Legal & privacy
Data processing
A transparent baseline for processing analytics data on behalf of our customers.
Last updated: 11 October 2026
Parties and roles
This agreement governs processing between the customer identified in the order as controller and minddraft AG, Säntisstrasse 12 6345 Neuheim Schweiz, as processor. It supplements the wayfold contract when expressly incorporated. The Swiss Federal Act on Data Protection and, where applicable, Article 28 GDPR apply. minddraft AG’s own account, contractual, payment and support purposes are described separately in the privacy notice.
Subject, nature, purpose and duration
The service collects, temporarily links, stores, analyses and deletes the website signals enabled by the customer to understand usage and improve their website. The commissioned team tool also includes deliberately created Test Mode issues. Processing continues for the agreed service period and subsequent specified return and deletion periods.
Data and people concerned
People concerned include visitors to customer websites and people authorized to use the team tools. Visitor-related processing includes transient IP/user-agent inputs, short-lived mappings, scrubbed paths and events, referrer/campaign values, coarse device/country information and enabled heatmap/performance signals. The visitor data policy bounds this scope. Test Mode issues contain deliberately authored comments, pins, structural element references, positions, timestamps, status and authorship. They require login and deliberate activation and are not attached to visitor sessions. Special categories of personal data, form contents and direct visitor identifiers are outside the intended collection scope and must not be submitted by the customer.
Instructions and customer duties
The customer determines purpose and permitted configuration, informs people concerned and establishes the required legal basis. Documented instructions arise from the contract, enabled features and authorized written requests. minddraft AG processes commissioned data only on these instructions, including transfers, unless a binding legal obligation requires otherwise. In that case the customer is informed beforehand where permitted. If we consider an instruction unlawful, we promptly inform the customer and suspend the affected processing pending clarification.
Confidentiality and access
People with access to commissioned data are bound by confidentiality commitments or equivalent statutory duties. Access rights are limited to the task concerned. Workspace and role checks constrain ordinary customer access; administrative customer management is separate from visitor analytics.
Technical and organizational measures
The agreed technical measures include input minimisation and validation, scrubbed URLs and event values, server-side workspace and role checks, time-limited Test Mode access, encrypted server-side integration tokens and HTTPS transmission. Visitor identifiers are not linked to customer names or team issues. Private profile images and explicitly shared issue screenshots require authorisation for delivery. Access and secrets are limited to necessary tasks. minddraft AG is responsible for operations. The production database uses daily managed Supabase backups with a rolling recovery window of approximately seven days. Database backups exclude separately uploaded files. No PITR, independent additional backup or particular recovery time is promised. Following recovery, previously instructed deletions must be reapplied before data returns to routine use. Security measures are adapted to risks and technical developments without reducing the agreed level of protection.
Personal data breaches
minddraft AG informs the customer without undue delay after becoming aware of a breach affecting commissioned personal data. The notification includes available information on the nature of the incident, affected data and people, possible consequences, mitigation and a contact point. Missing information is supplied subsequently. The customer decides on its notifications to authorities and individuals, with assistance from minddraft AG.
Subprocessors
The customer generally authorises the Hetzner and Supabase infrastructure processing services described in the service provider list, which forms part of this agreement. Providers used for our own billing and Google services independently selected by the customer are not automatically subprocessors for visitor analytics. We impose corresponding data protection obligations on subprocessors and remain responsible to the customer for fulfilling our obligations. We notify the workspace owner by email at least 30 days before adding or replacing a subprocessor. The customer may object within that period on substantiated data protection grounds. We seek a reasonable alternative; if no solution is possible, the customer may terminate the affected service before the change without an additional termination charge. A necessary emergency change to protect data is communicated without undue delay with reasons; the customer’s rights remain intact.
Locations and international transfers
The application runs with Hetzner in Germany; the primary Supabase database is in Zurich, Switzerland. The service provider list describes data categories and further recipient countries. Transfers or remote access from another country require documented instructions or a notified binding legal obligation. Countries without an adequate level of protection require appropriate safeguards, including applicable Standard Contractual Clauses with necessary Swiss adaptations and supplementary measures. Evidence of the safeguards used is made available to the customer on request.
Assistance
Taking account of the processing and available information, minddraft AG assists the customer with individual rights, security requirements, data protection impact assessments and necessary consultation with authorities. Requests received directly about customer data are forwarded to the customer where permitted. Additional visitor identification is not built solely to attribute a request.
Return and deletion
During the contract, the customer may use available exports and request further return of entrusted data in a commonly used machine-readable format at support@wayfold.ch. Any requested return must be specified before instructing deletion. After the contract ends, we delete entrusted data on documented instruction or return it at the customer’s choice and delete remaining copies, unless legal retention obligations prevent this. We confirm handling without undue delay and explain any legally required continued retention. Deleting a website removes its entrusted data from the active database. Existing database backups are not individually rewritten; residual copies expire within the rolling backup window of approximately seven days and remain excluded from routine use meanwhile. Our own legally required business records are kept separately for their specific purposes. Merely describing data as “aggregated” does not authorise further use of personal data.
Evidence and audits
minddraft AG provides information needed to demonstrate the agreed data protection duties and permits corresponding audits by the customer or an appointed auditor. Scope and procedure are coordinated while protecting other customers and confidential information. Practical arrangements must not exclude legally required evidence and audits.
Incorporation and contact
This agreement is concluded by express incorporation into the customer agreement, which may occur electronically. The customer is identified by the order details and minddraft AG by the legal notice. Signing in or activating Test Mode alone does not conclude this agreement. The visitor analytics notice and service provider list specify its subject matter, data scope and infrastructure. In case of conflict, this agreement’s data protection obligations take precedence over general service terms. Contact for instructions and privacy requests: support@wayfold.ch.