Last updated: 22 June 2026. Governed by the Swiss Federal Act on Data Protection (nFADP / revDSG).
This policy explains how SmallWins ("we", "us") collects and processes personal data when you submit a daily reflection. We have written it to be clear and honest, in line with the Swiss New Federal Act on Data Protection (nFADP).
The data controller responsible for this service is:
Daan Bennad Engelbarts
11 Rue des Eaux-Vives, 1207 Geneva, Switzerland
Contact: daan@smallwins.ch
When you use the reflection form, we collect only what you provide:
No cookies, no tracking. This website does not set any cookies and uses no analytics, advertising, tracking pixels, or third-party trackers. Because nothing is stored on or read from your device, no cookie banner or cookie consent is required to use it.
Do Not Track. Because we do not track users across websites or over time, we do not respond differently to browser "Do Not Track" (DNT) signals. There is no cross-site tracking to disable.
We process your diary entry for a single purpose: to generate a short, supportive coaching summary (your small wins, recurring themes, and a suggested next action) and deliver it to your coach. We do not use your data for advertising or profiling, and we never sell it.
This is a lightweight service with no permanent database. Your entry is processed in real time and is not stored permanently by us. The generated summary exists as an email message; once it has been reviewed and delivered, the processing data is deleted. The email itself remains in the relevant inboxes (yours, your coach's, and our review inbox) under normal email retention.
To provide the service, your reflection is shared with the following processors:
gpt-4o-mini) to generate the summary. OpenAI may process this data outside Switzerland (for example, in the USA). We rely on OpenAI's API data-handling terms, under which API inputs are not used to train their models.Where data is transferred abroad, we take reasonable steps to ensure an adequate level of protection consistent with the nFADP.
Regardless of where you live, you can ask us to:
To exercise any of these, email daan@smallwins.ch and we will respond within a reasonable time. As we operate from Switzerland, you also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC / EDOEB).
If you are based in the United States: we collect only the information described in Section 2, use it solely to generate and deliver your coaching summary, and we do not sell or share your personal information for money or for cross-context behavioural advertising. We have no incentive to do so.
California residents may request to know what personal information we hold, request its deletion, and confirm that we do not sell or share it. We will not discriminate against you for exercising these rights. To make a request, email daan@smallwins.ch. Because we keep no permanent database (see Section 4), the data we hold about any individual is minimal.
If you are in the United Kingdom or the European Economic Area, your personal data is protected by the UK GDPR / EU GDPR. Our legal basis for processing your reflection is your consent, which you give by submitting an entry and may withdraw at any time (see Section 7). Alongside the rights in Section 7, you also have the right to data portability.
Some processing involves transfers outside the UK/EEA, for example the OpenAI API in the United States (see Section 5). We rely on appropriate safeguards and data minimisation for these transfers. You have the right to lodge a complaint with your data protection authority: in the UK, the Information Commissioner's Office (ico.org.uk); in the EU, your national supervisory authority.
Data is transmitted over encrypted HTTPS connections. We limit access to the review inbox to authorised persons only.
We may update this policy as the service evolves. The "last updated" date above reflects the current version.
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