Privacy policy
1. Responsible Entity
The responsible entity for the processing of personal data within the meaning of the Swiss Federal Act on Data Protection (revFADP) and, where applicable, the EU General Data Protection Regulation (GDPR) is:
Start-Unfolding.com
Owner: Fabienne Meyenhofer
Rüschlikon, Schweiz
E-Mail: fabienne@start-unfolding.com
2. Scope of this Privacy Policy
This Privacy Policy governs the processing of personal data in connection with the use of the website www.start-unfolding.com, the booking and delivery of online courses and coaching services, communication by e-mail, participation in video calls via Zoom, interactions on social media platforms (including Instagram, Facebook and LinkedIn), as well as the use of analytics, marketing and payment tools.
This Privacy Policy is primarily based on Swiss data protection law (revFADP) and additionally considers the requirements of the GDPR for users located in the European Union.
3. Legal Basis for Processing of Personal Data
Personal data is processed on the basis of applicable statutory legal grounds. Depending on the specific context, processing is carried out for the performance of a contract or pre-contractual measures, on the basis of consent, to comply with legal obligations, or based on legitimate interests. Legitimate interests include, in particular, ensuring the security, stability, functionality and optimization of our services.Where processing is based on consent, such consent may be withdrawn at any time with effect for the future.
Personal data is processed only to the extent necessary to ensure the operation and security of the website, to provide and deliver services and digital products, to process payments, to communicate with clients and interested parties, to analyze usage behavior, to carry out marketing activities, and to manage user accounts, course participation and progress. Processing is carried out lawfully, proportionately and for clearly defined purposes.
4. Website Hosting
The website is hosted by Wix.com Ltd., which acts as a data processor on our behalf. In the course of providing hosting and infrastructure services, Wix processes technical and usage-related data such as IP addresses, browser and device information, log files, access times and website interactions.
Data may be processed in Israel, the European Union or the United States. Where personal data is transferred to third countries, Wix relies on appropriate safeguards, in particular Standard Contractual Clauses approved by the European Commission, to ensure an adequate level of data protection in accordance with applicable data protection laws.
The processing of personal data by Wix is limited to what is technically necessary for the operation, security and performance of the website.
5. Cookies and Consent Management
This website uses cookies and similar technologies to ensure the proper functioning, security and optimization of the website. Cookies are small text files that are stored on a user’s device and enable the recognition of the browser, the saving of preferences and the analysis of website usage.
Visitors are informed about the use of cookies via a cookie banner and can actively decide which categories of cookies they wish to allow. Essential cookies are required for the technical operation of the website, including security-related functions and basic website features.
Analytics cookies are used to understand how visitors interact with the website and to improve content and performance. Marketing cookies are used to display relevant advertising and to measure the effectiveness of marketing campaigns. Analytics and marketing cookies are used only with prior consent where required by law.
Users may withdraw or adjust their consent at any time via the cookie settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
6. Analytics and Marketing Tools
Google Analytics is used to analyze the use of the website and to improve its content and functionality. In this context, information such as anonymized IP addresses, technical browser data, approximate location data and interaction patterns may be processed. For users located in the European Union, processing is based on consent.
Users have several options to control or limit the processing of their data in connection with Google Analytics. In particular, users may prevent the storage of cookies by adjusting their browser settings, withdraw consent via the cookie settings at any time, or use browser add-ons provided by Google to disable Google Analytics tracking.
For advertising and campaign optimization purposes, Meta Pixel and Facebook Ads Manager are used. These tools may process information such as IP addresses, device data, browsing behavior and interactions with advertisements. Meta may process data outside the European Union, in particular in the United States, based on appropriate safeguards including Standard Contractual Clauses.
Users may object to or restrict data processing for marketing purposes at any time by adjusting their cookie preferences or by using available opt-out options provided by Meta.
Processing for analytics and marketing purposes takes place only with prior consent where required by applicable law.
7. Online Courses, Checkout and E-Mail Marketing
Online courses, digital content, user accounts, checkouts and e-mail communication are provided via Kajabi, a service of Kajabi, LLC, based in the United States. Kajabi acts as a data processor on our behalf within the meaning of applicable data protection laws.
Kajabi is used to host course content, manage user registrations and accounts, process checkouts, deliver digital products, track course progress and facilitate e-mail communication related to courses and services.
In this context, personal data such as names, e-mail addresses, IP addresses, payment-related information, login credentials, course progress, interaction data and technical usage data may be processed.
Kajabi’s servers are located in the United States. Where personal data is transferred to the United States, such transfers are carried out on the basis of Standard Contractual Clauses to ensure an adequate level of data protection.
Kajabi processes personal data exclusively in accordance with our instructions and applicable data protection agreements.
Marketing e-mails are sent only with prior consent or within the scope of an existing customer relationship where legally permitted. Users may unsubscribe at any time via the link included in each e-mail or by contacting us directly.
8. Video Conferencing
Coaching sessions and online meetings are conducted using Zoom, a service provided by Zoom Video Communications, Inc., based in the United States. Zoom is used for the purpose of conducting virtual coaching sessions, consultations and meetings. Unless otherwise agreed, video calls are recorded and made available to the respective clients so they can review and continue to use the content for their own purposes.
Depending on the use, Zoom may process personal data such as names, e-mail addresses, IP addresses, meeting metadata (including date, duration and participants), device and technical information, as well as audio and video data transmitted during sessions.
Zoom acts as a data processor on our behalf. Where personal data is transferred to the United States or other third countries, such transfers are carried out on the basis of Standard Contractual Clauses and additional technical and organizational safeguards.
Recordings are stored securely and made accessible only to authorized persons and the respective clients. Recordings are retained only for as long as necessary for the agreed purpose or until they are no longer required by the client, after which they are deleted or permanently removed from our systems, unless longer storage is required by law or explicitly agreed otherwise.
Zoom applies appropriate technical and organizational security measures to protect personal data.
9. Payment Processing
Payments for digital products, online courses and services are processed via Stripe and PayPal. The payment process is integrated into the Kajabi platform, which facilitates the technical handling of checkouts and payment workflows. Kajabi itself does not process payment card data but transfers the relevant information to the selected payment provider.
Stripe is a payment service provider of Stripe, Inc., based in the United States, and acts as an independent data controller. Stripe processes personal and transactional data such as names, e-mail addresses, billing details, payment amounts and payment method information. Credit card and payment data are processed exclusively by Stripe and are not accessible to us at any time. Data may be transferred to the United States and other third countries on the basis of appropriate safeguards, in particular Standard Contractual Clauses.
For payments via PayPal, PayPal (Europe) S.à r.l. et Cie, S.C.A., based in Luxembourg, acts as an independent data controller. When using PayPal, personal data such as names, e-mail addresses, transaction details and payment information is processed directly by PayPal. The respective PayPal privacy policy applies to data processing carried out by PayPal.
We receive only confirmation of successful payments and limited transaction-related information necessary for accounting and contract fulfillment purposes.
10. Communication and Contact Requests
When contacting us via contact forms, booking tools or e-mail, the personal data voluntarily provided, including names, e-mail addresses, message content and appointment details, is processed exclusively for the purpose of responding to and handling the inquiry.
Contact forms and booking requests are provided either via the Wix website infrastructure or through integrated Kajabi forms, depending on the context of the inquiry. E-mail communication is conducted via standard e-mail services (e.g. Gmail). In this context, the respective service providers may process technical and communication-related data in accordance with their own privacy policies and applicable data protection laws.
11. Social Media Presence
We maintain profiles on social media platforms such as Instagram, Facebook and LinkedIn in order to communicate with users, provide information about our services and offerings, and interact with interested parties. When users visit our social media profiles, personal data is processed by the respective platform operators in accordance with their own privacy policies and terms of use.
In this context, the platform operators may process data such as IP addresses, device information, user interactions, content shared or reacted to, and profile-related information. We have no influence on the scope or further use of the data processed by the platform operators.
Depending on the platform, we may be jointly responsible with the respective provider for certain data processing activities within the meaning of applicable data protection law (in particular with regard to so-called page insights or statistics). Where applicable, the primary responsibility for data processing lies with the platform operator.
We receive aggregated and anonymized statistical information from the platform operators, such as interaction metrics, reach, engagement data and demographic insights. This information does not allow us to draw conclusions about individual users.
Users can adjust their privacy settings directly within the respective social media platforms and may exercise their data protection rights primarily with the platform operators.
12. Automated Decision-Making, Profiling and Disclosure to Third Parties
No automated decision-making or profiling within the meaning of applicable data protection law takes place. In particular, no decisions producing legal effects or similarly significant effects for users are made solely on the basis of automated processing.
Personal data is disclosed to third parties only where this is necessary to fulfill contractual obligations, to provide technical services and infrastructure, to comply with legal obligations, or where users have given their explicit consent. Third parties may include hosting providers, software and platform providers, payment service providers, analytics and marketing service providers, and communication tools, as described in this Privacy Policy.
Disclosure is always limited to the personal data required for the respective purpose and takes place in accordance with applicable data protection laws. Where third parties act as data processors, processing is carried out exclusively on the basis of contractual agreements and our instructions.
Personal data is not sold and is not disclosed to third parties for independent advertising or commercial purposes unrelated to the provision of our services.
13. Data Security and Storage Duration
We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure. In particular, all data transmitted via this website is protected using modern HTTPS encryption with TLS (Transport Layer Security). This ensures that information exchanged between users’ browsers and our servers is encrypted and cannot be read or manipulated by unauthorized third parties.
Access to personal data is restricted to authorized persons only and is protected by secure authentication procedures. We use professional hosting environments, regularly updated systems, secure password standards and access controls to safeguard stored data.
Personal data is stored only for as long as necessary to fulfill the respective processing purpose and in accordance with applicable legal retention obligations. Once the purpose no longer applies or statutory retention periods expire, the data is deleted or anonymized in a secure manner.
14. Rights of Data Subjects
Data subjects have the right to request access to their personal data, rectification, deletion, restriction of processing and, where applicable, data portability. Consent may be withdrawn at any time with effect for the future.
Requests may be submitted by e-mail. We reserve the right to verify the identity of the requesting person. Complaints may be lodged with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, for users located in the European Union, with the competent supervisory authority.
15. International Data Transfers
As part of the use of the services and tools described in this Privacy Policy, personal data may be transferred to recipients located outside Switzerland or the European Union, in particular to the United States. Such transfers may occur, for example, in connection with hosting services, platform providers, analytics and marketing tools, video conferencing services or payment processing.
Where personal data is transferred to third countries that do not provide an adequate level of data protection according to Swiss or EU standards, such transfers take place only where appropriate safeguards are in place. These safeguards include, in particular, the use of Standard Contractual Clauses approved by the European Commission or recognized under Swiss data protection law, as well as additional technical and organizational measures where required.
In certain cases, a transfer may also be necessary for the performance of a contract or for the implementation of pre-contractual measures at the request of the user, for example when booking services or processing payments. Users may request further information about the safeguards applied to international data transfers by contacting us.
16. Amendments
Our services are intended exclusively for adults. They are not directed at individuals under the age of 16. We do not knowingly collect or process personal data of minors. If we become aware that personal data of a minor has been processed inadvertently, such data will be deleted without undue delay.
Parents or legal guardians who believe that personal data of a minor has been provided to us may contact us at any time to request deletion.
This Privacy Policy may be amended from time to time to reflect legal, regulatory, technical or operational changes. Users are encouraged to review the Privacy Policy periodically. The current version published on the website applies at all times.