Privacy notice
Version 1.2 of 3 November 2026. Firnkern GmbH is in formation; registered office and commercial register details will follow after registration. The German version prevails.
1 Who is responsible?
The controller for the processing of personal data on firnkern.com, on the purchase page shop.firnkern.com, in the reporting service and for the Software's connections to Firnkern is Firnkern GmbH (in formation), Bosenhaldenweg 26, 4125 Riehen, Switzerland ("Firnkern", "we"). Contact for data protection questions: info@firnkern.ch or Marco Grieshaber, marco@firnkern.com. To the extent the GDPR applies, our representative in the EU is: none appointed at present.
2 What data do we process, for what purpose and for how long?
2.1 Visiting the website
When you access the website, our host stores technically necessary data (IP address, date and time, page accessed, browser, operating system, referrer) in server logs. Purpose: secure operation and troubleshooting. Retention period: at most 30 days. We do not set cookies for advertising or analytics purposes, no tracking pixels and no services that track your behaviour across websites. Fonts and films are hosted on our own server; no data is transmitted to video platforms when they are played.
2.2 Enquiry form and email
When you write to us, we process your details (name, company, email, telephone if provided, message) in order to answer your enquiry and, where applicable, prepare a quotation. Retention period: until the enquiry has been dealt with, at most 24 months, longer only in the case of a contract. If you choose the topic "Book", we keep your email only to inform you once when the book is published; we then delete it, at the latest after 24 months.
2.3 Download of the trial version
When you download the Software, the host stores the details described in 2.1. We do not require registration for the download.
2.4 Purchase page
When you place an order, we process company, name, billing address, email, where applicable UID/VAT number, order, licence number and payment status in order to perform the contract, deliver the licence key and keep our accounts. Retention period: 10 years (statutory retention of business records, Art. 958f CO).
When you pay by card or TWINT, we redirect you to Stripe (Stripe Payments Europe Ltd., Ireland, and affiliated companies, including in the USA). Stripe processes your payment data as an independent controller in accordance with its privacy terms (stripe.com/privacy). We do not see card data. When you choose "on invoice", no data flows to Stripe.
2.5 Reporting service, error reports and update check of the Software
The Firnkern Server software sends something to Firnkern only if the operation's admin switches this on:
- Feedback and reporting a problem: Before sending, you see exactly what is transmitted: your text, where applicable a screenshot that you select, the version of the Software, operating system, language, error location and time, optionally your email for follow-up questions. Dossier content is never transmitted.
- Automatic error reports (if switched on): technical details of the error (version, error location, program line, operating system), without content and without names.
- Update check (if switched on): The Software retrieves a list of the current versions; in doing so, our server receives the IP address and the version.
Purpose: remedy errors, improve the Software, provide updates. Retention period: reports until dealt with, at most 24 months; update check logs at most 30 days.
2.6 Other connections of the Software: speech and voice models (Hugging Face)
The Software runs on the operation's network. If a speech recognition or voice model is missing on the computer, the Software downloads it once from huggingface.co (Hugging Face, Inc., USA) and checks whether this address can be reached. Hugging Face receives the operation's IP address and technical details of the request, but no content from Firnkern. Firnkern receives none of this. Hugging Face processes this data as an independent controller in accordance with its privacy terms.
2.7 AI levels 2 and 3
Without add-ons, Firnkern works with AI on the operation's own computer (level 1); no content leaves the operation's network. The operation switches on level 2 and level 3 only if it wants to:
- Level 2: AI service of Infomaniak (Infomaniak Network SA, Geneva, Switzerland), Mistral model, operated in Geneva.
- Level 3: Anthropic (Anthropic, PBC, USA). Data may be transferred to the USA.
The operation uses its own account with the respective provider. The operation is the controller; the provider processes the data under its terms. Firnkern does not receive this content. Please direct questions on this to your employer.
2.8 Invitations and private devices
When an operation invites employees to Firnkern, the inviting person sends the message themselves – by email, QR code, SMS or WhatsApp. With SMS and WhatsApp, name, name of the operation and the personal link pass through the respective provider (for WhatsApp: Meta). Firnkern does not store any phone number. Whether employees use a private device is governed by the operation; Firnkern provides a template for this.
2.9 Cloud operation and AI via Firnkern
Note (as of 6 November 2026): Cloud operation is not currently offered (in preparation), and «AI via Firnkern» is not yet running. This section only applies once Firnkern offers these services.
For data that we process on behalf of a customer (cloud operation, AI via Firnkern), the Customer is the controller; we process it in accordance with the data processing agreement (DPA). Please direct questions on this to your employer.
2.10 AI assistant «Ask Firnkern»
On our website you can ask an AI assistant questions about Firnkern. Your question and the previous course of the conversation (at most six messages) are sent encrypted via our server to Infomaniak Network SA (data centre in Geneva, Switzerland), where an open language model (currently Qwen) generates the answer. According to Infomaniak, requests are neither stored nor used for training. We store neither your questions nor the answers nor your IP address. To prevent misuse we count requests using a pseudonymised counter (hash with a key that changes daily), which is deleted after two days at the most. The conversation remains in your browser only until you close the browser tab (sessionStorage). Please do not enter personal data. Answers are generated automatically and may be wrong; only what we confirm in writing is binding. The purpose is to answer your question; where the GDPR applies, we rely on our legitimate interest (Art. 6(1)(f) GDPR).
Voice input: If you tap the microphone button in the assistant, your browser first asks for permission to use the microphone. The speech recognition of your browser or operating system then converts your spoken question into text – depending on the device, on the device itself or on servers of the respective provider (e.g. Apple or Google), under that provider’s privacy terms. We do not receive any audio recording, only the text that you then send yourself. The microphone is never used unless you tap the button. Alternatively, you can use the dictation function of your phone keyboard.
2.11 Replies to e-mails with AI support
When you write to info@firnkern.ch, an AI assistant may read your e-mail and propose or send a reply based on the content of firnkern.com. For this, the text of your e-mail is sent encrypted to Infomaniak Network SA (data centre in Geneva, Switzerland); according to Infomaniak, requests are neither stored nor used for training. Automatic replies are marked as such. Enquiries about contracts, invoices, complaints, security and data protection as well as e-mails with attachments are always answered by a person. If you do not want AI support, write «without AI» in your e-mail and a person will reply. For this step we store no content, only a log with a checksum, the decision and the reason.
3 Legal bases (to the extent the GDPR applies)
Performance of a contract and pre-contractual measures (Art. 6(1)(b) GDPR) for enquiries, orders and support; legal obligations (point (c)) for retention; legitimate interest (point (f)) in the secure operation of the website and in improving the Software; consent (point (a)) where we ask you for it.
4 Disclosure and abroad
We do not sell data. We disclose data only to service providers that we need for operation (host of the website and the services: Infomaniak Network SA, Switzerland; email: Infomaniak Network SA, Switzerland; payments: Stripe), or where the law requires it. Processing in the USA may take place at Stripe; Stripe relies for this on the safeguards set out in Stripe's privacy terms. For the services in 2.6 to 2.8 (Hugging Face, Anthropic, Meta), the terms of these providers apply; WhatsApp states that it participates in the EU-U.S. and the Swiss-U.S. Data Privacy Framework.
5 Your rights
You may request access to your data, its rectification or deletion, restriction of processing, release in a common format and – to the extent the processing is based on consent – withdraw your consent at any time. Write to info@firnkern.ch for this purpose. You may complain to the supervisory authority: in Switzerland to the Federal Data Protection and Information Commissioner (FDPIC), in the EU to the authority of your place of residence or work.
6 Security
We transmit data in encrypted form (HTTPS) and protect it with appropriate technical and organisational measures.
7 Changes
We amend this privacy notice when our processing changes. The version published on firnkern.com applies.