1. Data Controller
zehnplus GmbH, registered at Baarerstrasse 52, 6300 Zug, Switzerland, serves as the data controller. The company relies on service providers including:
- Google (Language Model Provider)
- Hetzner (Cloud Server Provider)
- Stripe (Payment Services Provider)
Users acknowledge they are subject to these third parties' terms and policies.
2. Personal Data We Collect
Personal Data You Provide
- Account Information (name, contact details, credentials, payment info, transaction history)
- User Content (inputs, file uploads, feedback)
- Communication Information (messages sent to the company)
- Social Media Information (details shared on social platforms)
- Other Information You Provide (event participation, age/identity verification)
Personal Data Received Automatically
- Log Data (IP address, browser type, request timestamps, interaction patterns)
- Usage Data (content engagement, feature usage, timezone, device info)
- Device Information (name, operating system, identifiers, browser details)
- Cookies and Similar Technologies
Personal Data from Other Sources
Information from publicly available internet sources and trusted partners for fraud prevention and marketing purposes.
3. How We Use Personal Data
The company processes data for:
- Delivering and maintaining Services
- Improving and developing features
- Communicating updates and marketing materials
- Preventing fraud and criminal activities and ensuring system security
- Complying with legal obligations
Aggregated or de-identified data may be analyzed and shared for service effectiveness and research purposes.
4. Disclosure of Personal Data
Data may be shared with:
- Vendors and service providers assisting with business operations
- Business transaction counterparties during reorganizations or transfers
- Government authorities or other third parties as required by law
- Affiliates operating under common control
5. Retention
Data retention depends on processing purpose, data characteristics, risk assessment, and legal requirements. Users can disable chat history; conversations are deleted after 30 days when this setting is off. Deleted accounts result in anonymized or removed personal data, though anonymized inputs may be retained for service improvements.
6. Your Rights
Users have statutory rights to:
- Access personal data
- Request deletion
- Rectify or update information
- Transfer data to third parties (portability)
- Restrict processing
- Withdraw consent
- Lodge complaints with data protection authorities
Users may also object to direct marketing and processing based on legitimate interests.
Requests should be submitted via support-sanctions@zehnplus.ch. Rights may be limited in certain circumstances.
Accuracy Note
Services like Sanction Compass generate responses by predicting the most likely words to follow user requests, which may not be factually accurate. Users should not rely solely on output accuracy. Factual inaccuracies about individuals can be reported to support-sanctions@zehnplus.ch for potential correction.
7. Children
Services are not directed to children under 16. The company does not knowingly collect data from minors under 16. Users under 18 require parental or guardian permission. Suspected violations should be reported to support-sanctions@zehnplus.ch.
8. Legal Bases for Processing
| Purpose | Data Types | Legal Basis |
|---|---|---|
| Provide/maintain Services | Account, Content, Communication, Log, Usage, Device, Cookies | Contract performance |
| Improve/develop Services | Account, Content, Communication, Other, External, Log, Usage, Device, Cookies | Legitimate interests |
| Communicate with users | Account, Communication, Social Media, Other, Log, Usage, Device, Cookies | Contract performance; Consent |
| Prevent fraud/crime | Account, Content, Communication, Social Media, Other, External, Log, Usage, Device, Cookies | Legal obligation; Legitimate interests |
| Comply with legal obligations | All data types | Legal obligation; Legitimate interests |
9. Data Transfers
Data may transfer outside the EEA, Switzerland, and UK. The company relies on European Commission adequacy decisions and Standard Contractual Clauses for compliance. Data processing and storage occurs in company facilities and on the servers of third-party service providers located in the United States.
10. Changes to the Privacy Policy
Updates are posted on this page unless different notice is legally required.
11. How to Contact Us
General Support: support-sanctions@zehnplus.ch
Data Protection Officer: dpo-sanctions@zehnplus.ch
Supervisory Authorities:
- Federal Data Protection and Information Commissioner (Switzerland)
- Information Commissioner's Office (UK)
- Local supervisory authorities in other regions