Privacy Policy of Centimo
Centimo, version 1.0.0, effective as of 01.04.2027
Translation notice. This document is an English translation provided for convenience only. The French version is the sole legally binding version. In case of any discrepancy, the French text prevails.
This privacy policy (hereinafter the "Policy") applies to any person using the Centimo software (hereinafter the "Service") as well as to any person visiting our website. "Personal data" means any information relating to an identified or identifiable individual.
1. Contact Details
Controller:
company sa address number npa city Switzerland Company Registration No. (UID): CHE-000.000.000
Contact for any question relating to data protection: Use our data protection request form.
2. Applicable Law
The processing of your data is governed by the Federal Act on Data Protection (FADP). Centimo currently serves customers established in Switzerland; the European General Data Protection Regulation (GDPR) therefore does not apply to the processing Centimo carries out on its own behalf.
It is, however, for the Customer to assess whether its own activity brings it within the scope of the GDPR, for example if it offers goods or services to persons located in the EU/EEA or monitors their behaviour. In such a case, Centimo will, upon request, enter into a data protection addendum with the Customer containing the safeguards required by the GDPR.
3. Nature and Scope of Data Collection
3.1 Data collected directly from you
- Account data: e-mail address, password (stored in hashed form, never in plain text) and, if you activate them, technical data related to two-factor authentication (TOTP secret) or passkeys (passkeys, WebAuthn standard). If you sign in via Google or Microsoft, we receive the identifier and e-mail address associated with that third-party account.
- Organization data: your organization's name, the list of its owners and members, permission groups, and invitations sent.
- Billing data: Stripe customer identifier, subscribed plan, number of seats, subscription status and history. Payment data itself (card number, etc.) is entered and processed directly by Stripe and is neither transmitted to nor retained by Centimo.
- Security and connection data: IP address, identifier of the device used (in order to limit each account to a single active session at a time), timestamps of connections, audit log of actions performed within the Service.
- Support data: correspondence exchanged with our support. For the Enterprise plan, priority access to phone support is verified based on the phone number previously registered as belonging to the organization.
- Phone calls to support: calling number, timestamp and duration of the call, audio recording of the call and its written transcript. Calls are handled by an automated voice assistant, which produces a transcript in order to qualify your request and, as the case may be, open a support ticket or transfer the call to a member of our team. You are informed of this at the beginning of each call. We invite you to communicate, during such calls, only the information necessary to handle your request.
- Accounting data entered into the Service: see the scope limitation below.
3.2 Technical data collected when visiting our website
IP address, browser type and operating system, cookies, pages viewed, referring URL, timestamps. See article 7 (Cookies and Trackers) for details on the technologies used and your management options.
3.3 Sharing within your organization
The Service allows the holder of an organization to invite other individuals (colleagues, co-owners, external fiduciary, etc.) and to grant them differentiated access rights by means of permission groups. The organization holder retains control over these access rights and may restrict or revoke them at any time. Centimo exercises no control over an organization holder's decision to invite, or not invite, a third party.
3.4 Scope: your account data, not the data of your own customers
This Policy covers your personal data as a user of the Service. It does not cover personal data that you enter or import into the Service in connection with your own business activity (for example, data appearing in invoices or accounting entries concerning your own customers, suppliers, or employees). For such data, Centimo acts as a processor on your behalf, and you remain the controller; the applicable arrangements are described in the Data Processing Agreement, which supplements our General Terms and Conditions.
4. Purposes and Legal Bases for Processing
In accordance with the FADP, data processing is lawful provided it complies with the principles of lawfulness, good faith, proportionality, and purpose limitation, and does not unlawfully infringe the personality of the data subject. We process your data for the following purposes:
Necessary for the performance of the contract concluded with you:
- creating and managing your account, access to the Service;
- billing, subscription management, and collection;
- provision of support.
Based on our legitimate interest:
- security of the Service and of your account (authentication, detection of abnormal use, limiting each account to a single active session);
- improvement of the Service, based on aggregated or anonymized usage statistics;
- fraud and abuse prevention;
- defense of our rights in the event of a dispute.
Based on a legal obligation:
- compliance with our accounting, tax, and regulatory obligations.
Based on your consent, where required (for example for certain non-essential cookies, see article 7): consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before such withdrawal.
5. Data Transmission and Recipients
Your data may be communicated to the following recipients, strictly to the extent necessary for the purposes described above:
| Recipient | Role | Location |
|---|---|---|
| Infomaniak | Hosting of the infrastructure and data | Switzerland |
| Stripe | Processing of the payment for your Centimo subscription (access to the Service), unrelated to any invoicing or accounting feature within the Service itself | See Stripe's privacy policy: stripe.com/legal/privacy-center (entities, location, and transfer safeguards applicable, kept up to date directly by Stripe) |
| Microsoft (Microsoft Graph) | Sending transactional e-mails (account confirmation, password reset, invitations, etc.) | company sa's Microsoft 365/Entra tenant is bound to Switzerland; Microsoft states that this tenant's data location relies on "data centers bound by the EU Standard Contractual Clauses", meaning the physical location of the data is not guaranteed to be in Switzerland or the EU/EEA, protection instead relying on the EU Standard Contractual Clauses as a transfer safeguard. |
| Twilio | Routing of inbound and outbound support phone calls, and temporary recording thereof | United States. The recording is downloaded by Centimo to its own Swiss hosting (Infomaniak) and then deleted from Twilio's infrastructure; it is therefore not retained there on a lasting basis. Transfer safeguard: standard contractual clauses. See twilio.com/legal/privacy |
| Anthropic | Processing of the call transcript by the automated voice assistant (language model) | United States. Anthropic states that data submitted through its commercial API is not used to train its models. Transfer safeguard: standard contractual clauses. See anthropic.com/legal/privacy |
| Cloudflare | Bot/spam protection (CAPTCHA) on account registration and on the public contact/data-protection forms | United States. Transfer safeguard: standard contractual clauses. See cloudflare.com/privacypolicy |
| Google, Microsoft | Single sign-on (SSO), only if you choose to activate it yourself, using your own personal Google or Microsoft account | Depends on the third-party account you use and its own location, specific to each user. Centimo has no knowledge of, nor control over, this location. See the respective privacy policies of Google and Microsoft for further information. |
These providers use your data only on Centimo's behalf and according to our instructions. We do not sell or rent your data to third parties, and we do not share it for advertising purposes.
6. International Data Transfers
Our data is hosted in Switzerland (Infomaniak). Certain recipients mentioned in article 5 nevertheless process data from abroad: Stripe (see the link provided in article 5 for details on the applicable safeguards), Microsoft, whose exact data location is not guaranteed to be in Switzerland or the EU/EEA but relies on the EU Standard Contractual Clauses as a transfer safeguard (see article 5), as well as Twilio and Anthropic for support phone calls and their transcription, and Cloudflare for bot/spam protection on account registration and the public forms (see article 5). These transfers benefit from safeguards compliant with the FADP (countries recognized by the Federal Council as offering an adequate level of protection, or standard contractual clauses).
7. Cookies and Trackers
The Service exclusively uses cookies and similar technologies strictly necessary for its operation. We do not use any advertising cookies nor, to date, any audience measurement tool.
| Technology | Purpose | Legal basis | Retention period |
|---|---|---|---|
| Session cookie | Keep your login session active, so you do not have to log in again on every visit | Necessary for the performance of the contract (provision of the Service) | 7 days, renewed with each active use of the Service |
| Browser local storage (localStorage) | Remember certain preferences and technical information specific to your device, to ensure the proper functioning and security of the Service | Necessary for the performance of the contract (provision and security of the Service) | Retained on your device until deleted by you |
As these two elements are strictly necessary for the operation and security of the Service, they do not require your prior consent. You may delete them at any time via your browser settings (cookies and site data), which may require logging in again and resetting certain preferences.
8. Data Security
We implement technical and organizational measures consistent with recognized industry standards, intended to protect your data against any unauthorized manipulation, loss, destruction, access, or disclosure, including in particular:
- encryption of communications (HTTPS/TLS);
- hashing of passwords;
- support for two-factor authentication (TOTP) and passkeys (passkeys, WebAuthn);
- limiting each account to a single active session at a time, with an alert in the event of detection of abnormal use;
- logging of sensitive actions for traceability purposes (retained for 180 days);
- controlled management of infrastructure secrets (application secrets encrypted, never stored in plain text);
- regular, automated backups of the database, enabling restoration in the event of an incident;
- internal access by Centimo staff to data limited according to the principle of least privilege, to only those persons who need it in the course of their duties.
We cannot, however, guarantee absolute security of data transmissions over the Internet; transmission by e-mail in particular carries a risk of interception by third parties.
9. Profiling and Automated Decisions
We do not use your data for the purposes of a fully automated decision producing legal effects concerning you, or similarly significantly affecting you, without human intervention.
The automated voice assistant described in article 3.1 qualifies your request and may, as the case may be, open a support ticket or transfer the call to a member of our team. These operations produce no legal effects concerning you and do not significantly affect you; you may at any time ask to be put through to a person, or write to us at the address indicated in article 14.
10. Retention Period
- Account and organization data: retained for as long as the account is active. For inactive Free plan accounts, data is retained for 180 days from the last activity, and then deleted. For organizations that have held a paid subscription, data is retained after the end of the contractual relationship in order to allow you to meet your own legal retention obligations (art. 958f CO, in principle 10 years), and is then deleted at the latest 10 years after the end of that relationship. You may at any time request earlier deletion, following the procedure described in article 11.2.
- Support call recordings and transcripts: retained with the call to which they relate and deleted together with the account and organization data, under the rules set out above.
- Audit logs: 180 days.
- Billing data: retained for the period required by our legal accounting and tax retention obligations (in principle 10 years under Swiss law).
- Technical operational data (system logs, etc.): retained for a limited period, in principle less than twelve months.
Once these periods have elapsed, the data is deleted or anonymized.
11. Your Rights
In accordance with the FADP (art. 25 ff.), you have the following rights over your personal data:
- right of access: obtain confirmation that data concerning you is being processed, and obtain a copy of it;
- right of rectification: have inaccurate data corrected;
- right to restriction or objection, in cases provided for by law;
- right to data portability: receive your data in a structured, commonly used format;
- right to erasure, within the limits of our legal retention obligations (in particular accounting and tax obligations).
11.1 How to exercise your rights Submit your request through our data protection request form, which creates a case directly tracked by our support team.
11.2 Identity verification In order to prevent a request from being made by an unauthorized person, in particular for any request for complete erasure of data, we ask the requester to prove their identity by means of a document establishing that they are indeed the holder of the data concerned. This verification is intended solely to protect your data against deletion requested by an unauthorized third party.
The identity document submitted for this sole purpose is deleted as soon as the verification has been carried out, and at the latest 30 days after the request has been closed. We thereafter retain only a record of the verification itself — date, type of document presented, person who carried it out, and the outcome of the request — for 10 years, corresponding to the ordinary contractual limitation period under Swiss law (art. 127 CO), so that Centimo is able to establish that it carried out the necessary verifications in the event of a later dispute, for example if the person whose data was deleted claims never to have made the request (identity theft, unauthorized access to their mailbox, etc.). This record contains no copy of the identity document.
11.3 Response time We undertake to respond to your request as promptly as possible.
11.4 Complaint You have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).
12. Links to Third-Party Websites
The Service or our website may contain links to third-party websites. Centimo exercises no control over such websites and disclaims any liability regarding their content or their data protection practices.
13. Amendment of this Policy
We may amend this Policy, in particular to reflect changes in the Service or in applicable regulations. The version published on our website shall be authoritative. Any substantial amendment will be notified to you by e-mail and/or via the Service before it takes effect.
14. Contact
company sa address number, npa city, Switzerland Contact form · Data protection request