Legal

Privacy Policy

Last updated: 7 June 2026

1. Who is responsible for your data

The controller responsible for the personal data described here is CRMPosition, Geneva, 1206, Switzerland.

For any privacy question, or to exercise the rights described below, contact us at contact@crmposition.ch.

2. What we collect, and why

Newsletter subscription

When you subscribe, we process the email address you provide and the page on our site you subscribed from. Our newsletter uses a double opt-in process: you receive a confirmation email and are only added to the list once you click to confirm. As proof of that consent, our email provider also records the date, time, and IP address of your subscription and confirmation. We use this data solely to send you the newsletter.

Server logs

Our hosting provider may automatically record standard technical request data (such as IP address, browser type, and the time of access) to operate and secure the website. This is ordinary server housekeeping; we do not use these logs to identify or profile you.

Web fonts

The site currently loads typefaces from Google Fonts. When a page loads, your browser requests these fonts from Google's servers, which involves transmitting your IP address to Google. We plan to self-host these fonts to remove this dependency. See Google's privacy policy for how they handle that request.

What we deliberately do not do

• We set no cookies of our own.
• We run no analytics (no Google Analytics or equivalent) and no advertising or tracking pixels.
• We do not build profiles, run automated decision-making, or track you across other sites.
• We do not sell, rent, or share your data with third parties for their own marketing.

3. Legal basis for processing

Under the EU GDPR, we rely on:

• Your consent (Art. 6(1)(a) GDPR) to send you the newsletter. You give it by confirming your subscription, and you can withdraw it at any time without affecting prior processing.
• Our legitimate interests (Art. 6(1)(f) GDPR) in operating, securing, and presenting the website (server logs and font delivery).

The same processing is likewise covered under the Swiss Federal Act on Data Protection (FADP).

4. Who we share data with

We do not sell your data. We use a small number of carefully chosen service providers (processors) strictly to operate the newsletter and the website:

• Beehiiv, Inc. (United States) — our email/newsletter platform, which stores your subscription and sends the editions. (privacy policy)
• Make (Celonis SE) (European Union) — the automation service that relays your signup from our form to Beehiiv. (privacy notice)
• Infomaniak Network SA (Switzerland) — our website host. (legal & privacy)
• Google LLC (United States) — delivery of web fonts only, as described above.

5. International data transfers

Some of these providers are located in the United States, so subscribing or visiting the site may involve transferring data outside Switzerland and the EU/EEA. Where that happens, we rely on appropriate safeguards — such as the EU–US and Swiss–US Data Privacy Framework or the European Commission's Standard Contractual Clauses — as provided for by the relevant providers.

6. How long we keep it

• Newsletter data is kept for as long as you remain subscribed. If you unsubscribe or ask us to delete it, we remove your address; our provider may retain a minimal suppression record so we can honour your opt-out and not email you again.
• Server logs are retained only for a limited period as part of standard hosting operation, then deleted or anonymised.

7. Your rights

You have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw your consent at any time.

The fastest way to unsubscribe is the link at the bottom of every newsletter. For anything else, email contact@crmposition.ch and we will respond promptly.

8. Complaints

If you believe we have handled your data improperly, you can lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC). If you are in the EU/EEA, you may instead contact your local data protection authority.

9. Children

This site and newsletter are intended for professionals and are not directed to children under 16. We do not knowingly collect data from children.

10. Security

We serve the site over HTTPS and work only with reputable providers that apply their own technical and organisational safeguards. No method of transmission or storage is ever completely secure, but we take reasonable measures to protect your data.

11. Changes to this policy

We may update this policy as the site evolves. When we do, we will revise the "last updated" date above. Material changes affecting how we use your data will be communicated clearly.

12. Contact

Questions about this policy or your data? Email contact@crmposition.ch.