Privacy Policy

 Last updated: 22 December 2025

  1. Responsible Entity

Responsible for data processing (Controller):

Nicolas Schwarz
Operating under the name NeverBanked
Heidenmösliweg 7
8713 Uerikon
Switzerland

Email: [email protected]
Phone: +41 79 128 90 10

(Hereafter referred to as “NeverBanked”, “we”, or “us”)

  1. Scope and Consent

This Privacy Policy explains the nature, scope, and purpose of how we collect and use your personal data when you visit our website (www.neverbanked.com / www.neverbanked.ch) and use our services (e.g., accessing free resources, purchasing online courses, participating in coaching programs).

By using our website and services, you acknowledge the data processing practices described herein, in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

  1. Categories of Personal Data Processed

We process the following categories of personal data:

  •  Master & Contact Data:Name, address, email, phone number.
  •  Contract & Payment Data:Information related to your purchases, subscriptions, and payment details (processed securely by third-party providers; we do not store full payment card data).
  •  Application & Content Data:For coaching programs, this includes CVs, cover letters, LinkedIn profiles, questionnaires, survey responses, other documents you upload, as well as recordings of coaching or consultation calls where such recording is agreed in advance.
  •  Communication Data:Correspondence via email, messages, notes from calls, and written feedback or statements provided during the coaching relationship.
  •  Technical & Usage Data:IP address, browser type/version, operating system, device information, referrer URL, time of access, pages visited, and interaction data. This includes data collected via cookies, log files, and similar technologies such as tracking pixels (e.g. Meta Pixel, LinkedIn Insight Tag), where implemented.
  1. Purposes of Processing & Legal Bases

We process your data for the following purposes and on the corresponding legal bases:

  •  Contract Fulfillment:Providing and administering purchased courses and coaching services, processing payments, and communicating with you about the service.
    Legal basis: Performance of a contract (Art. 31(2) FADP / Art. 6(1)(b) GDPR)
  •  Legitimate Interests:Operating, securing, and improving our website and services; direct marketing of our own similar products/services; preventing misuse.
    Legal basis: Legitimate interest (Art. 31(1) FADP / Art. 6(1)(f) GDPR)
  •  Legal Compliance:Fulfilling our accounting, tax, and other legal obligations under Swiss law.
    Legal basis: Compliance with a legal obligation (Art. 6(1)(c) GDPR)
  •  Consent:For specific, optional purposes where we have asked for and you have given explicit consent (e.g., certain newsletters).
    Legal basis: Your consent (Art. 30 FADP / Art. 6(1)(a) GDPR)
  1. Log Files, Hosting & Cookies

Hosting & Log Files

Our website and services are hosted on the Kajabi platform. When you access our site, Kajabi automatically collects and stores technical data in server log files (as detailed in Section 3). This data is essential for technical operation, security, and error analysis. IP addresses are anonymized or deleted after a short period.

Cookies & Tracking Technologies

We use necessary cookies to ensure the basic functionality of the website (e.g., maintaining your login session). We may also use analytics and marketing technologies, such as cookies and tracking pixels (e.g. Meta Pixel, LinkedIn Insight Tag), to measure the effectiveness of our marketing campaigns, analyse user interactions, and improve our services.

Where required by applicable law, such technologies are only used based on your consent. You can manage cookie and tracking settings via your browser or any consent tools implemented on the website. Restricting cookies or tracking technologies may limit website functionality.

  1. Data Disclosure to Third Parties

We engage specialised third-party service providers to operate our business. They are categorized and obligated as follows:

  •  Processors:Service providers who process personal data only on our documented instructions and are contractually obligated to comply with data protection law. (e.g., Kajabi for hosting, Bexio for accounting).
  •  Independent Controllers:Service providers who determine the purpose and means of their processing independently. Their processing is governed by their own privacy policies. (e.g., Payment providers like Stripe, advertising platforms like Meta).

Users are encouraged to review the privacy policies of Independent Controllers.

Key processors and third-party services include:

  •  Kajabi LLC:Our primary platform (hosting, courses, CRM). Data may be transferred to and processed in the United States. Kajabi relies on recognised safeguards, including standard contractual clauses.
  •  HubSpot, Inc.:Customer relationship management (CRM), marketing automation, and communication tracking. Data may be transferred to and processed in the United States based on recognised safeguards.
  •  Payment Providers (e.g., Stripe, TWINT):For secure payment processing. These providers act as independent controllers for payment-related data. Please refer to their respective privacy policies.
  •  Analytics & Advertising Providers(e.g., Meta Platforms, LinkedIn): We may use advertising and analytics tools such as tracking pixels or insight tags to measure campaign performance, conversion events, and audience interactions. These providers process data as independent controllers under their own privacy policies.
  •  Accounting & Administration Providers (e.g., Bexio AG):Accounting, invoicing, and statutory record-keeping. Data is processed in Switzerland or the European Economic Area.
  •  Communication & Automation Tools(e.g., email marketing platforms, messaging tools, document signing services, workflow automation tools): For transactional and service-related communications, customer engagement, document execution, and automated process integration.

Personal data is disclosed to other third parties (e.g., authorities) only where required by Swiss law or necessary to protect our rights.

  1. International Data Transfers

As indicated above, data may be transferred to countries outside Switzerland and the European Economic Area (EEA), notably to the USA. We ensure such transfers are protected by appropriate safeguards, such as the standard contractual clauses approved by the Swiss Federal Council and the European Commission.

  1. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, absolute security on the internet cannot be guaranteed.

  1. Data Retention

We retain personal data only as long as necessary for the fulfillment of the purposes outlined in Section 4 or as required by law (e.g., Swiss accounting law requires retention of business records for 10 years).

  •  Course & Coaching Data:Retained for up to 24 months after the end of the contractual relationship for service continuity and support, unless longer retention is required for legal reasons.
  •  Marketing Data:Retained as long as you are an active customer or have not withdrawn your consent or objected to marketing.
  1. Your Rights

You have the following rights regarding your personal data:

  •  Right of Access
  •  Right to Rectification
  •  Right to Erasure ("Right to be Forgotten"), subject to legal limitations
  •  Right to Restriction of Processing
  •  Right to Data Portability
  •  Right to Object to processing based on our legitimate interests
  •  Right to Withdraw Consent at any time with future effect

Please note that these rights are subject to conditions, exceptions, or restrictions (e.g., to protect third parties or trade secrets).

To exercise these rights, contact us at [email protected]. We may require proof of identity.

You also have the right to lodge a complaint with the competent supervisory authority, the Swiss Federal Data Protection and Information Commissioner (FDPIC).

  1. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy at any time. The latest version will always be published on this page, with the "Last updated" date revised accordingly.

We will notify you of material changes that affect your rights or our core processing activities (e.g., a change of controller, a new purpose of processing) through appropriate means, such as a prominent notice on our website or direct communication. For other updates, your continued use of our services after the publication of the revised policy constitutes acceptance of the changes.