Website Terms and Conditions
Komma AG | komma.ch and kommacargo.ch
Effective date: 14.09.2026
This policy explains how Komma AG processes personal data when you visit komma.ch or kommacargo.ch, including their www versions (the Websites), submit an enquiry or demonstration request, or communicate with us. It applies to both Websites and the related activities described below.
1 Who is responsible
The controller is Komma AG, Via Losanna 4, 6900 Lugano, Switzerland. For privacy questions or to exercise your rights, write to info@komma.ch, preferably with “Privacy” in the subject line, or contact us at the postal address above.
We process personal data in accordance with the Swiss Federal Act on Data Protection and its implementing provisions. Where applicable, we also comply with the EU General Data Protection Regulation (GDPR) and other mandatory data protection laws. This policy does not require you to waive any statutory rights.
2 Information we process
Website enquiries and demonstration requests: your first and last name, email address and message; and, if you provide them, your telephone number, company, fleet size, area of interest and other information relevant to your request. Required fields are identified in the form. Optional fields may be left blank. Without the information necessary to understand and respond to a request, we may be unable to handle it.
Communications and business contacts: correspondence, scheduling details, professional contact information, your role or organisation and records of our interaction. For online meetings, this may include participant identifiers, technical connection information and the audio, video, chat, files or screen content you choose to share.
Website operation: technical information such as IP address, access time, requested pages, referring website, browser and device information, and security or anti-spam signals. The information processed depends on the service and technical configuration.
Marketing and events: contact details, communication preferences, evidence of any consent, objections and unsubscribe requests, and relevant information you provide when registering for an event or requesting updates.
We generally obtain this information directly from you or through your use of the Websites. We may also receive relevant professional contact details from your organisation, an event organiser or a partner that introduces you to us, or from public professional sources. Where required, we inform you about the source and processing when we first contact you or within the applicable statutory period. Please provide third-party personal data only where you are entitled to do so.
3 Why we use information
We use information to answer enquiries, assess requested business opportunities, arrange demonstrations and meetings, manage business relationships, operate and protect the Websites, prevent abuse, maintain appropriate records and establish, exercise or defend legal claims.
Where the GDPR applies, handling a request by an individual who is a prospective contracting party may be necessary for pre-contractual steps requested by that individual or performance of a contract (Article 6(1)(b)). Handling contacts acting for organisations, routine correspondence, website security and legal claims is generally based on our legitimate interests (Article 6(1)(f)), balanced against the individual’s rights and interests.
Where consent is required, processing is based on consent (Article 6(1)(a) GDPR where applicable). Where processing is required by an applicable EU or Member State legal obligation, Article 6(1)(c) GDPR may apply; other legal recordkeeping requirements are addressed under the applicable law and, where appropriate, legitimate interests. We do not rely on public-interest or vital-interest grounds for routine website enquiries.
4 Enquiries marketing and partner introductions
Submitting an enquiry or requesting a demonstration authorises us to respond to that request; it does not automatically subscribe you to newsletters or unrelated promotional campaigns. Where we offer marketing subscriptions, consent is requested separately and is optional. You may unsubscribe using the link in a marketing message or by contacting us. Where the law permits advertising to existing customers about our own similar products or services without fresh consent, we provide an opportunity to object.
If you request an introduction to a leasing, distribution, service or other commercial partner, we share only information relevant to that introduction. We identify the recipient and purpose before sharing and obtain consent where required. A partner acting as an independent controller provides its own privacy information. A general enquiry does not itself authorise disclosure to partners for their unrelated marketing.
5 Website hosting forms and analytics
The Websites use Framer for website hosting and delivery. Framer may process website access data and personal data submitted through its form functionality on our behalf. Authorised personnel and relevant communication or business-record systems may receive submissions so that we can respond. Where an additional form, integration or CRM provider processes this information, it acts in the role described in the relevant notice and subject to the safeguards described below.
We use Framer’s built-in analytics to understand aggregate website use and improve content. Framer describes this analytics service as operating without tracking cookies or persistent visitor identifiers. Technical processing needed to deliver, secure and measure the Websites may still occur; a cookieless service should not be understood as meaning that no data are processed.
Where a feature uses cookies or similar technologies, we provide the applicable information and choices. Non-essential tracking that requires consent is activated only after that consent and can be disabled through the relevant preference controls. If we introduce advertising pixels, session recording, heatmaps or additional analytics requiring further notice or consent, we will provide that information and obtain the necessary consent before activation. Browser controls can also restrict cookies, although this may affect some functionality.
Where a feature uses cookies or similar technologies, we provide the applicable information and choices. Non-essential tracking that requires consent is activated only after that consent and can be disabled through the relevant preference controls. If we introduce advertising pixels, session recording, heatmaps or additional analytics requiring further notice or consent, we will provide that information and obtain the necessary consent before activation. Browser controls can also restrict cookies, although this may affect some functionality.
6 Wire Proton and Zoom
We use Wire, Proton and Zoom for business communications and collaboration. Depending on the service used for a particular exchange, this may involve messaging, email, calls, online meetings, scheduling or sharing documents. The specific channel will be apparent from our correspondence or invitation. The provider’s processing depends on the product, account configuration and features used.
Relevant information may include your name, email address or other participant identifier, communication content, attachments, meeting details and technical or diagnostic data. Other participants can receive information you share during a meeting or conversation. You can limit optional disclosures, for example by turning off your camera or avoiding unnecessary screen sharing.
Before we record, transcribe or use an automated meeting-summary feature, we will inform participants of the purpose, recipients and retention arrangements and obtain any legally required consent. Participation alone is not treated as consent to optional recording. Please contact us if you need an alternative communication arrangement.
Providers may act as processors for services supplied to us and as independent controllers for certain account, security or service-administration activities. Their privacy information supplements this policy for their own processing. Using a particular provider does not mean that every communication is end-to-end encrypted or that all content and metadata are processed exclusively in Switzerland.
7 Recipients and international processing
Access is limited to personnel and service providers who need information for the purposes described in this policy. Recipients may include website and IT providers, communication providers, business-record and support providers, professional advisers and partners involved in a requested introduction. We may disclose information to authorities or other parties where legally required or necessary for the establishment, exercise or defence of legal claims.
Processors engaged on our behalf must act under appropriate contractual instructions, confidentiality and security obligations. A provider’s Swiss or European headquarters does not mean that all hosting, support access or sub-processing takes place there.
Personal data may be processed in Switzerland, the European Economic Area (EEA) and other countries where our service providers or their sub-processors operate. Where data are disclosed to a country without a recognised adequate level of protection, we use an applicable lawful transfer mechanism, such as recognised standard contractual clauses with Swiss adaptations where necessary and additional safeguards where required. A Data Privacy Framework adequacy arrangement is used only where the recipient has the relevant current certification and the transfer falls within its scope. A statutory exception may be relied on only where its conditions are met. You may request information about the safeguards and a copy of applicable contractual safeguards, subject to necessary redactions, using our privacy contact.
8 Retention
We retain enquiry and communication records while needed to deal with the request and reasonably related follow-up. Where a business relationship results, relevant records are retained for its administration and the applicable legal retention and limitation periods. Records that are no longer needed for these purposes are deleted or anonymised.
Marketing contact information is retained while the subscription or other lawful marketing basis remains applicable. Following an objection or withdrawal, we stop the relevant marketing and may retain the minimum suppression and consent-history information necessary to respect that choice and demonstrate compliance.
Technical and security records are retained for the period needed to operate the relevant service, investigate incidents and protect against misuse. Recordings or transcripts, if created after the information and consent process described above, follow the retention arrangements communicated for that activity. Data relating to a closed programme are retained only where still necessary for existing rights, obligations, legal records or another lawful purpose. Backups are removed or overwritten in the applicable backup cycle and are not retained for continued routine use.
9 Security and automated decisions
We apply technical and organisational measures appropriate to the risks, including access controls, secure transmission and appropriate handling of service-provider access. No internet transmission or information system can be guaranteed completely secure. If a personal data breach occurs, we assess it and notify the competent authority and affected individuals where required by law.
Ordinary website enquiries are handled by our team. If we introduce a decision based solely on automated processing that produces legal or similarly significant effects, we will provide the information and safeguards required by applicable law, including any right to obtain human review.
10 Your rights
Subject to the conditions and exceptions of the applicable law, you may request access to your personal data and information about its processing, correction of inaccurate information, deletion, restriction of processing, and delivery or transfer of data in a portable format where that right applies.
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. Where the GDPR applies and we rely on legitimate interests, you may object on grounds relating to your particular situation. You may object to direct marketing at any time, including related profiling.
Contact us using the details in section 1. We may request proportionate information to verify your identity. We respond within the time limits required by law and explain any lawful limitation or refusal. Requests are generally handled free of charge, subject to statutory exceptions.
You may contact the Swiss Federal Data Protection and Information Commissioner (FDPIC). Where the GDPR applies, you may also lodge a complaint with a competent supervisory authority, in particular in the EU or EEA country of your habitual residence, place of work or alleged infringement. These options do not prevent you from seeking a judicial remedy.
11 Vehicle data and changes to this policy
This policy addresses website and related business-contact processing. It does not, by itself, describe or authorise every form of vehicle telemetry, driver monitoring, location tracking or connected-service processing. Before such processing begins in connection with a demonstration or supplied vehicle, we will provide the relevant additional information, identify the parties’ roles and establish any required contractual arrangements and permissions.
We may update this policy to reflect changes in our activities, services or legal requirements. The current version is published on both Websites with its effective date. Where a material change requires additional notice or renewed consent, we provide that notice or obtain that consent before the relevant processing. A policy update does not retrospectively authorise incompatible use of information collected for a former programme.