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This translation is for information only. The German version prevails. German version

Legal

Data Processing Agreement (DPA)

This agreement governs how N. Haas Consulting (the “Processor”) processes personal data on behalf of the customer (the “Controller”) when the customer uses EasyWeb AI. It forms part of the Terms and Conditions and applies under Art. 9 FADP and, where applicable, Art. 28 GDPR.

1. Subject matter and duration

The subject matter is the editing, storing, publishing and hosting of the customer's website with EasyWeb AI and the associated processing of personal data. The agreement applies for the duration of the subscription and beyond, for as long as we process the customer's data.

2. Type of data and data subjects

  • Website visitors: details from the contact form (e.g. name, email, telephone, message); where hosted by EasyWeb AI, technical details on access (IP address, time, page, browser) in the server's access logs, which are deleted automatically after 14 days. For visitor counts without cookies, the IP address is not stored but used only as a non-traceable daily code.
  • The customer's employees and agents: user accounts (name, email, role), messages to the AI Editor, log of changes.
  • Persons who appear in the website's content (e.g. team, contact persons), to the extent the customer enters them.

3. Instructions

We process the data only to provide EasyWeb AI in accordance with the Terms and Conditions and in accordance with the customer's instructions. The customer gives instructions via EasyWeb AI (e.g. jobs in the AI Editor, settings, deletion) or by email. If we consider an instruction to be unlawful, we will inform the customer.

4. Confidentiality and support access

Persons at our company who have access to the data are bound to confidentiality and access it only to the extent necessary for operation and support.

We access the customer's customer area for support purposes only on the basis of a support request from the customer or with their prior consent. In the event of an urgent security incident, we may exceptionally access it without consent, to the extent necessary to avert a specific danger; we will inform the customer's administrators of this immediately by email.

Every access is limited to the necessary scope and to one hour at most. Purchases, user management and login credentials remain blocked throughout. We log the time, duration, reason and the person accessing; the customer's administrators can see this information under “Trust & data”.

5. Technical and organisational measures

  • Hosting and database in data centres in Switzerland; encrypted transmission (HTTPS).
  • Access with password; two-factor login available for all accounts, administrators are clearly reminded of it until it is set up; protection against password guessing; invitation and reset links valid only once.
  • Roles and permissions (administrator, editor); protected areas; every change traceable as a version.
  • Daily backups retained for up to 60 days; regular automatic testing of restoration.
  • AI changes first as a draft; published only after approval.
  • Visitor counts without cookies and without stored IP addresses.

6. Sub-processors

The customer consents to the engagement of the following sub-processors. We bind them by contract to equivalent data protection.

We use Anthropic's AI models via Microsoft Azure (Foundry). For requests and responses, Anthropic is our sub-processor; depending on the deployment, Anthropic runs the models on Microsoft Azure infrastructure and in that respect engages Microsoft as its own sub-processor. Microsoft receives directly from us only contract, billing and usage data of our own account, no content from the customers' websites.

  • Infomaniak Network SA (Geneva, Switzerland): Servers, hosting of the websites, database, backups, email delivery, and domains and email mailboxes ordered via EasyWeb AI. Location: Switzerland.
  • Anthropic Ireland, Limited (KI-Modelle Claude, betrieben über Microsoft Azure / Foundry) (Dublin, Ireland): AI processing of the tasks in the AI Editor. Location: Data centres worldwide are possible, including outside Switzerland and the EU (e.g. USA).
  • We generally notify new or replaced sub-processors by email at least 30 days before they are used. If one of our service providers announces a change at shorter notice, we will inform you as soon as possible. The customer may object within the notified period on justified data protection grounds. If we cannot offer a reasonable alternative, the customer may terminate the contract effective on the date of the change; we will refund, pro rata, fees paid in advance for the period thereafter.
  • We bind sub-processors by contract to appropriate data protection obligations and remain responsible to the customer for the performance of our obligations.

7. Disclosure abroad and AI processing

For AI processing, data may reach countries without adequate data protection (e.g. the USA).

For transfers abroad, the European Commission’s Standard Contractual Clauses apply, including the Swiss addendum (Anthropic’s data protection agreement).

Under its contract, Anthropic may not use content from our tasks to train AI models. Anthropic deletes requests and responses within 30 days. Content that the safety systems flag as a possible violation of the usage policies may be retained for up to 2 years and, in exceptional cases, reviewed by Anthropic staff.

8. Supporting the customer

We support the customer appropriately with requests from data subjects (access, rectification, erasure, release) – much of which they can do directly in EasyWeb AI, e.g. delete form messages or export the website – and, where necessary, with data protection impact assessments.

If we become aware of a personal data breach affecting personal data that we process on behalf of the customer, we will inform the customer without undue delay after becoming aware of it: of the nature and scope, the categories of data concerned, possible consequences and measures taken, as far as known; we will provide any missing information subsequently. We support the customer with statutory reporting and notification obligations.

9. Deletion after the end of the contract

After the end of the contract, the customer can export their data for 30 days. We then delete it automatically, and from the backups after a further 60 days at the latest, unless there is a statutory retention obligation. On request, we confirm the deletion in writing.

10. Audits

On request, we give the customer the information they need to demonstrate compliance with this agreement. We agree on-site audits on a case-by-case basis; the customer bears the costs.

11. Final provisions

The Terms and Conditions apply to liability. In the event of conflict, this agreement takes precedence over the Terms and Conditions on data protection matters. Swiss law applies.

Version dated 30 October 2026 · Version 2026-11-06.1

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