Cookie Policy

Last Updated: October 27, 2025

1. Introduction

This Cookie Policy explains how CLEANPACT GmbH ("CLEANPACT", "we", "us", or "our") uses cookies and similar tracking technologies on our website https://cleanpact.io (the "Website").

This policy provides you with clear and comprehensive information about the cookies we use, why we use them, and how you can manage your cookie preferences.

By using our Website, you acknowledge that you have read and understood this Cookie Policy. If you do not agree with this policy, please adjust your browser settings or refrain from using our Website.

2. Company Information

CLEANPACT GmbH
Registered in Zug, Switzerland
Commercial Registry: CHE-250.598.316
Registered Office: c/o Confidaris AG, Hertizentrum 15, 6300 Zug
Legal Form: Gesellschaft mit beschränkter Haftung (Limited Liability Company)

3. What Are Cookies?

Cookies are small text files that are stored on your device (computer, tablet, smartphone, or other electronic device) when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners.

Cookies allow websites to:

• Remember your actions and preferences (such as login details, language settings, font size)
• Improve your user experience by providing personalized content
• Analyze how visitors use the website to improve functionality and performance
• Enable certain features and functionalities

Cookies can be set by the website you are visiting (first-party cookies) or by third-party services that the website uses (third-party cookies).

4. Legal Basis for Using Cookies

4.1 Swiss Law

Under Swiss law, specifically Article 45c of the Swiss Telecommunications Act (TCA), website operators must:

• Inform users clearly about the use of cookies and their purposes
• Provide users with the right to refuse cookie processing
• Obtain explicit consent for cookies that process sensitive personal data or create personality profiles

The revised Swiss Federal Act on Data Protection (FADP/nDSG), which came into force on September 1, 2023, requires:

• Consent for processing sensitive personal data (Article 6 FADP)
• Privacy by design and data protection-friendly default settings (Article 7 FADP)
• Transparency about data processing activities

4.2 EU General Data Protection Regulation (GDPR)

Although CLEANPACT is based in Switzerland, we recognize that our services may be accessed by users in the European Union. Therefore, we also comply with the EU General Data Protection Regulation (GDPR) and the ePrivacy Directive when applicable.

Under the GDPR and ePrivacy Directive:

• Prior and explicit consent must be obtained before placing non-essential cookies on users' devices
• Users must be able to provide granular consent (accept some cookies while rejecting others)
• Consent must be freely given, specific, informed, and unambiguous
• Consent must be as easily withdrawn as given
• Pre-ticked checkboxes and implied consent through continued browsing are not valid

If you are accessing our Website from the EU or EEA, the stricter GDPR requirements apply to you.

5. Types of Cookies We Use

We use different types of cookies on our Website. Below is a comprehensive explanation of each category:

5.1 Essential Cookies (Strictly Necessary)

Purpose: These cookies are absolutely necessary for the Website to function properly. Without these cookies, certain features and services cannot be provided.

Examples of essential cookies include:

• Session cookies: Remember your actions during a single browsing session (e.g., keeping you logged in while navigating between pages)
• Authentication cookies: Verify your identity when you log in to secure areas
• Security cookies: Detect authentication abuse and protect against fraudulent activity
• Load-balancing cookies: Distribute server traffic to ensure optimal website performance
• User-input cookies: Remember information you enter into forms or shopping carts

Legal Basis: These cookies do not require your consent under Swiss or EU law because they are necessary for the Website to function. However, we inform you of their use in the interest of transparency.

Retention Period: Session cookies are deleted when you close your browser. Other essential cookies may persist for up to 12 months or as needed for security purposes.

5.2 Functional Cookies (Preference Cookies)

Purpose: These cookies enable enhanced functionality and personalization based on your preferences. They remember choices you make (such as language, region, or display preferences) to provide a more personalized experience.

Examples include:

• Language preference cookies
• Region or location preference cookies
• Accessibility settings cookies
• Customization preferences (e.g., font size, color themes)

Legal Basis: These cookies enhance your user experience but are not strictly necessary. We seek your consent before placing these cookies unless they can be justified under legitimate interest.

Retention Period: Typically 6 to 12 months, or until you clear your browser cookies.

5.3 Analytics and Performance Cookies

Purpose: These cookies collect information about how visitors use our Website, including which pages are visited most often, how long visitors stay on pages, and any error messages encountered. This information helps us improve the Website's performance and user experience.

Examples include:

• Google Analytics cookies (if applicable)
• Matomo/Piwik analytics cookies (if applicable)
• Heatmap and session recording tools
• Page load performance measurement

Data Collected: These cookies may collect:

• IP addresses (anonymized where possible)
• Pages visited and time spent on each page
• Referral sources (how you arrived at our Website)
• Device type, browser type, and operating system
• Click patterns and navigation behavior

Legal Basis: Consent is required for analytics cookies under GDPR and recommended under Swiss law. We will not activate these cookies without your consent if you are in the EU/EEA.

Retention Period: Analytics data is typically retained for 6 to 26 months, depending on the tool used and the purpose of analysis.

Third-Party Providers: We may use third-party analytics services. Data shared with these providers is processed in accordance with their privacy policies and our data processing agreements.

5.4 Marketing and Advertising Cookies (Targeting Cookies)

Purpose: These cookies are used to deliver advertisements that are relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and to measure the effectiveness of advertising campaigns.

Examples include:

• Remarketing cookies (e.g., Google Ads, Facebook Pixel, LinkedIn Insight Tag)
• Advertising network cookies (e.g., DoubleClick, AdRoll)
• Social media advertising cookies

Data Collected: These cookies may collect:

• Browsing history and behavior across websites
• Interaction with advertisements
• Demographic information and interests
• Unique identifiers for targeted advertising

Legal Basis: Explicit consent is required before placing marketing cookies on your device under both Swiss and EU law.

Retention Period: Marketing cookies may be stored for 6 to 13 months, depending on the advertising platform and regulatory requirements in your jurisdiction.

Third-Party Providers: These cookies are typically set by third-party advertising networks. We do not control these cookies directly, and their use is governed by the respective third parties' privacy policies.

5.5 Social Media Cookies

Purpose: These cookies are set by social media platforms (such as LinkedIn, Twitter/X, Facebook) when you share content or interact with social media widgets embedded on our Website.

Examples include:

• LinkedIn Share buttons
• Facebook Like buttons
• Twitter/X Tweet buttons

Data Collected: These cookies may track your interaction with social media content and may be used by the social media platforms for their own advertising and analytics purposes.

Legal Basis: Consent is required before activating social media cookies.

Retention Period: Varies by social media platform, typically 6 to 24 months.

Third-Party Control: These cookies are controlled by the respective social media platforms. Please refer to their privacy policies for more information.

6. First-Party vs. Third-Party Cookies

6.1 First-Party Cookies

First-party cookies are set directly by CLEANPACT and are used solely for the operation and improvement of our Website. We have full control over these cookies and the data they collect.

6.2 Third-Party Cookies

Third-party cookies are set by external services and platforms that we integrate into our Website (e.g., analytics providers, advertising networks, social media platforms). These third parties may use the data collected for their own purposes, including cross-site tracking and profiling.

We work only with reputable third-party providers who comply with applicable data protection laws. However, we do not control how third parties process data collected through their cookies. We recommend reviewing the privacy policies of these third-party services.

7. Cookie Consent and Your Choices

7.1 Cookie Consent Banner

When you first visit our Website, you will see a cookie consent banner that allows you to:

• Accept all cookies
• Reject non-essential cookies
• Customize your cookie preferences by category (essential, functional, analytics, marketing, social media)

If you are located in the EU/EEA, no non-essential cookies will be placed on your device until you provide explicit consent.

7.2 Managing Your Cookie Preferences

You can change your cookie preferences at any time by:

• Clicking the "Cookie Settings" or "Manage Cookies" link available in the footer of our Website
• Adjusting your preferences in the cookie consent banner if it reappears
• Using your browser settings to block or delete cookies (see Section 7.3 below)

Withdrawing Consent: You can withdraw your consent at any time by adjusting your cookie settings. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

7.3 Browser Settings

Most web browsers allow you to control cookies through their settings. You can:

• Block all cookies
• Block third-party cookies only
• Delete cookies after each browsing session
• Receive notifications when cookies are being set

Please note: Blocking or deleting essential cookies may affect the functionality of our Website, and certain features may not work properly.

How to manage cookies in popular browsers:

• Google Chrome: Settings > Privacy and security > Cookies and other site data
• Mozilla Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and site permissions > Manage and delete cookies and site data
• Opera: Settings > Privacy & Security > Cookies

For more detailed instructions, please refer to your browser's help documentation.

7.4 Opt-Out Tools for Third-Party Advertising

You can opt out of interest-based advertising from participating companies through the following industry opt-out platforms:

• European Interactive Digital Advertising Alliance (EDAA): http://www.youronlinechoices.eu/
• Digital Advertising Alliance (DAA): http://optout.aboutads.info/
• Network Advertising Initiative (NAI): http://optout.networkadvertising.org/

Please note: Opting out does not mean you will stop seeing advertisements; it means the advertisements will not be tailored to your interests.

8. Specific Cookies Used on Our Website

Below is a detailed list of the specific cookies we currently use on our Website:

Note: This list is subject to change as we add or remove services. We will update this Cookie Policy accordingly and notify you of significant changes.

To view a real-time, automatically updated list of all cookies on our Website, please click the "Cookie Settings" link in the footer.

9. Data Retention

We retain cookie data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

General Retention Periods:

• Session cookies: Deleted immediately when you close your browser
• Essential persistent cookies: Up to 12 months
• Functional cookies: 6 to 12 months
• Analytics cookies: 6 to 26 months (typically 14 months for Google Analytics)
• Marketing cookies: 6 to 13 months, depending on jurisdiction and provider
• Consent records: We retain records of your cookie consent for up to 24 months for compliance and accountability purposes

Automatic Deletion: Cookies are automatically deleted when they reach their expiration date. You can also manually delete cookies through your browser settings at any time.

10. International Data Transfers

Some of the third-party services we use may transfer data collected through cookies to countries outside Switzerland and the European Economic Area (EEA), including the United States.

We ensure that any international data transfers comply with applicable data protection laws, including:

• EU-US Data Privacy Framework (for transfers to the US)
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions recognizing equivalent data protection standards

For more information about how we safeguard international data transfers, please refer to our Privacy Policy.

11. Your Data Protection Rights

Under Swiss data protection law (FADP) and the EU GDPR (if applicable), you have the following rights regarding your personal data collected through cookies:

11.1 Right of Access

You have the right to request access to the personal data we hold about you, including data collected through cookies.

11.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

11.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data under certain conditions.

11.4 Right to Restrict Processing

You have the right to request that we limit the processing of your personal data in certain circumstances.

11.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

11.6 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

11.7 Right to Withdraw Consent

Where we process your personal data based on consent (e.g., for analytics or marketing cookies), you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

11.8 Right to Lodge a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with the competent supervisory authority:

Switzerland:
Federal Data Protection and Information Commissioner (FDPIC)
Website: https://www.edoeb.admin.ch/

EU/EEA:
Your local Data Protection Authority

To exercise any of these rights, please contact us using the details in Section 14 below.

12. Cookies and Children's Privacy

Our Website and services are not directed at children under the age of 18. We do not knowingly collect personal data from children through cookies or any other means.

If you believe we have inadvertently collected information from a child, please contact us immediately, and we will take steps to delete such information.

13. Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

We will notify you of any material changes by:

• Posting the updated Cookie Policy on our Website with a new "Last Updated" date
• Displaying a prominent notice on our Website
• Sending you an email notification (if you have provided your email address)

Your continued use of our Website after any changes constitute your acceptance of the updated Cookie Policy.

We encourage you to review this Cookie Policy periodically to stay informed about how we use cookies and protect your privacy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Cookie Policy or our use of cookies, please contact us:

CLEANPACT GmbH
c/o Confidaris AG
Hertizentrum 15
6300 Zug
Switzerland

Email: privacy@cleanpact.io
Website: https://cleanpact.io
Data Protection Officer: privacy@cleanpact.io

15. Additional Resources

For more information about cookies and data protection, we recommend the following resources:

• Swiss Federal Data Protection and Information Commissioner (FDPIC): https://www.edoeb.admin.ch/
• European Data Protection Board (EDPB): https://edpb.europa.eu/
• All About Cookies: https://www.allaboutcookies.org/
• Your Online Choices (EU): http://www.youronlinechoices.eu/

16. Summary of Key Points

✅ What cookies we use: Essential, functional, analytics, marketing, and social media cookies
✅ Why we use them: To provide, secure, personalize, and improve our Website and services
✅ Your control: You can accept, reject, or customize cookie preferences at any time
✅ Legal compliance: We comply with Swiss FADP, EU GDPR, and ePrivacy Directive
✅ Transparency: We provide clear information about all cookies and their purposes
✅ Your rights: Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent
✅ Data protection: We partner only with reputable third parties and implement appropriate safeguards

BY USING OUR WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS COOKIE POLICY AND AGREE TO THE USE OF COOKIES AS DESCRIBED HEREIN, SUBJECT TO YOUR CONSENT PREFERENCES.

THANK YOU FOR TAKING THE TIME TO UNDERSTAND HOW WE USE COOKIES TO ENHANCE YOUR EXPERIENCE ON OUR WEBSITE.