Privacy Policy
Last revised October 7, 2026
This policy explains how Jonkai Ventures OÜ, Tartu mnt 67/1-13b, 10115 Tallinn, Harju maakond, Estonia (registry code 17322110), the controller, processes personal data when you use switchhorizon.com. Contact: info@switchhorizon.com.
1. The free assessment
Your assessment answers are stored only in your browser (local storage) and in the results link. We don't receive them unless you create a report while signed in.
2. Data we process
- Account data: email address, optional name, password (stored only as a salted hash), email verification status and sign-in sessions.
- Purchases: which package you bought, amount, currency, date, Stripe payment references, the time you consented to immediate delivery and any refund. We never see or store your card details.
- Reports: the answers and shortlist you used to create a report, the optional details you add to it (name for the cover, citizenship, country of residence, monthly budget, household size, moving timeline) and the AI-written summary.
- AI assistant: the questions you send are processed to generate an answer. We store a daily message count for fair use. Conversation text is kept only in your browser session.
- Contact form: your name, email and message, delivered to our inbox.
- Technical data: IP address and request logs processed by our hosting provider for security and rate limiting.
- Usage statistics: Cloudflare Web Analytics counts page views and performance in aggregate. It sets no cookies and doesn't build visitor profiles.
3. Why and on what legal basis
- To provide your account, purchases, refunds and reports: performance of a contract (GDPR Art. 6(1)(b)).
- Bookkeeping and tax records for purchases: legal obligation (Art. 6(1)(c)).
- Security, fraud and abuse prevention, rate limiting and aggregated, cookieless usage statistics: legitimate interests (Art. 6(1)(f)).
4. Processors and recipients
- Cloudflare, Inc.: hosting, database, file storage, Cloudflare Web Analytics and the AI model that powers the assistant (Workers AI). Processor.
- Anthropic, PBC: the AI model (Claude) that writes the personal summary in reports. It receives your assessment answers, the optional report details except your name, and the report figures; never your name or email. Under its commercial terms, Anthropic does not use this data to train models. Processor.
- Stripe (including Sold through Link, LLC and Stripe Technology Europe, Ltd.): Stripe is the merchant of record for your purchase and processes payment, tax, receipts, refunds, disputes and transaction support. For that processing Stripe acts as an independent controller under its own privacy policy (stripe.com/privacy and link.com/privacy). We receive from Stripe the details we need to deliver your purchase (email, package, amount, payment status).
- Zoho Corporation (ZeptoMail, EU data centre): transactional email such as verification, password reset and contact messages. Processor.
Some providers may process data outside the EEA. Where they do, transfers rely on the EU–US Data Privacy Framework or Standard Contractual Clauses.
5. Cookies and local storage
We only use storage that is strictly necessary or that you ask for, so no consent banner is needed:
- A sign-in session cookie (HttpOnly, 7 days), set only when you sign in.
- Local storage in your browser for your assessment answers and latest results, and your theme choice; session storage for your assistant conversation. This data stays on your device.
- Cloudflare may set strictly necessary security cookies (for example to filter bots).
We don't use advertising or analytics cookies. Cloudflare Web Analytics is cookieless.
6. How long we keep data
Account data and reports: until you delete your account. Sessions expire after 7 days.
Purchase records: 7 years, as required by Estonian accounting law. When you delete your account, they are detached from your identity.
Contact messages: as long as needed to handle your request, and no more than 2 years. AI usage counters: 90 days. Cloudflare Web Analytics keeps only aggregated statistics.
7. Your rights
You can request access, correction, deletion, restriction, data portability, or object to processing based on legitimate interests. You can delete your account yourself from the account page. For anything else, email info@switchhorizon.com.
You can also complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or your local supervisory authority.
8. Changes
We'll update this policy when our processing changes. The revision date at the top shows the latest version.