Privacy Policy

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).

1. Data Controller

The data controller responsible for this service is:
[Your Full Name / Company Name]
[Street Address], [Postal Code] [City], Switzerland
Contact: daan@engelbarts.ch

2. What Data We Collect

When you use the reflection form, we collect only what you provide:

• Your email address (the client) — so we can reach you if needed.
• Your coach's email address — to deliver the summary to the correct recipient.
• Your diary entry — the free-text reflection you write about your day.
• Basic technical metadata — the page URL you submitted from.

We do not use cookies, tracking pixels, or analytics on the reflection form.

3. Why We Process It (Purpose)

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.

4. Data Retention

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.

5. Sharing With Third Parties

To provide the service, your reflection is shared with the following processors:

• OpenAI — your diary text is sent to the OpenAI API (model gpt-4o-mini) to generate the summary. OpenAI may process this data outside Switzerland (e.g. in the USA). We rely on OpenAI's API data-handling terms, under which API inputs are not used to train their models.
• Our email provider — used to deliver the summary email to your coach and to our review inbox.

Where data is transferred abroad, we take reasonable steps to ensure an adequate level of protection consistent with the nFADP.

6. Human Review (Quality Assurance)

7. Your Rights

Under the nFADP, you have the right to:

• Request information about the personal data we hold about you;
• Request correction or deletion of your data;
• Object to or restrict the processing of your data;
• Withdraw consent at any time.

To exercise any of these rights, email daan@engelbarts.ch. You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC / EDÖB).

8. Security

Data is transmitted over encrypted HTTPS connections. We limit access to the review inbox to authorised persons only.

9. Changes to This Policy

We may update this policy as the service evolves. The "last updated" date above reflects the current version.