Privacy Policy
Draft · Pending legal review · Placeholder company details
1. Controller
Clu Swiss Security AG, Oberallmendstrasse 18, 6300 Zug, Switzerland (operating the Tervolt platform; "Tervolt", "we") is the controller responsible for the processing of personal data described here. Because we address users in the EU, this notice follows the EU GDPR; the Swiss Federal Act on Data Protection (revFADP) applies in parallel. Contact: support@tervolt.com. A data protection officer has not been appointed, as the statutory thresholds are not currently met; this will be reassessed as the company grows.
2. What we process, why, and on which legal basis
a) Waitlist.When you join the waitlist we process your email address, your language preference, your referral code, and — if you arrived through a referral link — the code that referred you. Purpose: managing the waitlist and sending you updates about Tervolt's launch. Legal basis: your consent, Art. 6(1)(a) GDPR, given via the consent checkbox (single opt-in). You can withdraw consent at any time via the unsubscribe link in every email or by writing to us.
b) Account (preview dashboard). If you create an account we process your email address and authentication data. Purpose: providing the login-protected preview. Legal basis: performance of a contract, Art. 6(1)(b) GDPR.
c) Analytics. With your consent (cookie banner), we use Vercel Analytics, Vercel Speed Insights, and Plausible — privacy-focused tools that work without advertising cookies and without cross-site tracking. Legal basis: consent, Art. 6(1)(a) GDPR / § 25 TDDDG. If you decline, no analytics scripts are loaded.
d) Server logs & security. Our hosting provider processes technical data (IP address, timestamps, requested URLs) to deliver the site and defend against abuse. We rate-limit form submissions by IP. Legal basis: legitimate interest in a secure, functioning service, Art. 6(1)(f) GDPR.
3. Recipients (processors)
We share data only with processors bound by data-processing agreements (Art. 28 GDPR): Supabase (database and authentication), Resend (email delivery), Vercel (hosting and, with consent, analytics), and Plausible (with consent, EU-hosted analytics). We do not sell personal data and we do not share it with third parties for advertising.
4. International transfers
Where processors process data outside the EU/EEA (e.g. US entities of Supabase, Resend, or Vercel), transfers rely on the EU–US Data Privacy Framework and/or EU Standard Contractual Clauses (Art. 46 GDPR). We configure EU data regions where the provider offers them.
5. Retention
Waitlist data is kept until you unsubscribe or request deletion, and at the latest until the waitlist phase ends and is wound down. Account data is kept for the life of the account. Unsubscribed entries are retained only as a suppression record. Server logs are retained for a short, rolling period. Statutory retention duties (e.g. commercial and tax law) remain unaffected.
6. Your rights
You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection to processing based on legitimate interests (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future (Art. 7(3)). You also have the right to lodge a complaint with a supervisory authority (Art. 77): EU residents may complain to the data protection authority of their country of residence; in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC / EDÖB). To exercise any right, email support@tervolt.com.
7. No automated decision-making
We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.
8. Cookies and local storage
The site itself uses only technically necessary storage: your language choice (cookie), your cookie-banner decision (local storage), and — if you log in — an authentication session cookie. Analytics runs only after you accept the banner and can be declined without any loss of functionality.
9. Changes
We will update this policy as the product evolves (in particular before any real investment functionality launches, which will involve additional processing such as identity verification). The version published here is always the current one.
This is a working draft published for transparency during the waitlist phase. Lawyer-reviewed, localized versions will replace it before launch. The company details in the Impressum are authoritative.