Privacy Policy

1. Data Controller

Alexandre de Sousa Bally (Small Scale)
Herbstgasse 6
4056 Basel
Switzerland
Email: privacy@smallscale.ch

2. Scope

This privacy policy explains what personal data we process in connection with our website smallscale.ch and our services, for what purpose, and what rights data subjects have. It applies under the Swiss Data Protection Act (DSG) and, where applicable, the European General Data Protection Regulation (GDPR).

3. Personal Data Collected

We process the following categories of personal data:

Contact data: Name, email address, phone number, and other information you submit via our contact form or by email.

Technical data: IP address (anonymised), browser type, operating system, referrer URL, page views, and time of access. This data is collected via web analytics tools (see Section 6).

Business data: In the context of consulting engagements, we may process additional data as governed by separate engagement agreements.

4. Purpose of Processing

We process personal data for the following purposes:

Providing and improving our website; responding to your enquiries and communicating with you; delivering our consulting services; complying with legal obligations; web analytics to optimise our offering.

5. Legal Basis

Processing is based on our legitimate interest (Art. 31 para. 1 DSG), the performance of a contract or pre-contractual measures, and, where required, your consent. Where the GDPR applies, we rely on Art. 6 para. 1 lit. a, b, and f GDPR.

6. Web Analytics (Google Analytics)

We use Google Analytics 4 (GA4), a web analytics service by Google Ireland Limited. GA4 is only loaded after your consent and sets cookies to track page views, session duration, referral source, and approximate location. IP addresses are anonymised. Data is processed on Google servers, potentially including in the USA. Google is certified under the EU-U.S. Data Privacy Framework. More information: Google Privacy Policy. You can withdraw your consent at any time by resetting your cookie settings in your browser.

7. Cookies and Consent

This website does not set optional cookies unless you explicitly consent. On your first visit, a dialog appears allowing you to choose whether only essential services or also analytics and the contact form should be loaded. Your choice is stored in your browser (localStorage) so the dialog does not reappear on every visit. You can reset your settings at any time via your browser settings.

Essential (always active)

These are strictly necessary for the website to function. No consent is required.

Functional (requires consent)

These are only set after you click "Accept all" in the cookie dialog.

8. Contact Form (HubSpot)

Our contact form is provided by HubSpot and is only loaded after your consent. When you use the form, your data is processed on servers of HubSpot Inc. (USA). HubSpot may set cookies. HubSpot is certified under the EU-U.S. Data Privacy Framework. Details: HubSpot Privacy Policy. Alternatively, you can always contact us by email at privacy@smallscale.ch.

9. Hosting

This website is hosted on Cloudflare Pages. Cloudflare may process technical data (e.g. IP addresses) to provide and secure the website. Cloudflare Inc. is certified under the EU-U.S. Data Privacy Framework. Details: Cloudflare Privacy Policy.

10. Disclosure to Third Parties

We only disclose personal data where necessary for the provision of our services, where a legal obligation exists, or where you have given consent. We do not share data for advertising purposes.

11. International Data Transfers

Certain service providers (HubSpot, Cloudflare) are based in the USA. Transfers are based on appropriate safeguards under Art. 16 et seq. DSG, in particular certification under the EU-U.S. Data Privacy Framework and standard contractual clauses.

12. Retention Period

We retain personal data only as long as necessary for the purposes stated above or as required by statutory retention periods. Contact enquiries are generally deleted after 12 months unless a client relationship is established.

13. Your Rights

Under the Swiss DSG, you have the following rights: access to your stored personal data; rectification of incorrect data; deletion of your data; restriction of processing; data portability; objection to processing; withdrawal of consent.

Please direct your request to: privacy@smallscale.ch. You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).

14. Changes

We reserve the right to amend this privacy policy at any time. The current version is available on this page.