Privacy Policy
This policy in short
- We collect the data we need to market, sell and deliver our programs, to stay in touch with you and to run our business.
- We never sell your data.
- We use AI to help us work. Our AI providers don’t use your data to train their models, and a person on our team checks before anything important is decided about you.
- We record all of our calls. Recordings of coaching calls stay inside our programs and are never used in our marketing.
- If you don’t pay what you owe, we may pass your details to a collection agency or a lawyer.
- You can ask what data we hold about you, have it corrected or deleted, and stop our marketing emails at any time.
Who we are
Sigrun GmbH is responsible for your personal data. “We”, “us” and “our” mean Sigrun GmbH. “You” means anyone whose data we handle: our students, members and clients, people on our email list, visitors to our websites, and anyone who contacts us.
Sigrun GmbH, Suurstoffi 37, 6343 Rotkreuz, Switzerland. Email: info@sigrun.com.
Our representative in the EU, for EU data protection authorities and for people in the EU, is VGS Datenschutzpartner GmbH, Am Kaiserkai 69, 20457 Hamburg, Germany, info@datenschutzpartner.eu.
This policy applies to all our websites, including sigrun.com and programs.sigrun.com, our programs and communities, our emails, our calls and events, and our social media pages. Our terms and conditions, also on sigrun.com, set out the rules for buying and using our programs.
We follow the Swiss Federal Act on Data Protection. Where the EU General Data Protection Regulation (GDPR) applies, for example because you live in the EU, we follow it too.
What data we collect
Data you give us
- Contact details: your name, email address, phone number, business name and country.
- Purchase and billing details: what you bought, when, the price, your billing address and your payment history. Your card details go straight to our payment provider. We don’t see or store your full card number.
- Program data: your login, what you post in our community, your questions, form and survey answers, your progress, and your feedback and testimonials.
- Business audit answers: in some programs, for example SOMBA® Advantage, we ask you detailed questions about your business, such as your revenue, clients, offers, audience, marketing, brand and use of AI, to create your personal business and brand audit.
- Messages: emails, chat messages, social media messages and anything else you send us.
- Call data: your name, image, voice and what you say or write in the chat when you join a call that we record.
- Other people’s details: if you buy partner access for a business partner or team member, you give us their name and email address. Please tell them about this policy.
- Website chats: when you chat with Gudrun, the AI assistant on our website, your first name, email address, your messages and her answers, the page you started the chat on, the time, and whether the chat was passed to our team.
Data we collect automatically
- Website and app data: your IP address, browser and device, the pages you visit, how long you stay and how you found us. We collect some of this with cookies, and only with your consent where the law requires it.
- Email data: whether you open our emails and click on links.
- Acceptance records: which version of our terms you accepted, when, and how, for example the order or login it came from.
Data we get from others
- Payment providers tell us whether a payment went through, failed or was disputed.
- Advertising platforms such as Meta and Google tell us how our ads perform, mostly in summary form.
- Collection agencies and lawyers tell us how the collection of an unpaid amount is going.
- We may look at public information, such as your website or business profile, for example when you apply for a program. For a brand audit, we search the internet for public information about you and your business, such as your website, press, podcast appearances, books and social media, and we measure how visible your website is.
Data we don’t want
Please don’t share sensitive data with us, such as health details, religious or political views or financial account details, in our community, calls or forms. If you choose to share it, for example in a coaching call, we use it only to coach you.
Why we use your data
We only use your data for clear purposes, and the law gives us a reason (a “legal basis”) for each.
- To sell and deliver our programs: to give you access, run calls and the community, support you, take payments and send you program emails. Legal basis: our contract with you.
- To create your business and brand audit, and to recommend your next program and coaching group. Legal basis: our contract with you.
- To keep records and meet our legal duties, for example accounting and tax. Legal basis: the law.
- To collect unpaid amounts and to protect our rights, for example if someone copies our programs. Legal basis: our legitimate interest.
- To keep a record of who accepted our terms, so that we can prove it if there is ever a dispute. Legal basis: our legitimate interest.
- To improve our programs, website and marketing, for example by analysing feedback, questions and website use. Legal basis: our legitimate interest.
- To answer your questions in our website chat, follow up on them by email, for example to correct an answer, and improve our AI assistant’s answers. Legal basis: our legitimate interest, or the steps before a contract when you ask about a program.
- To send you marketing emails about our programs, workshops and events. Legal basis: your consent, or our legitimate interest if you are already a student.
- To show you our ads on social media and measure how they work. Legal basis: your consent, through our cookie banner.
- To keep our websites, platforms and accounts safe. Legal basis: our legitimate interest.
Call recordings
We record all our coaching calls, workshops, masterclasses and webinars. When a call is recorded, you are told as you join it. Recordings may include your name, image, voice and chat messages.
We use recordings of coaching calls only inside our programs, so that students can watch them later, and to improve our programs. We never use coaching calls in our marketing.
Recordings of our free and paid workshops, masterclasses and webinars may be shared as replays and used in our marketing. If you don’t want to appear in a recording, turn off your camera and don’t use the chat. We don’t remove anyone’s video, voice or chat messages from a recording afterwards.
We may use AI to transcribe and summarise recordings. The section on AI explains how.
Please don’t record our calls yourself or bring your own AI note-taker or recording tool, unless we allow it. Our terms and conditions explain this.
How we use AI
We use AI tools to help our team work faster and to build the AI agents in our programs. This section explains what that means for your data.
What we use AI for
- Writing and editing drafts, such as emails, lessons and posts.
- Transcribing, summarising and searching call recordings.
- Sorting and answering questions and support requests.
- Analysing feedback, survey answers and program results.
- Reading public web pages about you for your brand audit.
- Editing video and audio.
- Building and improving the AI agents and tools in our programs.
What data may go into AI tools
When we use AI for these tasks, it may handle your name, your messages, what you share in our programs and calls, and your form answers. We don’t put your payment details into AI tools. We put in only what the task needs.
How we protect your data in AI tools
- We use AI providers as our service providers, under a data processing agreement. They may use your data only to provide their service to us.
- We use AI accounts and settings under which the providers don’t use our data to train their AI models.
- AI can be wrong, so a person on our team checks AI output before we rely on it.
- We don’t make decisions about you by AI alone if they have legal or similarly important effects for you, such as whether you can join a program or must pay an amount. A person always makes those decisions.
- Audit scores are calculated by fixed rules, not by AI. A person on our team checks your evidence before it counts, and you can ask us to review your result.
- We don’t use AI to create images, video or voice recordings of you without your permission.
- If you chat with an AI assistant on our websites or in our programs, we tell you that it is AI.
AI agents in your own account
Some of our programs give you AI agents or skills that run in your own AI account, with a provider you choose. What you type into them goes to that provider, under your own agreement with them. We don’t see it unless you share it with us. Check your provider’s privacy settings, including whether it may train on your data.
Using what we learn
We may use questions, feedback and results from our programs to improve our lessons and AI agents. When we do this, we remove names and details that show who you are.
The chat on our website
Gudrun, the chat assistant on our website, is AI. To write her answers, each message goes to our AI provider. We keep every chat for 90 days, and then it is deleted automatically. Our support team reads the chats to answer and follow up on your questions, and to improve Gudrun’s answers, for example by writing approved answers to questions many people ask. Those answers don’t contain your name or details. If Gudrun passes your chat to our team, we also share it in our internal team chat. Chatting with us doesn’t add you to our email list. If you tick the box to get our emails, we add you to the list, and you can unsubscribe at any time. Please don’t share sensitive data in the chat.
Marketing emails and ads
We send marketing emails about our programs, workshops, events, podcast and book if you signed up for them or if you are already a student. Every email has a link to unsubscribe. You can also email info@sigrun.com. Unsubscribing doesn’t stop emails about a program you have bought or about money you owe.
We show ads on social media and other websites. With your consent through our cookie banner, ad platforms such as Meta and Google can tell us whether an ad led to a visit or a purchase. We may also upload email addresses in coded (hashed) form to these platforms, to show our ads to people on our list or to stop showing ads to people who have already bought. You can object to this at any time by emailing info@sigrun.com.
Who we share your data with
We never sell your data. We share it only when we need to:
- With service providers who work for us: checkout and payments, email and CRM, our program platform and community, video calls, file storage, video editing, booking, electronic signatures, team tools, website hosting and security, web search and website analysis, bookkeeping, and AI. We have a data processing agreement with each of them, and they may use your data only for the work they do for us.
- With our team, coaches and contractors, as far as their work needs it. They are bound to confidentiality.
- With collection agencies, lawyers and courts, in Switzerland or in your country, if you don’t pay what you owe or if we need to protect our rights. We share what they need: your name, contact details, what you bought, what you owe and our messages with you.
- With professional advisers, such as accountants, auditors, lawyers and insurers.
- With authorities, if the law requires it.
- With a buyer or new owner, if we sell or transfer all or part of our business. Your data stays protected under this policy.
Other students can see what you post in our community and what you say in group calls.
Data sent to other countries
We are in Switzerland. Our service providers are mainly in Switzerland, the EU and the United States, and some of them work with partners in other countries.
When your data goes to a country whose data protection Switzerland and the EU don’t consider adequate, we protect it with recognised safeguards. In the United States, this means providers certified under the Swiss-US and EU-US Data Privacy Framework, or the standard contract clauses approved by the European Commission and the Swiss data protection authority. You can ask us for a copy of these safeguards.
How long we keep your data
- Accounting records, such as invoices and payments: 10 years, as Swiss law requires.
- Your student account and program data: for as long as you are a student, then up to 2 years, so that you can come back and we can answer questions. Recordings that are part of our programs stay as long as the program uses them.
- Records of who accepted our terms, contracts and messages about them: 10 years after our relationship ends, because claims can be made for that long under Swiss law.
- Unpaid amounts: until they are settled, and for as long as the law allows us to collect them.
- Your email list details: until you unsubscribe. We then keep a short record that you unsubscribed, so that we don’t email you again.
- Website chats: 90 days, then they are deleted automatically.
- Website and advertising data: as set out in our cookie banner, usually no longer than 2 years.
After that, we delete your data or make it anonymous.
How we keep your data safe
We protect your data with technical and organisational measures, such as access controls, two-step login, password managers and secure providers. Only people who need your data for their work can see it. If a data breach puts you at risk, we tell you and the authorities as the law requires.
Your rights
You have the right to:
- ask what data we hold about you and get a copy;
- have wrong data corrected;
- have your data deleted, unless we must or may keep it, for example for accounting, to collect an unpaid amount, or because it is part of a call recording;
- object to how we use your data, including for marketing, at any time;
- limit how we use your data while a question about it is being settled;
- get the data you gave us in a common format, to take it elsewhere;
- withdraw your consent at any time, for the future;
- ask for a person to review a decision made by automated means.
To use these rights, email info@sigrun.com. We may ask you to confirm who you are. We reply within 30 days, and it is free unless a request is clearly unfounded or excessive.
If you think we handle your data wrongly, please tell us first so we can fix it. You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch) or, if you live in the EU, to the data protection authority in your country.
Cookies
Our websites use cookies and similar technology. Cookies that the website needs to work are always on. Cookies for analytics and advertising are only used if you agree in our cookie banner. You can change your choice at any time through the cookie settings link on our website or in your browser.
Children
Our programs are for adults. We don’t knowingly collect data from anyone under 18. If you think we have, please tell us and we will delete it.
Changes to this policy
We update this policy when our business or the law changes. The latest version is always on sigrun.com.