Privacy policy. SWAN-Network

Working translation of the French text. In case of divergence, the French version prevails.

1. Controller

SWAN-ID, Anas Lahras, Rue des Hirondelles 42, 2502 Bienne. contact@swan-id.com.

Reference: Federal Act on Data Protection of 25 September 2020 (FADP), in force since 1 September 2023.

2. What we collect, and why

Newsletter. Your email address and the date of your consent. To send you new articles and episodes. Basis: your consent, withdrawn in one click from every message.

Fact sheets and documents received by email. Your email address, the document requested, the page you requested it from. To send it to you, and to know which content is useful. Basis: your request.

Contact, proposal and Club waiting-list forms. Your first name, your email address, your telephone number if you give one, your message, the offer or profile you indicated, the page you came from. To answer you and prepare a proposal. Basis: your request, then the contract if one is concluded.

Taking part in the show (/radio/participer). Your name, your email address, your telephone number, what you do if you say so, the page you came from. To get back to you and agree on a recording date; that is why the number is required there, while it is optional elsewhere. Basis: your consent, given by ticking the box on the form.

What we do with your number, and what we do not do with it. It serves to agree on a recording date, or to call you back if you wish. No commercial cold calling by telephone, no sale of data. It is stored in a single, international form, and is erased with the rest of your request on the terms stated in article 4.

CV Generator. The information you enter to produce your CV (career, education, skills, contact details) and your delivery email address. To produce and deliver the document. This information is deleted 48 hours after delivery. Basis: the contract.

The writing of the text calls on the service of OpenAI, called by our server. What is transmitted is the information you entered in the form, including the contact details that will appear on the CV (name, email address, telephone, postal address, LinkedIn profile), since the document carries them. Neither your payment, nor your order identifier, nor any other data of your file is transmitted.

Orders and payments. Your email address, the product, the amount, the date, the payment identifier. To perform the order and keep the accounts. The payment itself is processed by Stripe: we neither see nor keep your card number. Basis: the contract, then the legal obligation to keep accounting records.

Courses and services. The information of the proposal and the invoice, the level assessments, the documents you entrust to us for a service. To perform the contract. Basis: the contract.

Technical data. The server log (IP address, page requested, date, browser) and usage events (page viewed, tool used, episode played, click towards a guest's site). An event records the name of the action, the page, the campaign you came from if you came from one, and technical values: a kind of form, a file format, the destination site of a click towards a guest. It records no IP address, no name and no email address, and the session identifier appears there as a digest, which does not lead back to a person. For the security and the proper working of the sites. Basis: our legitimate interest in running and protecting the sites.

The school converter processes the date of birth entered for the calculation only; it is neither stored nor logged.

3. Cookies

The sites use a session cookie, necessary to their working (forms, orders), and a language cookie on network.swan-id.com. The session cookie is set on the domain swan-id.com and holds for both sites. The measurement consent cookie, if set, lasts 6 months; it records your choice, accepted or refused, and nothing else.

Measuring our advertising. Until you accept, no tracker is loaded: no script, no vendor cookie, no call to their servers. The banner offers "Accept" and "Refuse" with the same weight, nothing is ticked in advance, and refusing is enough.

If you accept, two tools load:

Meta pixel, from Meta Platforms Ireland Limited, Dublin. Purpose: measuring what becomes of the visits that come from our advertising on Facebook and Instagram (page seen, form sent, order paid) and matching those events to our campaigns. It sets its own cookies, among them _fbp. Duration: three months, as Meta publishes it.
TikTok pixel, from TikTok Information Technologies UK Limited, London. Same purpose, for our advertising on TikTok. It sets its own cookies, among them _ttp. Duration: thirteen months, as TikTok publishes it.

We pass them neither your name, nor your email address, nor the content of a form.

Transfer to the United States. Both companies transfer the data so collected to their parent companies in the United States, Meta Platforms, Inc. and TikTok Inc. The transfer rests on the standard contractual clauses of their terms and, for Meta, on the Swiss-U.S. Data Privacy Framework. The United States does not offer protection equivalent to that of Switzerland: its authorities hold powers of access that Swiss law does not know. You accept this transfer by accepting measurement, and you refuse it by refusing measurement.

Withdrawing your consent. The "Cookies" link in the footer reopens the banner at any time: choose "Refuse", and no tracker is loaded any more. Cookies already set by the vendors are cleared from your browser settings. After 6 months, the question is put to you again.

No data is sold. Without consent, the site sets only the two technical cookies named above.

Links to our guests. When you follow, from an episode or an article, a link to a guest's site, that site receives two pieces of information: our address, https://swan-id.com/, as the referrer, and, in the link itself, the name of the episode or article you come from. This is what lets the guest see that the visit comes from us, and from which content. We pass on nothing that identifies you. Other outbound links open with no referrer.

4. For how long

Information entered in the CV Generator: 48 hours after delivery.
Contacts and proposals: 2 years after the last exchange, deleted then by the scheduled task, or earlier at your request.
Waiting list and newsletter: until you unsubscribe or ask for erasure; a sign-up left without consent is erased after 30 days.
Orders and invoices: 10 years, the legal retention period for accounting records.
Application logs: 14 days, by daily rotation.
Documents entrusted for a service: the duration of the service, then returned or deleted at your request.

Reference: art. 958f CO (keeping of books and accounting records for ten years).

5. Who has access

Your data is processed by SWAN-ID and by the providers necessary to the service:

Infomaniak Network SA, Geneva: hosting of the sites, of the database and of email sending. Data in Switzerland.
Stripe Payments Europe, Ltd., Dublin: processing of card and Twint payments. Stripe processes your payment data under its own policy.
OpenAI: writing of the text of the CV Generator, for the information entered in the form only.
Meta Platforms Ireland Limited and TikTok Information Technologies UK Limited: measuring our advertising, only if you have accepted it (article 3).

No data is sold or passed on for advertising purposes. For a company service, the practitioners we associate with an assessment are bound by the same confidentiality as we are.

6. Transfer abroad

The data is hosted in Switzerland. A transfer out of Switzerland occurs only for payment (Stripe, Ireland, a country recognised as providing adequate protection), for the writing of the CV Generator text, entrusted to OpenAI, and, if you have accepted measurement, to the United States for the Meta and TikTok pixels, on the terms stated in article 3.

7. Your rights

You may ask for access to the data we hold about you, its rectification, its erasure, or object to a processing, by email to contact@swan-id.com. We answer within thirty days. You may also address the Federal Data Protection and Information Commissioner (FDPIC).

For the newsletter, the unsubscribe link is in every message.

8. Security

The sites are served over HTTPS, administration access is protected by a second factor, delivered documents go through signed links with a limited lifetime, and the backups are encrypted and kept in Switzerland.

9. Changes

This policy may be amended; the version in force is the one published on the sites, with its date. Important changes are announced to the newsletter subscribers.

10. Language

This policy exists in French, English and German on network.swan-id.com. In case of divergence, the French version prevails.