Co. Defined Sagl · Last updated: 15 March 2026
This Privacy Policy explains how Co. Defined Sagl ("Co. Defined", "we", "us", or "our") collects, processes, stores, and protects the personal data ("Personal Data") of users of our website www.codefined.co ("Website") and clients who engage our services.
Co. Defined Sagl is a Swiss limited liability company with its registered office at Via dei Ronchi 6, 6964 Davesco-Soragno, Switzerland.
This Privacy Policy is issued in compliance with the Swiss Federal Act on Data Protection (nFADP/nDSG), which entered into force on 1 September 2023, and its implementing ordinance (DPO/DSV). To the extent that the General Data Protection Regulation (EU) 2016/679 ("GDPR") applies to the processing of your Personal Data (for example, where we offer services to individuals in the European Economic Area), we also comply with the applicable provisions of the GDPR.
If you do not agree to the terms of this Privacy Policy, you should discontinue use of the Website and our services.
The data controller responsible for the processing of your Personal Data is:
Co. Defined Sagl
Via dei Ronchi 6
6964 Davesco-Soragno
Switzerland
Email: privacy@codefined.co
Co. Defined has appointed a Data Protection Officer (DPO). For any enquiries relating to the processing of your Personal Data or the exercise of your rights, you may contact:
Email: dpo@codefined.co
In addition to the data above, when you engage our services we collect:
Payment transactions are processed by Stripe, Inc. Co. Defined does not collect, store, or have access to your full credit card number or payment account details. We receive only confirmation of payment, transaction identifiers, and billing information (name and email) from Stripe.
We process your Personal Data for the following purposes and on the following legal bases:
| Purpose | Legal Basis (nFADP) | Legal Basis (GDPR) |
|---|---|---|
| Providing access to the Website | Legitimate interest | Legitimate interest (Art. 6(1)(f)) |
| Responding to enquiries and requests | Performance of a contract / pre-contractual measures | Art. 6(1)(b) |
| Delivering services and creating deliverables | Performance of a contract | Art. 6(1)(b) |
| Processing Personal Data via AI tools for deliverable creation | Consent | Consent (Art. 6(1)(a)) |
| Processing payment transactions | Performance of a contract | Art. 6(1)(b) |
| Recording and transcribing calls | Consent | Consent (Art. 6(1)(a)) |
| Sending marketing communications and newsletters | Consent | Consent (Art. 6(1)(a)) |
| Statistical analysis and Website improvement | Legitimate interest | Legitimate interest (Art. 6(1)(f)) |
| Compliance with legal obligations | Legal obligation | Art. 6(1)(c) |
| Establishing, exercising, or defending legal claims | Legitimate interest | Legitimate interest (Art. 6(1)(f)) |
6.1. Co. Defined uses artificial intelligence ("AI") tools in the creation of client deliverables. Specifically, your Personal Data may be submitted to AI systems for processing.
6.2. The AI services used include those provided by Anthropic, PBC (a company based in the United States). Your data is transmitted to Anthropic's systems for processing and is subject to Anthropic's data handling practices and policies.
6.3. All AI-generated outputs are reviewed, edited, and approved by Co. Defined before being delivered to you. AI is used as an assistive tool; final deliverables reflect human professional judgement.
6.4. By engaging our services and providing your consent, you acknowledge and agree to the processing of your Personal Data by AI tools as described in this section.
Your Personal Data may be shared with the following categories of recipients:
We do not sell your Personal Data to third parties.
Your Personal Data may be transferred to and processed in countries outside of Switzerland and the European Economic Area, including the United States. Where Personal Data is transferred to a country that does not provide an adequate level of data protection, we ensure that appropriate safeguards are in place, including:
You may request a copy of the applicable safeguards by contacting us at privacy@codefined.co.
We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:
| Data Category | Retention Period |
|---|---|
| Client service data (transcripts, questionnaire responses, deliverables) | Duration of the service engagement plus 12 months |
| Google Drive shared folder access | Removed at Co. Defined's discretion after conclusion of service |
| Financial and billing records | 10 years (as required by Swiss commercial law, Art. 958f CO) |
| Marketing and newsletter data | Until you withdraw your consent |
| Website navigation and browsing data | 12 months |
| Contact form enquiries | 12 months from the date of enquiry, unless a service engagement follows |
After the applicable retention period, Personal Data is securely deleted or anonymised.
Under the nFADP (and, where applicable, the GDPR), you have the following rights in relation to your Personal Data:
To exercise any of these rights, please contact us at:
Email: privacy@codefined.co
Post: Co. Defined Sagl, Via dei Ronchi 6, 6964 Davesco-Soragno, Switzerland
We will respond to your request within 30 days.
If you believe that the processing of your Personal Data infringes applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority:
In Switzerland:
Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
3003 Bern
Switzerland
Website: www.edoeb.admin.ch
In the EU/EEA:
You may lodge a complaint with the supervisory authority in the EU/EEA Member State of your habitual residence, place of work, or place of the alleged infringement.
12.1. The Website uses cookies and similar technologies. Cookies are small text files placed on your device when you visit the Website.
12.2. Types of cookies used:
12.3. Managing cookies: You may control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.
12.4. For further details on the specific cookies used, please contact us at privacy@codefined.co.
We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular review of our security practices.
However, no method of transmission over the internet or method of electronic storage is entirely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.
In the event of a personal data breach that is likely to result in a high risk to your personality or fundamental rights, we will:
The Website may contain links to third-party websites, platforms, and services. These third-party services operate independently from Co. Defined and have their own privacy policies. We are not responsible for the privacy practices or content of any third-party service.
Our services are not directed at individuals under the age of 18. We do not knowingly collect Personal Data from children. If you believe we have inadvertently collected data from a minor, please contact us at privacy@codefined.co and we will promptly delete such data.
This Privacy Policy and all matters relating to the processing of your Personal Data shall be governed by Swiss law, in particular the Swiss Federal Act on Data Protection (nFADP/nDSG).
Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Lugano, Canton of Ticino, Switzerland.
We may update this Privacy Policy from time to time. The most current version will be posted on the Website with the "Last updated" date. Your continued use of the Website or our services after any changes constitutes your acceptance of the revised Privacy Policy.
For any questions regarding this Privacy Policy or the processing of your Personal Data, please contact:
Co. Defined Sagl
Via dei Ronchi 6
6964 Davesco-Soragno
Switzerland
Email: privacy@codefined.co
DPO: dpo@codefined.co