Privacy Policy

SeniorContact attaches great importance to the protection of privacy and personal data. We strive to handle personal data with care and in accordance with Swiss data protection law. This Privacy Policy explains how we collect, use and share personal data when you use our website and our SeniorContact app. It also informs you of the rights you have regarding the processing of your personal data by SeniorContact.

This statement was drafted in accordance with the Swiss Federal Act on Data Protection ("FADP" / "nLPD") of 25 September 2020, the Data Protection Ordinance ("DPO" / "OPDo") of 31 August 2022, and is inspired, as a matter of good practice, by the principles established by the General Data Protection Regulation (EU) 2016/679 ("GDPR").

Data Controller

SeniorContact Sarl (IDE: CHE-304.129.551).

Host

Our application and services are hosted in Switzerland (Geneva), using our trusted hosting provider Infomaniak.

1. Collection of your personal data

We obtain your personal data when you visit and use SeniorContact (website and app) and when you interact with the services and features we offer.

1.1. The data you provide to us

We collect the information you share with us, in particular:

• Creating an account: first name, last name and email address. Required fields are indicated at the time of collection; optional fields are always marked as such
• Contacting us: for example when you ask a question or request support (name, email and message content)
• Using the Service: messages, photos, videos, reminders and any other content you choose to share
• Signing in with Apple, Google or Facebook, if you choose that option (identifiers and account data provided by the relevant provider)

1.2. Data about your use of our website and app

We automatically collect technical and usage data when you use the Service, such as:

• IP address, device type, operating system, browser type, date and time of connection, and other technical identifiers
• Pages and screens viewed, time spent and diagnostic information
• App and device information needed to operate and secure the Service (including app version and operating system version)
• When applicable and enabled by your cookie consent, advertising and analytics identifiers used for marketing attribution

On the website, this may include browser and page interaction data. In the app, this may include technical diagnostics needed to keep the service reliable. Where analytics tools are used, they are configured according to your consent choices and applicable law.

1.3. App permissions

Depending on how you use the app, we may request access to certain features of your device:

• Camera and photo library, to take and send photos or videos
• Microphone, to record audio messages or make calls
• Contacts, to help you select or save contacts when using related features
• Notifications, to send app notifications and call alerts

You can manage these permissions at any time in your device settings. If a permission is not granted, some related features may not work as intended.

2. Use of your personal data

The personal information collected by SeniorContact is collected to operate the Service and, where applicable, for analytics and marketing purposes, and is treated as confidential. We process your personal data for the following purposes:

2.1. When we have your consent

Where required, we process personal data based on your consent, for example:

• To send you marketing communications where you have agreed to receive them
• To load non-essential cookies and similar technologies on the website, in accordance with our Cookie policy
• To access optional app permissions that depend on your choices on your device
• Sometimes, for the purposes described at the time of collection when we specifically ask for your consent

You may withdraw consent at any time where consent is the legal basis, without affecting processing already carried out before withdrawal.

2.2. When processing is necessary to comply with a legal obligation

This may include disclosing information to law enforcement authorities, in the context of exercising legal rights, or for regulatory purposes. We may also process personal data to comply with other legal requirements applicable to SeniorContact.

2.3. When processing is necessary for our legitimate interests

We process personal data for legitimate business interests such as:

• Providing, maintaining and securing the Service
• Monitoring accounts to prevent, investigate and/or report fraud, security incidents or abusive activity, in accordance with applicable laws
• Investigating complaints or support requests you send us regarding the website, the app or our services
• Analysing use of the Service to help us improve, analyse and protect our content, products and services
• Measuring the performance of our website and app to help us improve them (marketing measurement, where used, relies on your cookie consent)
• Sending service-related communications such as notifications, security messages and support replies
• Protecting SeniorContact's rights, including for legal proceedings, compliance, audits, investigations and regulatory purposes

When we rely on legitimate interests, we take into account your rights and freedoms.

3. Subcontractors (service providers)

We use subcontractors and service providers to operate the Service and provide specific functionalities. They are required to handle personal data in accordance with applicable data protection law. They only process personal data for defined purposes under contractual obligations and security requirements.

In principle, your personal data is not transmitted to third parties unless a legal obligation requires it, or the provision of the Service requires the use of one of our partner providers (for example hosting, messaging, payments, analytics or support).

You can consult our current sub-processors list here: Sub-processors list (PDF)

Key subcontractors include:

• Infomaniak, for hosting
• Chatwoot, for customer support chat on the website
• Google, for analytics, attribution, Firebase services and social login when you use a Google account
• Meta, for website marketing analytics when enabled by cookie consent
• OneSignal, for app push notifications and call alerts
• RevenueCat, for subscription management in the app
• api.video, for video upload and processing
• Cloudflare, for TURN credentials used by in-app calling
• Apple and Google, for app store payments and platform services
• Apple, Google and Facebook, for social login

4. Data transfer / retention period

In principle, SeniorContact hosts and operates the Service from Switzerland (Geneva). Some service providers may process data outside Switzerland or the EEA as part of their infrastructure. Where data is processed outside Switzerland, we use providers that publish data protection commitments and privacy terms, and we aim to comply with the requirements of the FADP and, where applicable, the Data Protection Ordinance (OPDo). We have not separately documented Standard Contractual Clauses for each provider in this policy; if you need more detail about a specific transfer, contact us at support@seniorcontact.app.

We retain personal data only for as long as necessary for the purposes for which it was collected and to comply with our legal obligations. In particular:

• Account information is kept for as long as your account is active and for a limited period thereafter where needed for legal, security or accounting reasons
• Technical and security logs are kept for a limited period to protect the Service and investigate issues
• Marketing and attribution records are kept for a limited period after an ad-driven visit or install, typically up to 7 days where applicable
• Support communications may be kept for as long as needed to handle your request and for a reasonable follow-up period

If you request deletion of your account, we delete or anonymise the related personal data, subject to any legal retention obligation. Data that must be retained by law is kept only for the required period and then destroyed or anonymised.

5. Data security

We take appropriate security measures (both organisational and technological) to protect your information against unauthorised access, alteration, disclosure or destruction. These measures include encrypted connections, access controls and security monitoring. No system is 100% risk-free, but we continuously improve our safeguards and incident response practices.

6. Rectification of your personal data

We place great importance on the accuracy of the data we hold about you. Where possible, you can update certain personal information directly from your account settings in the SeniorContact app.

You have the following rights, subject to applicable law:

• Request access to the personal data we hold about you
• Request correction of inaccurate or incomplete personal data
• Request deletion of your account and associated data: Delete account
• Request restriction of processing in certain situations
• Withdraw consent at any time where processing is based on your consent
• Request to receive your personal data in a structured and machine-readable format (portability), where applicable
• Object to certain processing, in particular where we rely on legitimate interests

In all cases, you can make a request by email to support@seniorcontact.app. To protect your account, we may ask you to verify your identity before processing certain requests.

These rights may be limited in certain situations. If that is the case, we will provide the exception reason under the FADP, the DPO/OPDo or the GDPR where applicable. This may happen in particular when we are legally required to process or retain your data, when the request would affect the rights of a third party (including our rights), or when retention is necessary for our legitimate interests as permitted by law.

7. Payment security

The registration and transmission of payment data are handled through encrypted connections. We do not store your credit card details. Payments and subscriptions in the app are handled by the relevant payment platforms and services, in particular Apple, Google and RevenueCat, under their own privacy policies. Payment data is processed directly by these providers according to their security standards and contractual terms.

8. Use of cookies (cookie policy)

To make access to our website more convenient and to offer you a better experience, we use cookies and similar technologies.

What is a cookie?

A cookie is a small file stored by a server on a user's device (computer, phone, etc.) and associated with a web domain (in most cases, all pages of the same website). This file is automatically returned during subsequent contacts with the same domain. These files may be used to remember your choices, measure performance and, where applicable, support marketing attribution.

On SeniorContact, cookies and similar technologies may be deployed by SeniorContact and by third-party technical providers, depending on your consent choices.

What cookies and similar technologies do we use?

• Essential cookies: indispensable for the use of the website and its core features. They are generally set without prior consent where legally exempt. They ensure, for example, that your consent choice is remembered and that basic technical continuity is maintained.
• Functional cookies: allow the website to remember choices you make and provide enhanced features, such as live support chat session continuity.
• Analytics cookies: help us understand how visitors interact with the website by collecting and reporting information, so we can improve navigation, performance and content.
• Marketing / attribution cookies: used to measure ad performance and attribution across visits, where enabled by your consent.

For full details on cookie categories, the list of cookies, vendors and how to manage your preferences, please consult our cookie policy here: Cookie policy. That cookie policy is an essential part of this Privacy Policy.

9. Contact for data protection

For questions about data protection, contact us at support@seniorcontact.app.

10. Right to file a complaint

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC / PFPDT), Feldeggweg 1, CH-3003 Bern, regarding how SeniorContact collects and processes your personal data: https://www.edoeb.admin.ch.

11. Changes

This Privacy Policy may be modified at any time by SeniorContact. The updated version will be published on this page. We recommend checking this page regularly to stay informed of the latest version.