Privacy Policy

1. Introduction

Convolving GmbH ("Convolving", "we", "us", or "our") operates the website at convolving.ch and provides independent AI advisory services to investment firms. This Privacy Policy explains how we collect, use, and protect personal data when you visit our website or get in touch with us.

We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the European Union General Data Protection Regulation (GDPR).

2. Data Controller

The data controller responsible for your personal data is:

3. Data We Collect

3.1 Information you provide

When you contact us — for example, by email or by booking an introductory call — we collect the information you choose to share, such as your name, email address, company, and the content of your message.

3.2 Usage data

When you visit our website, we may collect anonymised usage data such as pages visited, referring site, device type, browser, and approximate location derived from your IP address. This data is collected via Google Analytics 4 and only when you have accepted analytics cookies (see section 6).

3.3 Cookies

We use a small number of cookies and similar technologies. See section 6 for details.

4. How We Use Your Data

We use your personal data to:

• Respond to your inquiries and provide information about our services
• Deliver services under an agreed client engagement
• Understand how our website is used and improve it
• Maintain the security and integrity of our website
• Comply with legal and regulatory obligations

5. Legal Bases for Processing

Where GDPR applies, we rely on the following legal bases under Article 6:

• Consent — for analytics cookies and any marketing communications you opt in to.
• Legitimate interests — for responding to inquiries, understanding website usage at an aggregate level, and protecting the security of our services.
• Contract — where processing is necessary to deliver services under an engagement letter or statement of work.
• Legal obligation — where we are required to process data by Swiss, EU, or other applicable law.

6. Cookies & Tracking

We use cookies and local storage for two purposes:

• Essential — a single entry in your browser's local storage that remembers your cookie consent choice so that we do not show the banner on every visit.
• Analytics — Google Analytics 4 (measurement ID G-KXNVJ3D6MT), which helps us understand how the site is used. Analytics only loads after you accept the cookie banner.

You can change or withdraw your consent at any time by clicking Cookie Preferences in the footer of any page.

7. Third-Party Services

We use the following third-party services to operate the website:

• Google Analytics 4 — processes anonymised usage data on Google's infrastructure. Data may be transferred outside the EU/Switzerland; Google provides appropriate safeguards including standard contractual clauses.
• Google Fonts — web fonts loaded from Google's CDN when you visit the site.

We do not currently use any CRM, marketing automation, or advertising tracking on this website.

8. Data Retention

We retain the information you send us (for example, email inquiries) for as long as necessary to respond to you and, where relevant, to document the course of our business relationship — typically no longer than 24 months unless a client engagement develops or longer retention is required by law. Google Analytics data is retained according to Google's default retention settings.

9. Data Storage & Security

We apply appropriate technical and organisational measures to protect personal data, including TLS encryption in transit, access-controlled infrastructure, and minimising the amount of personal data we collect in the first place.

10. Your Rights

Under the Swiss FADP and, where applicable, the GDPR, you have the right to:

• Access your personal data and receive a copy
• Rectify inaccurate or incomplete data
• Request deletion of your personal data ("right to be forgotten")
• Restrict or object to processing of your data
• Receive your data in a portable format
• Withdraw consent at any time where processing is based on consent
• Lodge a complaint with a competent data protection authority

To exercise any of these rights, please contact us at info@hebbian.ch. We will respond within 30 days.

11. International Data Transfers

Some of our third-party providers (notably Google Analytics) may process data on servers located outside the EU/EEA and Switzerland. In such cases, appropriate safeguards — including standard contractual clauses or equivalent protections — are in place as required by applicable law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post any changes on this page and update the "Last updated" date above. We encourage you to review this policy periodically.

13. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us: