Privacy Policy
This privacy policy informs you which personal data we process when you visit cturn.ch, obtain the free sample and purchase our products. It is based on the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Controller
cturn
Hirschparkweg 24
4800 Zofingen
Switzerland
E-mail: ak@cturn.ch
2. Visiting the website
Which data: When the website is accessed, our server automatically processes technical data: IP address, date and time, page accessed, referrer, browser and operating system (server log files).
Purpose: Provision of the website, security and error analysis.
Legal basis (GDPR): legitimate interest in secure operation (Art. 6(1)(f) GDPR).
Retention period: 15 days, then deleted or anonymised.
Cookies and tracking: We do not use any analytics, marketing or tracking tools. We do not use cookies, except technically necessary ones. When the checkout is opened, Paddle loads its own scripts and may set cookies (see section 4).
3. Free sample and updates
Which data: E-mail address (required); optionally name, role and company; language of the page; time of sign-up and of confirmation.
Purpose: Sending the free sample and contacting you in connection with our products. Role and company help us understand who uses the frameworks.
Updates: Only if you tick the separate box will we inform you about new frameworks, at most once a month.
Procedure: We use double opt-in. Your details are only stored once you click the link in our confirmation e-mail.
Legal basis (GDPR): your consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time: via the unsubscribe link in every e-mail or by e-mail to us.
Retention period: until you withdraw consent, at most 24 months after the last contact.
4. Purchase via Paddle
Role of Paddle: Our products are sold via Paddle. Paddle.com Market Limited (England and Wales) or the Paddle entity responsible for your location is the reseller (merchant of record). Paddle processes your payment, billing and tax data under its own responsibility. Paddle’s Privacy Policy applies.
Which data we receive: After the purchase, Paddle transmits to us your name, e-mail address, country, company (if provided), product purchased, amount and transaction number. We do not receive payment data such as credit card numbers.
Purpose: Delivery of the download links, customer service, proof of licence and accounting. We only use your purchase data for updates if you have given separate consent.
Legal basis (GDPR): performance of a contract (Art. 6(1)(b) GDPR) and legal obligations (Art. 6(1)(c) GDPR).
Retention period: as long as necessary for customer service and proof of licence; accounting-relevant data for the statutory retention period of ten years.
5. Contact by e-mail
If you write to us, we process your details to answer your enquiry. The legal basis under the GDPR is our legitimate interest or, for questions about a purchase, performance of a contract. We delete the correspondence when it is no longer needed.
6. Recipients and processors
We only pass on personal data to the extent necessary for the purposes stated:
| Recipient | Purpose | Location |
|---|---|---|
| Oracle (Oracle Cloud Infrastructure) | Operation of the website, storage of contact data | Germany (data centre in Frankfurt am Main) |
| Infomaniak Network SA | Sending confirmation, delivery and update e-mails | Switzerland |
| Paddle (own responsibility) | Payment, invoicing, taxes, refunds | United Kingdom; depending on location USA or Canada |
We do not sell personal data.
7. Disclosure abroad
Data may be transferred to the countries listed above. If a country does not provide an adequate level of data protection, we base the transfer on standard contractual clauses or a statutory exception, such as the performance of a contract.
Germany and Switzerland provide an adequate level of data protection. For the United Kingdom and Canada, adequacy decisions of the Swiss Federal Council (Annex 1 of the Data Protection Ordinance) and of the European Commission apply. For the USA, this applies only to companies certified under the Data Privacy Framework; otherwise the transfer is based on standard contractual clauses. Paddle is itself responsible for the transfers it makes under its own responsibility.
8. Your rights
Under the FADP and, where applicable, the GDPR, you have the right to:
- access
- rectification
- erasure
- restriction of processing
- objection
- data release or portability
- withdrawal of consent with effect for the future
To exercise these rights, write to us at ak@cturn.ch. You can also lodge a complaint: in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC), in the EU with the supervisory authority of your country of residence.
9. Data security
We protect your data with appropriate technical and organisational measures:
- encrypted transmission (HTTPS)
- access restrictions
- download links with limited validity
10. Changes
We adapt this privacy policy when our data processing changes. The version published here applies.
Last updated: November 2026