Privacy notice

Data controller

Native Digital SA, Agno, Ticino, Switzerland. For any questions about data protection and to exercise your rights: info@ndpa.ch.

Legal framework

The Federal Act on Data Protection (FADP) applies to the processing described in this notice. For people in the European Union or the European Economic Area (EEA), the General Data Protection Regulation (GDPR) may also apply; this is why we also state, for each processing activity, its legal basis under the GDPR. The FADP does not require a specific legal basis for each processing activity, but requires the processing to respect the principles of the Act, including good faith, proportionality and purpose limitation.

Visiting the site and technical logs

When you visit the site, the web server logs for each request the shortened IP address (for IPv4 the last number is replaced by 0, for IPv6 only the first three blocks are kept), the date and time, the method and the address requested, the outcome, the amount of data sent, the referring page and the identifier of the browser and operating system (user agent).

The server that runs the contact form and the assistant also keeps technical logs. For each message to the assistant: the outcome, the processing time, the language, the page, the number of the message in the conversation, how the automatic checks classify the message and the answer (for example relevant, off topic or misuse), the number of messages refused for misuse and whether the conversation was closed, the estimated cost of the day, and two pseudonymised codes, one for the conversation and one for the IP address, computed with a random key that the server creates each time it starts and does not save. For each request sent with the form: the sector, the type of request and the language. These logs contain neither the text of the messages nor IP addresses in readable form.

To limit automated submissions, the server counts the requests sent from each IP address to the form and to the assistant. The counts stay only in its memory, for one day at most.

We process this data to run the site, protect it from abuse and correct errors. Legal basis under the GDPR: our legitimate interest in operating and securing the site (Art. 6(1)(f)).

The contact form

With the contact form you send us:

• required: full name, work email address, organisation (public body, hospital, firm or company), sector and type of request;
• optional: role and the text of your message;
• the language in which you are viewing the site, sent automatically, so that we can reply in the same language;
• your consent, which you give with the checkbox on the form.

Without the required data and your consent the form cannot be sent and we do not receive the request. Please do not include sensitive personal data in your message, for example data about patients’ health, or information covered by professional secrecy.

We use this data to reply to your request, to organise the first step you ask us for (a demonstration, a pilot project, the archive inventory, a technical session) and, if a relationship follows, to manage it. Legal bases under the GDPR: to reply to your request and organise the first step, the consent you give with the checkbox on the form (Art. 6(1)(a)) and the pre-contractual steps you ask us for (Art. 6(1)(b)); to manage any relationship that follows, the contract (Art. 6(1)(b)); for the retention the law requires, our legal obligation (Art. 6(1)(c)). You can withdraw your consent at any time, with effect for the future: from then on we will no longer use your data to reply to your request, and we will keep only the data needed for a contractual relationship already under way or that the law requires us to keep.

The server does not save the request: it sends it by email to our address info@ndpa.ch through Native Digital’s email service (Google Workspace) and logs only its sector, type of request and language.

The NaDIA assistant

The NaDIA assistant, at the bottom right of the page, answers your questions from the content of this site. Its answers are generated by artificial intelligence and may be incomplete or contain errors. Using it is optional.

When you write to it, the server receives your question, with the language and the page of the site you ask it from, and the IP address it comes from (for the limits described above).

Questions, together with the earlier messages of the same conversation (your questions and the answers of NaDIA), are sent to Amazon Web Services (the Amazon Bedrock service) and processed in data centres located in the European Union by large language models (Claude, by Anthropic), which check the question and generate the answer. Some messages get a fixed reply from the server and are not sent, for example when a limit has been reached. The automatic checks also recognise messages that suggest a person in distress, so that NaDIA can point to a helpline; the technical logs do not record how these messages were classified. Before the text reaches the models, an automatic filter masks personal data in the most common formats, such as email addresses, phone numbers, IBANs, AHV numbers and payment card numbers. The filter does not recognise all personal data, for example names or postal addresses.

Please therefore do not enter personal data in the chat. If you would like us to contact you, use the contact form.

The conversation stays in the server’s memory only while it is active: after 60 minutes without activity it is forgotten, and it is not saved in any database. Your browser keeps what the panel showed you for the current session only (sessionStorage). To keep track of costs, the server saves only counts without personal data: the date and the number of messages that day and, for each call to the models, the hour (rounded down), the model, the number of tokens and the estimated cost, with no text, conversation code or address.

Legal basis under the GDPR: our legitimate interest in answering visitors’ questions about our offer (Art. 6(1)(f)).

We do not take decisions based solely on automated processing that have legal effects for you or affect you significantly. The assistant answers questions about the site; the only thing it can do automatically is close a conversation in case of misuse. In that case you can write to us at info@ndpa.ch and a person will look at your request.

Cookies and storage in your browser

The site uses no analytics tools, no tracking or advertising cookies and no third-party scripts; the fonts, too, are loaded from our own server.

Without using cookies, the site keeps in your browser only the language you choose in the language menu (localStorage) and, for the current session, your conversation with the assistant, the pages already visited in the tab and the state of its hints (sessionStorage). They serve only to make the site work, not for statistics or advertising; the full list is on the Cookies page. Legal basis under the GDPR: our legitimate interest in operating the site (Art. 6(1)(f)).

Recipients and service providers

For the site we use these service providers, which process the data on our behalf:

• Infomaniak, in Switzerland, which hosts the site, the server of the contact form and of the assistant, and their logs;
• Amazon Web Services, which processes the questions put to the assistant with the Amazon Bedrock service;
• Google, which runs Native Digital’s email with Google Workspace, including the info@ndpa.ch mailbox that receives the requests sent with the form and the account through which the server sends them.

We do not sell your data and do not disclose it to any other third party, unless the law requires us to.

Where the data is processed

The site, the server of the form and of the assistant, and the technical logs are in Switzerland, at Infomaniak.

Questions to the assistant are processed by Amazon Web Services in data centres in the European Union, which Amazon Bedrock selects from Frankfurt (Germany), Ireland, Paris (France), Stockholm (Sweden), Milan (Italy) and Spain. The Federal Council recognises these States as providing adequate data protection.

Emails from the contact form are processed by Google, which may also process them outside Switzerland, in the States where its data centres and its subprocessors are located, in particular the United States; Google publishes the list for Google Workspace. The safeguards are those Google provides: standard contractual clauses and, for the United States, the Swiss-U.S. Data Privacy Framework.

How long we keep it

• Web server logs, with the shortened IP address: 14 days.
• Technical logs of the server of the form and of the assistant, with the pseudonymised IP address: 30 days.
• Counts per IP address that limit automated submissions: only in the server’s memory, one day at most.
• Conversation with the assistant: in the server’s memory, forgotten after 60 minutes without activity.
• Requests sent with the form (emails, in the mailbox that receives them and in the account that sends them): for as long as needed to handle the request and any relationship that follows, and for as long as the statutory duties to retain business correspondence require.
• Data in your browser: the language until you delete it; the conversation and the pages visited until you close the tab.

Security

Connections between your browser and the site are encrypted (HTTPS), as are those between our server and Amazon Web Services. Before each call to the models, personal data in the most common formats is masked, and the logs do not contain the text of the messages.

Your rights

Within the limits set by law, you may ask at any time to access your data, to have it corrected or deleted, to have its processing restricted and to receive it in a commonly used electronic format, and you may withdraw your consent at any time, with effect for the future. Write to us at info@ndpa.ch. You may also contact the Federal Data Protection and Information Commissioner (FDPIC) or, if you are in the European Union or the EEA, the supervisory authority of your country.

Right to object. You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest (technical logs, the assistant and storage in your browser). Write to us at info@ndpa.ch.

Changes to this notice

We update this notice when the site or the processing described changes. The version published on this page applies; the date of the last update is shown at the top.