Privacy Policy

Effective Date: January 2026

Gray Matter GmbH (“we”, “our”, or “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you visit our website graymatter.ch.

1. Data Controller

Gray Matter GmbH Ufem Feld 21 3303 Münchringen Switzerland

Email: hello@graymatter.ch Phone: +41 31 536 12 77

2. Data We Collect

2.1 Contact Form Submissions

When you submit our contact form, we collect:

• Name
• Email address
• Company name (optional)
• Message content

2.2 Analytics Data

We use Cloudflare Web Analytics, a privacy-focused, cookie-less analytics solution. This means:

• No cookies are placed on your device
• We receive aggregated, anonymized reports about page views and visitor counts
• Cloudflare may process limited technical data (e.g., truncated IP addresses, device and request metadata) to provide analytics and security services
• This processing is covered by our legitimate interest in website security and improvement

2.3 Server Logs

Our hosting provider (Cloudflare) may collect standard server log data including:

• IP address (anonymized)
• Browser type
• Referring page
• Time of access

This data is used solely for security purposes and is not linked to your identity.

2.4 Bot Protection Data

When you interact with our contact form, Cloudflare Turnstile collects:

• Browser fingerprint data
• Interaction patterns
• Device characteristics

This data is used solely for distinguishing humans from automated bots and is processed by Cloudflare according to their privacy policy.

3. Purpose of Processing

We process your data for the following purposes:

Purpose	Legal Basis (nFADP Art. 31 / GDPR Art. 6)
Responding to contact form inquiries	Legitimate interest / Contract performance
Website security and fraud prevention	Legitimate interest
Anonymized website analytics	Legitimate interest

4. Data Retention

• General inquiries: 12 months after resolution of the inquiry
• Contract-related correspondence: 10 years (Swiss commercial law OR 958f)
• Server logs: Maximum 90 days
• Analytics data: Anonymized and aggregated, no personal data retained

5. Data Sharing

We do not sell, rent, or trade your personal information. We may share data with:

Service Providers

• Cloudflare: Website hosting, security, and analytics (EU data centers)
• Resend (email delivery): Processes contact form submissions to deliver emails. Resend is a US-based service that operates under Standard Contractual Clauses for EU/Swiss data transfers. Their privacy policy is available at resend.com/privacy.

Legal Requirements

We may disclose your information if required by law or to protect our legal rights.

6. Data Transfers

Your data is processed within the European Economic Area (EEA) and Switzerland. Cloudflare operates EU-based data centers and is committed to GDPR compliance.

Where transfers outside the EEA occur (e.g., for Cloudflare’s global CDN), appropriate safeguards are in place including Standard Contractual Clauses (SCCs).

Similarly, Resend (our email delivery provider) is based in the United States and processes contact form data under Standard Contractual Clauses ensuring adequate protection for EU/Swiss data subjects.

7. Your Rights

Under GDPR and the Swiss Federal Act on Data Protection (nFADP), you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data (“right to be forgotten”)
• Restrict processing of your data
• Data portability - receive your data in a structured format
• Object to processing based on legitimate interest
• Withdraw consent at any time (where applicable)

To exercise these rights, contact us at: hello@graymatter.ch

8. Cookies

We do not use cookies. Our analytics solution (Cloudflare Web Analytics) is completely cookie-less and does not require consent.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these sites. Please review their privacy policies before providing personal information.

10. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on individuals. Bot detection via Cloudflare Turnstile is used solely for security purposes and does not affect your ability to contact us.

11. Children’s Privacy

Our services are not directed at individuals under 16 years of age. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date.

13. Contact & Complaints

For questions about this Privacy Policy or to exercise your data protection rights:

Gray Matter GmbH Email: hello@graymatter.ch Phone: +41 31 536 12 77

You also have the right to lodge a complaint with a supervisory authority:

Swiss: Federal Data Protection and Information Commissioner (FDPIC) EU: Your local data protection authority