Privacy policy
Last updated: 15.06.2026
1) Introduction and contact details of the controller
1.1 We are pleased that you are visiting Top-zusatzversicherung.ch and are interested in our service. Below, we explain transparently how we handle your personal data when you use our website or submit an enquiry about insurance products through us.
Personal data means any information relating to an identified or identifiable natural person (e.g. name, address, email address, telephone number, date of birth, details of your current insurance situation).
1.2 The controller responsible for data processing on this website within the meaning of the Swiss Federal Act on Data Protection (FADP/DSG) is:
Blegistrasse 15
6340 Baar
Switzerland
Email: [email protected]
Telephone: on request
Managing Director: Nicola Hegg
Top-zusatzversicherung.ch is a service of solvana AG.
Where the EU General Data Protection Regulation (GDPR) additionally applies to individual processing operations – for instance because we also address persons in the EU – we additionally comply with its requirements.
2) Business model and note on data sharing
2.1 What we are – and what we are not
Top-zusatzversicherung.ch is not an insurance company, not an insurance broker and not an insurance intermediary within the meaning of the Insurance Supervision Act (ISA/VAG). We do not provide insurance advice of our own and do not conclude any insurance contracts with you.
Our business model is the referral of contact requests (known as "leads") to our vetted cooperation partners. In concrete terms, this means: when you submit an enquiry via Top-zusatzversicherung.ch, we forward your data to one or more of our partner companies – these are generally registered insurance intermediaries or insurance companies directly supervised by FINMA. These partners will then contact you and advise you individually on your enquiry.
2.2 Commercial interest / remuneration
We wish to inform you transparently that we receive remuneration from our cooperation partners for referring your enquiry. For you as a user, an enquiry via Top-zusatzversicherung.ch is free of charge and non-binding.
2.3 Categories of recipients of your data
We pass your data on exclusively to the following categories of recipients:
- Registered insurance intermediaries (entered in FINMA's register of intermediaries pursuant to the Insurance Supervision Act (VAG))
- Insurance companies supervised by FINMA
- Technical service providers acting as processors on our behalf (hosting, CRM, email dispatch)
An up-to-date list of our cooperation partners can be found at: https://top-zusatzversicherung.ch/en/partner
3) Data collection when you visit our website (server log files)
When you use our website purely for information purposes, i.e. if you do not register or otherwise submit information to us, we only collect the data that your browser transmits to our server (known as "server log files"):
- Website / URL accessed
- Date and time of access
- Amount of data transferred in bytes
- Source / referrer
- Browser and operating system used
- IP address (truncated / anonymised where technically possible)
Basis for processing: our overriding legitimate interest (Art. 31 para. 1 FADP) in ensuring the stability, functionality and security of our website.
This data is not passed on or used in any other way. However, we reserve the right to review the server log files retrospectively should there be concrete indications of unlawful use.
SSL/TLS encryption: For security reasons and to protect the transmission of personal data (e.g. enquiries submitted via our form), this website uses SSL or TLS encryption. You can recognise an encrypted connection by "https://" and the padlock symbol in your browser's address bar.
4) Hosting
We use the services of the following provider to host our website:
Industriestr. 25
91710 Gunzenhausen
Germany
All data collected on our website is processed on servers in Germany (EU/EEA). The EU/EEA states provide an adequate level of data protection recognised by the Swiss Federal Council (Art. 16 para. 1 FADP in conjunction with Annex 1 of the Data Protection Ordinance), so disclosure abroad in the context of hosting is permitted.
We have concluded a data processing agreement with Hetzner in accordance with Art. 9 FADP, which ensures the protection of your data and prohibits unauthorised disclosure to third parties.
Basis for processing: our overriding legitimate interest (Art. 31 para. 1 FADP) in the secure and efficient provision of our online services.
5) Cookies and similar technologies
To make using our website attractive and to enable certain functions, we use cookies – small text files that are stored on your device.
- Session cookies: deleted automatically when you close your browser.
- Persistent cookies: remain stored for longer and make it possible, for example, to save your settings.
Bases for processing:
- Technically necessary cookies: our overriding legitimate interest (Art. 31 para. 1 FADP) and Art. 45c lit. b of the Telecommunications Act (FMG).
- All other cookies (marketing, analytics, convenience): your consent (Art. 6 para. 6 FADP).
We obtain your express consent via our cookie consent banner. You can withdraw your consent at any time via the cookie settings on our website.
6) Contacting us and referral of your enquiry
6.1 What data we collect
Via our enquiry forms, we collect the data required to forward your enquiry appropriately to our cooperation partners, in particular:
- Title, first name and surname
- Date of birth
- Address (street, postcode, town/city)
- Email address and telephone number
- Details of your current insurance situation and the insurance cover you are looking for
- Occupation and, where applicable, income details (insofar as relevant to the insurance enquiry)
- For health insurance, where applicable, information about your state of health (sensitive personal data pursuant to Art. 5 lit. c FADP)
6.2 Purposes and bases of processing
We process your data for the following purposes:
a) Handling your enquiry and referring it to our cooperation partners → basis: processing directly connected with your enquiry (Art. 31 para. 2 lit. a FADP)
b) Forwarding your data to our cooperation partners → basis: your express consent (Art. 6 para. 6 FADP), which you give before submitting the form
c) Processing of sensitive personal data (health data) – only insofar as required for your enquiry (e.g. supplementary health or supplementary dental insurance) → basis: your express consent (Art. 6 para. 7 lit. a FADP)
d) Quality assurance and documentation → basis: our overriding legitimate interest (Art. 31 para. 1 FADP) in verifiability and compliance
6.3 Withdrawal of consent
You may withdraw any consent you have given at any time with effect for the future. An informal message to [email protected] is sufficient. Withdrawal does not affect the lawfulness of the processing carried out up to the point of withdrawal.
Important: Once we have already forwarded your data to a cooperation partner, that partner becomes an independent controller within the meaning of the FADP. The partner's own privacy notices apply to data processing by the partner from the time of transmission. You must therefore assert any withdrawal against the partner directly with that partner. On request, we will be happy to forward your withdrawal to the partners concerned.
6.4 Retention period
Your enquiry data will be deleted as soon as your enquiry has been fully dealt with and no statutory retention obligations (e.g. the ten-year retention obligation for business records under Art. 958f of the Swiss Code of Obligations (OR)) prevent deletion. As a rule, we delete enquiry data from our operational systems no later than 90 days after final processing.
7) Newsletter and direct marketing
7.1 Newsletter sign-up (double opt-in)
When you sign up for our newsletter, we use the double opt-in procedure: after you enter your email address, we send you a confirmation email. You will only receive our newsletter once you have clicked the confirmation link.
Basis for processing: your consent (Art. 6 para. 6 FADP; Art. 3 para. 1 lit. o of the Unfair Competition Act (UWG)).
When you sign up, we store your IP address and the date and time of sign-up and confirmation in order to be able to prove consent.
You can unsubscribe from the newsletter at any time via the unsubscribe link in the newsletter or by emailing [email protected].
7.2 Newsletter dispatch service provider: ActiveCampaign
Our email newsletters are sent via the service of the following provider:
1 N Dearborn St., 5th Floor
Chicago, IL 60602
USA
On the basis of your consent (Art. 6 para. 6 FADP), we share the data you provide when signing up for the newsletter with this provider so that it can send the newsletter on our behalf.
The provider also carries out statistical performance analysis of newsletter campaigns using web beacons or tracking pixels in the emails sent, which can measure open rates and specific interactions with the newsletter content. Device information (e.g. time of access, IP address, browser type and operating system) is also collected and analysed in the process, but is not combined with other data sets.
You can withdraw your consent to newsletter tracking at any time with effect for the future.
We have concluded a data processing agreement with ActiveCampaign in accordance with Art. 9 FADP, which ensures the protection of your data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider has joined the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), which the Swiss Federal Council recognises as providing adequate data protection. In addition, we base the transfer on standard contractual clauses.
8) Web analytics and tracking
8.1 Google Analytics 4
This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.
Basis for processing: your consent (Art. 6 para. 6 FADP).
Cookies are only set if you have actively given your consent in the cookie banner. Your IP address is truncated before storage. Retention period of the collected data: a maximum of 14 months. A data processing agreement is in place. Data transfers to the USA take place on the basis of the Swiss-U.S. Data Privacy Framework.
You can withdraw your consent at any time via the cookie consent tool.
8.2 Google Tag Manager
We use Google Tag Manager to manage our tracking tags. The Tag Manager itself does not store any cookies and does not carry out any analyses of its own. However, your IP address is transmitted to Google when a page is accessed.
Basis for processing: your consent (Art. 6 para. 6 FADP) via the cookie banner.
8.3 Meta Pixel (Facebook / Instagram)
We use the Meta Pixel of Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, for conversion tracking and custom audiences.
Basis for processing: your consent (Art. 6 para. 6 FADP).
Note on joint controllership: Meta and we are joint controllers for the collection of your data via the Meta Pixel. The joint controllership agreement can be found here: https://www.facebook.com/legal/controller_addendum
8.4 Google Ads conversion tracking
We use Google Ads conversion tracking to measure the effectiveness of our advertisements.
Basis for processing: your consent (Art. 6 para. 6 FADP).
9) Rights of data subjects
You have the following rights vis-à-vis us with regard to personal data concerning you:
- Right of access (Art. 25 FADP)
- Right to rectification (Art. 32 para. 1 FADP)
- Right to erasure or destruction (Art. 32 para. 2 FADP)
- Right to the release and transfer of data (data portability, Art. 28 FADP)
- Right to object to data processing (Art. 30 para. 2 lit. b FADP)
- Right to withdraw consent given (Art. 6 para. 6 FADP)
- Right to lodge a report with the FDPIC (Art. 49 FADP)
To exercise your rights, an informal message to the following address is sufficient: [email protected]
Right to object
Where we process personal data on the basis of our overriding legitimate interest (Art. 31 para. 1 FADP), you have the right to object to this processing at any time on grounds relating to your particular situation.
Where your personal data is processed for direct marketing purposes, you have the right to object at any time. Once you have objected, your data will no longer be processed for marketing purposes.
Report to the FDPIC
You have the right to lodge a report with the Federal Data Protection and Information Commissioner (FDPIC). The competent authority is:
Feldeggweg 1
3003 Bern
Switzerland
Web: www.edoeb.admin.ch
10) How long personal data is stored
The retention period depends on the respective purpose of the processing and its respective basis:
- Where based on consent (Art. 6 para. 6 FADP): until withdrawn
- Where based on contract performance: until fully performed, thereafter within the scope of statutory retention periods (e.g. 10 years under Art. 958f of the Swiss Code of Obligations (OR))
- Where based on an overriding legitimate interest (Art. 31 para. 1 FADP): until you object or the legitimate interest ceases to exist
- Server log files: a maximum of 7 days, unless there are indications of misuse
- Enquiry data after processing: as a rule 90 days in operational systems, thereafter moved to a retention archive with restricted access
11) No automated individual decision-making / no profiling
We do not use automated individual decision-making within the meaning of Art. 21 FADP. Any automated pre-selection of possible cooperation partners based on your details (e.g. postcode, insurance requirements) serves solely to route your enquiry to the right recipient and has no legal effect on you or any similarly significant impact.
12) Security of your data
We use technical and organisational security measures to protect your personal data against accidental or deliberate manipulation, loss, destruction and access by unauthorised persons. Our security measures are continuously improved in line with technological developments.
Specifically, we use, among other things:
- SSL/TLS encryption of data transmission
- Hosting in Germany (Hetzner Online GmbH) – processing within the EU/EEA area with recognised adequate data protection
- Access restrictions to IT systems (password policies, two-factor authentication)
- Regular training of our staff
- Data processing agreements with all service providers
- Pseudonymisation and encryption where technically possible
13) Validity and amendment of this privacy policy
This privacy policy is currently valid and was last updated on 15.06.2026. It may become necessary to amend this privacy policy as our website and services develop further or due to changes in legal or regulatory requirements. The current version of the privacy policy can be accessed at any time on our website at https://top-zusatzversicherung.ch/en/datenschutz.