Privacy Policy
Version: 3.2
Effective date: 2 November 2026
Last updated: 2 November 2026
This Privacy Policy explains how Ocio processes personal data when you use the Ocio platform: the websites and apps powered by Ocio, through which organizations offer their products and services and end users find, book and use them. The words "organization", "end user" and "Ocio platform" have the meaning given in the Ocio End-User Terms and Conditions.
1. Who we are
The controller of personal data processed through the Ocio platform is Apsara Software GmbH, Hohlstrasse 210, 8004 Zürich, Switzerland, commercial register of the Canton of Zürich, UID CHE-228.016.109, email [email protected] ("Ocio", "we", "us", "our"). We act as data controller under the Swiss Federal Act on Data Protection ("FADP").
Supervisory authorities. You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner ("FDPIC") at edoeb.admin.ch.
2. Scope of this policy
2.1 This policy applies to the personal data Ocio processes in operating the Ocio platform: the websites and apps powered by Ocio, the administration tools, the backend services and related communications. It covers every person who uses the Ocio platform, including owners, administrators, teachers and other staff of an organization.
2.2 If you act for an organization. This policy governs the processing connected with your own use of the platform. The organization's relationship with Ocio, including any processing Ocio carries out on the organization's instructions, is governed by the General Terms and Conditions for Organizations and the organization's individual contract.
2.3 This policy does not apply to:
(a) an organization's use of the personal data it receives through the Ocio platform, or any processing it carries out outside the platform, for example video surveillance, paper records or its own marketing lists — the organization is responsible and its own privacy notice applies (§ 6.3);
(b) third-party websites or services that you reach by a link from the Ocio platform; or
(c) personal data processed by Stripe, by Google when you sign in with Google, or by other third parties acting as controllers in their own right — their privacy notices apply.
3. Your Ocio account
When you sign up on any website or app powered by Ocio, the platform creates a single Ocio account that works on all of them. Other users and organizations see you by your profile name (for example user_ab12cd34) and the details you publish; your internal account identifier is never shown to other users, organizations or third parties. The same account works on every website and app powered by Ocio, but each organization sees only what the platform shows it (§ 6.3).
4. What personal data we collect
We collect only the data we need to operate the Ocio platform. The categories below are not exhaustive; specific fields change as features evolve.
| Category | Data | Use |
|---|---|---|
| Account | Email and password or Google sign-in; first and last name; date of birth; optional picture, profile name, language and phone; account state and notification settings. | Name is public; date of birth confirms 18+. |
| Booking | What you booked, with dates, times and places; status; payment reference; QR code where issued. | Process bookings and purchases; QR codes expire when the session ends. |
| Community and content | Profile details you publish; plans; chat messages; connections and exchanged contact details; member-directory presence and opt-out; groups; reviews, comments and reactions; saved places. | Provide the community features you use; saved places are private. |
| Derived data |
5. Why we use your personal data and the legal basis
| Purpose | Legal basis |
|---|---|
| Create and operate your Ocio account; sign you in; confirm your age; show offers and process bookings and purchases; apply price categories; manage memberships and applications; process payments; issue and check QR codes; send booking and account emails; operate community and AI features; verify your phone by SMS; send activated and necessary notifications. | Performance of the contract with you and compliance with legal obligations under the FADP and Swiss law, in particular tax and accounting duties. |
| Keep accounting and order records (Art. 958f Swiss Code of Obligations); comply with legal process and answer authority requests. | Compliance with legal obligations under Swiss law. |
| Suggest people, plans, events and classes; compile anonymised statistics; show third-party events; keep the platform secure, prevent fraud and investigate reports; suggest the right community from your IP location; defend or pursue legal claims. | Our legitimate interests under the FADP, where your interests do not override them: helping users find relevant activities, keeping the platform secure, showing relevant offers, defending legal claims. You can object at any time. |
| Send marketing emails; send push notifications once allowed; personalisation offered as an option you switch on. | Your consent under the FADP, which you can withdraw at any time. |
6. Who we share personal data with
We share personal data only as described below. We do not sell or rent personal data and do not engage in cross-context behavioural advertising.
6.1 Current service providers acting on our instructions
| Recipient | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting of the platform and ocioapp.ai (database, backend, storage, backups, website). | EU |
| Cloudflare, Inc. | Network delivery and protection of ocioapp.ai (IP addresses, requests). | Global network; USA |
| Google (Google Ireland Ltd. / Google LLC) | Workspace email; Firebase push notifications; Calendar sync if connected; Maps lookups where used. | EU and USA |
| Stripe Payments Europe Ltd. | Online payments, including card and TWINT; payouts to the organization; independent controller for fraud prevention. | Ireland (EU); USA |
7. International transfers and data residency
7.1 Primary hosting in Switzerland and the EU. We operate the database, backend, file storage, backups and the ocioapp.ai website on servers rented from companies in Switzerland and the EU. No production data is stored outside Switzerland and the EU, and the EU/EEA recognise each other's protection as adequate.
7.2 Transfers outside Switzerland and the EU/EEA. The United Kingdom (OpenStreetMap) is recognised as adequate. For transfers to the USA (Cloudflare, Google, Stripe, Twilio, IPinfo, Anthropic, OpenAI, Ollama), we rely on the Swiss-U.S. Data Privacy Framework where the recipient is certified, and otherwise on standard contractual clauses recognized under Swiss law. Services you choose (§ 6.2), such as Telegram, WhatsApp or your calendar provider, may process data in countries without adequate protection; we send data only at your request when you connect or enable them (Art. 17 FADP).
8. Retention
We keep personal data only for as long as we need it.
| Category | Retention |
|---|---|
| Account data while active | Lifetime of the account. |
| Account data after deletion | Up to 30 days for recovery, then erased; backups age out within 100 days. |
| Booking and payment records | 10 years after the end of the calendar year of the transaction (Art. 958f Swiss Code of Obligations). |
| Chat messages | Until you or the organization delete them, or the community is deleted; backups age out within 100 days. |
| Logs and security data | At most 100 days, unless a longer period is needed for an open security or abuse investigation. |
| Marketing consent records | Until withdrawal. |
| Inactive accounts |
9. Your rights
You have the following rights, subject to the conditions and exceptions of applicable law:
- Access: a copy of the personal data we hold about you.
- Rectification: correction of inaccurate data.
- Erasure: deletion, subject to § 8.
- Restriction: restriction of processing in certain situations.
- Portability: a structured, commonly used, machine-readable copy, transmitted to another controller.
- Objection: to processing based on legitimate interests, including marketing profiling.
- Withdrawal of consent: at any time, with effect for the future.
- No automated decisions with legal or similarly significant effects (§ 5).
- Complaint to the FDPIC (Switzerland).
To exercise these rights, contact us at the address in § 13. We may need to verify your identity. We aim to respond within 30 days, which can be extended where the law allows. For an organization's use of your data, contact the organization (§ 6.3).
10. Security
10.1 We apply technical and organisational measures appropriate to the risk, including encrypted transmission (HTTPS/TLS), passwords stored only in one-way encrypted form (hashed), role-based staff permissions, secure QR codes that stop working when the session ends, regular backups, logging and monitoring of administrator actions, and vulnerability management and security updates.
10.2 No system can be guaranteed to be perfectly secure. We will inform you of personal data breaches affecting your data where the law requires it (Art. 24 FADP).
11. Children
11.1 The Ocio platform is intended for users aged 18 or older. We do not knowingly collect personal data of persons under 18.
11.2 Reports of suspected child-safety violations (child sexual abuse material, grooming, sextortion, trafficking, sexualisation of minors) are handled as set out in § 8.2 of the Ocio End-User Terms and Conditions and reported to the appropriate authorities, including clickandstop.ch in Switzerland and, where applicable, the National Center for Missing and Exploited Children (NCMEC).
12. Changes to this policy
We may amend this Privacy Policy as our processing changes or the law evolves. We will tell you about important changes by email or in the website or app at least 30 days before they take effect, unless the law requires a shorter period.
13. Contact
To exercise your rights or ask any question about this policy:
Apsara Software GmbH
Mailing address: Hohlstrasse 210, 8004 Zürich, Switzerland
Email: [email protected]