Privacy Policy

1. Who we are

Viviane Guignard, Florastrasse 21, 8008 Zurich, Switzerland, operates the website https://good-trials.ch (the “Service”) as a sole proprietorship. She is the data controller responsible for your personal data. For data protection enquiries, contact: [email protected]

2. Applicable law

This policy is governed by the Swiss Federal Act on Data Protection (nDSG), which entered into force on 1 September 2023. Where the European Union’s General Data Protection Regulation (GDPR) applies to residents of EU/EEA member states, we comply with its requirements as well. References to “applicable data protection law” mean whichever of these instruments applies to you.

3. Data we collect and why

4. How we use your data

We use your data only for the purposes described above. We do not:

• Sell, rent, or trade your personal data to third parties
• Use your data for advertising or profiling
• Process your data for purposes incompatible with those stated above

5. Third-party processors

We share data with the following processors under data processing agreements:

• Hosting provider — application server located in Germany, on which the PostgreSQL database holding your account data also runs (EU/EEA; no transfer outside the EEA)
• Cloudflare — CDN, reverse proxy and TLS termination (USA; certified under the EU–US Data Privacy Framework, with EU Standard Contractual Clauses as fallback)
• Stripe — payment processing (USA/Ireland; SCCs apply)
• Resend — transactional email delivery (USA; SCCs apply)
• PostHog — product analytics, see section 10 (PostHog, Inc., USA; data stored in PostHog’s EU cloud in Frankfurt, Germany; certified under the EU–US and Swiss–US Data Privacy Framework, SCCs apply)

6. Certificate verification (public endpoint)

The URL https://good-trials.ch/api/certificate/verify/[id] is publicly accessible without authentication, so that an employer or ethics committee can check your credential without an account. It serves two versions of the same record.

• The page a browser shows — your name, the course level, the date of issue, the certificate identifier, and the guideline version the course was reviewed against. It does not show your assessment score.
• The machine-readable version (an Open Badges 3.0 credential, served to software that requests JSON) — the same fields, plus your final assessment score and an irreversible SHA-256 hash of your email address. The hash lets a badge platform confirm the credential belongs to a given address without the address itself being published.

We publish this to perform our contract with you: a certificate that cannot be checked by a third party would not be a certificate. You may ask us to withdraw the public endpoint at any time by contacting us; this will invalidate your certificate for third-party verification purposes.

7. Data retention

• Account and progress data: retained for as long as your account exists, and deleted once you ask us to delete it
• Correspondence: retained for as long as it is useful to answer you and to improve the course, and deleted once you ask us to delete it
• Certificate data: retained indefinitely while the certificate is valid
• Payment records: retained for 10 years per Swiss accounting obligations (OR Art. 958)
• Server logs: 30 days
• Analytics events (PostHog): for the retention period of our PostHog plan, which is 1 year on PostHog’s free plan and 7 years on its paid plans

8. Your rights

Under the nDSG (and GDPR where applicable) you have the right to:

• Access — receive a copy of the personal data we hold about you
• Correction — have inaccurate data corrected
• Deletion — request erasure of your data (subject to retention obligations above)
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interest
• Complaint — lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch

To exercise any of these rights, email [email protected]. We will respond within 30 days.

9. Cookies and tracking

We use cookies only to sign you in and keep you signed in. Our authentication library (Auth.js) sets a session cookie — __Secure-authjs.session-token over HTTPS, or authjs.session-token in local development — together with a CSRF token cookie and a callback-URL cookie that the sign-in flow needs. We do not use analytics cookies or advertising cookies. Our product analytics (section 10) works without cookies. No cookie consent banner is required for strictly necessary cookies of this kind under Swiss law.

10. Product analytics (PostHog)

We use PostHog, a product analytics service of PostHog, Inc. (USA), to understand how the Service is used. The data goes to PostHog’s EU cloud (eu.posthog.com), which is hosted in Frankfurt, Germany. The analytics code is served from our own site; no script is loaded from PostHog. Two kinds of events are sent:

• From your browser — an event for each page you open, and one when you close the page or leave the site. It contains the page address without anything after “?” or “#”, the page title, the page you came from, campaign tags such as utm_source in the link you followed, how long you stayed on the previous page and how far you scrolled it, and your browser and its version, operating system, device type, language, time zone, and screen and window size. Advertising click IDs (such as gclid) are replaced by a placeholder. When you open Module 1, an event also records whether you are signed in and whether you have bought the course.
• From our server — an event when you register (including whether you used an access code), start a checkout, complete a purchase, or receive a certificate. Checkout and purchase events contain the product, quantity, amount, currency, discount, whether a promotion code was used, and whether it was a test payment. These events carry a pseudonymous ID, computed from your account with a secret key that PostHog does not have. They never contain your name, email address, IP address, card details, or Stripe identifiers. For access codes bought without an account, the ID is computed in the same way from the checkout, and PostHog creates no profile for it.

Events from your browser are not linked to your account or to the events from our server. Each time the site is loaded afresh, you count as a new, anonymous visitor. Analytics sets no cookies and keeps nothing in your browser’s storage: the script only writes a test value and deletes it at once, to check whether storage is available. Session recording, heatmaps, click tracking and surveys are switched off.

Your browser’s requests to PostHog carry your IP address, as every request on the internet does. Our PostHog project is set to discard it, so it is not stored with the events. Before discarding it, PostHog may use it to derive an approximate location, such as country and city.

We use these data to see which pages are read, and how many visitors open the free module, register, buy the course and complete it, so that we can improve the Service. The legal basis is our legitimate interest in doing so. Section 7 says how long the events are kept.

You can object at any time. Switching on “Do Not Track” or Global Privacy Control in your browser stops all analytics from your browser on this site, and so does a content blocker that blocks eu.i.posthog.com. To object to the events from our server, or to have the events linked to your account deleted, email [email protected].

11. Security

Passwords are hashed using bcrypt (cost factor 12) and are never stored in plaintext. The site is served over HTTPS, so traffic between your browser and the Service is encrypted in transit.

12. Changes to this policy

We may update this policy when required by changes in the law or our practices. Any update is published on this page with a new “Last updated” date, which is the date the current version took effect. Please check back here for the version that applies to you.