Privacy Policy

Effective date: 1 June 2026 · Last updated: 21 June 2026

1. Controller

TennoTenRyu Inh. Cesarano, Baarerstrasse 87, 6300 Zug, Schweiz (CHE-272.196.618) is the data controller responsible for the processing of personal data on this platform. Contact: info@cesaranogilbert.com

2. Data We Collect

When you use the APEX Business Modernization OS diagnostic or subscription services, we may collect:

• Email address and company name (provided by you in the diagnostic form or checkout)
• Company profile information submitted for the BMO-001 assessment (industry, size, processes, tools)
• Subscription and billing data processed by Stripe (we do not store card details)
• Usage logs (server-side access logs, diagnostic submission timestamps)

3. Purpose and Legal Basis

• Contract fulfilment (Art. 6(1)(b) GDPR / Art. 31 nDSG): Processing your assessment inputs to deliver diagnostic results and managing your subscription.
• Legitimate interests (Art. 6(1)(f) GDPR): Service improvement, security, and fraud prevention.
• Consent (Art. 6(1)(a) GDPR): Email communications via double opt-in confirmation.

4. Diagnostic Data Handling

Company profile data submitted for BMO-001 assessments is processed ephemerally — it is used to generate your diagnostic result and is not stored permanently or shared with third parties. Assessment results are returned only to you.

5. Third-Party Processors

• Stripe Inc. (USA) — payment processing. Stripe is certified under EU-US Data Privacy Framework.
• Resend / Transactional Email — email delivery for confirmation and nurture sequences.
• OpenAI / Groq — AI inference for diagnostic generation. Data is processed under their enterprise API terms and not used for model training.
• Render Inc. (USA) — cloud infrastructure hosting in Frankfurt, Germany (EU).

6. Data Retention

Subscriber email addresses and company names are retained for the duration of the subscription plus 12 months for legal and contractual purposes. Diagnostic session data is not retained beyond the session. You may request deletion at any time.

7. Your Rights

Under GDPR and Swiss nDSG you have the right to: access, rectify, erase, restrict, and port your personal data; withdraw consent at any time; lodge a complaint with the relevant supervisory authority (FDPIC in Switzerland; your local DPA in the EU).

To exercise your rights: info@cesaranogilbert.com

8. Cookies

This platform does not use tracking cookies or third-party analytics. No cookie consent banner is required.

9. Changes

We may update this policy. Material changes will be communicated by email to active subscribers.

TennoTenRyu Inh. Cesarano · CHE-272.196.618 · Baarerstrasse 87 · 6300 Zug, Schweiz · Imprint · Terms