GDPR & SWISS FADP COMPLIANCE STATEMENT

www.janinehugo.com
Last updated: 28th March 2026

1. Our Commitment

We respect privacy as a fundamental right. This Website is operated by Janine Hugo, an individual based in Canton Vaud, Switzerland, offering executive coaching, HR consulting, career mentoring, and related professional services. We comply with the Swiss Federal Act on Data Protection (revDSG/FADP), which has been in force since 1 September 2023, and with the EU General Data Protection Regulation (GDPR) where applicable to users in the European Union or European Economic Area. Our goal is to handle your personal data lawfully, fairly, and transparently — no surprises, no unnecessary data.

2. Legal Basis for Processing

We process personal data only when there is a clear and lawful basis for doing so. This includes:

Consent — when you opt in to email communications, free resource downloads, or non-essential cookies via our consent banner;

Legitimate interests — for managing enquiries, operating this Website, and improving our services, balanced against your privacy rights;

Contractual necessity — to respond to service requests and deliver agreed professional engagements;

Legal obligation — when required under Swiss or EU law.

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of any processing that took place before withdrawal.

3. Our Responsibilities

We ensure that:

Personal data is collected for a clear purpose and used only for that purpose;

Data collected is accurate, up to date, and limited to what is strictly necessary;

Appropriate technical and organisational security measures protect personal data at all times;

Data is stored and transferred only through secure, reputable, and compliant platforms and systems;

International transfers outside Switzerland and the EEA — including to providers such as Google Analytics, Meta Pixel, Microsoft Clarity, Zapier, and Coachvox’s AWS-hosted infrastructure — are made exclusively under EU Standard Contractual Clauses (SCCs) or equivalent safeguards recognised under the FADP.

4. Janine AI

Janine AI is a career mentoring tool built on the Coachvox platform and accessible via a redirect link from this Website. As creator of Janine AI, we act as joint controller with Coachvox Ltd. in respect of chat content generated on the platform. We do not monitor user conversations in real time, and we review completed transcripts only for quality improvement and service development purposes.

Users are clearly informed that Janine AI is an artificially intelligent model and not a real person. For full details of how personal data is managed on the Coachvox platform, please review Coachvox’s Privacy Policy at coachvox.ai/privacy/.

5. Your Rights

Under both the Swiss FADP and the GDPR, you have the right to:

Access the personal data we hold about you;

Request correction of inaccurate or incomplete data;

Request deletion of your data where it is no longer required or where you withdraw consent;

Restrict or object to certain types of processing;

Receive your data in a portable format where processing is automated and based on consent or contract;

Withdraw consent at any time for marketing communications or non-essential cookies;

Request human review of any AI-generated guidance where you consider it may have had a significant impact on you.

To exercise any of these rights, please contact us via the contact form at www.janinehugo.com. We will respond within 30 days of receiving your request.

6. Data Breach Management

In the event of a personal data breach that poses a risk to your rights or personality, we will:

Take immediate steps to contain and assess the breach;

Notify the Federal Data Protection and Information Commissioner (FDPIC) where required under Article 24 of the revised FADP, or the relevant EU supervisory authority within 72 hours where required under Article 33 of the GDPR;

Inform affected individuals without undue delay where there is a high risk of harm, providing clear information about the nature of the breach and the steps being taken.

Analytics cookies on this Website are only placed with your prior explicit consent.
The following analytics tools are in use:

Google Analytics (Google LLC)
– Purpose: Measures website traffic, user behaviour, page performance, and referral sources.
– Data collected: Anonymised/pseudonymised IP address, browser type, device type, pages visited, session duration, referral source.
– Data transfer: United States. Safeguard: EU Standard Contractual Clauses (SCCs).
– Retention: Up to 14 months (configurable; set at default).
– More information: policies.google.com/privacy

Microsoft Clarity (Microsoft Corporation)
– Purpose: Provides session recordings and heatmap data to help understand how users navigate the Website, where they click, and how far they scroll. No keystrokes or passwords are recorded.
– Data collected: Mouse movements, clicks, scrolling behaviour, session replays, device and browser type.
– Data transfer: United States. Safeguard: SCCs.
– Retention: Up to 90 days.
– More information: privacy.microsoft.com

7. Supervisory Authorities

For Swiss users, the competent supervisory authority for data protection matters is:

Federal Data Protection and Information Commissioner (FDPIC)

Feldeggweg 1, CH-3003 Bern, Switzerland

www.edoeb.admin.ch

EU and EEA users may contact the supervisory authority in their member state of habitual residence. A directory of EU supervisory authorities is available at edpb.europa.eu.

8. Continuous Improvement

Data protection is an ongoing commitment, not a one-time exercise. We review our privacy practices regularly, apply a privacy-by-design and privacy-by-default approach to any new service or tool we introduce, and update this statement and our Privacy Policy whenever our processing activities or applicable law changes.

9. Contact Us

Questions about data protection, this statement, or how we handle your personal data?

Janine Hugo

Canton Vaud, Switzerland

Website: www.janinehugo.com

Contact: via the contact form at www.janinehugo.com