This text is a draft and has not yet been reviewed by a lawyer. Details in square brackets are still to be completed.
Overview
This policy explains which personal data One Choice processes, why, and what rights you have. It covers this website, the One Choice app, which picks one place to eat, drink, go out at night or do something, and the dashboard for venues. We process personal data under the Swiss Federal Act on Data Protection (FADP) and, where it applies to people in the European Union or the EEA, the General Data Protection Regulation (GDPR).
In short: this website sets no tracking cookies and runs no analytics. The app processes what it needs to pick one place for you, and we sell no personal data.
Who is responsible
The controller is:
[Legal entity name, e.g. Illyronix GmbH]
[Street and number, postcode and town, Switzerland]
For people in the EU and EEA, our representative under Article 27 GDPR is: [Name and address of the EU representative, Art. 27 GDPR].
Write to info@illyronix.com with any question about your data or to exercise your rights.
This website
This website is a set of static pages. It has no sign-in and no comments. Its only form is the waitlist sign-up, described under “Newsletter and waitlist”.
It sets no cookies: none for tracking, none for advertising, none for analytics. It has no social media plugins and no third-party embeds. Fonts, images and videos come from this site itself, not from Google or anyone else.
The language you choose is part of the address (/de, /fr, /it, /en). On the bare address we read your browser's language setting once to send you to the right version, and we don't store it.
The site is hosted by Netlify, Inc. (USA), which delivers it from servers around the world. To deliver the pages and protect them from abuse, Netlify records technical data in server logs: IP address, date and time, the page requested, the referring page, browser and operating system. These logs are used only for security and troubleshooting and are deleted after a short period.
Links to the venue dashboard and to the app stores lead to other services, with their own privacy information.
Legal basis (GDPR): our legitimate interest in a secure, working website (Art. 6(1)(f)).
Your app account
To create an account you give us a phone number or an email address, to which we send a one-time sign-in code or link. We also store the name and username you choose, an optional profile photo, your language and your date of birth.
We ask for your date of birth to check your age: bars, clubs and other places for adults are only suggested to people aged 18 or over. Your age is worked out when it is needed and is never shown to other users.
Legal basis (GDPR): performance of our contract with you (Art. 6(1)(b)).
Location
With your permission, the app uses your device's location to find places near you. You can refuse or withdraw this permission in your device settings at any time; the app then works from a place you enter yourself.
The location sent with a request is stored with that recommendation, so we can explain and improve the pick and keep the service secure. The app does not track your location in the background.
Legal basis (GDPR): your consent (Art. 6(1)(a)).
Requests, taste and recommendations
To pick one place we use what you ask for, who you are with, the places you save, accept, skip and review, and the preferences you set. Each recommendation is recorded with its inputs and the places considered, so we can explain why a place was chosen, measure quality and correct mistakes.
If you tell us about dietary needs or allergies, this can reveal information about your health. We use it only to leave out places that don't fit, never for ranking or advertising, and only with your explicit consent, which you can withdraw in the app.
Legal basis (GDPR): performance of contract (Art. 6(1)(b)); for dietary and health information, your explicit consent (Art. 9(2)(a)).
Contacts and friends
If you allow access to your address book, the app sends the phone numbers in it over an encrypted connection, and we immediately replace each one with a keyed hash. We never store your contacts' numbers or names in readable form. The hashes are used only to show you which of your contacts already use One Choice. You can withdraw access at any time.
Friends are people you add, or people you share a group with. You can block anyone.
Legal basis (GDPR): your consent for the address book (Art. 6(1)(a)); performance of contract for friends (Art. 6(1)(b)).
Posts, stories, groups and chat
What you publish is processed so that it can be shown to the people it is meant for:
Posts and reviews, with their photos, appear on your profile and on the venue's page.
Stories are visible to signed-in users for 24 hours, then disappear.
Group plans and chat messages are visible to the members of that group.
Photos and other media are stored with our hosting provider in Frankfurt (Germany). We review content that is reported to us and remove what breaks our terms of use.
Legal basis (GDPR): performance of contract (Art. 6(1)(b)); for moderation, our legitimate interest in a safe service (Art. 6(1)(f)).
Venues and the venue dashboard
Venue pages start from public information about the place and from photos guests have taken there. Venues that claim their page use the dashboard with a business account. For it we process the name and email address of the people who sign in, the venue's details, posts, menus, campaigns and invoices. Venues see counts per day, never which guests they were.
Paid features for venues will be paid through Stripe. Card and payment details go directly to Stripe; we never see full card numbers. Stripe processes them under its own privacy policy, partly in the USA.
Legal basis (GDPR): performance of contract (Art. 6(1)(b)); legal obligations such as bookkeeping (Art. 6(1)(c)).
Messages and notifications
We send sign-in codes, service messages and, if you allow them, push notifications. Push notifications are delivered through Apple (iOS) or Google (Android). Emails and text messages are sent through [Email and SMS providers for sign-in codes]. You can turn push notifications off in your device settings at any time.
Newsletter and waitlist
If you join the waitlist on this website, or switch on “News and picks by email” in the app, we email you about the launch in your city and, now and then, about places worth going to. Venue accounts can choose to receive product news.
What we store: your email address, your language, the city you chose, whether you signed up as a guest or a venue, where you signed up, and when you gave and confirmed your consent.
Double opt-in: we first send a link to confirm the address. Nothing else is sent until you open it, and a sign-up that is never confirmed is deleted after [period, e.g. 30 days].
Legal basis: your consent, which you can withdraw at any time.
The emails are sent through Brevo (Sendinblue SAS, France), which processes the data on our behalf on servers in the EU. Brevo records whether an email was delivered and may record whether it was opened or a link clicked; we use this only to see which emails are useful.
Unsubscribe anytime: every email has a link to unsubscribe, you can switch it off in the app's settings, or write to info@illyronix.com. We then stop at once and keep only what we need to respect your choice.
Service providers and transfers abroad
We work with service providers who process data on our behalf and on our instructions:
Amazon Web Services: hosting of the app, its database and media in the Frankfurt region (Germany, EU).
Netlify, Inc.: hosting of this website (USA).
Stripe: payments for venues, once paid features start.
[Email and SMS providers for sign-in codes]: sign-in codes and service messages.
Brevo (Sendinblue SAS, France, EU): newsletter and waitlist emails, only if you sign up.
Apple and Google: delivery of push notifications.
We do not sell personal data and do not pass it to advertisers. Sponsored suggestions are labelled, and the venue never learns who saw them.
Germany and the EU offer adequate data protection under Swiss law. Where data goes to the USA, we rely on the Swiss-US and EU-US Data Privacy Framework where the recipient is certified, and otherwise on standard contractual clauses recognised by the European Commission and the FDPIC.
How long we keep data
We keep personal data only as long as we need it for the purposes above:
Your account and what you published: until you delete your account. Backups are overwritten within [backup period, e.g. 30 days].
Recommendation records: [retention period, e.g. 24 months], then they are deleted or anonymised.
Server and security logs: [log period, e.g. 30 days].
Invoices and bookkeeping records: 10 years, as Swiss law requires.
You can delete your account in the app at any time.
Your rights
You have the right to:
know whether we process personal data about you, which data, and receive a copy;
have incorrect data corrected;
have your data deleted;
receive the data you gave us in a common, machine-readable format;
object to processing based on our legitimate interests, and ask us to restrict processing;
withdraw any consent at any time, without affecting what was done before.
Write to info@illyronix.com. We may ask you to confirm your identity. You can also complain to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch), in the EU the authority of the country where you live.
Automatic recommendations
One Choice picks a place automatically. The pick is a suggestion, not a decision with legal or similarly significant effects on you: you can always ask again, skip it or go somewhere else. A place can be left out because of hard requirements, such as dietary needs or an age limit.
Age
One Choice is meant for people aged [16] and over. We do not knowingly process data of younger children. Places for adults only are suggested to users aged 18 and over.
Security
Data travels encrypted (HTTPS). Contact numbers are stored only as keyed hashes, staff passwords only as hashes, and access to production systems is limited to the people who need it. No system is perfectly secure: if a breach puts your data at high risk, we will inform you and the authorities as the law requires.
Changes to this policy
We update this policy when One Choice or the law changes. The date at the top shows the current version; we will tell you about important changes in the app.
