type your street or town into the application form, your browser sends what you have typed (from the third character of a street, the second of a town) to Photon, an address search service run by komoot GmbH, Germany, and built on OpenStreetMap data, and shows you the addresses it finds. Because your browser contacts Photon directly, komoot also receives your IP address. Nothing else about you is sent, and no cookies are set through it.

Protection against misuse. Before either form is sent, your browser solves a small computing puzzle that keeps automated spam out. The puzzle comes from our own domain, sets no cookies and involves no third party. To limit how many messages one sender can submit, our server holds the sender’s IP address in working memory only, counting submissions over ten minutes; it is not written to any database. When you enter your email address in the application form, our server checks that its domain, the part after the @, can receive mail; your address itself is not passed on for this.

1. What types of personal data do we collect?

We collect information and personal data directly from you, from third party devices and services you connect to, and automatically through your use of our products.

When you create a profile to use our products, we collect information and personal data you provide, including your name and email address, plus any additional information you choose to add to your profile. If you process personal data of others, it is your responsibility to ensure compliance with applicable data protection laws.

When you access our website, data automatically stored by our server is collected, including the date and time of access, the name of the file accessed, amount of data transferred and access time, your web browser, browser language and requesting domain, as well as your IP address. Further data is only collected via our website if you provide this information voluntarily, for example as part of a registration or request.

2. Communication

If you contact us directly, we will receive the content of your message or any attachments you send to us, as well as any additional information you choose to provide.

3. For what purposes do we process personal data?

We process your information, including your personal data, for the following purposes:

1. When you create a profile to use our products, you provide us with your personal information as described in Section 1.
2. To enable you to access our products, to communicate with you about your use of them, to respond to your inquiries and for other customer service purposes.
3. When you use our products, we process the personal data submitted to us through your use, including but not limited to pupil data (as further described in the Terms of Use or a contract).
4. To research and develop new products and features, as permitted by law and, if necessary, with your consent.
5. For marketing, promotional and informational purposes, to the extent permitted by law and, if necessary, with your consent. For example, we may use your information, such as your email address, to send you news and newsletters, special offers and promotions, or to otherwise inform you about products or information that we think may interest you. We may also use the information we learn about you to promote our services on third party websites. You may opt out of receiving these emails at any time.
6. To better understand how users access and use our products, both on an aggregate and individual basis, to improve them and respond to user requests and preferences, and for other analytical purposes.
7. To personalize the content and information we send or display to you, to provide personalized help and instructions, and to otherwise personalize your experience when using our products.
8. To comply with legal and regulatory obligations and responsibilities, as part of our general business operations and for other business administration purposes.
9. When we deem it necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Policy.

4. On what legal basis and for what purposes do we process personal data?

Depending on the purpose of the processing activity, the processing of your information and personal data will take one of the following forms:

1. Necessary for MindMetrix AG’s legitimate interests without unreasonably prejudicing your interests or fundamental rights and freedoms (see below);
2. Necessary for the formation or performance of a contract with you for the services or products you have requested or for the performance of our obligations under such contract, for example, where we use your data for some of the purposes set out in Sections 3(1) to 3(3) above (as well as for some of the data sharing described in Section 5);
3. Necessary to comply with our legal or regulatory obligations, including carrying out checks to identify you and disclosing information to authorities, regulators and government bodies, for the purposes set out in Sections 5(5) and 5(6);
4. In some cases, necessary for the performance of a task in the public interest;
5. Where we use special categories of personal data necessary for the establishment, exercise or defense of legal claims, or where the processing relates to personal data that are manifestly in the public domain; and
6. Processed with your consent, which we may obtain from you from time to time (for example, when required by law), or processed with your explicit consent, which may be necessary where special categories of personal data are involved.

Examples of “legitimate interests”:

1. The pursuit of certain purposes of Sections 3(5) to 3(7);
2. Exercising our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our entrepreneurial freedom and right to property;
3. When making the disclosures set forth in Section 5 below, providing products and services, and ensuring a consistently high standard of service and satisfaction of our customers, employees and other stakeholders; and
4. Meeting our accountability and legal requirements around the world,

…unless your interests in privacy outweigh these interests.

5. Who has access to personal data and with whom is it shared?

We may share your information, including personal information, as follows:

1. Aggregated and anonymized information. We may use aggregated or anonymized information so that it cannot be used to identify an individual to perform various types of analyses, such as improving our products and services or other similar analyses.
2. Service providers. We may share your information with third-party vendors, service providers, contractors or agents who perform service functions we need to operate our business, such as providers of hosting, email communications, customer services, analytics, marketing and advertising, based on our instructions and in accordance with this Statement and other appropriate confidentiality and security measures.
3. Business transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will notify affected users before transferring personal information to a new company.
4. In response to legal process. We may disclose information we collect from you to comply with the law, a court proceeding, a court order, or other legal process, such as in response to a court order or subpoena.
5. In response to regulatory or legal obligations. As required from time to time, we may disclose personal information to public and judicial authorities, regulatory agencies or governmental bodies and in proceedings, including as required by law or regulation or by such authorities or bodies.
6. To protect ourselves and others. We may disclose information we collect from you if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Statement, or as evidence in any legal proceeding involving MindMetrix AG.
7. Third party analytics tools. We use automated devices and applications, such as Google Analytics, to evaluate the use of our Service. We may also use other analytics tools to evaluate our websites. We use these tools to improve our products, their performance and the user experience.

6. International transfer of personal data

The recipients mentioned in Section 5 above may be located outside of Switzerland. In such cases, except where the country in question has been determined by the EU or Switzerland to provide an adequate level of protection, MindMetrix AG will implement appropriate safeguards to ensure that any such transfer is in compliance with applicable data protection laws.

You may request additional information in this regard and obtain a copy of the appropriate safeguards by contacting us at the address provided at the end of this notice. When MindMetrix AG transfers personal data to service providers in countries that do not provide an adequate level of protection, we rely on standard contractual clauses approved by the European Commission or Switzerland.

7. How long do we store your data for?

We will retain your information, including personal data, only as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal requirements. To this end, we apply criteria to determine the appropriate time periods to retain your personal information based on its purpose, such as proper recordkeeping, facilitating the management of customer relationships, and responding to legal claims or regulatory inquiries.

8. Cookies

This section describes cookies in our products. The cookies of this website are described above.

Cookies are small text files that are stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. In addition to improving the user experience, we also use cookies and similar technologies for analytics and advertising purposes. You can manage your cookies locally by adjusting your browser settings, or you can opt out of targeted advertising through cookies by visiting networkadvertising.org/choices or aboutads.info/choices. Because there is not yet a common understanding of how to interpret “Do Not Track” signals, we cannot respond to “Do Not Track” requests from browsers. However, we are monitoring for updates and will revise this statement once a common standard is established.

9. Links from third parties

Our Service may contain links to third party websites. Access to and use of such linked websites is not governed by this Privacy Policy, but by the privacy policies of such third party websites. We are not responsible for the information practices of such third party websites.

10. Security of my personal data

We have taken reasonable precautions to protect the information we collect from loss, misuse and unauthorized access, disclosure, alteration and destruction. Please note that despite our best efforts, no data security measures can guarantee security.

We are not responsible for lost, stolen or compromised passwords or for any activity on your account due to unauthorized password activity.

11. Access to, storage of and deletion of personal information

You can access and change the personal data you have entered by going to your profile and updating your profile information. Your personal information is stored and accessible on your device and in the cloud.

We store the information associated with your account until your account is deleted. You may delete your account at any time by contacting support@mindmetrix.ch. Please note that deleting your account information may take some time and we may retain it for legal or damage prevention reasons, as described in the sharing section above.

12. Users under 18 years

Our services are not intended for users under the age of 18. If we discover that a user under the age of 18 has provided us with personal information, we will delete that information from our systems.

13. Your rights

13.1 What rights do I have?

Individuals located in Switzerland or the European Economic Area (EEA) have certain rights with respect to their personal information. MindMetrix AG offers all of our worldwide users the opportunity to exercise these rights, including:

1. The right to access your personal data;
2. The right to correct or rectify inaccurate personal data;
3. The right to restrict or object to the processing of personal data;
4. The right to erase your personal data; and
5. The right to portability of personal data.

This Privacy Policy does not apply to individuals if our customer uses our services and there is an agreement between our customer and the individual regarding the use of our services or products and the processing of personal data relating to that individual; in such a case, the customer controls the data collected and the customer’s privacy policy, rather than this Privacy Policy, applies.

13.2 How can I exercise my individual rights?

Users of our services or products whose data is covered by this Privacy Policy may access and update their personal data worldwide as follows: they may exercise their rights to data erasure and data portability by contacting MindMetrix AG’s Privacy Officer at support@mindmetrix.ch.

Please note that MindMetrix AG may request additional information from you to verify your identity before we disclose any personal or account information.

14. Contact

If you have any questions about our privacy practices, please contact us at support@mindmetrix.ch or at the following address:

MindMetrix AG
Campus Biotech
Chemin des Mines 9
1202 Genève
Switzerland

If you, as a customer, are unable to contact MindMetrix AG using the contact information provided above, you have the right to contact your local data protection authority.

15. Changes to this declaration

This statement is effective as of the effective date indicated above. We may change this Statement from time to time, so you should review it periodically. We will post any changes to this Statement. If we make any changes to this Statement that materially affect our practices with respect to the personal information we have previously collected from you, we will endeavor to notify you in advance of any such change.

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