Data Privacy Policy

Version effective as of 30 June 2026.

With this Data Privacy Notice we, wearefreemovers GmbH (hereinafter we or us), describe how we collect and further process personal data. This Data Privacy Policy is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements such as a concluded contract are applicable to specific circumstances.

The term “personal data” in this Data Privacy Policy shall mean any information that identifies or could reasonably be used to identify any person.

If you provide us with personal data of other persons (such as family members, student colleagues), please make sure the respective persons are aware of this Data Privacy Policy and only provide us with their data if you are allowed to do so and such personal data is correct.

This Data Privacy Policy is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA»). However, the application of these laws depends on each individual case.

Table of Contents

Controller and EU Representative

The “controller” of data processing as described in this Data Privacy Policy (i.e. the responsible person) is

wearefreemovers GmbH
c/o startup space AG
Neuhofstrasse 12
6340 Baar
Switzerland
Email: [email protected]

You can notify us of any data protection related concerns under the specified address above.

Our representative in the European Union according to art. 27 GDPR is:

Mrs. Lina Zoppi
Via Pavia 16
26854 Pieve Fissiraga (LO)
Italy
Email: [email protected]

Collection and Processing of Personal Data

We only process personal data that we obtain from our students directly, i.e. which you upload in your account with us, such as:

  • Passport or national ID, including name, birth date, nationality
  • Academic transcripts and records
  • Degree certificates and diplomas
  • Language proficiency certificates
  • CV and motivation letter
  • Letters of recommendation
  • Proof of enrolment at the home university and nomination or learning-agreement documents
  • Passport photo
  • Financial documents or bank statements, where a visa or scholarship requires them
  • Health, insurance, or disability documents, where relevant
  • Criminal-record certificate, where a programme requires it

Purpose of Data Processing and Legal Grounds

We use the collected data in order to match you with suitable educational institutions, the procurement of our placement services, as well as in order to comply with our domestic and foreign legal obligations.

In addition, in line with applicable law and where appropriate, we may process your personal data for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:

  • Providing and developing our services and websites, apps and other platforms, on which we are active;
  • Communication with educational institutions;
  • Server monitoring to prevent errors;
  • Advertisement and marketing, provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
  • Asserting legal claims and defense in legal disputes and official proceedings;
  • Prevention and investigation of misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
  • Ensuring our operation, including our IT, our websites, apps and other appliances;
  • Acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of wearefreemovers GmbH.

If you have given us your consent to process your personal data for certain purposes (for application, matching check and enrollment with chosen educational institutions), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

Please note that we have no control on the processing of your personal data by the educational institution chosen by you, to which we have transmitted your personal data on your behalf and pursuant to your instruction for application and enrollment services. You enter into a separate contractual relationship with the chosen educational institution, pursuant to which the chosen educational institution becomes the controller of your personal data submitted.

Analytics

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and to track you across several visits.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called «cookie»). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. If you block cookies, it is possible that certain functions are no longer available to you. By using our websites, you agree to our use of such techniques.

The specific tracking technologies we use on our website, the third-party providers involved, and the options available to you to manage or refuse them are described in detail in our Cookie Policy.

Datatransfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned: 

  • Educational institution(s) chosen by you;
  • Our service providers (such as e.g. hosting providers, email service provider, IT providers, accounting service provider, payment service provider, AI services provider);
  • Domestic and foreign authorities or courts;
  • Other parties in possible or pending legal proceedings.

together Recipients.

Certain Recipients may be within Switzerland or the European Union, but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which the educational institution is domiciled and where our service providers are located (such as Cloudways, Cloudflare, New Relic and Zapier, which are based in the United States).

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for the transmission to the educational institution chosen, which happens pursuant to your explicit instruction, as well as in case of legal proceedings abroad or in cases of overriding.

Retention Periods for your Personal Data

We process and retain all your personal data uploaded in your account as long as we consider them as required for the performance of our services, for which you registered with us. Provided that you have successfully enrolled with an educational institution to which we referred you, we will delete your data within 30 days of receiving notification from the respective educational institution. In case you have registered an account with us but not successfully enrolled with an educational institution, we assume that you are still interested and retain your personal data for 3 years and delete them only on expiration of these 3 years, subject to your earlier deletion request.

We retain your personal data relevant to accounting (i.e. invoices and placement confirmation) beyond the duration described above in compliance with legal obligations, such as accounting and documentation regulations, as well as for the period during which claims can be asserted against our company (e.g., for bookkeeping, evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).

Data Security

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access. such as IT and network security solutions, access controls and restrictions, and encryption of data in transit.

Obligation to Provide Personal Data To Us

In the context of our business relationship you must provide us with any personal data that is necessary for application, matching and enrollment process with educational institutions (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to provide the placement services to you.

Your Rights

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights.
  • You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Sections 3- 5.
  • Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you wish to exercise the above-mentioned rights in relation to us, please contact us by e-mail to the email address pursuant Section 1 of this Data Privacy Policy. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).

You also have these rights in relation to the educational institutions as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you are located in the European Union, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://www.edpb.europa.eu/about-edpb/our-members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/en/.

Amendments of this Data Privacy Policy

We may amend this Data Privacy Policy at any time without prior notice. The current version published on our website shall apply. If the Data Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of a material amendment.

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