Privacy Policy
Effective as of January 1, 2026
Article 1 – Purpose of this Policy
This Privacy Policy informs users of how Pugin Hybrid Nutrition Sàrl ("PHN") collects, processes, and protects personal data in accordance with Swiss data protection law (FADP) and the EU General Data Protection Regulation (GDPR).
Article 2 – Data Controller
The data controller is:
Pugin Hybrid Nutrition Sàrl
Route du Merley 16, 1233 Bernex, Geneva, Switzerland
Company registration number: CHE-246.578.888
Represented by its managing director: Sébastien Pugin
Contact: privacy@phnutrition.ch
Article 3 – Data Collected
PHN may collect the following categories of personal data:
- Identification data (first name, last name, date of birth, gender).
- Contact details (postal address, email, phone number).
- Account details (login, password).
- Transaction data (orders, invoices, payment information).
- Browsing data (cookies, IP address, device type, user preferences).
- Training and nutrition information provided voluntarily through PHN Coach.
Article 4 – Purpose of Processing
Personal data is processed for the following purposes:
- Processing and fulfilling product orders.
- Managing customer accounts and providing customer service.
- Communicating promotional offers and newsletters (with consent).
- Personalizing training and nutrition guidance through PHN Coach.
- Analyzing website performance and improving services.
- Complying with legal and regulatory obligations.
Article 5 – Legal Basis
Data processing is based on:
- The performance of a contract (order fulfillment).
- Legal obligations (accounting, tax).
- Legitimate interests of PHN (service improvement, fraud prevention).
- Consent of the user (marketing communications, cookies).
Article 6 – Data Retention
- Accounting and financial data: retained for 10 years (legal requirement).
- Customer account data: retained as long as the account is active.
- Marketing data: retained until consent is withdrawn.
- Browsing data: retained for 12–24 months.
Article 7 – Data Sharing
Personal data may be shared with:
- Payment service providers (for secure transactions).
- Delivery and logistics partners.
- IT and hosting service providers.
- Authorities when required by law.
PHN guarantees that all partners comply with data protection requirements.
Article 8 – International Transfers
If personal data is transferred outside Switzerland or the EU, PHN ensures that adequate safeguards are in place (e.g., standard contractual clauses, adequacy decisions).
Article 9 – User Rights
In accordance with applicable law, users have the right to:
- Access their personal data.
- Rectify inaccurate data.
- Request deletion of their data ("right to be forgotten").
- Restrict or object to processing.
- Request portability of their data.
To exercise these rights, users may contact privacy@phnutrition.ch. PHN undertakes to respond within 30 days.
Article 10 – Security Measures
PHN implements appropriate technical and organizational measures to ensure the security and confidentiality of personal data, including encryption, restricted access, and secure servers.
Article 11 – Cookies
The website uses cookies for essential functions, analytics, and marketing purposes. Details are available in PHN's Cookie Policy.
Article 12 – Amendments
PHN reserves the right to update this Privacy Policy at any time. The updated version will be published on the website with its effective date.
Article 13 – Governing Law and Jurisdiction
This Privacy Policy is governed by Swiss law. Any dispute shall fall under the exclusive jurisdiction of the courts of Geneva, Switzerland.