1. Introduction

This Privacy Policy explains how Mária Bordáné Móré, trading as Móré Creative Arts (“I”, “we”, or “the data controller”), operating the Slow Cubing coaching website at slowcubing.ch, collects, uses, stores, and protects your personal data.

This policy is issued in accordance with the Swiss Federal Act on Data Protection (nDSG/revDSG, in force since 1 September 2023) and, where applicable, the European Union General Data Protection Regulation (GDPR). As this website offers services to visitors from Switzerland and the EU, both frameworks apply.

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2. Identity of the Data Controller

Legal name: Mária Bordáné Móré

Trading as: Móré Creative Arts (Slow Cubing)

Legal form: Sole proprietorship (entreprise individuelle), Switzerland

Address: Chemin Falconnier 5, 1260 Nyon, Switzerland

Email: csaba@slowcubing.ch

Móré Creative Arts is a sole proprietorship owned by Mária Bordáné Móré. As the business currently operates below the CHF 100,000 annual revenue threshold, it is not registered in the Swiss Commercial Register, and therefore has no separate UID/CHE number. Under Swiss law, the data controller for this website is the natural person Mária Bordáné Móré, operating under the trading name Móré Creative Arts.

No Data Protection Officer (DPO) has been appointed, as this is not legally required for a sole proprietorship of this size.

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3. Personal Data Collected

Depending on how you interact with this website, I collect the following categories of personal data:

3.1  Contact form

• Name
• Email address
• Phone number
• Message content

3.2  Newsletter subscription

• Name
• Email address
• Subscription preferences and engagement data

3.3  Booking & coaching sessions

• Name and email address
• Preferred session date and time
• Time zone (where provided)
• Any information you voluntarily share before or during a session

3.4  Payment processing

• Billing name and email
• Payment details (processed directly by Stripe — I do not store card data)

3.5  Website analytics

• Anonymised or pseudonymised IP address
• Browser and device type
• Pages visited, session duration, referral source
• Cookie identifiers set by Google Analytics

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4. Purposes and Legal Basis of Processing

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4.1  Responding to enquiries (contact form)

Purpose: To respond to your message.

Legal basis: Legitimate interest (nDSG Art. 31; GDPR Art. 6(1)(f)) — I have a legitimate interest in communicating with people who contact me.

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4.2  Newsletter

Purpose: To send you updates, articles, and offers related to Slow Cubing.

Legal basis: Consent (nDSG Art. 31; GDPR Art. 6(1)(a)). You may withdraw consent at any time by clicking 'Unsubscribe' in any email.

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4.3  Booking & coaching sessions

Purpose: To schedule, confirm, and deliver coaching sessions.

Legal basis: Performance of a contract (GDPR Art. 6(1)(b); nDSG Art. 31).

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4.4  Payment processing

Purpose: To process payments for coaching sessions.

Legal basis: Performance of a contract and compliance with a legal obligation (Swiss Code of Obligations; GDPR Art. 6(1)(b) and (c)).

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4.5  Website analytics

Purpose: To understand how visitors use the site and to improve content and usability.

Legal basis: Consent, obtained via the cookie banner presented on your first visit (GDPR Art. 6(1)(a); nDSG Privacy-by-Default principle, Art. 7).

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5. Retention Periods

• Contact enquiries: retained for 2 years after last correspondence, then deleted.
• Newsletter data: retained until unsubscription, then deleted within 30 days.
• Booking records and payment invoices: retained for 10 years in accordance with Swiss accounting obligations (Code of Obligations, Art. 958f).
• Analytics data: retained for 14 months as configured in Google Analytics, then automatically deleted.
• Cookies: see Section 7 for specific cookie lifetimes.

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6. Third-Party Processors and International Data Transfers

I work with the following third-party service providers who process personal data on my behalf:

6.1  Google Analytics (Google LLC, USA)

• Purpose: website analytics and usage statistics
• Data transfer: USA — covered by Google's Standard Contractual Clauses (SCCs) with the EU Commission
• More info: policies.google.com/privacy

6.2  Calendly (Calendly LLC, USA)

• Purpose: scheduling and booking of coaching sessions
• Data transfer: USA — covered by SCCs
• More info: calendly.com/privacy

6.3  Stripe (Stripe Inc., USA / Stripe Payments Europe, Ireland)

• Purpose: payment processing
• Data transfer: USA/EU — covered by SCCs and EU adequacy frameworks
• More info: stripe.com/en-ch/privacy

6.4  Mailchimp / Brevo

• Purpose: newsletter dispatch and list management
• Mailchimp (Intuit Inc., USA): data transfer covered by SCCs
• Brevo (Sendinblue SAS, France): data stored in the EU
• More info: mailchimp.com/legal/privacy / brevo.com/legal/privacypolicy

Switzerland has been confirmed as providing an adequate level of data protection by the European Commission (January 2024). Data transfers from the EU to Switzerland therefore do not require additional safeguards.

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7. Cookies

This website uses cookies. A cookie is a small file stored on your device that helps the website function and understand how it is used.

7.1  Strictly necessary cookies

These enable core site functions (security, session management). They are set without consent and cannot be disabled.

7.2  Analytics cookies (consent required)

Google Analytics sets cookies (_ga, _gid, _gat) to collect anonymised usage data. These are only activated after you give consent via the cookie banner.

7.3  Functional cookies (consent required)

Calendly and other booking tools may set cookies to remember your preferences and session state.

7.4  Managing your preferences

You can change or withdraw your consent at any time via the cookie settings link in the website footer. You may also configure your browser to block or delete cookies, though this may affect site functionality.

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8. Your Rights

Under the nDSG and GDPR, you have the following rights:

• Right of access — request a copy of the personal data I hold about you (nDSG Art. 25; GDPR Art. 15)
• Right to rectification — ask me to correct inaccurate data (GDPR Art. 16)
• Right to erasure — ask me to delete your data (GDPR Art. 17)
• Right to restriction — ask me to limit how I process your data (GDPR Art. 18)
• Right to data portability — receive your data in a structured, machine-readable format (GDPR Art. 20)
• Right to object — object to processing based on legitimate interest, including direct marketing (GDPR Art. 21)
• Right to withdraw consent — at any time, without affecting the lawfulness of prior processing
• Right to lodge a complaint — with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch, or with your local EU supervisory authority

To exercise any of these rights, please contact me at: csaba@slowcubing.ch. I will respond within 30 days.

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9. Security

I implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. These include HTTPS encryption, access controls, and data minimisation practices. Third-party processors are selected based on their demonstrated security standards.

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10. Links to Other Websites

This website may contain links to third-party websites. I am not responsible for the privacy practices of those sites and encourage you to review their own privacy policies.

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11. Changes to This Policy

I may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. For significant changes, I will notify subscribers by email.

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12. Contact

For any questions, requests, or complaints regarding your personal data, please contact:

Mária Bordáné Móré, Móré Creative Arts — csaba@slowcubing.ch