Privacy policy

The controller of the data collected on the website djtal.ch and in the course of the assignments entrusted to Djtal is:

The processing carried out by Djtal Sàrl is based, as the case may be, on one of the following legal bases:

• Your consent, for direct marketing and for cookies that are not strictly necessary.
• The performance of a contract or of steps taken at your request prior to entering into a contract, for handling audit requests and managing assignments.
• Our legitimate interest in operating and improving the site, provided that your rights and freedoms do not override it.
• Compliance with legal obligations, in particular accounting, tax and contractual retention obligations.

Your data is kept for as long as is strictly necessary for the purposes for which it is processed:

• ·Enquiries that did not lead to an engagement: 12 months at most from the last exchange.
• ·Active contractual relationship: for the whole duration of the assignment.
• ·Post-contractual archiving: 10 years, pursuant to Swiss accounting and tax law (Art. 958f of the Swiss Code of Obligations, CO).
• ·Web analytics data: 13 months at most, in aggregated form.
• ·Commercial opt-in lists: until you unsubscribe.

Your data is accessible only to the following persons and entities, to the extent necessary for their task:

• The Djtal internal team: management and operations in Switzerland, engineering hub in Tunisia.
• Our technical processors: Zoho Corporation (ERP/CRM suite, hosted in the United States), Infomaniak SA (website hosting, Geneva), Anthropic PBC (AI models, United States, with a commitment not to use the data for training), and other service providers necessary for delivering the service.
• The competent authorities, solely upon a lawful order.

Each of our processors is bound by a data processing agreement (DPA) that guarantees a level of protection that complies with the GDPR and the Swiss FADP. Your data is never resold or transferred to third parties for commercial purposes.

Where the data is hosted. The website and its server are hosted in Switzerland with Infomaniak. Our Zoho suite (CRM, ERP, email) is operated from Zoho's US data centres (organisation on the zoho.com domain).

Access from Tunisia. Our engineering hub is based in Tunisia. This access is governed by a confidentiality and data processing agreement. Tunisia is not covered by an adequacy decision of the European Commission or of the Swiss Federal Data Protection and Information Commissioner (FDPIC); we have therefore implemented standard contractual clauses and technical measures (encryption, separation of environments, audit trail) to guarantee an equivalent level of protection.

CRM and business data: a governed transfer to the United States. Our Zoho organisation is hosted in Zoho's US data centres. This transfer is governed by Zoho's data processing agreement (DPA), which incorporates the standard contractual clauses.

AI components: processing by a model hosted in the United States. The reasoning of our AI agents and coaches is carried out by the models of Anthropic PBC, hosted in the United States, with a non-reuse clause (‘no-training’ in the terminology of AI providers): your data is not used to train public models. Audio recordings, by contrast, are transcribed locally on our own machines, never in an online service. Our stated plan is to eventually bring the execution of the models back to infrastructure hosted in Switzerland.

Web analytics (Google Analytics 4): anonymised technical visit data may be transferred to Google servers in the United States. This transfer is governed by the EU-US Data Privacy Framework, and is activated only after your explicit consent via our cookie banner.

Measurement of our advertising campaigns (Google Ads): when you arrive on the site through one of our Google ads, a click identifier (‘GCLID’) may be passed to Google so that we can measure which ads generate qualified contacts. This transfer to Google (United States) is governed by the EU-US Data Privacy Framework. It concerns the measurement of our own return on advertising spend, with no third-party ad targeting and no resale of data.

Djtal Sàrl implements appropriate technical and organisational measures to protect your data: encryption in transit (HTTPS/TLS), access control on a need-to-know basis, a systematic audit trail on sensitive actions, regular backups and ongoing awareness-raising among our teams.

In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, we notify the competent supervisory authority without delay and, where appropriate, the data subjects, in accordance with the requirements of the GDPR and the Swiss FADP.

The djtal.ch website uses a minimal number of cookies, classified in three categories:

• Strictly necessary cookies for the operation of the site (session preferences, security). They do not require your consent.
• Web analytics cookies, Google Analytics 4, set only after we have obtained your explicit consent via our cookie banner. You may refuse or withdraw this consent at any time.
• First-party advertising measurement cookie: a djtal_click_ids cookie (set by djtal.ch, expires after 90 days) records the Google Ads click identifier (‘GCLID’) and its timestamp when you arrive through one of our ads. We use it solely to measure the effectiveness of our own campaigns: it contains no personally identifying data, is not used for any third-party ad targeting and is never resold. Legal basis: our legitimate interest in measuring our advertising; you may object to it at any time (see ‘Your rights’).

You can at any time configure your browser to block or delete cookies, or change your preferences via the cookie banner at the bottom of the page. Please note that refusing analytics cookies does not affect any feature of the site.