# Data processing agreement (Art. 9 FADP)

> Web version : https://www.calenoo.ch/en/legal/dpa
> Last modified : 2026-11-02
> Version 1.0 — 2 November 2026
> In case of any discrepancy between the language versions, the French version prevails.
> [Français](https://www.calenoo.ch/fr/legal/dpa.md) · [Deutsch](https://www.calenoo.ch/de/legal/dpa.md) · [English](https://www.calenoo.ch/en/legal/dpa.md) · [Italiano](https://www.calenoo.ch/it/legal/dpa.md)

This agreement governs how Calenoo processes, on your behalf, the personal data of your customers, guests and participants. It is aimed at professionals who use Calenoo in the course of their business.

## 1. Parties and scope

1.1 This agreement (“the Agreement”) is concluded between:

- the customer that uses Calenoo in the course of its professional activity (“the Client”, controller);
- Ekylibr SA, Avenue du Mail 18, CP 389, 2002 Neuchâtel, Switzerland (“Calenoo”, processor).

1.2 The Agreement applies where the Client processes personal data of third parties with Calenoo: its customers, its guests and the participants in its polls.

1.3 The Agreement forms an integral part of Calenoo's general terms of use (the “Terms”). It applies as soon as the Client uses the service for professional purposes, without signature. The Client may request a signed copy from legal@calenoo.ch.

1.4 The Agreement is based on Art. 9 of the Federal Act on Data Protection (FADP) and on the Data Protection Ordinance (DPO). Where the Client is subject to the General Data Protection Regulation (GDPR), the Agreement also applies within the meaning of Art. 28 GDPR.

1.5 The Agreement does not cover the Client's own data (its account and preferences). For that data, Calenoo is the controller, as set out in the [privacy policy](https://www.calenoo.ch/en/legal/privacy).

## 2. Subject matter and duration

2.1 Calenoo processes personal data on behalf of the Client as part of the service: booking pages, date polls, linked calendars, emails and webhooks.

2.2 The Agreement lasts for as long as the Client uses its account. It then continues for the erasure of the data, in accordance with clause 12.

## 3. Nature and purposes of the processing

3.1 Calenoo processes the data only to provide the service to the Client. The processing consists of:

- hosting and storing the data;
- displaying it to the Client and to the data subjects;
- sending emails (confirmations, reminders);
- writing appointments into the Client's linked calendars;
- sending bookings to the tools chosen by the Client (webhooks);
- erasing the data.

3.2 Calenoo does not sell this data. It does not use it for its own purposes, except for the security of the service (anti-abuse limits), for aggregated and anonymous operating statistics (daily counts, with no names or addresses), or where the law requires it.

## 4. Data subjects and categories of data

4.1 The data subjects are:

- guests who book on the Client's pages;
- participants in the Client's polls;
- people whom the Client invites by email;
- colleagues with whom the Client shares its availability.

4.2 The categories of data are:

- name and email address;
- the free-text message entered by the person;
- the date and time of the appointment, and the language;
- poll responses;
- the busy times of the Client's linked calendars: they are read at the time the free slots are calculated and are not stored by Calenoo;
- technical data: a fingerprint (hash) of the IP address, used to limit abuse.

4.3 Calenoo does not request sensitive personal data. The Client avoids collecting any, in particular through the free-text field.

## 5. Instructions from the Client

5.1 Calenoo processes the data only on the Client's documented instructions. The Client's instructions are the Terms, the Agreement and the account settings.

5.2 Calenoo informs the Client of any instruction that appears to it to be contrary to the law.

5.3 The Client remains responsible for the lawfulness of the processing and for informing the data subjects.

## 6. Confidentiality

6.1 Calenoo limits access to the data to the persons who need it to provide the service. These persons are bound by confidentiality.

## 7. Security

7.1 Calenoo takes appropriate technical and organisational measures to protect the data against any data security breach (Art. 8 FADP, Art. 1 to 3 DPO).

7.2 At the date of the Agreement, these measures include:

- a database hosted in Switzerland, in the Zurich region; the server functions also run in Zurich;
- communications protected by HTTPS (TLS);
- access tokens, app-specific passwords for linked calendars and webhook signing secrets, all encrypted (AES-256-GCM);
- data separated by account in the database (row-level security, or RLS);
- restricted administrative access;
- anti-abuse limits and an anti-bot check on some public forms;
- automatic erasure of the data at the end of their retention period (clause 12).

7.3 Calenoo adapts these measures when the risks or the technology change.

## 8. Sub-processors

8.1 The Client gives Calenoo general authorisation to engage sub-processors. Those in place at the date of the Agreement are listed in Annex 1.

8.2 Calenoo informs the Client of any addition or replacement at least 30 days in advance, by email or by updating Annex 1 (the version and date at the top of the page then change). During these 30 days, the Client may object to the change by email to legal@calenoo.ch. If the change is maintained, the Client may terminate its account before it takes effect.

8.3 Calenoo imposes on each sub-processor data protection obligations equivalent to those of the Agreement.

8.4 Calenoo remains responsible to the Client for its sub-processors' performance of these obligations.

8.5 The services that the Client itself chooses are not Calenoo's sub-processors: sign-in with Google or Apple, linked calendar providers (Google, Microsoft, Apple, Infomaniak), Jitsi video calls (8x8) and the tools that receive webhooks (for example Airtable, Zapier or Make). The Client chooses them and is responsible for them. Data only reaches them when the feature concerned is used.

## 9. International transfers

9.1 The database is hosted in Switzerland. Some sub-processors are based abroad, in particular in the United States (Annex 1).

9.2 These transfers outside Switzerland are covered by the European Commission's standard contractual clauses (SCC), adapted to Swiss law, or by equivalent safeguards. For Supabase, Vercel, Resend and Cloudflare, these clauses form part of the data processing agreement (DPA) concluded by Ekylibr SA with the provider. Germany offers a level of protection recognised as adequate by Switzerland.

9.3 The services chosen by the Client (clause 8.5) may be based outside Switzerland, in particular in the United States. They process the data under their own terms.

## 10. Assistance

10.1 Calenoo assists the Client, to a reasonable extent, in responding to requests from data subjects (access, rectification, erasure). If a data subject contacts Calenoo about data processed for the Client, Calenoo informs the Client.

10.2 Calenoo also assists the Client, to a reasonable extent, with any data protection impact assessment (Art. 22 FADP), by providing it with the information available to Calenoo.

## 11. Data security breach

11.1 Calenoo informs the Client as soon as possible (Art. 24 FADP) of a data security breach affecting data processed for the Client. It writes to the email address of the account.

11.2 It communicates the information available to it: nature of the breach, data and data subjects concerned, likely consequences, measures taken. It supplements this information progressively.

11.3 Notification to the Federal Data Protection and Information Commissioner (FDPIC) and to the data subjects is the responsibility of the Client, as controller.

## 12. Retention, erasure and end of the Agreement

12.1 Calenoo automatically erases the data at the following deadlines:

- bookings received (the guest's name, email address and message): 6 months after the end of the appointment; the event already written to a linked calendar is not affected;
- polls and everything they contain (slots, responses, names, email addresses, comments, invitations): 6 months after the last proposed date;
- content of deliveries to the Client's tools (webhooks): as soon as the delivery is complete; the technical log, without this content, is deleted after 30 days;
- credentials for linked calendars: as soon as the Client unlinks the calendar or deletes its account.

12.2 The Client may request from privacy@calenoo.ch faster erasure, or a copy of the data before it is erased.

12.3 If the Client requests deletion of its account, it takes effect after a 7-day withdrawal period; signing in cancels it. From the request, linked calendars are unlinked, booking pages are closed and upcoming appointments are cancelled (the data subjects are informed). After the 7 days, the account, the booking pages and all bookings received are permanently deleted. The Client's polls are anonymised (its name and email address are removed from them): they remain accessible to their participants, then are erased in accordance with clause 12.1.

12.4 An account with no activity at all for 12 months is considered inactive. Calenoo then writes to the Client three times, three weeks apart. Without a sign-in from the Client, the account is deleted eight weeks after the first message, with the same effects as a requested deletion (clause 12.3). Simply signing in is enough to keep it. Accounts with an ongoing paid subscription are not affected.

12.5 Backup copies held by the hosting provider are erased on its own cycle.

## 13. Verification

13.1 Calenoo makes available to the Client the documentation necessary to demonstrate compliance with the Agreement: the Agreement itself, the list of sub-processors (Annex 1) and the documents of these providers (their data processing agreements).

13.2 The Client may have compliance with the Agreement verified by an audit. The audit is at the Client's expense. It is announced with reasonable notice, conducted without disrupting the service and without access to the data of other Calenoo customers.

## 14. Liability

14.1 The liability of the parties is governed by section 9 of the Terms.

## 15. Governing law and jurisdiction

15.1 The Agreement is governed by Swiss law. The exclusive place of jurisdiction is the registered office of Calenoo, in Neuchâtel (Switzerland), as in section 13 of the Terms, subject to mandatory provisions.

## 16. Changes

16.1 The version and date of the Agreement appear at the top of this page.

16.2 In the event of a significant change, Calenoo informs its customers by appropriate means. A change of sub-processor is governed by clause 8.

## Annex 1 — Sub-processors

Calenoo uses the following sub-processors (as at 2 November 2026). This list is the one in section 7 of the [privacy policy](https://www.calenoo.ch/en/legal/privacy). Not all of them receive data each time the service is used: it depends on the feature used.

| Provider | Registered office | Role | Safeguards |
| --- | --- | --- | --- |
| Supabase Pte. Ltd. | Singapore. Affiliate: Supabase, Inc. (United States), for technical support. | Hosting of the database and server functions, in its Zurich region (Switzerland). | Data stored and processed primarily in Switzerland. For access by Supabase, Inc. (support): standard contractual clauses adapted to Swiss law, in the DPA concluded by Ekylibr SA. |
| Vercel Inc. | United States | Hosting and delivery of the web application. | Standard contractual clauses adapted to Swiss law, in the DPA concluded by Ekylibr SA. |
| Resend, operated by Plus Five Five, Inc. | United States | Sending of transactional emails (invitations, confirmations, reminders). | Standard contractual clauses adapted to Swiss law, in the DPA concluded by Ekylibr SA. |
| Google (Google Workspace) | United States | @calenoo.ch mailboxes: the messages written to Calenoo are received and stored there. | Standard contractual clauses adapted to Swiss law or equivalent safeguards (section 8 of the privacy policy). |
| Cloudflare (Turnstile) | United States | Spam protection for some forms. During the check, Cloudflare receives the IP address and technical information about the browser. | Standard contractual clauses adapted to Swiss law, in the DPA concluded by Ekylibr SA. |
| AlpiStats, a service by Ekytec | Switzerland | Aggregated audience measurement, no cookie. | Usage data hosted in Switzerland. |
| Photon, a service of komoot GmbH | Germany | Suggestions while typing the location of a poll. The text typed goes through Calenoo's server; the IP address is not passed on. | Germany offers a level of protection recognised as adequate by Switzerland. |
| Travel time calculation (“Prepare a meeting”) | Switzerland (Geneva) | Server operated by Ekylibr SA in Geneva (Infomaniak), based on the free OpenStreetMap map. The addresses entered are completed as you type and converted into coordinates by the Swiss federal service geo.admin.ch, from Calenoo's server; the route calculator only receives coordinates. | Processing in Switzerland (server in Geneva; federal service geo.admin.ch). |

A question about this agreement? Write to us at legal@calenoo.ch.