Sehklinik

Legal

Privacy

This is an English translation provided for convenience. The German version is the legally binding one.

Data controller

We take the protection of your data seriously. SehKlinik AG processes personal data in accordance with the Swiss Federal Act on Data Protection (revFADP) and, where applicable, the European General Data Protection Regulation (GDPR).

SehKlinik AG (“we”, “us”), Lorzenparkstrasse 12, 6330 Cham, Switzerland, is the controller for the processing of your personal data. For questions, access requests or any data protection matter you can reach us at info@sehklinik.ch.

What data do we process?

When you visit the websiteAs with any web server, technical connection data is processed:

  • IP address of your device
  • Date and time of access
  • Browser and operating system used
  • Referring website (referrer)

This data is necessary to operate and secure the website. The legal basis is our overriding interest in secure and stable operation (Art. 31(1) revFADP; Art. 6(1)(f) GDPR).

CookiesThis website sets no cookies of its own. Two items are stored only locally in your browser (localStorage) and are not transmitted to us: your consent decision and, if you switch language, your language choice. The language choice governs only whether we offer you the other language version; which version an address serves depends on the address alone, and deleting the item changes nothing about that. Cookies can only arise after you have consented to analytics or have explicitly loaded an external element (a map, the booking window).

Contacting usIf you contact us via the contact form, by email or by telephone, we process the details you provide — name, telephone number, email address and your message — solely in order to answer your enquiry. The legal basis is your enquiry itself (Art. 31(2)(a) revFADP; Art. 6(1)(b) GDPR).

Please do not send us information about your health via the contact form. For medical matters, please book an appointment.

For the technical delivery of your enquiry to our team we use Infobip Ltd. as a processor; the data sits on servers in the EU. To resolve faults in email and voice operations, Infobip may under its own processor policy additionally access that data from Bosnia and Herzegovina; there is no adequacy decision for that country. We document the consent you give when sending the form with a check value of the consent text as displayed — the check value allows no conclusions about your identity. After you send the form, an automatic acknowledgement is usually sent to the email address you entered; it is delivered through Infobip as well.

Appointment bookingOnline appointment booking is provided by OneDoc and is loaded only when you explicitly request it. Whatever you enter in the booking window is processed directly by OneDoc, which is a controller in its own right for that processing.

Use of PostHog (product analytics)

To improve what we offer we use PostHog, an analytics service provided by PostHog Inc. The data is processed on European servers and delivered via our own domain; no analytics data is transferred to servers outside the EU/EEA.

Analytics starts only after your explicit consent. Without consent no analytics data is collected — capture is disabled by default. The legal basis is your consent (Art. 31(1) revFADP; Art. 6(1)(a) GDPR).

We record page views and individual interactions that we have named ourselves. There is no automatic capture of form contents or of text on the page, and no session recording. Addresses of pages whose name would reveal a medical condition are replaced by a general category before being sent — “grauer-star-katarakt” becomes “cataract”.

You can withdraw your consent at any time with effect for the future.

Use of Google Analytics (audience measurement)

In addition we use Google Analytics 4, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). We use it to measure the use of this website in a way that stays comparable across the change of our website technology: page views, approximate origin, device type and the source of a visit.

This measurement, too, starts only after your explicit consent. Before that the Google code is neither loaded nor is any data transmitted to Google — not even so-called cookieless signals. The legal basis is your consent (Art. 31(1) revFADP; Art. 6(1)(a) GDPR).

Google Analytics 4 does not store IP addresses. Advertising features, Google Signals and ad personalisation are switched off in our integration. Addresses of pages whose name would reveal a medical condition are replaced by a general category here as well before being sent; the page title is not transmitted in that case.

After your consent Google Analytics sets cookies (prefix “_ga”) with a lifetime of 13 months. If you withdraw your consent, these cookies are deleted and the measurement ends.

The data may be transferred to servers of Google LLC in the United States. Google LLC is certified under the Data Privacy Framework; in addition we rely on the Standard Contractual Clauses for the transfer. The retention of event data at Google is limited to at most 14 months.

Further information on data protection at Google is available here: https://policies.google.com/privacy

Eye & lid check: processing of camera images

Our optional eye & lid check can use your camera. Use is voluntary; the check also works without a camera, and you can stop at any time.

What happensYour camera is evaluated exclusively within your browser. Measurement points on the face are derived from the live image — for the lid check to estimate lid position, lid opening, lid closure and blinking, and for the vision check solely to estimate your viewing distance.

What never leaves your deviceNo images, no video recordings and no measurement points are stored or transmitted — neither to us nor to any third party. The evaluation happens entirely on your device; the software required for it is loaded from our own server. The estimated values are shown to you and then discarded. Camera-based values are also not transmitted when you request your result by email or make an appointment enquiry.

Legal noteEstimates concerning your eyelids are health data and therefore particularly sensitive personal data (Art. 5(c) revFADP; Art. 9 GDPR). We process them exclusively on your device and exclusively on the basis of your explicit consent (Art. 6(7)(a) revFADP; Art. 9(2)(a) GDPR). This consent is separate from consent to analytics and is obtained separately.

The check is not a medical examination, does not provide a diagnosis and does not replace an ophthalmological assessment. It serves educational purposes only.

Questionnaire and sending your result

Your answers in the questionnaire are transmitted to our evaluation platform for scoring — as answer numbers, not as free text. We operate this platform ourselves; the data is processed on our behalf and within the EU/EEA.

If you request your result by email or would like an appointment, we receive your email address together with the information about which area you selected and how pronounced your interest in a consultation is. Details of individual symptoms are not transmitted.

For the technical delivery of these emails — your result and the internal notification to our team — we use Infobip Ltd. as a processor; the data sits on servers in the EU. To resolve faults in email and voice operations, Infobip may additionally access that data from Bosnia and Herzegovina; there is no adequacy decision for that country. Your email address is used solely for delivery.

As evidence of your consent we additionally store a check value of the consent text in the version shown to you, together with the time, language and the purposes you selected. This makes it possible to demonstrate later what you consented to — the check value allows no conclusions about your identity.

Digital reception assistant (chat)

Our website offers a digital reception assistant. It is an AI-supported system, not a person, and it says so at the start of every conversation. It answers organisational questions — opening hours, locations, booking, insurance and our team — using only texts our clinic has reviewed and released beforehand. It does not diagnose, does not give medical advice, does not assess symptoms, and is not suitable for emergencies.

If your message suggests a possible medical emergency, the assistant ends the conversation and points you to the Swiss emergency number 144 or the European emergency number 112. Any further input receives the same message. That is intended: in an emergency you should be given a number, not a chat reply.

Without your consentUntil you expressly consent, we store nothing from the conversation. Your message is processed for the duration of the request and then discarded; the only thing kept is a check value (a hash) of your text, from which your text cannot be reconstructed. We use it solely to see which questions our released answers do not yet cover. Your session is given a random identifier that is not derived from anything you entered and expires when the conversation ends. If you leave the chat without consenting, nothing remains.

With your consentIf you would like a call back or want to request an appointment, we obtain your express consent first, in a dialog of its own. This consent is entirely separate from the cookie consent — accepting analytics cookies is not consent to the processing of health data. In the dialog we collect your email address, optionally your name and phone number, and the enquiry category you choose. The content of your enquiry about eye health is sensitive personal data (Art. 5 lit. c revFADP; Art. 9 GDPR). The legal basis is your express consent (Art. 6(7)(a) revFADP; Art. 9(2)(a) GDPR).

  • Purpose 1 — a call back from our practice team to answer your enquiry (consent record kept for this purpose: 90 days).
  • Purpose 2 — a single reminder about the appointment options discussed (consent record kept for this purpose: 365 days). There is one reminder only; a second is technically impossible.

What our team receives from the conversation is deliberately brief: the enquiry category you chose, the released topics covered in the conversation, a marker if a question was left open, and your contact details. Your own free text is not passed on — it cannot be represented in that handover at all.

For the technical delivery of that handover to our team we use Infobip Ltd. as a processor; the data sits on servers in the EU. To resolve faults in email and voice operations, Infobip may — under its own processor policy — additionally access that data from Bosnia and Herzegovina; there is no adequacy decision for that country. The records of your consent are stored with a managed-database provider in the EU (Frankfurt region).

We document your consent with a check value of the consent text you were actually shown, so that it can later be established exactly what you consented to. The check value allows no conclusion about you personally. Your email address itself is not stored in the record in clear text, only as a value derived from it.

You can withdraw your consent at any time with effect for the future; how to do so is set out under "Your rights". A withdrawal is re-checked at the moment of sending: anything no longer consented to at that moment is not sent.

The reception assistant is text-only. No telephone or voice-controlled channel is offered at present. If such a channel is introduced, we will inform you here separately and in advance; this notice does not cover it.

Maps

On our location pages we embed Google Maps, and on the home page an overview map whose map tiles come from OpenStreetMap (OpenStreetMap Foundation, United Kingdom). Both maps are loaded only when you explicitly request it or have previously consented. Before that, no connection to Google or to the OpenStreetMap Foundation is established.

As soon as you load a map, the respective provider receives your IP address and may set its own cookies; this may involve a transfer to the USA. All addresses and directions are also available in full on the page without the map.

Further information on how Google handles user data can be found here: https://policies.google.com/privacy

Purpose of the processing

We process your personal data for the following purposes:

  • Operating and securing the website: delivering the pages and preventing misuse.
  • Communication: answering your enquiries and arranging appointments.
  • Improving what we offer: analysing website use, exclusively after your consent.
  • Information and self-assessment: running the voluntary eye & lid check on your device.
  • Compliance with legal obligations: meeting legal requirements and enforcing rights.

Disclosure of data to third parties

We do not sell personal data and do not pass it on for advertising purposes. We use the following service providers to operate the website:

  • Vercel (hosting and execution of the website) — server location Frankfurt am Main, Germany.
  • Sanity (editorial system for the content of this website) — delivers the page content.
  • Our own evaluation platform (eye & lid check questionnaire) — processing on our behalf within the EU/EEA.
  • Infobip (technical delivery of the emails from the Eye & Lid Check and the contact form) — data on servers in the EU, access for fault resolution also from Bosnia and Herzegovina (no adequacy decision).
  • PostHog (product analytics) — European servers, exclusively after your consent.
  • Google Analytics (audience measurement) — Google Ireland Limited; transfer to the United States possible (Data Privacy Framework and Standard Contractual Clauses); exclusively after your consent.
  • OneDoc (online appointment booking) — only after you explicitly load the booking window; a controller in its own right.
  • Google Maps and OpenStreetMap (maps) — only after you explicitly load the respective map; the overview map on the home page obtains its map tiles from the OpenStreetMap Foundation, United Kingdom.

Beyond this we disclose data only where we are legally obliged to do so or where it is necessary to enforce our rights. Data processing agreements are in place with all processors; where processing takes place outside Switzerland or the EEA, we rely on the Standard Contractual Clauses or another permissible basis.

Data security

We use technical and organisational measures to protect your data against unauthorised access, loss or destruction. These include:

  • End-to-end transport encryption (HTTPS/TLS)
  • A browser security policy that technically restricts this website's outbound connections to the recipients named here
  • Evaluation of camera images exclusively on your device, without transmission
  • Access restrictions and regular reviews

Your rights

Under the applicable data protection laws you have the following rights:

  • Access: the right to know which personal data we process about you.
  • Rectification: the right to have inaccurate or incomplete data corrected.
  • Erasure: the right to have your data deleted, provided no statutory retention obligations prevent this.
  • Restriction of processing: the right to restrict the processing of your data under certain conditions.
  • Data release and portability: the right to receive your data in a common electronic format.
  • Objection: the right to object to the processing of your data.
  • Withdrawal of consent: the right to withdraw consent at any time with effect for the future.

To exercise these rights you can reach us at info@sehklinik.ch.

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and, where the GDPR applies, with a data protection supervisory authority in the EU.

Retention periods

We store your personal data only for as long as is necessary for the stated purposes or as required by statutory retention obligations. Specifically:

  • Analytics data (only after consent): this data is stored by our analytics provider. No shorter deletion period is currently configured there; storage may last up to 84 months. We are working to shorten this period.
  • Measurement data in Google Analytics (only after consent): at most 14 months; the associated cookies expire after 13 months.
  • Evidence of your consent: 3 years, so that we can demonstrate what you consented to.
  • Details from the digital reception assistant: without consent, not at all; with consent, for as long as the relevant purpose named above requires. Your own free text is never stored.
  • Enquiries via the contact form or by email: until your matter has been dealt with, and thereafter no longer than 24 months.
  • Technical server and security logs: short-term, as part of operations by our hosting provider.
  • Camera images and measurement points derived from them: not at all — they never leave your device and are discarded after being displayed.

Legal framework and accessibility

This website is run by a Swiss clinic, so the revised Swiss Data Protection Act (revFADP) applies in the first instance. Where visitors from the EEA are reached, we additionally apply the GDPR.

This policy is our information about the processing of your personal data under Art. 19 revFADP: it names who processes, for which purpose, who receives the data and which countries it reaches.

For processing with an elevated risk, Art. 22 revFADP provides for a data protection impact assessment. We have prepared one for the camera-based Eye & Lid Check; it is with the clinic management for approval.

The Swiss Disability Discrimination Act (BehiG) obliges public bodies in the first instance to make the web accessible. We align with it voluntarily, and with the Web Content Accessibility Guidelines (WCAG) 2.1 level AA. If a page makes access difficult for you, write to us — we will fix it, and in the meantime name you a route that works.

Changes to this privacy policy

We reserve the right to update this privacy policy as necessary in order to adapt it to changed legal conditions or to new services. The current version is always published on our website.

This privacy policy describes what this website actually does. If you have questions or concerns about data protection, please contact us at info@sehklinik.ch.

Last updated: 5 August 2026