Privacy Policy

This is a courtesy translation. In case of discrepancies, the German version prevails.

The essentials

  • Students need no account: no e-mail address, no password, no real name.
  • What is written on the cards is stored – plus at most a freely chosen name and an optional PIN, the latter only as a hash.
  • No tracking, no advertising, no content from third-party servers. Students get no cookie.
  • All data is kept in Switzerland. Data only leaves the country when a teacher actively buys Pro (payment processing by Paddle).
  • When the teacher deletes a board, its cards, images and identifiers disappear with it. Server logs are usually deleted after 30 days.
  • The controller is dh training gmbh in Spiez, reachable at info@pinwally.ch.

The full policy below is what counts.

For schools

Information for parents (Word) – a template explaining how the class works with pinwally and which data is involved. Fill in your school, class and own rules where it is highlighted in yellow. German version

A data processing agreement and an overview of the technical and organisational measures are available on request from info@pinwally.ch.

Data controller is dh training gmbh, Alpenstrasse 1, 3700 Spiez, Switzerland, e-mail info@pinwally.ch (see legal notice).

Purpose of processing

We process personal data solely to run this application: managing teacher accounts, storing and displaying boards, handling subscriptions, and ensuring security and stability. We do not sell data and we show no advertising.

What data is processed?

Account data (teachers): e-mail address, display name, password (stored as a hash only), language preference, plan and its term.

Content data: the boards you create with their cards (title, text, position), drawn lines, uploaded images and the share links.

Participants (students): Working on a board requires no account. At most we collect: a freely chosen name (or none at all, depending on the teacher's settings), an optional short numeric PIN (stored as a hash only, solely so that students can find their own cards again on another device), and the card content they write. No e-mail addresses, no real names and no device profiles are collected.

Device identifier: So that a device recognises its own cards, the browser generates a random identifier and keeps it in local browser storage (localStorage). Only a hash of it is stored on the server, separately per board — linking a person across several boards is therefore not possible. The identifier contains no information about the person or the device.

Technical data: server log files (IP address, timestamp, requested URL, browser type) for troubleshooting and abuse prevention (for retention see “Retention”).

Payment processing (Paddle)

Paid subscriptions are handled by Paddle as reseller (merchant of record): Paddle.com Market Ltd, London (UK), and Paddle.com Inc. (USA). Your purchase contract is with Paddle; Paddle collects the data required for processing (name, e-mail, billing address, payment method) directly. Credit card or PayPal details never reach our servers. We only receive confirmation of a purchase and its term, linked to your account. Paddle's checkout window is loaded only when you actively click a buy button — no connection to Paddle is made before that. Details: Paddle Privacy Policy.

Purchase by invoice (Switzerland and Liechtenstein): if you buy Pro by invoice directly from us, we process the necessary details ourselves — name, billing address, e-mail and the receipt of payment. We keep these records for ten years as required by accounting law, including after an account has been deleted. No data is disclosed abroad in this case.

Legal bases

We process data under Swiss law (revFADP): to perform the usage relationship, based on consent (e.g. voluntary account creation), and based on overriding legitimate interests (operation, security, abuse prevention). For users in the EU/EEA, the rights of the GDPR apply in addition; the legal bases there are Art. 6(1)(b) (contract), (a) (consent) and (f) (legitimate interests) GDPR.

Transfers abroad

The application is hosted in Switzerland. Data is disclosed abroad only as part of payment processing through Paddle, and only once you actively start a purchase: to Paddle.com Market Ltd in the United Kingdom — a country whose level of data protection Switzerland recognises as adequate — and to Paddle.com Inc. in the USA. For transfers to the USA, Paddle relies, according to its privacy policy, on the European Commission's Standard Contractual Clauses (SCCs); a copy can be requested from Paddle (privacy@paddle.com).

Retention

Account data and content are kept for as long as the account exists; on request we delete the account including all content. Teachers can delete individual boards at any time — the board's cards, participant identifiers and share links disappear with it. Server logs are typically deleted after 30 days.

Cookies and browser storage

Teachers: one technically necessary session cookie (httponly, secure) while signed in. Switching the language adds a language cookie containing nothing but the chosen language code (e.g. “de”), valid for one year. Both serve operation only; there is no analytics and no recognition across websites.

Participants: no cookie. Their page works without a session, and switching the language sets none either. Local browser storage holds exactly two things for them: the random identifier described above, so the device recognises its own cards, and — if the language was switched — the chosen language code. Both stay in the browser; the language code is merely appended to the board's own address as a parameter so the page appears in the chosen language.

No trackers, no external content

This website uses no analytics tools, no ad networks, no external fonts and no content from third-party servers. Fonts and scripts are served from our own server. The only exception is Paddle's checkout window described above, which loads only on click.

Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and withdrawal of consent. Contact info@pinwally.ch. The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC); persons in the EU/EEA may additionally contact their national data protection authority.

Minors

The platform is built for classroom use: students need no account and disclose no personal data. We recommend that teachers use pseudonyms instead of real names. Responsibility for classroom use lies with the supervising teacher or school. On request, we provide schools with a data processing agreement (within the meaning of Art. 28 GDPR).

Last updated: 8 October 2026