1. Scope of this policy
    1.1 This policy explains how personal data is processed in connection with the AIDEAS Program, Swiss Edition (the "Program"), and with the website at https://aideas.org/swiss/de (the "Website").


    1.2 It does not cover:
    (a) the account on the training platform and the use of the platform itself — see the separate privacy policy available at https://platforma.generatorpomyslow.pl/legal/terms?lang=de;
    (b) the GeneratorGPT application, in which the Participant creates a separate account — see the separate privacy policy available at https://gpt.generatorpomyslow.pl/privacy-policy;
    (c) the Discord server, which is governed by separate rules accepted upon entry to the server, and by the privacy policy of Discord Inc.


    1.3 Defined terms used here — Participant, Edition, Free Phase, Paid Phase, Access Period, Certificates — have the meaning given to them in the General Terms and Conditions of participation in the Program, available at https://aideas.org/swiss/eng/terms-conditions.


  2. Who is responsible for your data
    Responsibility is divided between two companies, according to the stage at which the data is collected. Each is responsible for its own layer.

2.1 Generator Pomysłów is not a party to the contract for participation in the Program. Requests concerning the Program are addressed to HR Vision Center GmbH; requests concerning the Website are addressed to Generator Pomysłów. Section 15 explains how to route a request and what happens if it reaches the wrong company.

  1. The Website, cookies, analytics and advertising
    This section describes the layer for which Generator Pomysłów is the controller. It applies to every visitor to aideas.org, whether or not they register for the Program.
    3.1 Cookies and similar technologies


    (a) On the first visit, a consent banner is displayed. Cookies which are strictly necessary for the Website to function are used on the basis of the legitimate interest of Generator Pomysłów in delivering a working service. All other categories — analytics, session recording and advertising — are used only after consent is given, and consent may be withdrawn at any time through the settings available at swiss@aideas.org.

    (b) A single banner in the European standard is used for all visitors, including visitors from Switzerland. The same pages serve visitors from the European Union, and two regimes on one domain would be a cost without a benefit.
    (c) A list of the individual cookies, their purposes and their retention periods is set out at https://cookie-script.com/legal/privacy-policy.

    3.2 Analytics and session recording
    (a) Google Analytics is used to measure traffic and the effectiveness of campaigns.
    (b) Microsoft Clarity records how pages are used — pointer movement, clicks and scrolling — and produces session replays. Masking of form fields is enabled, which means that the content typed into the registration form is not recorded and is not transmitted to Microsoft.
    (c) Both tools operate only after consent under 3.1(a). Withdrawing consent stops further collection.

    3.3 Advertising pixels and joint controllership
    (a) The Website uses the Meta pixel and Google Ads tags to measure and target advertising campaigns.
    (b) In relation to the collection and transmission of data through those tags, Generator Pomysłów and, respectively, Meta Platforms Ireland Ltd. and Google Ireland Ltd. act as joint controllers within the meaning of Article 26 GDPR. The joint controllership covers collection on the Website and transmission to the provider. Any subsequent processing by the provider for its own purposes takes place under its sole responsibility and under its own privacy policy.
    (c) The essential content of the arrangements between the joint controllers is available on request at kontakt@visioncentre.ch. A data subject may exercise their rights against either joint controller.
    (d) These tags operate only after consent under 3.1(a).


  2. Registration and the personalisation survey
    The registration form serves two different purposes and the data it collects falls into two groups with different legal bases. This distinction matters: the first group cannot be declined without giving up participation, the second can be declined with no consequence at all.

4.1 Free-text fields — an express request. The two free-text fields are optional. Please do not enter into them any information about health, disability, religious or philosophical beliefs, political opinions, trade union membership, sexual life or orientation, or racial or ethnic origin — whether about yourself or about anyone else. That information is not needed to deliver the Program and is not wanted.
4.2 If, despite the request in 4.1, an answer contains data of a special category within the meaning of Article 9 GDPR or Article 5(c) FADP, it is deleted from the answer as soon as it is identified. Such data is not used for personalisation, is not used to compose teams and is not passed to any other Participant. The deletion is recorded.
4.3 Withdrawing consent to personalisation, or declining to give it, does not restrict access to the Program or to any of its materials and has no effect on the conditions for the issue of a Certificate. Consent may be withdrawn at any time by writing to kontakt@visioncentre.ch.

  1. Data processed during the Program

  1. Assessment, automated processing and the right to human review
    6.1 What is assessed automatically
    The results of module quizzes and of the final examination are determined automatically, on a points basis, against a closed set of correct answers. Passing them at the threshold set in the General Terms and Conditions is a condition for the issue of a Certificate. No person reviews the scoring of a quiz unless a request is made under 6.4.
    6.2 What is not assessed automatically
    Practical assignments and the Final Project are not assessed on their merits and are not assessed by any automated system. They are subject only to a check of formal completeness against criteria published in the description of the assignment.
    6.3 Who carries out the completeness check
    An automated system may flag a submitted work for review. It does not return work and does not block the issue of a Certificate. The decision to return a work for completion is taken by a person acting on behalf of HR Vision Center GmbH; the review is carried out by AIDEAS (Ideas Generator) acting as processor. Every flagging and every decision is recorded together with the date, the reason and the identifier of the person deciding.
    6.4 Your right to have a decision reviewed by a person
    You may request review by a person of: the result of a module quiz, the result of the final examination, and a decision to return work for completion. The request is made within 7 days using the function on the platform or by writing to kontakt@visioncentre.ch; a response follows within 14 days and in any event before Certificates are issued. This right implements Article 22(3) GDPR and Article 21 FADP. Every request and its outcome is recorded.
    6.5 The decision to issue a Certificate
    A decision to issue or to refuse a Certificate is not taken solely by automated means. Any discretionary element — in particular the assessment of a Participant's own contribution to the Final Project — is decided by a person acting on behalf of HR Vision Center GmbH.

  2. What other Participants can see
    7.1 Peer feedback
    (a) Practical assignments are made available for review to other Participants of the same Edition. The allocation is made by the system at random. A work may be allocated to more than one reviewer and there is no maximum number of reviews it may receive.
    (b) For that reason it is not possible to tell you in advance which Participants will see a particular piece of your work, or how many times it will be reviewed. What can be stated is the boundary: works are seen only by Participants of the same Edition, only through an allocation made by the system, and by the persons acting on behalf of the controller who carry out the check under 6.3.
    (c) A reviewer sees the work together with the first name and surname of its author.
    (d) Works are not published, are not shown in any gallery and cannot be browsed outside the allocation made by the system.
    7.2 Team work
    In the practical part of the Paid Phase, members of a team see, in relation to one another: first name and surname [to be confirmed], the preferred business challenge to be worked on, and the preferred AI tool. No other data from the registration form or from the survey is disclosed to team members — in particular, neither the free-text answers nor the age bracket.

  3. Certificates and the verification page
    8.1 Certificates are issued in the name of the Participant and contain a unique identifier, a link to the verification page and the identification details of the issuer.
    8.2 The verification page is public. Verification is carried out by entering the identifier of the Certificate and returns only confirmation that it is valid, the name of the Program and the date of issue. It does not disclose the first name or surname of the Participant.
    8.3 For that reason, the data set retained for verification purposes after the end of the Access Period is limited to the identifier, the name of the Program, the date of issue and the status of the Certificate.

  4. Artificial intelligence in the Program
    9.1 The following components supported by artificial intelligence are used: the AI explanatory assistant, the AI support assistant, video materials featuring a synthetic presenter, and the quiz and examination engine. You are informed in the interface, on first interaction, that you are interacting with a system and not with a person.
    9.2 Video materials featuring a synthetic presenter. The avatars appearing in the materials were created from the likeness of real subject-matter experts, who consented to that use. No data of Participants is transmitted to the supplier of the avatar technology, which therefore does not process Participants' personal data and is not listed among the recipients in section 11. The materials are marked as generated content.
    9.3 Language models. Content that you enter into the AI assistants is transmitted to the model providers listed in section 11 for the sole purpose of generating a response.
    9.4 Your content is not used to train models. Content entered by Participants, their work, their peer feedback and their conversations with the assistants are not used to train, fine-tune or evaluate any language model — neither by the controller, nor by the processors, nor by the model providers. This is a contractual arrangement with each provider, not an assumption about how the service behaves by default.
    9.5 Service improvement. Only anonymised and aggregated data is used to develop the service. Anonymisation here means the irreversible removal of any ability to link the data to a person; pseudonymisation does not satisfy that condition. Where a rating of a response is given, the value of the rating, the version of the model and the category of the query may be used in aggregate; the content of the conversation may not.
    9.6 Please do not enter into the AI components the personal data of third parties, or data of the special categories referred to in Article 9 GDPR and the corresponding provisions of the FADP.

  5. Live sessions and marketing communications
    10.1 Live sessions
    Webinars and Q&A sessions are delivered as a broadcast and are recorded. The recording covers the transmission by the person conducting the session. The image and voice of Participants are not recorded, since Participants do not appear on camera and do not speak during the broadcast. Recordings are made available to Participants on the platform.
    10.2 Marketing
    (a) At registration you may consent to receive information from HR Vision Center GmbH about further programmes and cohorts. The consent is optional, is not ticked by default, and may be withdrawn at any time — through the link in every message or by writing to kontakt@visioncentre.ch. Withdrawal does not affect the lawfulness of processing carried out before it.
    (b) A separate consent covering information from Generator Pomysłów about the platform is collected when the platform account is created, and is governed by the separate policy referred to in section 1.2(a). It is not collected through the Program registration form.
    (c) Service messages are not marketing. Notification of a change to the schedule, of the return of a work, of the issue of a Certificate or of the forthcoming expiry of the Access Period is part of performing the contract and is sent regardless of any marketing consent.
    (d) The mailing tool is operated on an account held by Generator Pomysłów.

  6. Recipients of the data
    11.1 The following table lists everyone who receives personal data, in what role and where. It is kept current; any change is notified in advance in accordance with section 16.

11.2 Personal data may also be transferred to other countries in which our service providers or their appointed sub-processors operate, potentially worldwide.
11.3 Data may also be disclosed to public authorities where an obligation to do so arises under applicable law.

  1. Transfers outside Switzerland and the European Union
    12.1 Data is processed primarily in the European Union and in Switzerland. Switzerland recognises the adequacy of the level of protection in the European Union, so transfers to the platform infrastructure require no additional safeguard.
    12.2 Transfers to recipients in the United States take place on the basis of the Swiss-U.S. Data Privacy Framework, which has been in force since 15 September 2024 and covers recipients certified under that framework, and — as regards operations carried out by the processor established in the European Union — the corresponding EU-U.S. framework.
    12.3 Certification of each recipient is verified before the transfer and re-verified periodically.
    12.4 You may request further information about the safeguards applied by writing to the address in section 18.

  2. Security and separation of data
    13.1 Technical and organisational measures appropriate to the risk are applied, including encryption in transit, access control on a need-to-know basis, and logging of access to data.
    13.2 Separation between clients. Data of the Program is logically separated from the data of other programmes delivered on the same platform. Search does not operate across that boundary.
    13.3 Vector representations. Works and peer feedback of Participants are not indexed into the vector database serving the AI explanatory assistant and do not enter any shared search space. The assistant operates on the canonical Program materials.
    13.4 Where a breach of the security of personal data is likely to result in a high risk to the personality or fundamental rights of the data subjects, the controller notifies the FDPIC as soon as possible, as required by applicable law. Affected persons are informed where this is necessary for their protection or is otherwise required under applicable law.

  3. How long data is kept

14.1 The account on the platform and the Access Period are governed by the separate policy referred to in section 1.2(a).

  1. Your rights
    15.1 Under the FADP: you may exercise the rights available under Swiss law, including the right to access, rectification, objection and, where applicable, erasure/destruction and data portability. Where the GDPR applies: you may have additional or more extensive rights, including the rights to restriction of processing and erasure under the GDPR.
    15.2 You also have the right not to be subject to a decision based solely on automated processing which produces legal effects or similarly significantly affects you. Section 6 explains how that right operates in this Program and how to exercise it.
    15.3 Where to send a request. Matters concerning the course of the Program, results, works, peer feedback, Certificates and payments — to HR Vision Center GmbH at kontakt@visioncentre.ch. Matters concerning the Website, cookies, analytics or advertising — to Generator Pomysłów at swiss@aideas.org. Matters concerning the platform account — to the address given in the policy referred to in section 1.2(a).
    15.4 A request sent to the wrong company will not be refused on that ground. It is passed to the company responsible and you are informed that it has been passed on.
    15.5 Complaint to a supervisory authority. You may report a breach of Swiss data protection law to the Federal Data Protection and Information Commissioner (EDÖB, Feldeggweg 1, 3003 Bern); insofar as processing carried out by Generator Pomysłów is subject to the GDPR, you may also lodge a complaint with the President of the Personal Data Protection Office in Poland (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw).

  2. Changes to this policy
    16.1 Where the substance of this policy changes — in particular where a new recipient is added or a purpose of processing is extended — Participants are informed in advance by e-mail and the change takes effect no earlier than 14 days after that notification.
    16.2 Editorial corrections take effect upon publication. The date of the most recent update is stated at the beginning of this document.

  3. Automated decision-making and profiling — summary
    For clarity, gathered in one place: quiz and examination results are determined automatically and are a condition for the issue of a Certificate; you may have them reviewed by a person under 6.4. Practical work is not assessed by any system. Personalisation of content on the basis of declared data does not produce legal effects and may be switched off without any consequence. No automated system decides whether a Certificate is issued.

  4. Contact
    Matters concerning payment and marketing: HR Vision Center GmbH, kontakt@visioncentre.ch. Matters concerning the Website: Generator Pomysłów Sp. z o.o., swiss@aideas.org.

  5. Language versions
    19.1 This Privacy Policy is made available in English and in German.
    19.2 This document is issued in English and in German, and may be issued in further language versions. The English version is the governing version. In the event of any discrepancy, inconsistency, omission, or difference in interpretation between the English version and any other language version, the English version prevails and constitutes the sole basis for interpreting this document. Other language versions are provided for convenience and have no independent interpretative effect. The foregoing does not derogate from mandatory provisions of applicable law; in particular, in a relationship with a Consumer, the language version required by such provisions prevails to the extent required by them.

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