Privacy Policy

This privacy policy describes which personal data we process when operating the platform xhorn.ch, why we do so and which rights you have in this respect.

Please read first

On this platform, data is processed that allows conclusions to be drawn about a person's intimate life. Under Art. 5 let. c FADP, such data is sensitive personal data and enjoys increased protection.

Three points you should know before using the platform:

• Your listings are public and can be viewed without logging in (section 3).
• Contact with providers does not run through us but takes place directly by telephone, SMS, WhatsApp or Telegram (section 6).
• You can delete your account yourself; it is blocked and hidden from the public immediately, and we then remove it permanently (section 7).

1. Controller

Patrick Stern
Zürichstrasse 5
6004 Luzern
Switzerland

For questions about data protection and to exercise your rights, you can contact this address at any time.

2. Terms and basics

Personal data means any information relating to an identified or identifiable natural person.

Sensitive personal data includes, among other things, data on the intimate sphere, health, religious, philosophical, political or trade union views, membership of an ethnic group, genetic and biometric data, and data on criminal prosecutions and sanctions.

Processing means any handling of personal data, in particular collecting, storing, using, modifying, disclosing, archiving, deleting and destroying.

We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and the Data Protection Ordinance (DPO). The platform is offered in several languages and can also be accessed from abroad; if you are located in the European Union or the EEA, the General Data Protection Regulation (GDPR) may also apply.

Depending on the purpose, we base the processing on your consent, on the performance of the user agreement, on legal obligations or on our overriding interest in secure and abuse-free operation. For sensitive personal data, we rely on your express consent.

3. Public nature of content

Listings, club entries, real estate listings and Stories are public and can be viewed without logging in. Everything you publish, including description text, images, video, contact name, telephone number, contact email, website, address and location, opening hours, price information and features, is visible to everyone.

Publicly accessible content can be captured and indexed by search engines. It can be copied, stored, archived, redistributed or placed in caches and web archives by third parties. We have no influence over this. After deletion on our side, copies may continue to exist with third parties.

We therefore recommend:

• Only publish information whose permanent public availability you can accept.
• Do not use your full name or your private home address. Where possible, use a separate telephone number for the contact details.
• Check images and videos for recognisable backgrounds, reflections, tattoos, vehicle registration plates and other features that make identification possible.
• Remove metadata (EXIF) from your files before uploading them, in particular GPS location data. Many cameras and mobile phones store the location of the shot in the file.

Publication is based on your express consent to the processing of sensitive personal data (Art. 6 para. 7 let. a FADP). You can withdraw this consent at any time by deleting the content or requesting the deletion of your account. The withdrawal applies for the future; it does not make the processing carried out up to then unlawful and does not extend to copies held by third parties.

The age stated in a listing is voluntary self-declaration. We do not check it for accuracy.

4. Which data we process

Our services are intended exclusively for persons aged 18 and over. We do not knowingly process data of minors. If we become aware that data of a minor is being processed, we block the account concerned without delay and delete the data, unless we are required to retain it to fulfil legal obligations or for official proceedings.

Account data

Name, email address, password (stored exclusively as a cryptographic hash value), profile picture, preferred language, role, account status, credit balance, registration date and status of the email confirmation.

Purpose: providing and managing the user account, authentication, communication. Basis: performance of the user agreement.

Provider details

With your first listing, you can additionally store a company name, description, telephone number, contact email, website, address and opening hours. These details are displayed publicly to the extent that you provide them.

Purpose: presenting your offer. Basis: your consent.

Listing, club and real estate data

Title, description, category, region, price type and price information, age information, contact details and preferred contact channels, address, postcode and town, images and videos, features, and creation, modification and expiry times.

Purpose: publication in accordance with your instructions. This data generally constitutes sensitive personal data. You alone decide on its content and scope. Basis: your express consent.

Stories

Image or video, time of publication and assignment to your provider profile. Stories are removed automatically 24 hours after publication.

Purpose: presenting time-limited posts. Basis: your express consent.

Verification data

You can voluntarily submit a photo of yourself, free of charge, to receive a verification badge. In doing so, we process the photo, the review status, the review date, the name of the reviewing person and, in the case of a rejection, the reason for it.

• The review is carried out manually.
• The photo is not published and cannot be accessed by other users or via a public address. Only persons with administrative rights have access. Only the badge appears publicly.
• We do not create biometric profiles from the photo and do not carry out automated facial matching.
• In the case of a rejection, the review record is retained; a new submission is possible.
• If you submit an identity document, please cover all information that is not required for the age and identity check.

Purpose: checking that you are of legal age and your identity, reducing abuse, protecting minors. Basis: your express consent and our overriding interest in an abuse-free platform.

Payment and credit data

Order data (amount, currency, status, time), the complete credit history with purchases, usage, refunds and corrections, and the details on your receipts.

Your credit card data is never transmitted to us and is not stored by us. Payment processing takes place entirely with the payment service provider (section 8).

Purpose: processing and traceability of payments, accounting. Basis: performance of the contract and statutory retention obligations.

Contact form

Name, email address, category of your enquiry and your message. This information is stored by us and additionally forwarded to us by email. To protect against automated submissions, we use a hidden form field and a limit on the sending frequency.

Purpose: answering your enquiry and traceability. Basis: our overriding interest in handling enquiries.

Favourites, recently viewed, view counts

Saved favourites are linked to your account. The list of recently viewed listings is stored exclusively locally in your browser; this data does not reach our servers. The number of views per listing is counted anonymously and is not assigned to any person.

Technical access and security data

Technical data is generated when the platform is accessed, in particular IP address, time, requested page, HTTP status, browser type and version, operating system and, where applicable, the referring page. To protect against automated attacks, we limit the number of attempts for login, password reset and the contact form per email address; the email address is stored briefly for this purpose. For reports without an account, we limit the number of reports per internet connection; for this purpose, we store a non-reversible identifier (hash value) of your IP address for one hour, not the IP address itself.

Purpose: operation and stability, error analysis, IT security, defence against attacks and abuse. Basis: our overriding interest in secure operation.

Reporting, moderation and administration logs

Reports about listings, provider profiles, users and Stories, our review log, blocking and deletion decisions and the related correspondence. Reports are also possible without an account; in that case we process the selected reason, your description and your email address for follow-up questions (only if you provide it voluntarily). In addition, we log administrative actions in an internal log that records the time, the acting person, the type of action and the data records concerned; this log may contain names and email addresses.

Purpose: handling reports, enforcing the terms of use, proof of compliance with our duties of care, internal control, cooperation with authorities. Basis: legal obligations and our overriding interest in traceable operation.

5. Data about other persons

Agencies, salons and studios can publish listings for persons who work for them. In doing so, they transmit personal data of these persons to us, including images and descriptions.

The business concerned is responsible for being entitled to do so, for the person concerned being of legal age, having expressly consented and having been informed about the publication. We require corresponding assurances and may request proof of them at any time.

For each business, we additionally process the name and contact details of the responsible contact person and the evidence submitted. This information is not published.

If you appear in a listing: If you are depicted or described in a listing that someone else has placed, you can request its deletion directly from us at any time, without an account, without giving a reason and without going through the business or the advertising person. We remove the content immediately and only review afterwards. Write to support@xhorn.ch.

Even if you transmit data about other persons to us, for example in a report or enquiry, you are responsible for being entitled to do so and for the data being correct.

6. Contacting providers

Listings have buttons that you can use to contact providers directly. The platform has no internal messaging system; communication with providers takes place outside the platform, and we have no access to it.

The buttons for calls and SMS open the corresponding application on your device; no data is transmitted to us or to third parties in the process.

The buttons for WhatsApp and Telegram open the respective service with a prepared message that contains the provider's name and a reference to xhorn.ch. From that point on, the terms and privacy provisions of the respective provider apply (WhatsApp: Meta Platforms Ireland Limited; Telegram: Telegram Messenger Inc.). We have no influence over which data these services process in the process. Do not use these buttons if you wish to avoid this.

No map is embedded on the listing detail page. If an address is stored, we display it as text and offer a link "Open in Google Maps". This link opens Google Maps in a new tab with the address as the search term; no data is transmitted from us to Google in the process. Only when you actively click this link do the terms of use and privacy provisions of Google (Google Ireland Limited) apply.

7. Retention and deletion

We only retain personal data for as long as this is necessary for the respective purpose or as statutory retention and limitation periods require.

Data category	Retention
Account data	Until deletion by you or by us; after self-deletion, first blocked and hidden, and removed permanently by us without a fixed deadline
Listings and associated files	Until deletion by you or by us. Expired listings are marked as expired but not deleted automatically; they remain until they are reactivated or deleted
Stories	24 hours (automatic)
Verification data (photo and review record)	30 days after the review is completed (automatic)
Order, credit and receipt data	10 years (Art. 958f CO)
Contact form	12 months
Technical access data	30 days
Data for abuse prevention (login, password and form attempts; reports without an account)	15 minutes or 1 hour (time window of the limit), then deleted automatically in the next daily clean-up
Reporting and moderation data	24 months after the processing is completed
Administration log	12 months
Recycle bin: identity verifications	30 days after being moved to the recycle bin (automatic)
Recycle bin: listings and club listings	No automatic deadline; until permanent deletion by us
Data relating to pending proceedings	Until final conclusion of the proceedings

Deletion of your account. You can delete your account yourself at any time in the account settings (confirmation with your password). After that you can no longer log in, and your listings, club listings and Stories disappear immediately from public view. We then carry out the final, irrevocable deletion of all data, including listings and Stories, insofar as no statutory retention obligation prevents it; no automatic deadline currently applies to this. You can additionally request final deletion at any time at support@xhorn.ch. Your right to deletion exists independently of this and is not restricted by it.

Deleted content first goes to a recycle bin and is then removed permanently. Uploaded files are deleted together with the associated data record.

After deletion, individual data may still exist in backup copies for a limited time until these are overwritten in the regular cycle. Data that we must retain due to legal obligations or for pending proceedings, in particular accounting data, is exempt from deletion.

8. Service providers

We use specialised service providers to operate the platform, who process personal data on our behalf. They are contractually obliged to process the data exclusively according to our instructions and in compliance with data protection.

Service provider	Purpose	Location
Supabase	Database, storage of images and videos, real-time notifications, scheduled tasks	Data centre Zurich; provider based in the USA
Hostinger	Operation of the website, sending of system emails	Data centre Frankfurt am Main, Germany

9. Disclosure to third parties

Beyond the service providers under section 8, we only disclose personal data insofar as this is necessary or we are legally obliged to do so. Recipients may be lawyers, authorities, courts and law enforcement authorities.

We disclose personal data to law enforcement authorities and other competent bodies if we are obliged to do so or if this is necessary to avert dangers, to clarify criminal offences or to protect persons. If there is a suspicion of the involvement of minors, of human trafficking or of coercion, we file a report and make the available data accessible to the authorities.

We do not sell personal data and do not pass it on to third parties for advertising purposes.

10. Disclosure abroad

The platform's database as well as its images and videos are stored in Switzerland (data centre Zurich). The website and the sending of system emails run at Hostinger in Germany. Germany has an adequate level of data protection. In addition, individual service providers are based abroad, which is why access from abroad in the context of operation, support and maintenance cannot be ruled out.

Disclosure to countries without adequate data protection only takes place if suitable safeguards exist, in particular standard data protection clauses, or if one of the statutory exceptions under Art. 17 FADP applies. On request, we will inform you about the safeguards in place and provide you with a copy.

11. Cookies and local storage

Cookies are small data records that are stored in your browser. We use the following:

Cookie	Purpose	Consent
Session cookie	Keeps you logged in	not required
Language setting	Remembers the selected language	not required
Cookie decision	Stores your choice in the cookie banner	not required

These three are technically necessary for the operation of the platform and cannot be deselected without impairing its functionality.

In addition, we store the list of recently viewed listings locally in your browser. This data is not transmitted to us.

You can delete or block cookies and local storage in your browser settings at any time. The platform may then no longer be fully available.

12. Audience measurement

The platform is technically prepared to use Google Analytics. If it is used, this takes place exclusively after your express consent via the cookie banner. Before consent, no script is loaded and no usage data is transmitted to third parties. With consent, a transfer of data to the United States is possible.

No Facebook pixel or other tracking by third parties is used.

13. Emails

We send no advertising emails and no newsletter.

We send operationally necessary messages, in particular to confirm your email address, to reset your password, to confirm payments including a receipt and in reply to enquiries via the contact form or to reports for which you have provided an email address. In addition, we may send you individual emails in the context of support or moderation. These messages are part of the user relationship.

We do not use tracking pixels for success measurement in our emails.

14. Data security

We take appropriate technical and organisational measures to protect the personal data processed, in particular:

• Encrypted transmission via HTTPS (TLS)
• Storage of passwords exclusively as cryptographic hash values (bcrypt)
• Confirmation of the email address on registration
• Access restricted to persons who need access to perform their tasks
• Access-protected storage of verification photos
• Logging of administrative actions
• Limiting of repeated login and form attempts
• Regular backup copies

Absolute security cannot be guaranteed for the transmission and storage of data on the internet. In particular, transmission by unencrypted email is not secure.

Like any digital communication, use of this platform is also subject to state surveillance measures over which we have no influence.

Data security breaches. If a breach of data security occurs that is likely to result in a high risk to your personality or your fundamental rights, we will report this to the Federal Data Protection and Information Commissioner (FDPIC) as soon as possible (Art. 24 FADP). We will also inform you if this is necessary for your protection or if the supervisory authority requires it.

15. Your rights

You have in particular the following rights:

• Access. You can request information on whether and which personal data we process about you, as well as on the purpose, retention period, origin and any recipients.
• Rectification. You can have incorrect data rectified and incomplete data completed.
• Deletion. You can request the deletion of your data.
• Restriction and objection. You can have the processing restricted and object to it with effect for the future.
• Data disclosure and portability. You can request the disclosure of your data in a common electronic format or its transfer to another controller.
• Withdrawal of consent. You can withdraw any consent given at any time with effect for the future.

To exercise these rights, contact support@xhorn.ch. We generally answer your request within 30 days. We are obliged to verify your identity by appropriate means and ask for your cooperation. Information is generally free of charge.

Within the legally permitted framework, we may postpone, restrict or refuse the exercise of these rights, in particular to protect overriding interests of third parties, because of statutory retention obligations or if proceedings are pending.

16. Supervisory authority

You have the right to enforce your claims in court or to file a complaint with the supervisory authority. In Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.

If you are located in the European Union or the EEA, you can additionally contact the data protection authority of your country of residence.

17. Changes to this privacy policy

We may amend this privacy policy, in particular if the legal situation, the service providers used or the scope of functions of the platform change. The version published on the platform at the relevant time is authoritative. We inform registered users of material changes by email.

This privacy policy is published in several languages. In the event of discrepancies, the German version prevails.