PRIVACY POLICY
1. Who we are
This policy explains how Hotwork International AG, Romanshornerstrasse 123, 9322 Egnach, Switzerland ("Hotwork", "we"), processes personal data. It applies to visitors of our websites, customers, suppliers, partners and their contact persons, subcontractor personnel we deploy on projects, users of our HOTware portals and job applicants. Where another Hotwork group company is your contract partner, that company is responsible together with us.
Contact for data protection: privacy@hotwork.ag, +41 71 649 20 90.
We process personal data in line with the Swiss Federal Act on Data Protection (FADP) and, where it applies to us, the EU General Data Protection Regulation (GDPR). Our employees receive a separate data protection notice (HWI-FRM-DP-01) in HOTware.
2. What data we process and why
| Situation | Data | Purpose and legal basis |
|---|---|---|
| Visiting our website | IP address, date and time, pages viewed, browser, referring site | Operating and securing the website · legitimate interest (GDPR Art. 6(1)(f)) |
| Contact forms, email, phone | Name, company, contact details, content of your message | Answering your request · legitimate interest or pre-contractual steps (Art. 6(1)(b), (f)) |
| Customers, suppliers and partners | Contact persons, business cards, orders, offers, invoices, payment data | Performing contracts, accounting, sales contacts · Art. 6(1)(b), (c), (f) |
| Subcontractor personnel on our projects | Name, contact data, passport, ID, visa and permit data, qualifications, travel data | Travel booking, visa and site-access documentation for client projects · Art. 6(1)(b), (f) |
| HOTware portals (customers, partners) | User account, login and log data, documents you upload | Providing the portal and its security · Art. 6(1)(b), (f) |
| Job applications | CV, certificates, contact details, interview notes | Selection process · Art. 6(1)(b); kept longer only with your consent |
3. AI-assisted processing
We use AI services to read and extract data from business documents, for example invoices, business cards, travel documents, passports and visas of personnel we deploy, and to prepare bookings and visa checks.
- The AI services are connected to our own system (HOTware) and act as our processors. Our current provider is Google (Gemini API, paid service). The provider does not use the data to train its models.
- A Hotwork employee checks AI results before decisions or bookings that affect you. We do not take decisions based solely on automated processing that have legal or similarly significant effects on you.
- We do not use AI services to process health data.
4. Service providers and other recipients
We share personal data only as far as needed:
- IT and cloud providers: Microsoft (Microsoft 365, SharePoint, Azure), Google (Gemini API), Amazon Web Services where needed, and providers of our accounting and payroll software.
- Hotwork group companies for project execution and central administration.
- Travel providers and authorities: airlines, travel agencies, hotels, rental car companies, embassies, visa agencies and immigration authorities.
- Clients and their safety officers, for site access and mandatory project documentation.
- Banks, payment providers, logistics companies, insurers, auditors and tax advisors.
5. Transfers to other countries
We work worldwide. Data may therefore be processed in countries outside Switzerland and the EU/EEA, including the USA, the Philippines, India, Indonesia and other countries where we have group companies or projects. Where a country does not have adequate data protection, we use the Swiss-US / EU-US Data Privacy Framework, standard contractual clauses or an intra-group data transfer agreement, or the transfer is needed to perform a contract with you or in your interest (Art. 17 FADP, Art. 49 GDPR).
6. Website: cookies and analytics
Our website uses technically necessary cookies and, only if you consent in the cookie banner, Google Analytics 4, a web analytics service of Google Ireland Limited and Google LLC (USA).
- What it does: Google Analytics shows us how visitors use the website (pages viewed, time on page, device type, approximate location by country or city, referring website). We use this only to improve the website.
- Cookies: _ga and _ga_<ID>, stored for up to 2 years. They contain a random identifier, not your name.
- IP addresses: Google Analytics 4 does not store IP addresses.
- Transfer: data may be transferred to Google LLC in the USA under the EU-US and Swiss-US Data Privacy Framework.
- Legal basis: your consent (GDPR Art. 6(1)(a)). You can withdraw it at any time via the cookie settings link in the website footer.
- Retention: analytics data is kept for 2 months in Google Analytics and then deleted automatically.
We do not use social media plugins that send data to social networks when the page loads.
7. How long we keep data
| Data | Retention |
|---|---|
| Contracts, invoices, accounting records | 10 years (Art. 958f Swiss Code of Obligations) |
| Business correspondence and contact data | As long as the business relationship lasts, then up to 10 years where relevant for accounting |
| Passport, ID and visa copies of deployed personnel | Until the project ends; deleted at the latest 3 months afterwards |
| Job applications | 6 months after the decision, unless you agree to a longer period |
| Website server logs | 30 days, longer only to investigate security incidents |
8. Security
We protect personal data with role-based access, multi-factor authentication, encryption and regular backups. Our systems are hosted mainly in Microsoft data centres.
9. Your rights
You can request access to your data, correction, deletion, restriction, data portability, and object to processing based on legitimate interest. You can withdraw a consent at any time for the future. Please write to privacy@hotwork.ag. You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch) or, if you live in the EU, with your local data protection authority.
10. Changes
We update this policy when our processing changes. The version published on this website applies. Last updated: 04.11.2026.