Privacy Policy

Effective Data: August 1st, 2024

We, the A-Sharp Consulting GmbH (hereinafter, “A-Sharp Consulting GmbH” „we“, „us“, or „our“), operate the www.ajjazza.com website, the ajjazza mobile application, and the software application(s) that you receive or access in connection with your acquisition of an ajjazza learning package (the “Service”).

With this Privacy Policy, we describe how we collect and further process personal data when you use our Service. This Privacy Policy informs you of definitions and our policies regarding the collection, use, and disclosure of information in digital data form, including personal data, when you use our Service.This Privacy Policy is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

This Privacy Policy is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection («revDPA»). However, the application of these laws depends on each individual case.

Our website address is: https://www.ajjazza.com.

1. Definitions

The following table explains the terms used in this privacy policy.

Service	Service means the website www.ajjazza.com, the ajjazza mobile application and the software application(s) that you receive or access in connection with your acquisition of an ajjazza learning package.
Personal Data	Personal Data shall mean any information that identifies, or could reasonably be used to identify any person.
Usage Data	Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookie	A cookie is information that our website puts on a user’s device (computer, smartphone, tablet, etc). Cookies store limited information from a web browser session on our website that can then be retrieved during subsequent visits to recognize your device. They are also sometimes referred to as browser cookies, web cookies or internet cookies. Cookies serve various purposes, such as improving your browsing experience, remembering your preferences, and providing personalized content. They may also be used for analytical purposes to gather information about how users interact with the service, helping to enhance its functionality and performance.
Data Controller	Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)	Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)	Data Subject (or user) is any living individual who is using our Service and is the subject of Personal Data.

2. Collection and Processing of Data

2.1 Type of Data Collected

We collect several different types of data for various purposes to provide and improve our Service to you.

2.1.1 Personal Data

While using our Service, we may ask you to provide certain personally identifiable information (“Personal Data”) that allows us to identify or contact you. Personal Data may include:

Email address
First name and last name
Username (including preferred username and nickname, if applicable)

We process your Personal Data only where necessary, such as to provide and improve our Service, authenticate users, and communicate with you. With your explicit consent, we may also use your Personal Data to send you newsletters, marketing, or promotional materials. You can opt out of receiving such communications at any time by clicking the unsubscribe link in any email or following the provided instructions.

2.1.2 Usage Data

When you visit or use our Service, we may collect certain Usage Data that your browser or mobile device automatically sends to us. This data helps us improve our Service, analyze performance, and enhance user experience.

Usage Data may include:

Technical information: IP address, browser type, browser version, operating system, and mobile device type.
Interaction data: Pages visited, time and date of visits, time spent on pages, and user interactions (such as progress through a practice list).
Device identifiers: Unique device ID, mobile network information, and diagnostic data.

We collect this data to analyze trends, improve functionality, and ensure security. Where possible, we anonymize or aggregate this data to protect user privacy.

2.1.3 Cookies

We use cookies and similar tracking technologies to enhance your experience, analyze traffic, and improve our Service.

Types of cookies we use:

Essential Cookies: Necessary for authentication, security, and proper website functionality (e.g., AWS Cognito authentication cookies). These cannot be disabled.
Functional Cookies: Remember values of your last session in the application that allow to operate our Service more efficiently for you, e.g. last tab you used in the app, etc.
Analytical Cookies: Help us understand how users interact with our Service (e.g., pages visited, time spent). We use anonymized data where possible.

Managing Cookies:
You can control or disable cookies through your browser settings. However, disabling essential cookies may affect the functionality of our Service.

3. Purpose of Data Processing and Legal Grounds

In line with applicable law and where appropriate, we may process your personal data and usage data for various purposes, which are in our legitimate interest, such as:

providing and developing our products, services and websites, apps and other platforms, on which we are active
providing customer support to you in case of questions or incidents with our Service
notifying you about changes to our Service
ensuring our operation, including our IT, our websites, apps and other appliances
advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

4. Retention of Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations.

Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g. system logs).

We also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

5. Data Transfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of data processing set out in Section 4, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:

Our service providers, including processors (such as Amazon Web Services);
Suppliers, subcontractors, and other business partners;
Domestic and foreign authorities or courts;
The public, including users of our websites and social media;
Acquirers or parties interested in acquiring our business;
Other parties in possible or pending legal proceedings;

together “Recipients”.

We store and process user data on Amazon Web Services (AWS) cloud servers located in Zurich, Switzerland. In general, personal data remains within Switzerland.

However, AWS may, in some cases, process or back up data in other regions for security, performance, or technical reasons. In such cases, AWS ensures compliance with the Swiss Data Protection Act (nDSG) and the EU General Data Protection Regulation (GDPR). AWS relies on Standard Contractual Clauses (SCCs) and other appropriate safeguards to ensure data protection when transferring data internationally.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection regulations. For this purpose, we use the revised European Commission’s Standard Contractual Clauses (SCCs), which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj. This ensures that your data remains protected even when processed outside Switzerland.

By using our services, you acknowledge that your data may be processed outside of Switzerland where necessary.

6. Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, training, IT and network security solutions, access controls and restrictions.

7. Controller / Data Protection Officer

The “controller” of data processing as described in this privacy policy statement (i.e. the responsible person) is Christian Wyss. You can notify us of any data protection related concerns or questions using the following contact details: info@ajjazza.com.

Our representative in the EEA according to art. 27 GDPR (if required) is:
Christian Wyss
Limmattalstrasse 333
8049 Zürich, Switzerland
email: christian.wyss@a-sharp.ch.

8. Amendments of this Privacy Policy

We may amend this Privacy Policy at any time without prior notice. The current version published on our website shall apply. If the Privacy Policy Statement is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.