Legal

Privacy Policy

Courtesy translation, provided for information only. The French original (version française) is the sole authoritative version.

Version 2.7 of 13 October 2026. This policy describes the processing of personal data carried out by the Publisher of LEMIA (art. 19 FADP, the Swiss Federal Act on Data Protection; art. 13 and 14 GDPR where applicable). It replaces version 2.6 of 7 October 2026 (§5.4: the Software’s three calls to lemia.ch — the update check, the reading of the list of reference registers and the download of a register — are declared, with what leaves the workstation and what does not; §8: the hosting also serves those downloads).

Contents

• 1. Scope
• 2. Definitions
• 3. Controller and roles
• 4. Principles and architecture
• 5. Data processed and purposes
• 6. Cookies and analytics
• 7. Retention periods
• 8. Recipients and processors
• 9. Transfers abroad
• 10. Security
• 11. Data security breaches
• 12. Your rights
• 13. Automated individual decision-making
• 14. Changes
• 15. Governing law and jurisdiction

1. Scope

This policy describes how the Publisher of LEMIA processes personal data:

• on the public website lemia.ch (the “Site”, also reachable at www.lemia.ch), including the contact and access-request forms;
• in the context of the contractual relationship (account, licence, subscription, billing, support);
• through the LEMIA software (the “Software”), a desktop application installed on the Client’s own computer, and the technical link between the Software and the Publisher’s servers (the “control server”).

It does not govern the processing that the Client itself carries out with the Software on the data in its own case files: for these processing operations, the Client is the data controller (see §3 and §5.5). This policy supplements the terms of use and the legal notice.

2. Definitions

• Personal data: any information relating to an identified or identifiable natural person (art. 5 let. a FADP).
• Sensitive data: personal data concerning, in particular, health, the intimate sphere, religious, philosophical, political or trade-union views or activities, genetic or biometric data, criminal or administrative proceedings and sanctions, or social assistance measures (art. 5 let. c FADP).
• Processing: any operation relating to personal data, irrespective of the means used — collection, recording, storage, use, disclosure, archiving, erasure (art. 5 let. d FADP). Merely routing a piece of data is already processing.
• Controller: the person or body that decides on the purposes and means of a processing operation (art. 5 let. j FADP).
• Processor: the person or body that processes personal data on behalf of the controller (art. 5 let. k FADP).
• Client: the professional, firm, practice or institution that subscribes to the Software licence; User: any natural person authorised by the Client to use the Software.
• Content: the documents, instructions, texts and results that the Client processes or produces with the Software.
• Technical metadata: operational markers devoid of content — device and version identifiers, execution steps, name of the model called, task and token counters, estimated cost, durations, statuses, technical scores.

3. Controller and roles

Controller for the processing operations described in this policy (Site, contact, account, licence, billing, technical metadata):

Colin Thompson, Geneva, Switzerland, who publishes LEMIA in his own name (the “Publisher”). Contact: contact@lemia.ch (subject line “Data protection”).

The Publisher acts in two distinct capacities:

• Controller for the data described above (Site visitors, prospects, Clients and Users);
• For the Content that the Client processes with the Software: the Client is the sole data controller (art. 5 let. j FADP and, where applicable, art. 4 no. 7 GDPR). The Publisher does not receive this Content and has no access to it (see §4). Access to the AI models takes place using the Client’s own access keys (“BYO keys”): the Client contracts directly with the AI provider, including, where required, the necessary data processing agreement (DPA) — the Publisher is not a party to that relationship nor to the flow of Content (see the Terms of Use, art. 5.1 and 11.2).

4. Principles and architecture

The Publisher applies the principles of lawfulness, proportionality, purpose limitation and data minimisation (art. 6 FADP), as well as data protection by design and by default (art. 7 FADP). The product architecture is the direct expression of these principles — a “desktop + content-blind server” model:

• The Software is a desktop application: your files stay on your own computer. The documents you open, the Content produced and your execution logs do not pass through any of the Publisher’s servers and are never transmitted to it. The Software embeds no content telemetry.
• AI processing goes from your own computer directly to a Swiss operator (INFOMANIAK NETWORK SA — see §5.5 and §8): only the excerpts strictly necessary for the requested task are transmitted to it, and the processing takes place in Switzerland.
• The Publisher’s control server sees technical metadata only. The link between the Software and the Publisher’s servers is filtered by a strict allowlist, applied in “closed by default” mode on both sides of the link: only enumerated technical markers (steps, counters, durations, statuses) may cross the link. Content — your texts, your instructions, your documents, the results produced — is not on that list and therefore never crosses the link.

As a result, the Publisher is technically unable to view, hand over or return its Clients’ Content: it does not hold it. These commitments are to be understood as best-efforts obligations (obligations de moyens), implemented through the measures described on the Security page; they are restated in the Terms of Use (art. 4.2, 4.3 and 11.2).

5. Data processed and purposes

5.1 Website

The Site is a static showcase website hosted by INFOMANIAK NETWORK SA (Geneva, Switzerland). When you visit it, the only data processed are the host’s technical server logs (IP address, timestamp, page requested, user agent), generated for security and operational purposes. Purposes: display, stability and security of the Site. Basis: overriding interest in the secure operation of the Site (art. 31 para. 1 FADP).

5.2 Contact and access requests

If you write to us (contact@lemia.ch) or submit one of our forms — contact or access request (name of the firm or practice, professional e-mail address, profession, message), we process the data you voluntarily provide for the sole purpose of responding to your enquiry, reviewing your access request and, where applicable, preparing the contractual relationship. Basis: pre-contractual steps and performance of the contract. This data is neither sold nor passed on to third parties for marketing purposes.

5.3 Account, licence and billing

If you subscribe to a licence, we process the data necessary for the conclusion and performance of the contract:

• Identity and contact details: company name, surname, first name, e-mail, professional contact details;
• Contractual data: plan subscribed, number of seats, version of the Terms of Use accepted and timestamp of acceptance;
• Access: your practice’s enrolment code, the number of workstations and the workstations enrolled;
• Billing: billing details, history of invoices and payments;
• Support: your communications and support requests.

Purposes: account and access management, provision of the service and support, billing, contract management, abuse prevention. Basis: performance of the contract and legal obligations (in particular accounting obligations).

5.4 Operational and licence metadata

For licence management and service stability, the Software may transmit technical metadata to the Publisher: device and version identifiers, name of the model called, originating area, task and token counters, estimated cost, durations, execution statuses, technical scores, session events and content-free error logs (only the error code, the time and the area concerned, linked to the workstation and the practice, kept 90 days). This metadata never includes the content processed — no text, no document, no instruction, no file name.

By way of illustration, here is the form of a typical record on the Publisher’s side:

2026-07-10 14:32:11 run=8f21 etape=redaction-2 statut=termine
modele=Qwen3.5-397B tokens_entree=10350 tokens_sortie=2239 duree=4.2s verdict=success

What never appears in it: your texts, your instructions, the content of your documents, the names of your files, the subject matter of your cases.

This metadata is not used to bill your AI usage: when you use your own access keys, your AI usage is billed to you directly by the AI provider (Terms of Use, art. 5.1) and the Publisher receives nothing on that usage.

Three calls to lemia.ch. In addition to the licence server, the Software contacts the Publisher’s website (lemia.ch, hosted in Switzerland) in three cases, and only those:

• Update check, when the Software starts: the request reads the number of the latest published version. What leaves: the workstation’s IP address. What does not leave: any content, any practice identifier.
• Reading the list of reference registers, when the Software starts: the request reads the list of published registers, so that the Software can offer those of your profession and tell you when an update exists. What leaves: the workstation’s session token (it proves that the request comes from a licensed workstation) and its IP address. What does not leave: any content, or the list of registers installed on your workstation. No register is downloaded at that point.
• Download of a reference register, only when you request it (Terms of Use, art. 12.3): what leaves is the workstation’s session token — it proves that the request comes from a licensed workstation —, its IP address, the name of the requested package and its version. What does not leave: any content, any file name, or any of the searches you later run in the register, which stay on your workstation.

Like any request addressed to the Site, these three calls may appear in its technical logs (§7). The registers themselves are copies of data published by their sources, identical for every workstation: they contain no data of your practice.

5.5 Data processed with the Software

The data you process with the Software (documents, instructions, Content produced) is your responsibility: you are the data controller, and the Publisher has no access to it. This data may include sensitive data (art. 5 let. c FADP) when you open such documents in the Software; it is up to you to have an adequate justification and to comply with your professional obligations, in particular professional secrecy where it applies.

To produce the requested results, the Software transmits the strictly necessary elements to the sole AI provider it calls:

• A single flow, by design: the Software is designed to call only Infomaniak (INFOMANIAK NETWORK SA, Geneva, Switzerland) — every AI call is processed in Switzerland, by a Swiss operator, and this commitment is restated in our contracts. Infomaniak states that its models are not trained on your data; this statement is reflected in the applicable data processing agreement.
• No public AI services: the large public AI platforms are neither offered nor callable by the Software — there is no setting to enable them.
• Web tools switched off by default: AI-initiated web search and web reading tools are switched off by default — no content is transmitted to a third party outside Switzerland at the AI’s initiative, unless you explicitly enable the optional web mode (disclaimer to accept, logged), under your responsibility; the AI is then instructed never to disclose anything sensitive in its queries.

Outbound sends that you approve yourself (e-mails, connected services) are your own acts, carried out from your own accounts: they are your responsibility. The details of the technical measures (sandbox, forbidden folders, human approval, encrypted logs) are set out on the Security page.

6. Cookies and analytics

The Site uses no cookies, no trackers, no analytics tool and no fingerprinting. No browsing profile is built.

7. Retention periods

We keep personal data only for as long as necessary for the purposes pursued, then delete or anonymise it (art. 6 para. 4 FADP):

On the Client’s own computer, the Software itself applies retention rules: the local activity log (art. 12 FADP / art. 4 OPDo) is kept for at least one year for traceability purposes, and temporary working files (for example the files exported from the conversational assistant) are purged automatically after a few days. This data stays on your machine and under your control.

8. Recipients and processors

The data for which the Publisher is the controller is neither sold, nor rented, nor passed on to third parties for commercial purposes. It is accessed only by the people who need it to operate, secure and maintain the service (“need to know” principle). The Publisher uses the following service providers:

For the Content processed with the Software, the AI provider is the processor of the Client (direct contractual relationship, with the provider’s DPA): the Publisher plays no part in that relationship and does not appear in the processing chain of the Content. The Publisher may also disclose data where a legal obligation compels it to do so — it being recalled that it holds no Content and is therefore unable to hand any over.

9. Transfers abroad

The Publisher transfers no personal data abroad: the Site, the Publisher’s servers and the AI processing are operated in Switzerland, and the Software directs no AI call to a foreign provider (see §5.5). Sends that the Client itself triggers to recipients abroad, from its own accounts and after approval, are the Client’s responsibility.

For Clients established in the European Union: Switzerland benefits from an adequacy decision of the European Commission recognising an adequate level of protection of personal data; transfers from the European Union to Switzerland are covered on that basis (art. 45 GDPR).

10. Security

The Publisher takes appropriate technical and organisational measures (art. 8 FADP; OPDo) to protect the data it processes: encryption of connections, filtering of the control server limited to metadata only, in “closed by default” mode, redacted logs (secrets, personal data and paths masked), compartmentalised access. On the Client’s own computer, the Software applies in particular: a sandbox restricting access to the folders you open only, a list of forbidden folders that are technically unreadable, a staging area for the documents produced, human approval before any send, reversibility of changes to existing documents, logs encrypted at rest, access keys kept in a local encrypted vault. The details, in plain words, are set out on the Security page. These measures constitute best-efforts obligations.

11. Data security breaches

The Publisher documents any data security breach affecting the processing operations for which it is the controller, notifies the FDPIC (PFPDT) of breaches likely to result in a high risk to the personality or fundamental rights of the data subjects (art. 24 FADP), and informs the Clients concerned without delay, in accordance with the applicable contracts. The Software additionally provides the Client, in its Compliance area, with a breach documentation register for the Client’s own notification obligations.

12. Your rights

For the data for which the Publisher is the controller (Site, contact, account, licence, metadata), you have the following rights:

• access (art. 25 FADP) — response as a rule within 30 days, free of charge;
• rectification (art. 32 FADP);
• erasure or destruction (art. 32 para. 2 let. c FADP);
• objection to processing (art. 30 para. 2 let. b FADP);
• delivery or portability of your data (art. 28 FADP);
• and, if the GDPR applies to your situation, the corresponding rights (art. 15 to 22 GDPR).

How to exercise them: write to contact@lemia.ch (subject line “Data protection”), specifying the right you are exercising. To protect your data against abusive requests, we may ask for proof of identity where doubt remains as to the requester’s identity.

Persons whose data is processed by a firm or practice using LEMIA (a firm’s clients, patients or principals): your point of contact is the firm or practice, which is the data controller and, where applicable, the holder of professional secrecy. The Publisher does not hold this data and is technically unable to access it; it therefore cannot respond directly to a request concerning it.

You may at any time contact the Federal Data Protection and Information Commissioner (FDPIC/PFPDT, edoeb.admin.ch).

13. Automated individual decision-making

Neither the Publisher nor the Software carries out any exclusively automated decision producing legal effects on, or significantly affecting, the data subjects (art. 21 FADP): the Software is designed so that a human — the Client — approves every result before any use. Nothing is sent without your approval; produced documents await your approval (unless you explicitly waive it); edits to an existing document you designated apply at once and remain reversible.

14. Changes

This policy may be updated, in particular in the event of changes to the service, to our service providers or to the legal framework. The version in force is published on this page with its date and version number. In the event of a substantial change affecting Clients under contract, a communication is sent to them. Minor changes (clarifications, corrections with no impact on rights) may be made without prior notice.

15. Governing law and jurisdiction

This policy is governed by Swiss law. Any dispute relating to it falls within the jurisdiction of the ordinary courts of the Publisher’s domicile, namely Geneva, Switzerland, subject to any mandatory forums provided for by law.

Version 2.7 of 13 October 2026. Contact: contact@lemia.ch.