Privacy Policy

Cyclem SA
Last updated:01.01.2026

This document has been automatically translated.

The original French version is authoritative.

1. Purpose and scope

This privacy policy describes how Cyclem SA processes personal data in the context of the operation of its digital platform dedicated to the purchase and sale of second-hand items, accessible via a mobile application and a website.

She specifies, in particular:

• the categories of personal data processed,
• the purposes and legal bases of the processing,
• the recipients of the data,
• the rights of the people concerned.

Data processing is carried out in accordance with theFederal Act on Data Protection of 25 September 2020 (FADP)effective September 1, 2023

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2. Data Controller

Cyclem SA
19 Rue des Caroubiers
1227 Carouge (GE) – Switzerland
Email address:support.reply@cyclem.ch

Cyclem SA is responsible for the processing of personal data that it collects and uses in the operation of its platform.

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3. Personal data processed

In the context of using the Cyclem platform, the following categories of personal data may be processed, depending on the user's interactions:

• Identification data: name, surname, date of birth, gender;
• Contact details: email address, telephone number, postal address;
• User account data: profile picture, description, preferences, login details;
• Data relating to the use of the platform: articles published, bought or sold, transaction history, communications between users;
• Technical and connection dataIP address, device identifier, connection logs, browsing data.

THE payment transactions, thefund storage, THE bank detailsas well as theidentity verification dataanti-money laundering (AML), politically exposed person (PEP) control and sanctionsare not processed by Cyclem SA.

This data is processed exclusively by a third-party payment service provider.Payrexx AGacting asindependent data controller.
Cyclem SA does not have access to users’ full bank details and does not hold any funds on behalf of sellers.

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4. Purposes of the processing

The personal data processed by Cyclem SA is used exclusively for the following purposes:

• creation, management and administration of user accounts;
• connecting users for the purchase and sale of second-hand items;
• managing communications between users and with customer support;
• customer relationship management and handling of support requests;
• maintenance, security and technical improvement of the platform;
• statistical analysis and performance measurement, subject to anonymization or prior consent where required;
• communication of information relating to the services of Cyclem SA, subject to the right to object provided by law.

The purposes related topayments, At deposit and withdrawal of funds, as well as compliance with legal obligations regardingfight against money launderingandidentity verificationare exclusively the responsibility of Payrexx AG.

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5. Legal basis for processing

The processing of personal data carried out by Cyclem SA is based on the following legal grounds:

• the execution of a contract or pre-contractual measures(art. 31, para. 2, let. a LPD), in particular for the creation and management of the user account and the use of the platform;
• compliance with legal obligationsapplicable to Cyclem SA;
• the overriding interest of Cyclem SA or third parties(art. 31, para. 1 LPD), in particular with regard to security, prevention of abuse and improvement of services;
• the consent of the person concernedwhen required by law.

The processing carried out by Payrexx AG in the context of payment services is based on the legal bases specific to Payrexx AG, as an independent data controller.

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6. Disclosure of data to third parties

Personal data may be disclosed to third parties only to the extent necessary to achieve the purposes described in this policy.

These third parties include, in particular:

• of the technical and IT service providersproviding hosting, maintenance and support for the platform.
  Cyclem's infrastructure is hosted onservers located in Switzerlandprovided by Microsoft Azure;
• of the logistics and delivery partners, notably Swiss Post, for the delivery of parcels between users;
• theSwiss Relay collection point serviceoperated directly by Cyclem SA.
  In this context, onlypackage references and necessary logistics informationare shared with relay point partners;
• Payrexx AG, a Swiss payment service provider, acting asindependent data controller For :
  
  • payment processing,
  • the storage of sellers' funds
  • the management of named merchant accounts,
  • fund withdrawals,
  • compliance with regulatory obligations regarding KYC, AML, PEP and sanctions;
• administrative or judicial authorities when required by law.

When certain service providers process personal data outside of Switzerland, Cyclem SA ensures that appropriate safeguards are in place to ensure an adequate level of protection in accordance with the LPD.

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7. Shelf life

Personal data is kept only for as long as necessary to fulfill the purposes for which it was collected or as long as required by law.

• User account data is retained until the account is deleted, subject to any contrary legal obligations;
• Transaction and accounting data are kept in accordance with applicable legal retention periods;
• Technical and analytical data is kept for a limited time and anonymized as soon as possible.

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8. Rights of the persons concerned

In accordance with the LPD (Federal Law on Data Protection), data subjects have the following rights in relation to the processing carried out by Cyclem SA:

• right of access;
• right of rectification;
• right to delete;
• right to restriction of processing;
• right to object;
• right to data portability where provided for by law;
• right to withdraw their consent at any time when the processing is based on it.

Applications can be sent to:support.reply@cyclem.ch.
A response is provided within the time limits stipulated by applicable legislation.

The individuals concerned also have the right to lodge a complaint with theFederal Data Protection and Transparency Commissioner (FDPIC)if they believe that the processing of their personal data violates applicable data protection legislation.

Important :
For data processed by Payrexx AG in the context of payments and regulatory obligations, data subjects are invited to exercise their rights directly with Payrexx AG, in accordance with its own privacy policy.

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9. Data Security

Cyclem SA implements appropriate technical and organizational measures to guarantee the confidentiality, integrity and availability of personal data, including:

• encryption of communications when appropriate;
• access control and limitation;
• authentication procedures;
• Regular backups and appropriate security measures.

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10. Cookies and similar technologies

The platform may use cookies and similar technologies for technical operation, analysis and service improvement purposes.

• Strictly necessary cookies are used without prior consent;
• Optional cookies, particularly analytical or marketing cookies, are subject to user consent.

Consent can be withdrawn at any time via browser or application settings.

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11. Policy changes

Cyclem SA reserves the right to modify this privacy policy at any time.
Any substantial changes will be published on the platform. The version in effect is the one available at the time of consultation.

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12. Contact

For any questions relating to the processing of personal data:

Cyclem SA
19 Rue des Caroubiers
1227 Carouge (GE) – Switzerland
support.reply@cyclem.ch

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