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Privacy Policy

1. Data Controller

The entity responsible for processing your personal data is 1A3D GmbH, 8172 Niederglatt, Switzerland (Email: contact@roger-bachmann.ch).

2. Scope

This Privacy Policy governs data collection via our website, webstore, members area, the AI-powered tools available to members, and through the execution of our professional services (coaching, CV editing, job application support).

3. Categories of Data Processed

We process identity data, contact details, payment information, sensitive professional documents (CVs, cover letters, employment history), technical tracking data, and communication logs.

4. Purposes of Processing

Data is used exclusively to fulfil our contractual duties, provide access to AI tools, manage billing, ensure website security, and comply with legal accounting obligations.

5. Legal Basis (GDPR & FADP)

We process data based on contractual necessity, legal obligations, legitimate business interests (security), and user consent where explicitly required.

6. Manual Handling of CVs by the Operator

In addition to the automated CV Analyser described in Section 7, Roger Bachmann may review CVs manually as part of coaching and job application support services. This section describes how that manual process handles your data.

CVs reach the operator in two ways: as attachments to emails sent directly to contact@roger-bachmann.ch, and as files reviewed or edited locally during coaching engagements. These files are stored on the operator's personal laptop and backed up to Microsoft OneDrive.

The operator works from Switzerland and, at times, from other locations both within and outside the European Economic Area. CVs stored on the laptop may therefore be accessed from outside Switzerland and outside the EU/EEA during business travel, even though the underlying data remains stored in Switzerland as described below.

All email communication, including CVs received as attachments, is handled through Microsoft 365 (Exchange Online), with a committed data storage location of Switzerland. Incoming email may pass through automated malware and spam filtering hosted elsewhere in the EU/EFTA region before delivery, a standard, transient security step that does not involve storage of the message content outside that filtering process. Backups of CV files are held on Microsoft OneDrive, also with a committed data storage location of Switzerland, and are encrypted at rest as standard for the Microsoft 365 platform.

CVs and related correspondence handled through this manual process are retained in accordance with Section 11 below.

You may request access to, correction of, or deletion of CVs and correspondence held under this manual process by contacting contact@roger-bachmann.ch.

7. AI-Powered Career Tools and Data Processing

Career Hub Switzerland gives members access to tools built on Anthropic's Claude AI model: Currently the CV Analyser and Interview Prep. These tools work differently and carry different data handling profiles. Read the subsection for the tool you are using.

7.1 CV Analyser

When you use the CV Analyser, the text extracted from your uploaded CV, and from a job description if you provide one, is sent to Anthropic for analysis.

If you upload a Word document (.docx), the extracted text passes through an automated filter that attempts to remove email addresses, phone numbers, postal address lines, postcodes, and your name before transmission. If you upload a PDF, the file is sent to Anthropic as a complete document for direct analysis, and no automated filtering is applied to it. In neither case is filtering guaranteed to catch every identifier.

You are responsible for what your CV contains before you upload it. Remove any personal data you do not want processed by the AI, including a photo, before uploading your file. This is stated in plain language in the tool itself before you upload.

We do not store the content of your CV on our servers. The extracted text exists only for the duration of the request to Anthropic and is discarded once the analysis is returned to you.

Each time you use the CV Analyser, we record that you gave consent: your member account, the date and time, your IP address, and the version of this notice you agreed to. We do not record what was in your CV. This record exists to demonstrate that consent was obtained before processing, and is retained for the duration of your membership plus a reasonable period afterward.

Use of the CV Analyser is limited to a set number of uses per member account.

7.2 Interview Prep

Interview Prep is a conversational coaching tool. It does not require, accept, or process a CV.

Interview Prep applies no automated filtering to what you type. Whatever you enter into the chat, including names, employers, salary figures, or personal circumstances you choose to share, is sent to Anthropic exactly as written, with no redaction step.

You are responsible for what you type into Interview Prep. Do not enter sensitive personal data (health information, financial account details, national identification numbers, or personal data belonging to other people) into the chat. Treat the chat as you would any message sent to a third party.

We do not store your Interview Prep conversation on our servers. Conversation history exists only in your browser for the duration of your session and is cleared when you reset the chat or leave the page.

7.3 Where and how Anthropic processes this data

Both tools call Anthropic's Claude API, which processes requests in the United States. Anthropic's standard policy for API data is that prompts and responses are not retained by default beyond what is technically necessary to operate the service and to screen for misuse under its usage policy. Content flagged by Anthropic's automated safety systems may be retained for a longer period under Anthropic's own policies, independent of anything Career Hub Switzerland controls.

Career Hub Switzerland does not operate or control Anthropic's infrastructure and relies on Anthropic's published data handling commitments, available at Anthropic's Trust Center and Privacy Center. If your use of these tools requires assurances beyond what is stated here, such as a signed Data Processing Agreement for your own compliance purposes, contact us before use.

8. Liability Disclaimer for AI-Powered Tools

Automated systems, including the CV Analyser's identifier-stripping filter, are imperfect. 1A3D GmbH does not guarantee complete anonymisation of any data submitted to the CV Analyser, and applies no filtering at all to Interview Prep.

You use both tools entirely at your own discretion and risk. 1A3D GmbH disclaims liability for personal data that bypasses the CV Analyser's filter, and for any personal data you choose to enter into Interview Prep, to the fullest extent permitted by applicable Swiss law. This disclaimer does not exclude liability for damages caused by gross negligence or wilful misconduct on the part of 1A3D GmbH, which cannot be excluded under Article 100 of the Swiss Code of Obligations.

9. Third-Party Service Providers

We do not sell your data. We use the following third-party providers, each acting as a data processor under their respective data processing terms:

  • Microsoft 365 (Exchange Online, OneDrive): email communication and file backup, committed data storage location of Switzerland.
  • Anthropic: AI processing for the CV Analyser and Interview Prep, processed in the United States as described in Section 7.
  • Stripe: payment processing for membership purchases.
  • Brevo: delivery of transactional emails (account notifications, password resets, receipts). Brevo is not used for marketing communications.
  • Our web hosting provider: hosting of the Career Hub Switzerland website and members area.

We are in the process of confirming and documenting formal Data Processing Agreements with each provider listed above. Where a provider processes data outside Switzerland or the EEA, the safeguards described in Section 10 apply.

10. International Data Transfers

Email and file backups handled through Microsoft 365 are stored in Switzerland under a committed geography guarantee and do not constitute an international transfer under normal operation.

Where data is transferred outside Switzerland or the EEA, for example to Anthropic's or Stripe's servers in the United States, we rely on the legal safeguards made available by those providers, such as Standard Contractual Clauses or participation in the EU-U.S. Data Privacy Framework, as applicable and as published by each provider. We recommend reviewing each provider's current certification status directly, as these frameworks are subject to legal and regulatory change.

11. Data Retention

Client documents and coaching notes handled manually under Section 6 are retained for twenty-four (24) months after the service they relate to has concluded, then deleted, unless you request earlier deletion or a longer retention period applies for record-keeping reasons.

The CV Analyser and Interview Prep do not store client content beyond what is described in Section 7. There is no CV or conversation content retained by these tools for the 24-month period to apply to.

Billing and transaction data are archived for ten (10) years in accordance with Swiss commercial law (Art. 958f of the Swiss Code of Obligations).

12. Your Data Subject Rights

You have the right to request access, rectification, erasure (Right to be Forgotten), restriction of processing, and data portability under the GDPR and FADP. Contact us at contact@roger-bachmann.ch to exercise these rights.

13. Cookies and Tracking

Essential cookies are used to maintain your session (e.g., in the webstore or members area). Non-essential tracking cookies are only placed if you provide explicit consent via our cookie consent banner.

14. Security Measures and Governing Law

We protect your data through access controls, encryption where applicable, and the data storage commitments described throughout this policy. This Privacy Policy is subject to change as technologies and laws evolve. It is governed exclusively by Swiss law.

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