Privacy Policy

01

Who we are

This policy explains how Somcommerce GmbH ("Somcommerce", "we", "us") handles personal data. We are the controller for the data described here.

We process personal data in line with the Swiss Federal Act on Data Protection (FADP) and, where it applies to you, the EU and UK General Data Protection Regulation (GDPR).

02

What we collect

Data you give us

• When you contact us: your name, email address, company and anything you write in your message.
• When you book a call: your name, email, company, website and the answers you give in the booking form.
• When you apply for a job: your CV, portfolio, links and anything else you send with your application.
• When you become a client: the contact and billing details we need to run the engagement.

Data collected automatically

When you visit the website, our hosting provider records standard technical data such as your IP address, browser type, device, the pages you request and the time of the request. This is needed to deliver the website securely and is not used to profile you.

03

How we use it

• To reply to your messages and hold the calls you book.
• To prepare proposals and deliver our services to clients.
• To review job applications and run our hiring process.
• To keep the website secure, working and free of abuse.
• To meet our legal, tax and accounting obligations.
• To send you occasional updates about our services if you are a client or have asked us to. You can opt out at any time.

We do not sell personal data and we do not use it for automated decisions that have legal or similarly significant effects on you.

04

Our legal basis

Where the GDPR applies, we rely on:

• Contract: to take steps you ask for before a contract, and to perform our contract with you.
• Legitimate interests: to run, secure and improve our business and website, and to reply to enquiries.
• Legal obligation: to keep records required by law.
• Consent: where we ask for it, for example to keep your application for future roles. You can withdraw consent at any time.

05

Who we share it with

We share personal data only with providers that help us run the business, under agreements that require them to protect it, and only as much as they need:

• Webflow, which hosts this website.
• Calendly, which runs our call booking page.
• Google Workspace, for email and documents.
• Our accounting, legal and professional advisers, where needed.
• Authorities, where the law requires it.

If we work with you as a client, data you give us access to (for example in your ad accounts) is handled under our client agreement, and we process it only on your instructions.

06

International transfers

Some of our providers are based in, or store data in, the United States and other countries. Where a country does not offer a level of protection recognised as adequate by Switzerland or the EU, we rely on safeguards such as the Swiss-US and EU-US Data Privacy Frameworks or the European Commission's Standard Contractual Clauses.

07

How long we keep it

• Enquiries and booked calls that do not lead to a project: up to 24 months.
• Client records: for the length of the engagement and then as long as the law requires, generally 10 years for accounting records in Switzerland.
• Job applications: up to 6 months after the role is filled, or longer if you agree that we can keep them for future roles.
• Technical logs: kept by our hosting provider for a short period, in line with its own retention rules.

08

Your rights

Depending on where you live, you have the right to:

• Ask what personal data we hold about you and get a copy.
• Ask us to correct data that is wrong or incomplete.
• Ask us to delete your data, or to restrict how we use it.
• Object to processing based on our legitimate interests, including direct marketing.
• Receive your data in a portable format.
• Withdraw consent at any time, where we rely on consent.

To use any of these rights, email matteo@somcommerce.com. We will reply within 30 days. You also have the right to complain to a data protection authority: in Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC), and in the EU it is the authority in your country.

09

Security

We use access controls and encrypted connections to protect personal data, and we limit access to the people who need it to do their job. No system is perfectly secure, but we take reasonable steps to protect your data and will tell you if a breach puts you at high risk.

10

Cookies

This website does not use advertising or analytics cookies. Our booking page loads Calendly, which may set its own cookies. Webflow, our hosting provider, may set technical cookies needed to deliver the site securely. You can block or delete cookies in your browser settings at any time. If we ever add analytics or advertising tools, we will ask for your consent first and update this policy.

11

Changes to this policy

We may update this policy as our business or the law changes. We will post the new version on this page and tell clients directly about any important change.