Privacy Policy (Full Version, GDPR Prioritised)

Sparissimo Food LTD
Churerstrasse 16
8808 Pfäffikon Schwyz
Switzerland

Version: February 2026

1. Controller

The controller within the meaning of the GDPR and Swiss data protection law is:

Sparissimo Food LTD
Churerstrasse 16
8808 Pfäffikon Schwyz
Switzerland
Email: admin@sparissimo.com

2. EU Representative (Art. 27 GDPR)

As Sparissimo Food LTD processes personal data of individuals in the EU
without having an establishment in the EU, an EU representative will be appointed.

3. Legal Bases

Personal data is processed on the basis of:
- Art. 6(1)(a) GDPR (consent)
- Art. 6(1)(b) GDPR (contract)
- Art. 6(1)(c) GDPR (legal obligation)
- Art. 6(1)(f) GDPR (legitimate interests)

4. Data Categories and Purposes

We process:
- usage and log data (security, operations)
- contact and communication data
- contractual and payment data
- marketing and newsletter data (consent-based)

5. Cookies and Tracking

We use essential cookies and, subject to consent,
analytics and marketing cookies.

6. Tools Used

- Hosting (EU/CH)
- Google Analytics 4 (consent-based)
- Google reCAPTCHA
- HubSpot (newsletter, double opt-in)
- Payment providers: Payrexx, Stripe, PostFinance

7. International Transfers

Transfers to third countries take place only based on adequacy decisions
(EU-US Data Privacy Framework / Swiss-US DPF) or standard contractual clauses.

8. Retention Period

Personal data is retained only as long as necessary
or required by statutory obligations.

9. Data Subject Rights

You have the right of access, rectification, erasure, restriction,
data portability, objection and withdrawal of consent.

10. Amendments

This Privacy Policy may be updated at any time.
The current published version shall apply.