Privacy Policy

Effective date: March 18, 2025.

This page explains Cortexia SA’s (“we”, “us”, “our”) policies regarding the collection, use and disclosure of personal data when you use our Service (as described below) and the choices you have associated with that data.

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Definitions

• Service By Service we mean the website https://www.cortexia.ch and all urban cleanliness measurement services offered by Cortexia SA.
• Personal data Personal Data means data about a living individual who can be identified from such data (or from such data and other information in our possession or likely to come into our possession).
• Use Data Usage Data is collected automatically and is generated either by the use of the Service or by the infrastructure of the Service itself (for example, the duration of a page consultation).
• Cookies Cookies are small files stored on your device (computer or mobile device).
• Data Controller Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the means by which any personal data are or are to be processed. For the purposes of this Privacy Policy, we are a Data Controller of your personal data.
• Subcontractors (or Service Providers) The term Subcontractor (or Service Provider) means any natural or legal person who processes data on behalf of the Data Controller. We may use the services of several Service Providers in order to process your data more efficiently.
• Person Concerned (or User) A Concerned Person is any living person who uses our Service and is the subject of Personal Data.

Data processing

Who are the recipients of the data?

The recipients of the data are:

• Authorized employees of Cortexia SA
• Customers when returning data
• Some subcontractors under contract

Are there any data transfers outside the EU?

• In Switzerland (suitable country)
• In the USA, regarding the specific case of Google Analytics cookies, Google has certification regarding the Data Protection Framework (see https://business.safety.google/adsdatatransfers/ and https://www.dataprivacyframework.gov/s/ )

Learn more about the personal data processed by Cortexia

Processing of personal data that can be carried out by Cortexia-Boxes equipped with cameras

As part of the use of its artificial intelligence software solution, the Cortexia-Box, which aims to improve urban cleanliness and which is placed on its customers’ urban utilities (e.g., sweepers, bicycles, etc.), Cortexia SA may inadvertently collect personal data about you. The Cortexia-Box is not a video surveillance system because its purpose is absolutely not surveillance and does not operate in the same way as such a system.

What personal data may we collect?

The Cortexia-Box, for analyzing waste present on the ground, is equipped with an image sensor, oriented towards the ground, which can inadvertently capture only images of your face or the license plate of your vehicle if you are too close to the latter (for example, you are crouching near one of the utilities equipped with a Cortexia-Box). In its standard operation, images are not saved.

As part of the training of detection algorithms, a small percentage of images is collected (approximately 0.01%). These images are anonymized within 5 days of their collection by automatic and irreversible blurring of faces and license plates that may be visible.

For what purposes do we process your personal data?

In operational mode, the Cortexia-Box immediately processes the captured images, which are transformed into digital cleanliness metadata (type and quantity of waste detected, timestamp) in order to create urban cleanliness graphs and diagrams for Cortexia SA customers. Thus, no image that could inadvertently contain personal data about you (e.g. face or license plate) is recorded and/or transferred.

As part of continuous improvement, and in order to ensure the quality of image processing by the Cortexia-Box, Cortexia SA uses a sampling of approximately 0.01% of the images. These images are used to train the detection algorithm in order to improve its quality. This may include, for example:

• to detect new waste
• to enrich the contexts known by the algorithm (e.g. various soil types)
• to correct the detection of “false positives”

On what legal basis do we process images containing personal data that we may collect?

The processing of your personal data, inadvertently, within the framework of the operation of the Cortexia-Box is based on the legitimate interest of Cortexia SA and its client, to ensure the improvement and management of the quality of waste detection carried out by the Cortexia-Box.

Do we share images that may contain your personal data?

To ensure complete and reliable anonymization, Cortexia SA transmits the data anonymized by the blurring algorithm to a subcontractor located in the European Union subject to a strict contract ensuring the protection of your data. This subcontractor is responsible for sorting any images that may have escaped the algorithm. This ensures complete elimination of personal data.

What measures do we take to ensure the security of Cortexia-Boxes?

Cortexia SA has implemented organizational and technical measures to guarantee the security of Cortexia-boxes (e.g. regular maintenance, use of a private APN network for IT channels).

Cortexia SA also ensures the quality of its data blurring algorithms by conducting regular audits. Anonymized images are reviewed by a subcontractor located in the European Union, subject to a strict contract ensuring the protection of your data and guaranteeing complete anonymization.

What are your rights?

You are granted data protection rights under the General Data Protection Regulation (GDPR)

Cortexia SA intends to take reasonable steps to enable you to correct, amend, delete or limit the use of your Personal Data.

If you wish to know what Personal Data we hold about you and would like it deleted from our systems, please contact us.

You have the following rights regarding your personal data:

• The right to access, update or delete the information we hold about you. Where this option is provided, you can view or update your Personal Data or request its deletion in the settings section of your account. If you are unable to perform these actions yourself, please contact us for assistance.
• Right to object to the processing of your personal data based on a legitimate interest, unless there are legitimate and compelling reasons which override your interests.
• Right of limitation. You have the right to ask us to limit the processing of your personal data.
• Right to lodge a complaint with the personal data protection authority in your country (in France this is the CNIL).
• Right to withdraw consent. You also have the right to withdraw your consent at any time if Cortexia SA relied on your consent to process your personal data (e.g. newsletter).
• Right of correction. You have the right to have your data corrected if it is inaccurate or incomplete.
• Right to data portability. You have the right to receive a copy of the information we hold about you in a commonly used, structured and machine-readable format.
• Right to define post-mortem directives.

To exercise your rights, you can contact Cortexia SA directly:

• by email : rgpd@cortexia.ch
• by post : Cortexia SA, Route de Vevey 91, 1618 Châtel-St-Denis, Switzerland.

You may be asked for proof of identity if Cortexia SA has any doubts about your identity.

We also inform you that within the framework of the joint responsibility agreement concluded between Cortexia SA and each of its clients, in accordance with article 26 of the GDPR, Cortexia SA is responsible for informing and managing the response to the exercise of the rights of a data subject.

Disclosure of Data

Commercial operation

If Cortexia SA is involved in a merger, acquisition or sale of assets, your Personal Data may be transferred. Before your Personal Data is transferred and becomes subject to a different Privacy Policy, we will notify you.

Disclosure of Data to Law Enforcement Agencies

Under certain circumstances, Cortexia SA may be required to disclose your Personal Data if required by law or in response to valid requests from public authorities (e.g. a court or government agency).

Legal requirements

Cortexia CH may disclose your Personal Data if it believes in good faith that this is necessary to:

• Fulfill a legal obligation
• To protect and defend the rights or property of Cortexia SA.
• Preventing or investigating possible wrongdoing within the Service
• To ensure the personal safety of users of the Service or the public
• Protecting yourself against civil liability

Service Providers

We may use third party companies and third parties to facilitate the provision of our Service (“Service Providers”), to provide the Service on our behalf, to provide services related to the Service or to assist us in analyzing how our Service is used.

These third parties only have access to your Personal Information to perform these tasks on our behalf and are prohibited from disclosing or using it for any other purpose.

Analyses

We may use third party Service Providers to monitor and analyze the use of our Service.

• Google Analytics Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualize and customize ads from its own advertising network. You can prevent your activities within the Service from being made available to Google Analytics by installing the Google Analytics Opt out browser add-on plug-in. This plug-in prevents the Google Analytics JavaScript code (ga.js, analytics.js, and dc.js) from sharing information about visit-related activities with Google Analytics. For more information about Google’s privacy practices, please visit the Google Privacy and Terms webpage: https://policies.google.com/privacy?hl=en.
• For more information on Google’s privacy practices, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy?hl=en

Emailing

We may use third party Service Providers to monitor and analyze the use of our Service.

• Marketing automation and emailing service provided by Sendinblue For more details on Sendinblue’s privacy practices, please see the Sendinblue Platform Privacy Policy web page: https://fr.sendinblue.com/rgpd/

Links to other sites

Our Service may contain links to other sites that we do not operate. If you click on a third party link, you will be redirected to that third party’s site. We strongly recommend that you review the privacy policy of each and every site you visit.

We have no control over the content, policies or privacy practices of third party sites or services and assume no responsibility or liability for them.

Children’s Privacy

Our Service is not intended for persons under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from persons under the age of 18. If you are a parent or guardian and you know that your Child has provided us with Personal Information, please contact us. If we learn that we have collected Personal Information from children without verifying parental consent, we will take steps to delete this information from our servers.

Changes to this Privacy Policy

We reserve the right to update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Before the change takes effect, we will notify you by e-mail and/or by placing a prominent notice on our Service and we will update the “effective date” at the top of this Privacy Policy.

You should check this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Last updated: February 2025