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Glossary · D

Privacy Policy.

A privacy policy tells the visitors of a website which personal data is processed for what purpose, who it is passed to and what rights the people concerned have. In Switzerland, the duty to inform has followed from the revised Federal Act on Data Protection (revFADP, in German DSG) since 1 September 2023.

Illustration of "Privacy Policy": Document "Privacy policy" Privacy policy1. Controller2. Data we process3. Cookies and analytics4. Transfers abroad5. Your rights

Privacy Policy — Explained in Detail

Under Art. 19 revFADP, anyone who collects personal data must inform the people concerned appropriately. On a website this almost always involves several processes: contact forms, server log files, analytics and advertising services, embedded maps or videos, newsletter sign-ups and booking systems. The minimum information includes the identity and contact details of the controller, the purpose of processing, the recipients or categories of recipients and, if data is transferred abroad, the countries concerned and the safeguards provided for it.

The policy has to match the actual website. That sounds obvious, but it is the most common shortcoming: the privacy policy names services that were removed long ago and is silent about new ones that were added through a plugin or Google Tag Manager. A typical case is an analytics or advertising pixel installed by a marketing provider without anyone updating the policy. If the website specifically targets people in the EU, the requirements of the GDPR also apply, which go further on certain points, for example regarding the statement of legal bases.

An example from practice: a landscaping business uses a contact form, embedded Google Maps, an analytics tool and, recently, Google Ads with conversion measurement. The privacy policy dates from the year the website was built and mentions only the form. To update it, a list of all embedded services is enough. The most reliable way to compile it is to open the website in the browser with the network panel open and note which third-party servers are contacted. The policy is then supplemented accordingly, and services no longer in use are removed. Fewer embedded services mean less text and less risk.

The honest distinction: this entry is not legal advice. Generators provide a usable basis if they are fed the services actually in use; they do not, however, know by themselves what is running on the website. Whether a cookie banner is also needed is a separate question. A website with as few third parties as possible is also faster and needs less explaining, for instance with cookie-free measurement.

Frequently Asked Questions About Privacy Policy

Practically every company website processes personal data, if only through server log files, contact forms or embedded services. That triggers the duty to inform under Art. 19 revFADP. A privacy policy is therefore advisable for every business website.

At a minimum, the identity and contact details of the controller, the purposes of processing, the recipients or categories of recipients and, where data is disclosed abroad, the countries concerned together with the safeguards. Specific information on the services in use, such as analytics, maps, videos and forms, belongs in it too.

It can apply if the website specifically targets people in the EU, for instance through delivery to EU countries, prices in euros or a focus on EU markets. In that case both sets of rules have to be taken into account. If in doubt, a legal review is worthwhile.

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