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Privacy Policy

@gora - Privacy Policy

Last updated: January 2026

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1. General Information

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1.1 Introduction

Carbon Copy Association (“Carbon Copy”, “we”, “us”) attaches great importance to the protection of personal data.

This Privacy Policy explains how personal data is processed when you use the @gora mobile application and related digital services, or when you otherwise interact with Carbon Copy. It describes the categories of personal data processed, the purposes and legal bases of processing, potential recipients, retention periods, and the rights of data subjects.

 

This Privacy Policy complies with:

  • the Swiss Federal Act on Data Protection (DSG), and

  • the EU General Data Protection Regulation (GDPR), where applicable.

 

The applicability of the GDPR depends on the specific circumstances, including the place of residence of the data subject and the nature of the processing.

 

1.2 Controller

The controller within the meaning of Art. 4(7) GDPR is:

 

Carbon Copy Association
Oescherstrasse 26
CH-8702 Zollikon
Switzerland

 

📧 hi@carbon-copy.org

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Carbon Copy operates, inter alia, the @gora mobile application and related online services.

 

1.3 Scope

This Privacy Policy applies to all processing of personal data carried out within the scope of Carbon Copy’s activities and digital offerings.

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Specific offerings or processing activities (e.g. events, surveys, learning modules, participatory formats, job applications) may be governed by supplementary data protection notices. Such notices apply in addition to this Privacy Policy.

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Carbon Copy reserves the right to amend this Privacy Policy where necessary. The current version is made available via the app or website.

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2. Categories of Personal Data and Purposes of Processing

“Personal data” means any information relating to an identified or identifiable natural person.

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Carbon Copy processes personal data only insofar as necessary for the purposes set out below.

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2.1 Master Data

This may include:

  • Name or username

  • Email address

  • Contact details

  • Other information voluntarily provided when registering, contacting us, or participating in events, surveys, learning modules, or community features

Purpose:
User registration, communication, participation management, and provision of services.

 

2.2 Contractual and Participation Data

This may include:

  • Participation records

  • Consent records

  • Contractual or pre-contractual information

  • Administrative or billing data, where applicable

  • Data required to comply with legal obligations

Purpose:
Fulfilment of contractual or participation-related obligations and compliance with applicable law.

 

2.3 Communication Data

When you contact Carbon Copy, we process the content and metadata of communications via:

  • Email

  • In-app messaging

  • Contact forms

  • Social media channels

  • Telephone or video calls, where applicable

Purpose:
Handling inquiries, providing support, moderation, and documentation.

 

2.4 Usage and Analysis Data

When using the @gora app or website, we may process:

  • Information on usage patterns (e.g. visited sections, duration)

  • Interaction data

  • Technical events (e.g. errors, crashes)

Where feasible, such data is aggregated, anonymised, or pseudonymised and not combined with directly identifying information.

Purpose:
Ensuring technical stability, improving usability, evaluating participatory formats, and developing our offerings.

Once data is anonymised, it is no longer considered personal data and may be used independently of individual user accounts.

 

2.5 Content and Information Services

Where you have given your consent, we may process personal data to inform you about:

  • Our own events

  • Educational content

  • Programs and initiatives

Purpose:
Information and communication relating exclusively to Carbon Copy’s activities.

 

2.6 Technical and Security Data

This may include:

  • IP addresses (shortened or stored only temporarily where possible)

  • Log files

  • Device and app version data

  • Security-relevant events

Purpose:
IT security, abuse prevention, error analysis, and safeguarding system integrity.

 

2.7 Artificial Intelligence

In limited cases, Carbon Copy may use AI-supported tools to assist with:

  • Content moderation

  • Aggregated analysis

  • Improvement of educational or participatory formats

Where AI-supported tools are used:

  • Human oversight is ensured at all times

  • No automated decision-making producing legal or similarly significant effects takes place

  • Personal data is processed only where necessary and, where possible, in anonymised form

AI-supported language translation

For the purpose of enabling multilingual participation and accessibility, Carbon Copy may use AI-supported translation services (e.g. DeepL or comparable providers) to translate user-generated content, interface elements, or communications.

Translation is performed solely to render content in another language and does not involve profiling or automated decision-making. Where possible, translation is carried out on anonymised or pseudonymised content.

Any providers used for translation act either as processors under appropriate contractual safeguards or process data under their own responsibility in accordance with applicable data protection law.

 

3. Legal Bases for Processing

Where required, personal data is processed on the following legal bases:

  • Consent (Art. 6(1)(a) GDPR), in particular for participation, surveys, newsletters, and user-generated content

  • Contract or pre-contractual measures (Art. 6(1)(b) GDPR)

  • Legal obligation (Art. 6(1)(c) GDPR)

  • Legitimate interests (Art. 6(1)(f) GDPR), notably:

    • Operation and security of digital services

    • Improvement and further development of offerings

    • Prevention of misuse and abuse

Legitimate interests are always balanced against the fundamental rights and freedoms of data subjects.

 

4. Data Sharing and Processors

Personal data is shared within Carbon Copy only to the extent necessary for the stated purposes.

Carbon Copy may engage carefully selected service providers acting as processors within the meaning of Art. 28 GDPR. Such processors process personal data solely on our instructions and are subject to appropriate contractual safeguards.

Personal data is not sold and not used for third-party advertising.

Disclosure to authorities or third parties occurs only where legally required or permitted.

 

5. International Data Transfers

If personal data is transferred to recipients outside Switzerland or the EU/EFTA, Carbon Copy ensures an adequate level of protection, in particular through:

  • adequacy decisions, or

  • recognised safeguards such as standard contractual clauses.

 

6. Storage Duration

Personal data is retained only for as long as:

  • necessary for the stated purposes,

  • required by legitimate interests, or

  • mandated by applicable law.

Where possible, participation data is anonymised at an early stage. Thereafter, anonymised data may be retained for research, evaluation, and quality-assurance purposes.

 

7. Rights of Data Subjects

Data subjects have the right to:

  • Access

  • Rectification

  • Erasure

  • Restriction of processing

  • Data portability

  • Objection

  • Withdrawal of consent at any time

 

Requests may be submitted to:

 

Carbon Copy Association
Oescherstrasse 26
CH-8702 Zollikon
📧 hi@carbon-copy.org

 

Data subjects also have the right to lodge a complaint with a competent supervisory authority.

 

8. Cookies, Analytics, and Online Tracking

Where analytics tools are used:

  • IP addresses are shortened or anonymised where possible

  • Data is not combined with directly identifying information

  • Analytics providers act as processors and do not process data for their own purposes

Further details are available via the cookie preference settings.

 

9. Third-Party Platforms and Embedded Content

Carbon Copy maintains presences on third-party platforms (e.g. social media). These platforms process personal data under their own responsibility.

Carbon Copy receives only anonymised, aggregated statistics from such platforms and does not receive individual user profiles.

 

10. Use of the @gora App

When using the @gora app, technically necessary data is processed to ensure functionality, stability, and security.

Participation in surveys, polls, or dialogue formats is voluntary. Responses are:

  • not attributed to real names by default, and

  • evaluated in anonymised or aggregated form where possible.

Users may skip surveys at any time without disadvantage.

 

11. User-Generated Content

Certain features allow users to submit their own content (e.g. comments, arguments, dialogue contributions).

  • Content may be publicly visible

  • Usernames or pseudonyms may be displayed depending on the feature

  • Real names are not required unless explicitly stated

Public visibility is apparent to users at the time of submission.

User-generated content is retained only as long as necessary for its purpose and may be deleted upon request, unless legal obligations require otherwise.

 

12. Transparency and Boundaries

Carbon Copy is committed to data minimisation and purpose limitation. Our digital offerings are designed to enable meaningful participation and learning without extensive personal data collection.

We do not:

  • sell personal data,

  • use personal data for advertising or behavioural targeting,

  • create individual political or commercial profiles, or

  • carry out automated decision-making with legal or similarly significant effects.

 

Aggregated and anonymised data may be used to generate insights that serve the public interest, improve participatory formats, and support research and learning, without allowing conclusions about individual participants.

 

13. AI-Supported Sense-Making Tools (Separate Services)

Carbon Copy may, in specific contexts, use or provide access to AI-supported sense-making tools or corresponding services to support the evaluation, structuring, and synthesis of contributions arising from live group discussions or deliberative events.

These sense-making tools are not an integral part of the @gora mobile application, but may be used in combination with @gora in the context of moderated participation or deliberation formats (e.g. workshops, citizens’ panels, or live discussion settings).

 

13.1 Purpose of Processing

The purpose of such tools is to support facilitators and organisers in:

  • structuring large volumes of contributions,

  • identifying themes or patterns,

  • summarising discussions, and

  • improving the quality and clarity of deliberative outcomes.

 

13.2 Use of Artificial Intelligence

 

Sense-making tools may rely on AI models for data processing, including but not limited to large language models (e.g. ChatGPT or comparable technologies).

Processing serves exclusively analytical and organisational purposes and is intended to support human-led facilitation and interpretation. No automated decision-making with legal or similarly significant effects takes place.

 

13.3 Data Scope and Safeguards

 

Depending on the specific deliberative format:

  • inputs may consist of anonymised, pseudonymised, or contextualised contributions from group discussions,

  • personal data is processed only where necessary and proportionate to the stated purpose,

  • where feasible, data is anonymised prior to processing.

The use of sense-making tools does not involve the creation of individual profiles or behavioural scoring.

 

13.4 Separation from Core Platform Processing

Processing associated with AI-supported sense-making tools is functionally and purposefully distinct from the operation of the @gora app.

Where applicable, participants are informed about the use of such tools in the context of the specific deliberative format.

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