Privacy Notice
Version v1.0, as of 01.09.2026
English translation for information. The German version is authoritative.
1. Controller
FLOW Lernzentrum GmbH, Bottmingerstrasse 75, 4104 Oberwil BL, CHE-420.501.158 («FLOW»).
For questions on data protection and to exercise your rights: info@flowlernzentrum.ch.
2. Scope
This privacy notice describes how FLOW processes personal data of Clients, Participants and visitors to our website. It applies together with the General Terms and Conditions. The processing of employees’ personal data is governed separately.
3. Data we process
- Client master data: name, address, email, telephone number
- Participant details: name, date of birth, address, email, telephone number, school and level, subjects
- Contract and payment data: Offerten, invoices, incoming payments
- Tuition and coaching data: appointments, attendance, level of learning, notes on learning progress
- Sensitive personal data: information on diagnoses, medication and allergies, where disclosed by you (section 5)
- Emergency contact and collection arrangements
- Communication data: email correspondence and messages through the booking system
- Website data: server log data as described in section 12
4. Purposes of processing
We process personal data in order to:
- perform the contract: scheduling and delivery of Sessions, reporting to parents, invoicing
- ensure safety and the appropriate design of tuition
- meet legal obligations, in particular accounting retention duties
- with your consent: use image material and inform you about our services
Processing follows the principles of Art. 6 of the Swiss Data Protection Act (DSG), in particular good faith, proportionality and recognisability of the stated purposes.
5. Sensitive personal data
Information on diagnoses, medication and allergies constitutes sensitive personal data (Art. 5 lit. c DSG). We process it solely on the basis of your explicit consent, given on the registration form, and only for the purpose of delivering the service safely and appropriately. Consent may be withdrawn at any time with effect for the future. Without this information, we may be unable to deliver certain services, or able to deliver them only to a limited extent.
Where the working relationship continues, existing information is reused; you confirm that it remains current when the new Offerte is concluded.
6. Disclosure to third parties
We disclose personal data only where necessary for the delivery of the service or where required by law. We do not sell personal data.
We engage carefully selected service providers as processors (Art. 9 DSG). They process personal data solely on our instructions and are contractually bound to confidentiality and to appropriate security measures.
| Provider | Purpose | Location of processing |
|---|---|---|
| TutorCruncher | Management of client and tuition data, scheduling, communication | UK |
| Bexio | Accounting and invoicing; access by our fiduciary | Switzerland |
| Infomaniak | Website and email hosting | Switzerland |
| DeepSign | Electronic signature of Offerten | Switzerland |
Data may also be disclosed to our fiduciary, to authorities and to legal and tax advisers, where necessary or required by law.
7. Disclosure abroad
Where service providers process data outside Switzerland, disclosure takes place only to countries with adequate data protection or on the basis of contractual safeguards, in particular the standard contractual clauses (Art. 16 and 17 DSG). The providers and locations concerned are listed in section 6.
8. Retention periods
We retain personal data only for as long as necessary for the stated purposes or as required by statutory retention periods.
| Data | Period |
|---|---|
| Invoices and accounting records | 10 years (Art. 958f CO) |
| Offerten and contract documents | 10 years from end of contract |
| Master and registration data | 12 months after the last Session |
| Tuition data (appointments, attendance, progress) | 12 months after the last Session |
| Coaching notes | 12 months after the last Session |
| Email correspondence | 2 years after the last Session |
| Sensitive personal data (section 5) | 12 months after the last Session |
| Image material | until consent is withdrawn |
| Enquiries not leading to a contract | 12 months |
| Newsletter contacts | until withdrawal, at most 2 years after the last contact |
9. Data security
We take appropriate technical and organisational measures to protect personal data (Art. 8 DSG), in particular access restrictions, encrypted transmission, protected systems and confidentiality obligations for all staff. Paper records are kept locked.
10. Your rights
You have the right to information about the personal data we process (Art. 25 DSG), to rectification of inaccurate data, to erasure, and to the release or transfer of your data (Art. 28 DSG). You may object to processing and withdraw any consent given at any time.
Please address your request to info@flowlernzentrum.ch. We may require suitable proof of identity. Statutory retention obligations remain reserved.
11. Minor Participants
Where the Participant is a minor, the rights under section 10 are exercised by the parents or legal guardians. Minors capable of judgement exercise their rights themselves.
Participants receive their own access to the booking system from the age of 12. For younger Participants, administration takes place exclusively through the parents’ account.
What information from coaching is passed on to parents is governed by clause D.2 of the General Terms and Conditions.
12. Website and cookies
When you visit our website, technically necessary data is processed, in particular IP address, date and time of access and the pages visited. This processing serves the secure operation of the website.
Use of analytics and tracking services. Where such services are used, this takes place only after appropriate information and consent.
Enquiries submitted through the contact form are processed through our booking system (section 6).
13. Images and recordings
We use photographs and video recordings of Participants only on the basis of separate written consent, given for each intended use. Consent may be withdrawn at any time with effect for the future. Audio and video recordings of Sessions by Participants or parents require our prior written consent.
14. Amendments
We may amend this privacy notice at any time. The version published on our website applies.
15. Contact and complaints
For questions on data protection, please contact info@flowlernzentrum.ch. You also have the right to contact the Federal Data Protection and Information Commissioner (FDPIC).