Privacy Policy of Transpareo AG. How we process and protect personal data.
The controller for data processing within the meaning of the GDPR and the Swiss Data Protection Act (nDSG) is:
Transpareo AG
Tech Cluster Zug
6300 Zug
Switzerland
Company ID: CHE-220.381.580
Commercial register: CH-170.3.047.128-7 (Canton of Zug)
Represented by: Günter Reichelt, Chairman of the Board of Directors
When you use the platform, two kinds of data arise that we treat differently in law:
As a controller, we process the data that arises when you visit our website, register your account and are billed (Sections 3 to 8). For this data, we determine the purposes and means of processing ourselves.
As a processor, we process the product and passport data - and any personal data contained therein - that you as a customer enter, import or transmit via the interfaces into the platform (Section 5). Here you are the controller; we act exclusively on your instructions on the basis of a data processing agreement (DPA) under Section 14 of the Terms of Service.
As a controller, we collect personal data in the following situations:
Website use: When you visit our website, technical access data (IP address, browser type, timestamp) is logged. These server logs are deleted after 30 days. The geographic lookup of the IP address is performed via a local database on our own server; no data is transmitted to third parties in the process.
Registration & use of the platform: When you register, we collect your name, email, company name and country. Payment is handled by our payment service provider (Section 6); card details are entered directly with them and are not stored by us.
Contact form: For enquiries via the contact form, we process the contact details you provide in order to respond to your enquiry.
Insofar as we act as a controller, we process your data on the following legal bases:
As a Swiss company, Transpareo AG is also subject to the revised Swiss Data Protection Act (nDSG); its requirements are met in parallel with the GDPR.
The product and passport data that our customers place in the platform is processed by us as a processor, exclusively on their instructions. Where this data contains personal data (for example the name of a responsible person), the respective customer is the controller for it. The basis is the data processing agreement under Section 14 of the Terms of Service.
We store, process, translate and sign this data technically and make published Digital Product Passports publicly accessible via their permanent URL. Published passports are therefore publicly and permanently retrievable; for a passport registered in the EU register, the published versions additionally remain in an immutable archive for ten years (see Section 10 of the Terms of Service).
Data subjects whose data is contained in a product passport should exercise their rights with the respective customer as the controller. On the customer’s instructions, we support them in handling such requests.
We share personal data only where this is necessary to perform the contract or where you have consented. We use the following carefully selected processors, with each of whom a data processing agreement is in place:
Our entire hosting infrastructure and all data stored on it are located in Germany and thus within the EU/EEA data zone.
For delivery via the KeyCDN content delivery network (reachable at cdn.transpareo.com), visitors’ requests may be processed at edge servers outside the EU/EEA. Only publicly accessible content is delivered via the network; the master data stored in Germany is not affected by this. Any such transfers are safeguarded by Standard Contractual Clauses.
A transfer to the USA takes place exclusively in the context of payment processing via Stripe. This transfer is safeguarded by the European Commission’s Standard Contractual Clauses and by Stripe’s participation in the EU-U.S. Data Privacy Framework.
Transpareo AG is domiciled in Switzerland. For transfers from the EU to Switzerland, an adequacy decision of the European Commission is in place; the Swiss level of data protection is deemed equivalent.
We store personal data only for as long as is necessary for the respective purposes:
Product and passport data that we process on behalf of our customers is stored according to their instructions; published and registered passport versions are subject to the ten-year archive period under Section 10 of the Terms of Service.
We use only technically necessary cookies to operate our website (e.g. login session). We do not use analytics or tracking cookies.
We deliberately avoid third-party tracking technologies (Google Analytics, Facebook Pixel, etc.). Our internal statistics are privacy-compliant and do not capture personal profiles.
As a data subject, you have the following rights towards Transpareo:
We use technical and organisational measures to protect your data:
We have appointed an external data protection officer:
DGD Deutsche Gesellschaft für Datenschutz
Prof. Dr. h.c. Heiko Jonny Maniero
Franz-Joseph-Str. 11
80801 Munich, Germany
Email: info@mail.dg-datenschutz.de
Phone: +49 (0)800 6264376
Our representative in the EU (Article 27 GDPR), our representative in Switzerland (Article 14 nDSG) and the contact points for further jurisdictions are set out in our transparency document.
For questions about data protection and to exercise your rights, please contact:
Data protection contact at Transpareo AG
Email: datenschutz@mail.transpareo.com
You also have the right to lodge a complaint with a data protection supervisory authority - in Switzerland with the Federal Data Protection and Information Commissioner (FDPIC), and in the EU with the supervisory authority of your member state.
Last updated: June 2026