Dieses Dokument ist nur auf Englisch verfügbar. Massgebend ist die englische Fassung.

This cookie policy (“Cookie Policy”) is part of the technical and organizational measures implemented by Skew Labs SA, Via Ferruccio Pelli 13 c/o SiPaFid SA, 6900, Lugano (hereinafter the “Company”, “we”, “us”, “our”) to ensure its processing of personal data is performed in accordance with the Swiss Federal Act on Data Protection 2020 (“FADP”), Article 45c of the Telecommunications Act (“TCA”), as well as the guidelines issued by the Federal Data Protection and Information Commissioner (“FDPIC”) on 22 Jan 2025 (the “Guidelines”) with respect to the use of cookies on the Company’s website available at the following address: https://skew.net/ (hereinafter the “Website”) and on the Company’s web application available at the following address: https://app.skew.net/ (hereinafter the “App”).

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1. WHAT IS A COOKIE?

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A “cookie” is a small text file that is delivered by our Website server onto your computer whilst you visit our Website, which can generally be used by the Website to identify particular devices and thereby remember your Website preferences and sign-in details. Most cookies will not collect information that identifies you and instead will collect more general information such as how you arrived at and used our Website, or your general geographical location.

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Similar technologies, such as the “local storage” and “session storage” of your web browser, allow a website or web application to store small amounts of information on your device in a comparable way. In this Cookie Policy, the term “cookies” also covers these similar technologies, which are listed in the tables below together with the cookies.

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2. WHY ARE COOKIES NEEDED?

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Cookies make websites work better and they are a standard part of most modern websites. For example, they remember the items you’ve placed in your online shopping cart so that the items appear at the checkout when you make your purchase. Another example would be when you sign in to webmail services such as Hotmail or Gmail: on such occasions a cookie is generated that confirms you are signed in and when you sign out, the cookie is deleted. This means if someone goes back to your webmail address on your computer, you will still be signed out, and they won’t be able to read your emails.

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3. TYPES OF COOKIES

Cookies can be classified based on several specifications that help explain their nature and function, as detailed below.

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3.1 Issuer of cookies

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• First-party cookies: these are created and managed directly by the owner of the website that the user is visiting. Their installation occurs directly from the domain that the user has chosen to access.
• Third-party cookies: in contrast, these cookies are set by domains external to the website the user is visiting. This happens because the website contains elements that reside on servers different from those of the visited website, allowing third parties to collect data during browsing.

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3.2 Duration of cookies

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• Session cookies: these cookies are temporary, tied to the user’s browsing session, and are automatically deleted when the browser is closed. They do not retain any type of information about the user in the long term.
• Persistent cookies: these types of cookies remain on the user’s device for a predefined period, even after the browser is closed. They are used to remember the preferences or actions of the user for future visits, providing quicker and more convenient navigation.

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We use both first-party and third-party cookies, as further detailed in Sections 4 and 5 below.

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3.3 Purpose of cookies

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• Technical cookies: essential for navigating within a website and using all its features, such as accessing restricted areas. Without these cookies, some necessary operations, like signing in to the website could not be performed. Cookies used for security purposes (e.g. to protect the website against bots and malicious traffic) also fall within this category.
• Preference cookies: these cookies allow a website to remember choices made by the user (for example, that a notice has already been displayed or dismissed, or the user’s display settings) in order to provide a more convenient experience.
• Analytics cookies: these cookies collect information about users’ use of a website, such as the most visited pages and any error messages received. The information is collected aggregately, without identifying individual users, to improve the functioning of the website.
• Profiling cookies: they aim to create user profiles in aggregate to send advertising messages in line with the preferences shown during browsing. These cookies can be used to present more relevant content or limit the number of times content is viewed. Generally, they are cookies managed by third parties.

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We employ analytical and technical cookies for statistical purposes (as described in Section 4 below) for monitoring, by way of example, the flow of visitors on the Website. Therefore, we justify the use of such cookies in accordance with Article 31 par. 2 letter e) of the FADP and point 3.8.2. of the Guidelines ensuring the following:

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• all personal data collected is anonymized as soon as the user lands on the Website;
• if the processing involves sensitive personal data, we shall disclose such data to third parties in such a manner that the data subject is not identifiable; if this is not possible, it must be guaranteed that the third parties only process the data for purposes unrelated to the data subject’s person; and
• the results are published in such a manner that data subjects are not identifiable.

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In addition, analytics cookies on the Website are only activated if you have given your consent through the cookie banner (see Section 4.1 below).

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In general, many websites employ other kind of cookies including but not limited to:

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• Analytics cookies (Google Analytics 4): the Company uses Google Analytics 4 (“GA4”), a service provided by Google, which helps us to improve the Website by collecting and reporting information on how users interact with it. We have configured such cookies to collect information in a way that does not directly identify individuals.
• Marketing cookies: the Company does not use marketing or advertising cookies for its own purposes. However, some pages of the Website contain embedded videos hosted by YouTube (Google). If you consent to marketing cookies, YouTube may set its own cookies, which YouTube may also use for its own purposes, including advertising (see Section 4.3 below).
• Social Media Cookies: social media cookies allow users to interact more easily with social media, such as Facebook, Twitter, LinkedIn, Instagram, YouTube etc. Please refer to the relevant social media platforms’ privacy policies for information about these kinds of cookies.

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4. WHAT COOKIES DO WE USE ON THE WEBSITE?

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We collect your data automatically via cookies when you visit our Website, in line with the cookie settings in your browser and the choices you make in our cookie banner.

We use cookies to track your activity to help ensure you get the best possible experience when visiting our Website.

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We do not make any attempt to discover the identities of anyone who visits our Website, and we will not associate any of the data gathered from our Website with any personally identifiable information from any source. If we do want to collect personally identifiable information through our Website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

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The Company employs analytical cookies for examining traffic volume and user engagement with the Website, as well as for system management purposes (see the list below). The gathered information is processed anonymously.

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The Website does not use cookies for profiling activities.

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4.1 Cookie banner and your choices

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When you first visit the Website, a cookie banner allows you to “Accept” or “Reject” non-essential cookies, or to select individual categories via “Preferences”. Technical cookies are always active; analytics and marketing cookies are only set if you consent to them. Your choice is stored for 365 days, and you can change or withdraw it at any time by clicking the cookie preferences icon displayed at the bottom of every page of the Website.

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4.2 Cookies and similar technologies set by the Website

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4.3 Third-party cookies from embedded videos (YouTube)

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Some pages of the Website contain videos embedded from YouTube, a service provided by Google. These videos, and the related cookies, are only loaded if you have consented to marketing cookies. The cookies below are set and controlled by YouTube/Google, which may use them for its own purposes, including advertising; please refer to Google’s privacy policy for more information.

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YouTube may also store information in the local storage of your browser within the embedded player (for example, your caption preferences).

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4.4 Geolocation for the jurisdiction warning (ipapi.co)

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When you visit the Website, your IP address is transmitted to the geolocation service ipapi.co in order to determine your approximate country. This information is used exclusively to display, where applicable, a warning pop-up concerning the availability of the Skew services in your jurisdiction and the fact that you access them on your own initiative (reverse solicitation). This processing is necessary to comply with the regulatory requirements applicable to the Company and is based on the Company’s legitimate interest in, and legal obligation of, ensuring compliance with such requirements; it does not require your consent. No cookie is set for this purpose; the Website only records in the session storage that the pop-up has been shown (geoPopupShown, see Section 4.2).

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The newsletter subscription form on the Website is provided by Mailchimp (Intuit Inc.). It does not set any cookie when you visit the Website; the data you enter is transmitted to Mailchimp only when you submit the form.

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5. WHAT COOKIES DO WE USE IN THE APP?

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The App (https://app.skew.net/) does not use analytics, marketing or profiling cookies. It only uses cookies and similar technologies that are strictly necessary to provide the services you request, to keep your account secure and to remember your choices, as well as the third-party services described below. As these cookies and technologies are strictly necessary for the functioning of the App, they do not require your consent; you can nevertheless block or delete them through your web browser’s settings (see Section 6), but in that case you will not be able to sign in to or use the App.

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5.1 Session and authentication

When you sign in, the App stores your session in the local storage of your browser. This record is needed to keep you signed in while you move between pages and is deleted when you sign out or when your session expires. It also contains the preferences associated with your account, such as your display currency, so that amounts are shown in the currency you have chosen.

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5.2 Security (Cloudflare Turnstile)

The sign-in, sign-up and password-recovery pages of the App use Cloudflare Turnstile, a bot-protection service provided by Cloudflare, Inc., to verify that the request comes from a human user and not from an automated system. To do so, Turnstile processes technical information about your browser and device (such as your IP address and browser characteristics) on Cloudflare’s servers (challenges.cloudflare.com). In our tests, Turnstile did not store any cookie on the user’s device.

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5.3 Address autocompletion (Google Maps Platform)

On the address step of the sign-up form, the App uses the Places service of Google Maps Platform, provided by Google, to suggest complete addresses while you type. For this purpose, the characters you type in the address field and technical information such as your IP address are transmitted to Google (maps.googleapis.com and places.googleapis.com). This service does not store cookies on your device. You can always enter your address manually without selecting a suggestion.

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5.4 Customer support chat (Crisp)

The App includes a customer-support chat provided by Crisp IM SAS (client.crisp.chat), through which you can contact our support team directly from the App. The customer-support chat is part of the services provided through the App, and the related cookie is therefore strictly necessary and does not require your consent. To keep your conversation available across pages and visits, Crisp stores a session identifier in a cookie and in the local storage of your browser.

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5.5 List of cookies and similar technologies used in the App

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6. TURN OFF COOKIES

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You can change or withdraw your consent to non-essential cookies on the Website at any time through the cookie preferences icon described in Section 4.1.

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You can also turn off cookies for a particular website or several websites by adjusting your web browser’s settings to prevent it from accepting cookies, or delete cookies and other data already stored on your device. The relevant options are usually found in the “Settings”, “Privacy” or “Security” menu of your web browser (for example Google Chrome, Microsoft Edge, Mozilla Firefox, Apple Safari or Opera); please refer to the help pages of your browser for detailed instructions.

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It’s important to note that turning off cookies is likely to limit the functionality of not only our Website and App, but also the functionality of a large number of the world’s websites, and accordingly, your experience of ours and other websites may be impaired because data is no longer being captured about your interactions. In particular, if you block the local storage of your browser you will not be able to sign in to the App.

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It may be that your concerns around cookies relate to so-called “spyware” in which case, rather than switching off cookies in your browser, you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

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There are other methods to reduce the risk of online tracking, including using the “private” or “anonymous” browsing functionality of your browser (if available), which prevents cookies from being retained on your device after browsing.

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7. CHANGES TO OUR COOKIE POLICY

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The content of both this “Cookie Policy” and the “Cookie Banner” will be reviewed regularly by the Company, and the information contained therein shall be updated where necessary to reflect the true use of cookies by the Company.