EN — Privacy Policy – Essens Sàrl

1. Controller

2. Categories of data collected

We collect and process only the following data when you use our e-learning module:

• First and last name
• Email address
• Quiz and assessment results (score, dates taken, any certificates or attestations generated)
• Technical information related to your session (IP address, language preferences, browser version) to the extent necessary for service security and operation. These technical details will not be used to build intrusive profiles and will not be associated with you in an identifiable way outside the scope of the service.
  
  

3. Purposes of processing

• Provide and manage access to the e-learning module and learning progress tracking.
• Record and communicate your quiz results (for your training needs and access to attestations).
• Ensure service security, availability and performance (fraud prevention, detection of unauthorized access).
• Communicate about service updates, new learning content and information related to your account, where you have consented.
  
  

4. Legal basis for processing

• Performance of a contract: processing necessary to provide the e-learning module and manage your account.
• Legitimate interests: security, fraud prevention and service improvement.
• Consent: where specific purposes require it (e.g., sending marketing communications, if applicable and after explicit consent).
  
  

5. Storage and retention

Retention periods:

• Identification data (first/last name, email): as long as your account is active and for a retention period in line with legal obligations after termination (e.g., 5–10 years depending on internal and legal requirements).
• Quiz results: as long as your account is active and for a reasonable period after termination or inactivity to enable learning follow-up and verification of results.

Storage location: data are stored on infrastructure in Switzerland, or outside Switzerland only where necessary and under appropriate contractual safeguards (e.g., FADP-compliant clauses, DPA).

6. Consent statements and data subject rights

Consent: where required, you may withdraw your consent at any time (e.g., for marketing communications). Withdrawal will not affect the lawfulness of processing carried out before withdrawal.

Rights:

• Right of access: you may request which data concern you and obtain a copy.
• Right to rectification: you may correct inaccurate data.
• Right to erasure: you may request deletion of your data, subject to legal and contractual obligations.
• Right to restriction: you may request restriction of processing in certain cases.
• Right to portability: you may request transmission of your data in a structured, commonly used format.
  
  

How to exercise: send your request to stan@alloa.ch or to the dedicated contact indicated in your ToU.

7. Data sharing and transfers

• Sharing: your data will not be sold to third parties. They may be accessible to providers operating the platform (hosting, maintenance) under confidentiality and security obligations.

• International transfers: if data are transferred outside Switzerland, they will be protected by appropriate safeguards (standard contractual clauses, BCR or equivalent measures) in accordance with the FADP and, where applicable, the GDPR.

8. Security

• Technical and organizational measures: encrypted communications (TLS), secure credential management (hashed passwords), regular backups, strict access control, access logging and detection of abnormal activity.

• Confidentiality obligation: authorized persons processing your data are bound by confidentiality and security duties.

9) Cookies and similar technologies

• A separate Cookie Policy explains essential cookies and those requiring your consent, as well as cookie-management options. For personal data, cookies will not be used to profile you without explicit consent.

10) Legal obligations and archiving

• FADP compliance: we comply with Swiss requirements for personal data protection.

• Archiving and legal obligations: some data may be retained under legal or contractual obligations even after account deletion, where necessary for tax, security or compliance reasons.

11) Right to lodge a complaint

• If you believe your rights regarding the processing of your personal data are not respected, you may lodge a complaint with the competent Swiss data protection authority (e.g., the Federal Data Protection and Information Commissioner, FDPIC) or the competent cantonal authority.

12) Changes to this policy

• We may amend this Privacy Policy from time to time. Any changes will be published on the Platform and, where necessary, you will be informed through the usual channels.

13) Contact

• For any questions regarding this Privacy Policy or data protection, contact: stan@alloa.ch