Privacy Policy Avatar@EPS
Status: December 2025
Company: EPS Software Engineering AG, CH-9500 Wil
Scope of application: Use of the Avatar service based on Microsoft Azure
1. RESPONSIBLE BODY
We are responsible for the processing of your personal data:
EPS Software Engineering AG Obere Bahnhofstrasse 19 CH-9500 Wil
info@eps.ch
+41 71 914 40 50
2. PURPOSE OF DATA PROCESSING
The Avatar Service processes personal data exclusively for the following purposes:
- Creating an avatar using the Flux model on Azure
- Provision of the avatar to the user
- Processing of address data exclusively for the purpose of carrying out a physical dispatch (if provided)
It is not used for marketing, profiling or other commercial purposes.
3. CATEGORIES OF DATA PROCESSED
Depending on use, the following data may be processed:
- Uploaded images for avatar creation
- Generated avatars
- Technical metadata (upload information, file formats)
- Usage data of the service
- Address data for dispatch purposes (name, address)
- Log data for technical security (e.g. IP address, time stamp)
4. PROCESSING AZURE DATA CENTRES (EU)
The Avatar service is operated in its own dedicated Azure tenant in the European Union.
- All personal data is processed and stored exclusively in EU data centres.
- Microsoft Azure acts as a processor in compliance with the EU standard contractual clauses and relevant data protection regulations.
5. LEGAL BASES
Processing is carried out in accordance with:
- Swiss Data Protection Act (revDSG)
- EU General Data Protection Regulation (GDPR), as the data is processed in the EU and the service uses EU infrastructure
Legal bases in particular:
- Art. 31 para. 2 lit. a revDSG: Consent
- Art. 6 para. 1 lit. b GDPR: Fulfilment of a contract
- Art. 6 para. 1 lit. a GDPR: Consent for the processing of uploaded images
6. DISCLOSURE DATA
Data is not sold or used for marketing purposes.
The data will be passed on exclusively:
- To Microsoft Azure as a processor
- To shipping service providers, exclusively for the purpose of processing a physical shipment
There is no transfer to third countries unless there are recognised guarantees (e.g. standard contractual clauses or equivalent agreements).
7. STORAGE PERIOD
- Uploaded images will be deleted after the avatar creation process has been completed, unless expressly agreed otherwise.
- Address data will be deleted or anonymised after the mailing has been completed.
- Log data is only stored to the extent technically necessary.
8. SAFETY
The service uses modern security measures:
- Transport encryption (TLS)
- Access restrictions and role separation
- Operation in an isolated Azure tenant
- Regular safety and compliance checks
9. DECLARATION OF CONSENT
By using the avatar service you confirm:
- That you have read and understood this privacy policy,
- That you have the necessary rights to the uploaded images,
- That you consent to the automated processing of the images for avatar creation,
- That your address data will be used exclusively for dispatch.
