Privacy Policy
This Privacy Policy ("Policy") applies to the processing of your personal data by Cambrian KlG ("Cambrian", "we" or "us") through www.cambrian-group.com (the "Website"), in accordance with the Swiss Federal Act on Data Protection ("FADP") and, where it applies to visitors in the European Economic Area, Regulation (EU) 2016/679 (the "GDPR") and Directive 2002/58/EC (the "ePrivacy Directive").
1. Data controller
The data controller is Cambrian KlG, a partnership organised under Swiss law with its registered office at In der Luberzen 25, 8902 Urdorf, Switzerland (UID CHE-438.228.973). For any request regarding the processing of your personal data, or about this Policy, email us at info@cambrian-group.com. We have not appointed a data protection officer, as none is required for our processing.
2. Categories of personal data, purposes and legal bases
We process the following categories of personal data, for the purposes and on the legal bases indicated below. The Website has no accounts and no comment functions. Its only forms are the newsletter sign-ups described in Section 2.f, one of which also asks for an Instinct invite; beyond that, what we process is limited to what your browser transmits and what you choose to send us.
| Purpose | Legal basis | Categories of processed data |
|---|---|---|
| a. To deliver and secure the Website. | Our legitimate interest in operating the Website securely (art. 6(1)(f) GDPR, where applicable). | Technical connection data processed in our hosting provider's server logs, such as your IP address, browser details and the pages requested. |
| b. To respond to messages and requests you send us. | Taking steps at your request prior to entering into a contract, and our legitimate interest in answering you (art. 6(1)(b) and (f) GDPR, where applicable). | The identification and contact information you provide, such as your name and email address, and the content of your message. |
| c. To comply with our legal obligations and instructions received from the authorities. | Compliance with a legal obligation to which we are subject (art. 6(1)(c) GDPR, where applicable). | Any information necessary for these purposes. |
| d. To establish, exercise or defend our rights, and to carry out corporate transactions, for example a merger, reorganisation or sale of assets, including related due diligence. | Our legitimate interest in protecting our rights and conducting our business (art. 6(1)(f) GDPR, where applicable). | Any information necessary for these purposes. |
| e. To understand how the Website is used, through Google Analytics. | Your consent (art. 6(1)(a) GDPR and art. 5(3) ePrivacy Directive, where applicable). Nothing is requested from Google before you agree. | Your truncated IP address, pages viewed, approximate location, device and browser characteristics, referring pages, and the dates and times of your visits. |
| f. To send you the newsletter you asked for: new articles, products and announcements from Cambrian, once you have confirmed your address. If you ask for an Instinct invite on the Instinct skills page, also to show you the invite link after you confirm, while invites remain. | Your consent (art. 6(1)(a) GDPR, where applicable), given in the sign-up form and confirmed through the link we email you. You can withdraw it at any time with the unsubscribe link in every email. | Your email address, your first name if you give it, the page you signed up on, the wording you agreed to, and when you signed up, confirmed or unsubscribed; if you ask for an Instinct invite, when you asked and when the invite link was first shown to you. |
| g. To protect the sign-up forms from automated abuse. | Our legitimate interest in keeping the forms, and the emails we send from them, secure (art. 6(1)(f) GDPR, where applicable). | Browser and connection signals checked by Cloudflare Turnstile, which loads only once you start using a form, and a keyed one-way hash of your IP address that we use to limit sign-ups from one connection and, if you ask for an Instinct invite, to give one invite per connection. |
For how we process personal data through cookies and similar technologies, see Section 8 (Cookies) below.
3. Data retention
We keep personal data no longer than the purpose it was collected for requires. Specifically:
- Technical connection data (Section 2.a) is held in our hosting provider's server logs for a limited period as part of operating the service securely.
- Correspondence (Section 2.b) is kept for as long as needed to handle your request and any follow-up to it.
- Data processed under Sections 2.c and 2.d is kept for as long as the obligation or matter concerned requires.
- Analytics data (Section 2.e) is processed until you withdraw your consent; the associated cookies last at most 2 years, as listed in the Cookie Policy.
- Newsletter data (Section 2.f) is kept while you are subscribed. If you unsubscribe, we keep only your email address and the dates of your sign-up and unsubscribe, so that we do not write to you again, and, if you received an Instinct invite, the date it was shown to you, so that the number of invites given stays correct. A sign-up that is never confirmed is deleted within 30 days.
- The hashed IP address (Section 2.g) is deleted when you confirm your subscription, and in any case within 30 days. If you asked for an Instinct invite, a hash of the address you asked from is kept from your confirmation until the invite offer ends or all invites are taken, so that each connection gets one invite.
We take technical and organisational measures designed to prevent the loss, improper use and alteration of personal data. Transmissions over the internet are never completely secure, however, and you should not send us anything you want to carry no risk at all.
4. Your choices
Technical connection data is inherent to visiting any website. Everything else is your choice: analytics runs only if you accept it, declining changes nothing about how the Website works, and you can change or withdraw your answer at any time using Cookie Settings at the foot of every page. Information you send us by email is shared at your own initiative. The newsletter is opt-in: nothing is sent until you confirm your address, and every email carries a link to unsubscribe.
5. Sharing your personal data
We may share personal data with the following categories of recipients:
- service providers carrying out activities instrumental to operating the Website, acting as processors: our hosting provider (Vercel Inc.); for the newsletter, our database provider (Neon, which stores sign-ups in Frankfurt, Germany), our email delivery provider (Resend) and Cloudflare, Inc., which runs the sign-up form's bot check; only after your consent, our analytics provider (Google LLC); together with the IT and email providers we use to run the business;
- public, judicial or police authorities, within the limits established by applicable law;
- in the event of a corporate transaction, such as a merger, reorganisation or sale of assets, our advisors and the potential counterparties, in which case personal data may form part of the assets transferred.
The landscape on the homepage is drawn from an elevation file hosted with the Website. Only if that file cannot be loaded does your browser request public elevation tiles directly from Amazon Web Services, Inc. (the AWS Open Data programme), which, like any web server, receives your IP address and browser details with the request. We receive nothing from those requests.
We do not sell personal data, and we do not disclose it for any reason other than those above unless disclosure is required by law or we ask for your consent.
6. Transfers outside Switzerland and the EEA
Our hosting, newsletter and analytics providers, and Amazon Web Services in the fallback case described in Section 5, are established in the United States and may process personal data there, although newsletter sign-ups themselves are stored in Frankfurt, Germany. Such transfers rest on appropriate safeguards under the FADP and, where applicable, the GDPR: an adequacy decision covering the recipient, including certification under the Swiss-U.S. and EU-U.S. Data Privacy Frameworks where the provider holds it, or the standard contractual clauses developed by the European Commission. More information about these transfers is available by writing to info@cambrian-group.com.
7. Your rights
At any time and free of charge, subject to the limitations and exceptions of applicable law, you can exercise the following rights:
- Access. Obtain information about the processing of your personal data and a copy of it.
- Rectification. Ask for your personal data to be updated, corrected or completed.
- Erasure. Request the deletion of your personal data.
- Restriction. Request that the processing of your personal data be restricted.
- Portability. Obtain a portable electronic copy of personal data you have provided.
- Objection. Where we rely on legitimate interest, object to the processing on grounds relating to your situation.
- Withdrawal of consent. Where we rely on your consent, withdraw it at any time; processing carried out before the withdrawal remains valid.
You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, where the GDPR applies, with the data protection authority of your habitual residence, place of work or the place of the alleged infringement. To exercise your rights, write to info@cambrian-group.com or to the postal address above; we may take reasonable steps to verify your identity before responding.
8. Cookies
The Website uses strictly necessary browser storage entries, which remember your consent answer, that the opening animation has played and, on the Instinct skills page, that you closed or used the sign-up pop-up; a strictly necessary security check by Cloudflare Turnstile, loaded only when you use the newsletter sign-up form; and, solely after you accept, the Google Analytics cookies. It sets no advertising or profiling cookies and does not track you across other websites. Every entry is listed by name, with its purpose, duration and provider, in the Cookie Policy, which also explains how to manage or delete cookies in your browser.
9. Changes
We may modify or update this Policy, including to reflect changes in applicable law or new features that process personal data. If what we ask consent for changes, a previously stored answer is treated as expired and you are asked again. The date at the top of this page shows when it was last revised.
Contact
Questions about this Policy: info@cambrian-group.com, or by post: Cambrian KlG, In der Luberzen 25, 8902 Urdorf, Switzerland (UID CHE-438.228.973).
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