Privacy Policy



1. Applicability

This Privacy Policy applies to the Exfluency website and language services platform (the “Exfluency Platform“), but does not apply to any third party websites that may be linked to our websites, which will be governed by their own privacy policies.


2. Controller

Exfluency AG (c/o eMBe Finanz GmbH, Bahnhofstrasse 20, 6300 Zug, Switzerland, E-Mail: is controller in the sense of article 4 (7) of the European General Data Protection Regulation (“GDPR”).


Our representative in the EU for requests related to GDPR is Alma Oprasic, Chief of Staff,


3. General Information

The terms “We”, “Us”,” Our” mean Exfluency AG. The terms “You” and “Your” refer to You, as a language expert of our Exfluency Platform. The term “personal data” refers to all information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person, as set out in Art. 3 lit. a of the Swiss Data Protection Act (“DPA”) and Art. 4 (1) GDPR. In addition, personal data subject to the DPA comprises data of legal persons.


4. Collection of Data

Information. In order to be admitted to the Exfluency Platform as a language expert, we ask you to give Us information about You by submitting information on the Exfluency Platform or by corresponding with Us by phone, email or otherwise. The information You give Us may include your name, address, email address, phone number, personal description or photograph, CV and any other information related to Your application as a language expert on the Exfluency Platform. Any processing of your personal data is based on a legal basis which is indicated below.


5. Purpose of processing and legal basis

Within the applicability of GDPR, any processing of data requires a legal basis. If the processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the request of the data subject, the processing may be based on Art. 6 para. 1 lit. b) GDPR.


If the processing is necessary to safeguard the legitimate interests of the data controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, do not prevail, it can be based on Art. 6 para. 1 lit. f) GDPR.


We process your data for the following purposes:

• to check your suitability for acting as a language expert on the Exfluency Platform and subsequently to fulfill our obligation to make Exfluency Platform available to you in accordance with the service conditions concluded between you and us; the legal basis for data processing is Art. 13 para.2 lit. a) DPA and Art. 6 para. 1 lit. c) GDPR.

• to inform you about changes to our services; the legal basis for data processing is Art. 13 para.2 lit. a) DPA and Art. 6 para. 1 lit. b) GDPR.

• to ensure that the content of the Exfluency Platform is presented on your computer as efficiently as possible; the legal basis for data processing is Art. 13 para.1 DPA and Art. 6 para. 1 lit. b) or f) GDPR. • to inform you about parts of the services which we believe to be of interest to you if you have given your consent; the legal basis for data processing is Art. 13 para.1 DPA and Art. 6 para. 1 lit. a) GDPR; • as part of our efforts to offer you the greatest possible security when using our site. The legal basis for data processing is Art. 13 para.1 DPA and Art. 6 para. 1 lit. f) GDPR. We also process data that cannot be assigned to any person. These are data that do not personally identify you, including anonymous information and aggregated data. This information helps us better understand how our visitors use the Services, analyze demographics, interests and behaviors of our visitors, improve the Services, provide customized services and information to visitors, and similar purposes.


6. Activity

When You use the Services, We receive and store certain information which may include Your personal information, regarding Your use of the Services. Examples include IP addresses, browser types, domain names, and other statistical data regarding Your use of the Services. We may use this data in a way that does not disclose any of Your personally identifiable information, including, but not limited to, for purposes of developing new product and service offerings.


7. Cookies

We may send cookies to Your computer in order to uniquely identify Your browser and improve the quality of Our service. The term “cookies” refers to small pieces of information that a website sends to Your computer’s hard drive while You are viewing the site. We may use both session cookies (which expire once You close Your browser) and persistent cookies (which stay on Your computer until You delete them). Persistent cookies can be removed by following Your browser help directions. If You choose to disable cookies, some areas of Exfluency Platform and Services may not work properly or at all. The use of cookies is based on Art. 13 para.1 DPA and Art. 6 para. 1 lit. f) GDPR.


8. Disclosure of Information

We may disclose Your Personal Information:

(a) Legal obligation

In response to a request for information if we believe such disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation. The legal basis for processing to fulfil a legal obligation is Art. 13 para.1 DPA and Art. 6 para.1 lit. c) GDPR.

(b) Third Party Providers

We may also share personal data with partner custodians to reduce repetitive collection of know-your-customer documentation from You and to facilitate custodians meeting their obligations under the AMLA or applicable AML regulations in the Your jurisdiction of domicile. The legal basis for such transfer is Art. 13 para. 1 DPA and Art. 6 para. 1 lit. f) GDPR.

(c) Violation of Terms of Services

If we believe your actions are in violation of Our Terms of Service and Privacy Policy, or to protect the rights, property and safety of Us or others. In this case, the transfer is based on Art. 13 para.1 DPA and Art. 6 para. 1 lit. f) GDPR.


9. Security

We take commercially reasonable steps to protect Your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use up to date TLS-encryption that your systems support when transmitting data via Our systems. However, We cannot guarantee that all Internet or email transmission is fully secure or error free and except for Our guarantee to use commercially reasonable and up to date measures to technically secure any data transmission, We cannot guarantee their absolute security and We therefore cannot be held liable for intercepted information sent via the Internet or for third parties using revoked, stolen, forged, or otherwise insecure certificates. You should therefore take special care in deciding what information You send to Us via email and keep this in mind when disclosing any Personal Information to Us or to any other party via the Internet.


10. Retention Period

We store your personal data for as long as is necessary for the purpose for which it was collected or for fulfilling our legal obligations, such as statutory retention periods. The data will be deleted at the latest within one month after the respective purpose no longer applies.


11. Your Rights

You as the data subject are entitled to extensive rights which you can assert against us. Upon request, we will inform you in writing, in accordance with the applicable statutory provisions, whether and, if so, which personal data we have stored about you. You can inspect your personal data at any time and free of charge and demand its correction and/or deletion and/or blocking. For this purpose and/or to obtain further information, please contact us at


You have the right to receive the personal data we hold about you in a structured, common, machine-readable format. Upon request, we will transfer your personal data to another controller. If you wish to exercise any of the rights mentioned in this section or if you have any questions about the processing of your personal data, please contact us at the above email address.


You also have the right to file a complaint with the relevant data protection authority.


12. Existence of an Automated Decision Making Process

As a responsible company, we refrain from automatic decision-making or profiling.


13. Conditions and Changes to this Privacy Policy

We are free to change this privacy policy at any time. The new version will always be posted on this website. These changes will be effective immediately for new users of our services and will become effective for existing users through continued use of the services after the effective date of the posted change. If you do not wish to approve the changes to our use of your personal information, you must notify us before such changes take effect that you wish to deactivate your account with us. Please note that you are always responsible for keeping your personal information up to date and providing us with your current contact information.


Valid as of July 2021.