Legal

Impressum

The legally required Impressum for this site lives on the publisher's main site at factorsixty.com/impressum (opens in a new tab).

Empathy Ally is a project of Factorsixty. For general enquiries, please contact us via the details listed on the Factorsixty site.

Privacy Notice - Empathy Ally

Last updated: 13 May 2026

1. What is this Privacy Notice about?

Empathy Ally (https://empathya11y.com, the "website") is a project operated by Factorsixty GmbH ("we", "us"). This Privacy Notice explains what personal data we process when you visit this website, watch embedded videos, or subscribe to our newsletter.

For full company details (registered office, commercial register, etc.), please see our main Impressum at https://factorsixty.com/impressum (opens in a new tab).

"Personal data" means data relating to an identified or identifiable person. "Processing" means anything done with such data - collection, storage, use, disclosure, deletion, and so on.

This Privacy Notice is aligned with the Swiss Federal Act on Data Protection ("revDPA") and the EU General Data Protection Regulation ("GDPR"). Whether and how these laws apply depends on the individual case.

2. Who is responsible?

The controller for the processing described in this Privacy Notice is:

Factorsixty GmbH
Switzerland
Contact for data protection inquiries: see https://factorsixty.com/impressum (opens in a new tab).

We have not appointed a Data Protection Officer, a Data Protection Advisor, or representatives in the EU/UK, because we are not required to do so under applicable law.

3. What data do we process?

3.1 Technical data (server logs)

When you visit the website, our hosting provider automatically processes technical data such as your IP address, the date and time of the request, the page accessed, your browser and operating system, and the referring page. This is necessary to deliver the website to you and to maintain its security and stability.

We do not have direct access to these server logs; they are processed by our hosting provider as our processor.

3.2 Analytics data (Google Analytics 4)

If you consent via our cookie banner, we use Google Analytics 4, a service provided by Google Ireland Ltd. (Ireland), which relies on Google LLC (USA) as a sub-processor. Google Analytics sets cookies and collects information about your use of the website (pages viewed, duration, approximate geographic region, device type, etc.) to help us understand how the website is used and to improve it.

We have configured Google Analytics with IP anonymization. Data may nevertheless be transferred to the United States. Google may, under certain circumstances, link this data with Google accounts and use it for its own purposes.

You can withdraw your consent at any time via the cookie preferences link in the footer of every page.

Google's privacy information: https://policies.google.com/privacy (opens in a new tab)

3.3 Embedded videos (YouTube, Instagram, TikTok, etc.)

The website contains videos embedded from third-party platforms including YouTube (Google), Instagram (Meta), TikTok (ByteDance), and similar services.

By default, these embeds are click-to-load: no data is sent to these platforms until you actively click to load a video. Until then, you see only a local placeholder.

If you consent to "embed cookies" via our cookie banner, the placeholder is replaced with a static thumbnail image loaded directly from the respective platform. Loading this thumbnail means that your IP address and basic technical data (browser, time of request) are transmitted to the platform, even if you do not click play. This is a separate consent option in our cookie banner and is off by default.

If you click to play a video, the platform loads the full video player. From that point on, the platform receives further technical data, may set its own cookies, and processes your data as a separate controller under its own privacy policy.

You can withdraw consent for embed thumbnails at any time via the cookie preferences link in the footer.

Privacy policies of the platforms we embed from:

Data transmitted to these platforms may be processed in the United States, China, or other countries outside Switzerland and the EEA.

3.4 Newsletter

If you subscribe to our newsletter, we ask for your email address and, optionally, a comment about what you are interested in. We use this data to:

  • send you our newsletter (using a double opt-in confirmation process);
  • segment the newsletter so that we can send you content relevant to your stated interests; and
  • occasionally inform you about other Factorsixty services that may be relevant.

We use Mailchimp (The Rocket Science Group LLC, USA) as our newsletter provider, on the basis of a Data Processing Agreement. Mailchimp processes your subscription data on our behalf and transfers it to the United States. Mailchimp also collects technical data about how you interact with our emails (whether they are opened, which links are clicked) so we can measure newsletter engagement.

You can unsubscribe at any time via the unsubscribe link in every newsletter or by contacting us.

Mailchimp's privacy notice: https://mailchimp.com/legal/privacy/ (opens in a new tab)

3.5 Possible future use of Hotjar

We may in the future use Hotjar (Hotjar Ltd., Malta) to analyze how visitors interact with the website (heatmaps, anonymized behavior). Hotjar stores user and usage data on AWS infrastructure in Ireland (EU). Hotjar uses some sub-processors located outside the EU, with transfers safeguarded by Standard Contractual Clauses.

If we deploy Hotjar on this website, it will only run after you give consent via our cookie banner. Further information about Hotjar's processing can be found in the main Factorsixty privacy notice and at https://www.hotjar.com/legal/policies/privacy/ (opens in a new tab).

4. For what purposes do we process your data?

We process your data to:

  • operate the website (delivering pages, ensuring security and stability);
  • understand how the website is used (analytics) so we can improve it;
  • deliver embedded video content (thumbnails and/or full videos) that you have chosen to allow or load;
  • send our newsletter to subscribers, segment it based on stated interests, and occasionally inform them about our other services; and
  • comply with legal obligations that may apply to us.

5. On what basis do we process your data?

Depending on the processing activity, we rely on the following legal bases:

  • Your consent - for analytics, for loading embed thumbnails, for loading full embedded videos, for receiving the newsletter, and (where applicable) for Hotjar. You can withdraw consent at any time with effect for the future.
  • Our legitimate interests - in operating, securing, and improving the website (e.g. processing of technical server data).
  • Performance of a (pre-)contract - where you ask us to send you the newsletter, processing your email is necessary to do so.
  • Legal obligations - where applicable law requires us to process certain data.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

6. With whom do we share your data?

We share your data only with the third parties named in this Privacy Notice:

  • our hosting provider (as our processor);
  • Google (Google Analytics, if you consent);
  • the operators of embedded video platforms (YouTube, Instagram, TikTok, etc.) - if you consent to embed thumbnails, your IP and basic technical data are sent to them when thumbnails load; if you then click play, further data is transmitted. These platforms act as separate controllers;
  • Mailchimp (for newsletter delivery, if you subscribe);
  • Hotjar (if and when we deploy it, and only with your consent);
  • authorities, courts, or other third parties where we are legally obliged to disclose data.

We do not sell your personal data.

7. Is your data disclosed abroad?

Yes. Some of the providers above process data in the United States (Google, Mailchimp), and embedded video platforms may transfer data to the United States, China, or elsewhere. Where a recipient is in a country without an adequate level of data protection, we rely on the European Commission's Standard Contractual Clauses (opens in a new tab) or on a legal exception (such as your consent).

Hotjar (if used) primarily stores data in the EU (Ireland) but uses some sub-processors outside the EU, also covered by Standard Contractual Clauses.

Contractual safeguards cannot eliminate all risks, particularly the risk of government access in the recipient country. By consenting to analytics, embed thumbnails, video playback, or newsletter subscription, you accept this transfer.

8. How long do we keep your data?

  • Server logs: as configured by our hosting provider (typically a few weeks).
  • Google Analytics data: as configured in Google Analytics (we use the default retention period; standard maximum is 14 months).
  • Newsletter data: for as long as you remain subscribed, plus a short period after unsubscription to evidence your prior consent.
  • Embedded video / Hotjar data: see the respective providers' privacy notices.

We delete or anonymize data once it is no longer needed and we have no legal obligation to keep it.

9. How do we protect your data?

We take appropriate technical and organizational measures to protect your data, including transport encryption (HTTPS), access controls, and contractual safeguards with our processors. Residual risks cannot be excluded completely.

10. What are your rights?

Depending on the applicable law, you have the right to:

  • request information about the data we process about you;
  • request correction of inaccurate data;
  • request erasure of your data;
  • request a copy of your data in a commonly used electronic format, or its transfer to another controller;
  • withdraw consent at any time, where processing is based on consent;
  • object to processing based on our legitimate interests;
  • receive further information that helps you exercise these rights.

To exercise these rights, please contact us - see contact details in our main Impressum at https://factorsixty.com/impressum (opens in a new tab). To prevent misuse, we may need to verify your identity.

If you believe we are not handling your data lawfully, you also have the right to lodge a complaint with a data protection supervisory authority:

11. Cookie preferences

You can change your cookie and consent preferences at any time via the "Cookie settings" link in the footer of every page.

12. Updates to this Privacy Notice

This Privacy Notice is not part of a contract with you. We may update it at any time. The current version is the one published on this website.

Last updated: 13 May 2026