Legal

Privacy Policy

Effective date: 18 March 2025.

This page explains the policies of Cortexia SA ("we", "our", "us") regarding the collection, use and disclosure of personal data when you use our Service (as described below), and the choices you have in relation to that data.

1. Data Controller

Postal address Cortexia SA
Route de Vevey 91
1618 Châtel-Saint-Denis
Switzerland
Email address dpo@cortexia.ch
Phone +41 (0)21 931 45 28
Company registration 95135740900014

2. Definitions

Service means the website https://www.cortexia.ch and all urban cleanliness measurement services offered by Cortexia SA.

Personal Data means data about a living individual who can be identified from those data (or from those data and other information either in our possession or likely to come into our possession).

Usage Data is data collected automatically, generated either by the use of the Service or by the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on your device (computer, tablet or smartphone).

Data Controller means the natural or legal person who (alone, or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purposes of this Privacy Policy, we are the Data Controller of your personal data.

Subcontractors (or Service Providers): the term Subcontractor (or Service Provider) means any natural or legal person who processes data on behalf of the Data Controller. We may use the services of several Service Providers in order to process your data more effectively.

Data Subject (or User): a Data Subject is any living individual who uses our Service and is the subject of personal data.

3. Data Processing

Purpose Data Subjects Legal Basis Retention Period
Camera configuration and improvement of waste detection algorithms Any person visible from public spaces Legitimate interest 5 days before anonymisation
Presenting image evidence during detection alerts Any person visible from public spaces Legitimate interest 1 day before anonymisation
Monitoring the image visible by the camera Any person visible from public spaces Legitimate interest 3 days
Newsletter Any person subscribing to the newsletter Consent (B2C) / Legitimate interest (B2B) Until unsubscription
Website usage analysis (analytics cookies) Website visitors Consent 1 year and 1 month
Newsletter form submission (functional cookies) Website visitors Consent 6 months
Retaining user cookie consent; protecting the website from bot attacks (necessary cookies) Website visitors Legitimate interest 1 year

4. Data Recipients

The recipients of the data are:

5. Transfers Outside the EU

Data transfers outside the EU may take place:

6. Microsoft Clarity

This website uses Microsoft Clarity, a user experience analytics tool provided by Microsoft Corporation (One Microsoft Way, Redmond, WA 98052, USA). Clarity collects behavioural data (mouse movements, clicks, session recordings, heatmaps) via cookies deposited on your device.

This data is processed by Microsoft in accordance with its privacy policy. Clarity is activated only after your explicit consent. You may withdraw your consent at any time using the button on this page.

7. Learn More About Personal Data Processed by Cortexia

Processing of personal data that may be carried out by Cortexia-Boxes equipped with cameras

As part of the use of its artificial intelligence software solution, the Cortexia-Box — which aims to improve urban cleanliness and is mounted on its customers' urban vehicles (e.g. sweepers, bicycles, etc.) — Cortexia SA may inadvertently collect personal data about you. The Cortexia-Box is not a video surveillance system: its purpose is absolutely not surveillance, and it does not operate in the same way as such a system.

What personal data may we collect?

The Cortexia-Box, in order to analyse waste on the ground, is fitted with an image sensor oriented towards the ground, which may inadvertently capture only images of your face or the licence plate of your vehicle if you are very close to it (for example, if you are crouching near one of the vehicles fitted with a Cortexia-Box).

In its standard operation, images are not saved.

As part of the training of detection algorithms, a small percentage of images is collected (approximately 0.01%). These images are anonymised within 5 days of collection by automatic and irreversible blurring of faces and licence plates that may be visible.

For what purposes do we process your personal data?

In operational mode, the Cortexia-Box immediately processes the captured images, which are transformed into digital cleanliness metadata (type and quantity of waste detected, timestamp) in order to create urban cleanliness graphs and diagrams for Cortexia SA's customers. No image that could inadvertently contain personal data about you (e.g. face or licence plate) is recorded and/or transferred.

As part of continuous improvement, and in order to ensure the quality of image processing by the Cortexia-Box, Cortexia SA uses a sample of approximately 0.01% of images. These images are used to train the detection algorithm in order to improve its quality. This may involve, for example:

On what legal basis do we process images containing personal data?

The inadvertent processing of your personal data in the context of the operation of the Cortexia-Box is based on the legitimate interest of Cortexia SA and its customer, in order to ensure the improvement and quality management of waste detection carried out by the Cortexia-Box.

Do we share images that may contain your personal data?

To ensure complete and reliable anonymisation, Cortexia SA transmits data anonymised by the blurring algorithm to a subcontractor located in the European Union, subject to a strict contract ensuring the protection of your data. This subcontractor is responsible for sorting any images that may have escaped the algorithm. This ensures complete elimination of personal data.

What measures do we take to ensure the security of Cortexia-Boxes?

Cortexia SA has implemented organisational and technical measures to ensure the security of Cortexia-Boxes (e.g. regular maintenance, use of a private APN network for IT channels).

Cortexia SA also ensures the quality of its data blurring algorithms through regular audits. Anonymised images are reviewed by a subcontractor located in the European Union, subject to a strict contract ensuring the protection of your data and guaranteeing complete anonymisation.

8. Your Rights

Data protection rights are granted to you by the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).

Cortexia SA intends to take reasonable steps to enable you to correct, amend, delete or limit the use of your personal data. If you wish to know what personal data we hold about you and would like it to be deleted from our systems, please contact us.

You have the following rights with regard to your personal data:

To exercise these rights, you may contact Cortexia SA directly:

Proof of identity may be requested if Cortexia SA has doubts about your identity.

We also inform you that in the context of the joint responsibility agreement concluded between Cortexia SA and each of its customers, in accordance with Article 26 of the GDPR, Cortexia SA is responsible for providing information and managing responses to the exercise of rights by a data subject.

9. Cookies

For full details of the cookies used on this website, please consult our Cookie Policy.

10. Service Providers

We may use third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related tasks, or assist us in analysing how our Service is used.

These third parties have access to your personal data only to perform these tasks on our behalf and are prohibited from disclosing or using it for any other purpose.

We use Microsoft Clarity to monitor and analyse the use of our Service (only with your consent — see section 6).

11. Data Disclosure

Business transaction

If Cortexia SA is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Disclosure to law enforcement

Under certain circumstances, Cortexia SA may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency).

Cortexia SA may disclose your personal data in good faith where such action is necessary to:

12. Links to Other Sites

Our Service may contain links to other sites that we do not operate. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

13. Children's Privacy

Our Service is not directed at persons under the age of 18. We do not knowingly collect personally identifiable information from minors. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without parental consent, we take steps to remove that information from our servers.

14. Changes to this Privacy Policy

We reserve the right to update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the effective date at the top of this document. We advise you to review this Privacy Policy periodically for any changes.