We are delighted that you are interested in our website. Protecting your privacy is important to us. Below, we provide you with detailed information on how we handle your data.
Privacy Policy
This Privacy Policy informs you which personal data we process in connection with our activities, including our
Additional privacy policies as well as other legal documents, in particular our General Terms and Conditions (GTC), may apply to individual or additional activities.
1. Controller and Contact Details
The controller responsible for the processing of personal data is:
Anemis GmbH
Maihölzli 6
6331 Hünenberg
Switzerland
Anemis GmbH operates, among other things, the cancelled.ch service.
We will point out any cases in which other or additional controllers are responsible for the processing of personal data.
Data Protection Officer
The following person is available as a point of contact for data subjects and authorities regarding any questions related to data protection:
Edoardo Köppel
Anemis GmbH
Maihölzli 6
6331 Hünenberg
Switzerland
2. Terms and Legal Bases
2.1 Terms
Personal data means any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.
Processing covers any handling of personal data, regardless of the means and procedures applied, for example querying, comparing, adapting, archiving, retaining, reading, disclosing, obtaining, collecting, recording, erasing, disclosing, organising, storing, altering, disseminating, linking, destroying and using personal data.
2.2 Legal Bases
We process personal data in accordance with the applicable data protection law, in particular the Swiss Federal Act on Data Protection (FADP) and the Data Protection Ordinance (DPO).
Where applicable in an individual case, we also take foreign data protection law into account, in particular the General Data Protection Regulation of the European Union (GDPR).
Insofar as a legal basis is required for a processing activity, this is based in particular on consent, on the initiation or performance of a contract, on the fulfilment of legal obligations, on the assertion, exercise or defence of legal claims, or on overriding or legitimate private or public interests.
3. Nature, Scope and Purpose of the Processing of Personal Data
We process the personal data that is necessary to carry out our activities on a lasting, user-friendly, secure and reliable basis. This includes, in particular, personal data that is necessary or expedient for the review, handling, out-of-court or judicial enforcement, and settlement of claims.
The personal data we process may in particular include inventory and contact data, content data, contractual and case data, payment data, correspondence, travel and booking data, information on flight irregularities, receipts and other evidence, as well as browser, device, meta, peripheral, usage and location data.
Insofar as this is necessary or expedient in connection with a specific case, particularly sensitive personal data or special categories of personal data may also be processed.
We process personal data in particular in order to:
- receive and review enquiries and case submissions;
- assess claims from a legal and factual perspective;
- assert claims against airlines or other obligated parties;
- prepare and conduct out-of-court and judicial proceedings;
- communicate with customers and other parties involved;
- process documents, evidence and other records;
- process payments;
- clarify insurance coverage and communicate with legal protection insurers;
- provide and further develop our services;
- fulfil our contractual and legal obligations;
- operate our IT systems, website and other infrastructure securely and reliably.
We process personal data for the duration required for the respective purpose or purposes, or as required by law. Personal data whose processing is no longer necessary and for which there is no legal basis for further retention is erased or anonymised.
Statutory retention obligations as well as the further retention of data for the assertion, exercise or defence of legal claims remain reserved.
We may process personal data ourselves or have it processed by third parties. We may process personal data jointly with third parties or disclose it to third parties, insofar as this is necessary or expedient for our activities or permissible for other legal reasons.
Insofar as third parties process personal data on our behalf, we select such service providers taking data protection requirements into account and, where necessary, conclude corresponding contractual agreements regarding the processing of personal data.
We generally process personal data with the consent of the data subjects, insofar as such consent is required. Insofar as processing is permissible for other legal reasons, we may dispense with obtaining consent.
We also process personal data that we receive or collect from data subjects themselves, from third parties, from publicly accessible sources, or in the course of our activities, insofar as such processing is legally permissible.
3.1 Disclosure of Data in Connection with Case Handling
For the purposes of reviewing, enforcing out-of-court or judicially, and settling claims, we may disclose personal data to those third parties whose involvement is necessary or expedient for handling a case.
These include, in particular, airlines, partner lawyers, partner law firms, courts, authorities, conciliation bodies, and other persons and companies commissioned with or involved in the legal or factual enforcement of claims.
The disclosure may also include particularly sensitive personal data, insofar as its transmission is necessary or expedient for reviewing, substantiating, enforcing or defending claims.
Partner lawyers, partner law firms, and other parties involved may also be located abroad.
Personal data and documents may in particular be transmitted to the airline concerned or to bodies, service providers, legal representatives or communication platforms designated by it.
For this purpose, we generally use the communication and transmission channels provided or required by the respective airline. These may in particular include e-mail, web forms, online portals or other electronic communication channels.
Depending on the options provided or required by the airline or other parties involved, transmission may also take place via communication channels that are not end-to-end encrypted or whose security standard we cannot determine. This applies in particular where an airline, a court, an authority, a partner law firm or another party involved specifies certain communication channels.
We endeavour to only transmit personal data to the extent necessary or expedient for the respective processing.
If a customer has indicated, when submitting a case, that they hold legal protection insurance, or has registered the case as covered by such insurance, we are permitted to transmit to the relevant legal protection insurer the personal data and documents necessary for reviewing and processing the insurance coverage as well as for handling the case, and to receive corresponding information from it.
This includes, in particular, information on the facts of the case, the claim, the status of proceedings, costs, payments, and the legal assessment.
Data is disclosed to the aforementioned recipients only insofar as this is necessary or expedient for carrying out our activities, for the performance of a contract, for safeguarding legitimate or overriding interests, for asserting or defending legal claims, or for other reasons permissible under data protection law.
4. Communication
We process personal data in order to be able to communicate with customers, prospective customers, contractual partners, insurers, airlines, authorities, courts, legal representatives, and other third parties.
Communication may take place in particular by post, e-mail, telephone, contact or web forms, online portals, instant messaging, SMS, video conference, or via other electronic communication channels.
In this context, we in particular process the data transmitted to us as part of the communication, as well as technical and organisational information required for the communication. We may store such data in address books, customer management systems, case management systems or comparable tools.
Depending on the communication service used, personal data may be processed by the respective provider and, where applicable, also transmitted abroad.
Third parties who transmit personal data about other individuals to us are responsible for being authorised to do so and for the accuracy of the information provided.
5. Data Security
We take appropriate technical and organisational measures to ensure a level of data security appropriate to the respective risk.
Through our measures, we ensure in particular the confidentiality, availability, traceability and integrity of the personal data processed, without, however, being able to guarantee absolute data security.
We point out that, in the course of handling a case, we may in particular use the communication channels offered or required by airlines, courts, partner law firms, and other parties involved.
Depending on the provider, these communication channels may not be end-to-end encrypted or may present other potential security risks. Insofar as we have no influence on the choice of communication channel, we cannot guarantee its security standard.
Access to our website and our other online presence generally takes place by means of transport encryption, in particular via HTTPS or SSL / TLS.
Most browsers indicate such transport encryption with a corresponding symbol in the address bar.
Due to its technical nature, digital communication can generally be captured or monitored by state authorities and other authorised or unauthorised third parties. We cannot exert any direct influence on the corresponding processing by security authorities, telecommunications providers or other third parties.
6. Personal Data Abroad
We generally process personal data in Switzerland. However, in the course of our activities, personal data may also be disclosed to, stored in, or processed in other countries.
This may in particular be the case where we cooperate with airlines, partner lawyers, partner law firms, courts, authorities, legal protection insurers, as well as IT, hosting, cloud, communication, analytics or AI service providers abroad.
Disclosure may in particular take place to countries within the European Economic Area (EEA), to the United Kingdom and to the United States of America (USA), as well as to other countries, insofar as this is necessary or expedient for our activities.
Where a recipient is located in a country whose law does not ensure adequate data protection, we shall – insofar as necessary – ensure adequate protection by other means.
This may in particular be achieved through appropriate contractual agreements, standard data protection clauses, or other guarantees provided for by law.
Disclosure may also be permissible on the basis of a statutory exception, in particular where the data subject has expressly consented, where the disclosure is directly connected with the conclusion or performance of a contract, where it is necessary for the assertion, exercise or enforcement of legal claims, or where another statutory interest exists.
Upon request, we shall inform data subjects, to the extent provided by law, about recipient countries and any applicable guarantees.
7. Rights of Data Subjects
7.1 Data Protection Claims
Data subjects have the rights afforded to them under the applicable data protection law.
These may in particular include:
- Right of access: data subjects may request information as to whether we process personal data about them and, insofar as required by law, which personal data and for what purposes.
- Rectification: inaccurate personal data may be rectified and incomplete data completed.
- Erasure: data subjects may, to the extent provided by law, request the erasure of their personal data.
- Restriction of processing: insofar as the applicable data protection law provides for a corresponding right, restriction of processing may be requested.
- Objection: data subjects may object to processing insofar as the applicable data protection law grants them a corresponding right.
- Withdrawal of consent: consent given may generally be withdrawn at any time with effect for the future.
- Data portability: insofar as the statutory requirements are met, data subjects may request the disclosure of certain personal data or its transfer.
These rights are not unlimited. We may defer, restrict or refuse the exercise of data protection rights within the legally permissible framework.
This may in particular be the case where statutory retention obligations exist, where overriding interests of third parties stand in the way, where trade secrets are affected, or where personal data continues to be required for the assertion, exercise or defence of legal claims.
We may require data subjects to prove their identity in an appropriate manner.
Insofar as legally permissible, costs may be charged for requests that are manifestly unfounded, abusive, or associated with disproportionate effort. We shall inform data subjects in advance of any such costs.
7.2 Legal Recourse
Data subjects may assert their data protection claims through legal channels or contact the competent data protection supervisory authority.
The competent data protection supervisory authority for private controllers and federal bodies in Switzerland is in particular the Federal Data Protection and Information Commissioner (FDPIC).
Insofar as foreign data protection law is applicable, foreign supervisory authorities may also have jurisdiction.
8. Use of the Website
8.1 Cookies and Comparable Technologies
We use, or may use, cookies and comparable technologies.
Cookies are data stored in the browser or on the terminal device. These may be our own cookies or cookies from third parties.
Cookies may be stored for a single session, as so-called session cookies, or for a specified period, as permanent cookies.
We use cookies in particular insofar as they are necessary for the technical operation, security and user-friendliness of our website.
In addition, cookies and comparable technologies may be used for analytics, statistical, reach measurement and marketing purposes.
Insofar as legally required, the use of cookies or comparable technologies that are not technically necessary only takes place following corresponding consent.
Consent given may be withdrawn with effect for the future, or adjusted via the cookie settings provided for this purpose.
Users may also block or delete cookies, in whole or in part, via their browser settings. Without cookies, individual functions of our website may not be available, or only to a limited extent.
8.2 Logging
Technical information may be logged when accessing our website and other online offerings.
This includes in particular:
- date and time of access, including time zone;
- IP address;
- access status or HTTP status code;
- operating system;
- browser, language and version;
- pages or content accessed;
- amount of data transferred;
- referrer, i.e. the previously visited website;
- device and connection information.
Such information may constitute personal data.
We use it in particular to provide our website on a lasting, secure, reliable and user-friendly basis, to detect technical problems, to prevent attacks and abuse, and to analyse and further develop our offerings.
8.3 Analytics and Tracking Services
We may use services to analyse the use of our website in order to understand how our online offerings are used, to evaluate their reach and use, and to improve our offerings from a technical, economic and content perspective.
In this context, IP addresses, device and browser information, technical identifiers, usage data, pages accessed, interactions, as well as the time and duration of visits, may in particular be processed.
We use in particular Google Analytics and may use other Google services for analytics, reach measurement, success measurement, or the technical management of corresponding technologies.
Providers include in particular Google Ireland Limited in Ireland, or Google LLC in the USA.
Cookies and comparable technologies may be used in this context, and personal data may be transmitted to, or processed by, Google. Processing may in particular also take place in the USA.
We may also use comparable analytics, statistics, reach, conversion or tracking services from other providers, insofar as this is expedient for the analysis, optimisation, marketing or secure and economical operation of our website.
Insofar as legally required, we only use such services with the consent of users.
9. Notifications and Communications
We send notifications and communications in particular by e-mail and, where applicable, via other communication channels such as instant messaging or SMS.
In this respect, we in particular distinguish between necessary communication in connection with an enquiry, a contractual relationship, or the handling of a case, and voluntary or promotional communication.
Communications necessary for processing an enquiry, performing a contract, handling a case, enforcing claims, or fulfilling statutory obligations may be sent without separate consent, insofar as a corresponding legal basis exists.
9.1 Success and Reach Measurement
Insofar as we send newsletters, marketing communications, or comparable voluntary communications, these may contain web links, tracking pixels, or comparable technologies that can, for example, record whether a communication was opened and which links were clicked.
This serves in particular to measure success and reach as well as to improve our communications.
Insofar as legally required, personalised success and reach measurement only takes place with corresponding consent.
9.2 Consent and Objection
Insofar as consent is required for sending certain communications, we obtain this in accordance with the statutory requirements.
We may in particular use the double opt-in procedure. Under this procedure, a message containing a confirmation link is sent following registration.
We may log consents, including the IP address as well as the date and time, for evidentiary and security purposes.
Recipients may object at any time to receiving voluntary or promotional communications, such as newsletters in particular, or withdraw consent given.
This does not affect necessary communications in connection with existing enquiries, contractual relationships, case handling, payments, legal proceedings, or other statutory or contractual obligations.
10. Social Media and Online Platforms
We may be present on social media platforms and other online platforms in order to communicate with interested individuals and to provide information about our activities.
In connection with such platforms, personal data may also be processed outside Switzerland.
The respective terms of use and privacy policies of the operators of such platforms shall additionally apply to the use of such platforms.
Operators may process personal data in particular for their own purposes. Insofar as we are jointly responsible with a platform operator for a given processing activity, responsibility shall be determined in accordance with statutory requirements and any agreements concluded with the respective provider.
11. Third-Party Services
We use services provided by specialised third parties in order to be able to carry out our activities on a lasting, user-friendly, secure, efficient and reliable basis.
This may in particular involve providers in the fields of IT, hosting, cloud infrastructure, communication, analytics, document processing, artificial intelligence, and other digital services.
Insofar as such providers process personal data on our behalf, we select them taking data protection requirements into account and, where necessary, conclude corresponding data processing agreements.
Third parties may, insofar as this is necessary for the provision of their services, also process data for their own legally permissible purposes. The respective contractual terms and privacy policies of the providers apply in addition.
We use in particular services provided by Google. Depending on the service, the provider is in particular Google Ireland Limited, Ireland, or Google LLC, USA.
11.1 Digital Infrastructure
We use services provided by specialised third parties to make available the digital infrastructure required for our activities.
This includes in particular hosting, server, storage, security and cloud services.
We use in particular:
- Hetzner: hosting and other infrastructure; provider in particular Hetzner Online GmbH or Hetzner Cloud GmbH, Germany.
11.2 Digital Audio and Video Content
We may use services provided by specialised third parties to embed or play digital audio and video content directly on our website or other offerings.
We use in particular:
- YouTube: video platform; provider in particular Google Ireland Limited or Google LLC.
When embedded content is accessed, technical data, in particular the IP address, may be transmitted to the respective provider.
11.3 Fonts and Other Embedded Content
We may use third-party services to embed fonts, icons, logos, symbols, or other content on our website.
We use in particular Google Fonts or corresponding services provided by Google.
- Google Fonts: fonts; provider: Google.
Insofar as such content is retrieved from a third-party provider’s servers, the provider technically receives, in particular, the IP address of the accessing device.
11.4 Artificial Intelligence
We use services and systems in the field of artificial intelligence (AI) in order to be able to carry out our activities more efficiently.
AI services may in particular be used for:
- analysing and summarising content;
- drafting, revising and structuring texts;
- translations;
- classifying and structuring information;
- processing and evaluating documents;
- research support;
- administrative tasks;
- legal support and preparation;
- support in handling and assessing cases.
Depending on the intended purpose, personal data, case information, correspondence, documents and other content may be transmitted to, or processed by, such AI systems.
We use in particular AI services provided by OpenAI, Anthropic, Meta and xAI.
We may also use comparable services from other providers.
AI systems may be provided as cloud services by external providers or operated on infrastructure controlled by us or that we own.
Depending on the provider, service, product variant, contractual relationship, account type, and selected settings, data transmitted to an AI service may also be used by the respective provider to improve, further develop, or train its services, systems and AI models.
We may also use product or service variants where such use of the transmitted data by the provider is intended or permissible, insofar as this is lawful under the applicable data protection law.
When using AI services, personal data may also be processed outside Switzerland, in particular in countries in which the respective providers or their subcontractors are active.
The respective contractual terms and privacy policies of the providers concerned apply in addition to processing carried out by them.
We take care to use personal data for AI services only to the extent necessary or expedient for the respective purpose of use.
12. Extensions and Security Services for the Website
We use, or may use, extensions and services for our website in order to provide additional functions and to ensure security, availability, and protection against misuse.
We use in particular:
- hCaptcha: service for detecting or preventing automated access, bots, and spam; provider: Intuition Machines Inc., USA.
When using such services, technical data such as IP address, device and browser information, as well as information on the use of our website, may be transmitted to the respective provider.
Insofar as legally required, we take appropriate measures for the disclosure of personal data abroad.
13. Final Provisions
We may amend and supplement this Privacy Policy at any time.
The version published on our website at the relevant time shall generally be authoritative.
We shall inform you of material changes in an appropriate manner, insofar as this is required by the circumstances or applicable law.
Last updated: September 2026