Privacy Policy

Privacy Policy

Last updated: 5 July 2026

This policy applies to the ClinicaLister marketing website and explains how we handle personal data under the EU/UK GDPR, the Swiss revised Federal Act on Data Protection (revFADP), and US state privacy laws.

Who We Are (Data Controller)

The controller responsible for your personal data is Huemul David Nasillo, trading as ClinicaLister (Sole proprietor — incorporation pending), based in Saas-Fee, Canton of Valais, Switzerland.

For any privacy question or to exercise your rights, contact us at privacy@clinicalister.com.

Information We Collect

On this marketing site we collect only limited personal data:

  • Waiting-list details you submit — name, email address, and optional company.
  • Messages you send us by email or through a form.
  • Technical data needed to serve and secure the site — IP address, device/browser type, and basic request logs.

We run no advertising trackers on this site, we do not sell or share personal information, and we do not knowingly collect special-category (sensitive) data here.

Analytics. If — and only if — you enable analytics in the cookie banner, we use PostHog to count page views and which pricing plan was selected. This tells us which pages help people and which do not. It is loaded only after you consent, and nothing analytics-related runs before that choice.

How We Use Your Information & Our Legal Bases

We use your data for the following purposes, on these legal bases (GDPR Art. 6 / revFADP):

  • Manage the waiting list and contact you about early access — consent, which you may withdraw at any time.
  • Respond to your enquiries — legitimate interests / pre-contractual steps.
  • Operate, secure, and improve the site — legitimate interests in a safe, functional website.
  • Measure which pages and plans people find useful (analytics) — consent (GDPR Art. 6(1)(a); ePrivacy Art. 5(3) for the storage itself), withdrawable at any time from the cookie settings. Declining costs you nothing.
  • Comply with legal obligations — legal obligation.

Data Retention

We keep waiting-list data until the product launches and for up to 12 months afterwards, or until you ask us to delete it or withdraw consent — whichever is sooner. Enquiry emails are kept for as long as needed to handle your request and a reasonable follow-up period. Technical logs are kept for a short period for security and diagnostics.

Sharing & Sub-processors

We do not sell or share your personal information. We disclose it only to service providers who process it on our behalf under contract, when required by law, or in connection with a business transfer. Our current processors:

ProviderPurposeLocationTransfer basis
SupabaseBackend, authentication session, databaseUS / EU regionsSCCs; EU-US & Swiss-US Data Privacy Framework
RenderStatic-site hosting and deliveryUnited StatesSCCs; Data Privacy Framework
CloudflareCDN, security (DDoS), edge cachingGlobal edge (US HQ)SCCs; Data Privacy Framework
PostHogProduct analytics — aggregate page views and funnel stepsEuropean Union (EU Cloud, Frankfurt)None outside the EU/EEA; no transfer mechanism required
FilloutWaiting-list form capture (embedded form)United StatesSCCs; Data Privacy Framework (consent-gated)
AttioCRM for waiting-list follow-upUnited StatesSCCs; Data Privacy Framework

International Data Transfers

Some processors are located outside Switzerland and the EEA (for example, in the United States). Where we transfer personal data internationally, we rely on appropriate safeguards: the European Commission's Standard Contractual Clauses (SCCs) with the Swiss addendum, and the EU-US and Swiss-US Data Privacy Framework where the recipient is certified.

Your Rights

Depending on where you live, you have rights to:

  • Access the personal data we hold about you, and obtain a copy (portability)
  • Correct inaccurate data and delete your data
  • Object to or restrict certain processing
  • Withdraw consent at any time (without affecting prior processing)
  • Not be subject to solely automated decisions with legal effect (we make none)
  • Lodge a complaint with your data protection authority

To exercise any right, email privacy@clinicalister.com. We respond within 30 days (EU/Switzerland) or 45 days (US); we may need to verify your identity first. You can change cookie choices anytime via Cookie Settings in the footer.

EEA & UK (GDPR)

If you are in the European Economic Area or the UK, the GDPR/UK GDPR applies and you hold all the rights listed above. You may complain to your local supervisory authority. As a Switzerland-based controller offering a low-risk waiting list, we do not currently appoint an EU Article 27 representative in reliance on the Art. 27(2) exemption (occasional processing, low risk, no special-category data); we will revisit this if our processing changes.

Switzerland (revFADP)

We are based in Switzerland, so the revised Federal Act on Data Protection (revFADP) applies. You have equivalent rights of access, correction, and deletion, and you may contact or lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).

United States (California & other state laws)

If you are a US resident (e.g., California/CCPA-CPRA, Virginia, Colorado, Connecticut, Utah, and similar), you have rights to know, access, correct, delete, and obtain a copy of your personal information, and to not be discriminated against for exercising them.

We do not sell or share your personal information and we do not use it for targeted advertising or profiling — so no opt-out of sale/sharing is required. Our analytics is first-party measurement, not cross-context behavioural advertising, and we do not disclose it to anyone for their own purposes. We honor the Global Privacy Control (GPC) browser signal: if your browser sends it, analytics stays off even if a previous consent is stored, and you do not need to interact with the banner. You may use an authorized agent, and (where your state allows) appeal a declined request by replying to our response.

Cookies

We use only strictly necessary cookies plus, with your consent, a functional third-party form. See our Cookie Policy for details and to manage your choices.

Data Security

We use appropriate technical and organizational measures to protect your data. No method of transmission over the internet is 100% secure. Learn more on our Security page.

Children's Privacy

This site is intended for professionals and is not directed to children. We do not knowingly collect personal data from anyone under 16.

Changes & Contact

We may update this policy; we will revise the "last updated" date above and, for material changes, provide a more prominent notice.

Contact

Email: privacy@clinicalister.com

Huemul David Nasillo (trading as ClinicaLister) — Saas-Fee, Canton of Valais, Switzerland