Privacy Policy

Last updated: October 15th, 2025

1. Introduction

Wolky SA ("Wolky", "we", "our") is committed to protecting your privacy and treating with the utmost respect the sensitive information related to memorial services. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use our Wolky.ch platform (the "Service") dedicated to death notices, tributes, and memorial services in Switzerland.

It is designed to comply with the Swiss Federal Data Protection Act (FADP), the General Data Protection Regulation (GDPR), and other applicable laws. By using Wolky.ch, you agree to the collection and use of information in accordance with this Privacy Policy.

Given the sensitive nature of memorial services, we pay particular attention to protecting data relating to the deceased and bereaved families.

2. Data Controller and Contact Information

The data controller responsible for your personal data is Wolky SA, c/o Alessandro Soldati, Strada Regina 41, 6991 Neggio, Switzerland.

If you have questions or requests concerning your personal data, you can contact us:

  • At this postal address

  • Via our contact page at https://www.wolky.ch/en/contact

  • For privacy-specific requests, please include "Privacy Request" in your message

3. Personal Data We Collect

We only collect personal data necessary for providing our memorial services and operating our platform. Given the sensitive nature of these services, we treat all information with particular care.

3.1 User Account Information

Personal accounts: When creating an account, we collect your name, first name, and email address. If you create an account on behalf of a family to manage a death notice, we may collect additional information about your relationship to the deceased.

Professional accounts: If you represent a funeral home, newspaper, or association, we collect your organisation's name, business details (company address, identification number, VAT number), and your professional contact information.

3.2 Memorial Data and Death Notices

Information about the deceased: For publishing death notices, we collect biographical information such as name, first names, maiden name, birth and death dates, place of residence, funeral ceremony information.

Memorial content: Photos of the deceased, tribute texts, condolence messages, shared memories, testimonials, and any other information you choose to publish to honour the memory of the deceased.

Family information: When necessary to establish the legitimacy of a publication, we may collect information about family relationships and persons authorised to manage the death notice.

3.3 Interaction and Community Data

Condolences and testimonials: Name, first name, email address, and content of condolence messages you publish.

Memorial donations: Information necessary for processing donations (donor name, amount, beneficiary association) in accordance with legal requirements.

Notification preferences: Alerts for new death notices in certain regions, memorial anniversary notifications, update subscriptions.

3.4 Profile and Usage Data

Information you provide in your user profile and preferences. We also collect data about your use of the Service, such as notices viewed, condolences posted, time spent on certain pages, and frequency of visits.

3.5 Payment Information

If you use our paid services (notice publication, premium condolences, donations), payment details are collected via our secure processor Stripe. Wolky does not store your complete payment card details; we only retain transaction records (last four digits, dates, and amounts) for billing history.

3.6 Technical Data

When you use Wolky.ch, our systems automatically collect certain technical data: IP address, browser type, device information, operating system, cookie identifiers. We also record information about how you arrived at our site and how you interact with our Service.

3.7 Communications

If you contact us (support, special requests, complaints) or subscribe to our newsletter, we collect the information you provide and maintain records of our correspondence.

Important: We do not intentionally collect sensitive medical data. Information about causes of death is only collected if voluntarily provided and necessary for publication.

4. How We Collect Your Data

4.1 Directly from You

Most information is provided directly during registration, creating death notices, posting condolences, requesting newspaper publications, or contacting support.

4.2 Through Your Use of the Service

We automatically collect technical and usage data via cookies, server logs, and similar technologies during your browsing and use of features.

4.3 Public Sources and Partners

We may receive death notice information from public sources (civil registries, partner newspapers), partner funeral homes, or other legitimate sources to keep our database updated.

4.4 Third-Party Services

Our payment processor, authentication and analytics providers collect certain data and transmit the information necessary for service provision.

5. Purpose and Legal Basis for Personal Data Processing

We process your personal data only for specific and legitimate purposes, with particular attention to the sensitivity of memorial information.

5.1 Provision of Memorial Services

Legal basis: Contract performance

  • Creating and maintaining user accounts

  • Publishing and managing death notices

  • Processing condolences and testimonials

  • Managing the digital memorial garden

  • Coordinating with partner newspapers and funeral homes

5.2 Payment and Donation Processing

Legal basis: Contract performance

  • Processing notice publication fees

  • Managing memorial donations

  • Billing premium services

  • Payments to partners (newspapers, associations)

5.3 Communications and Support

Legal basis: Legitimate interest and consent

  • Transactional communications (confirmations, notifications)

  • Technical support and assistance to bereaved families

  • Newsletters and service information (with consent)

  • Emergency communications related to published notices

5.4 Memorial Preservation and Archiving

Legal basis: Legitimate interest and public interest

  • Long-term preservation of death notices for collective memory

  • Digital archiving of memorial content

  • Preservation of testimonials and tributes

  • Maintaining historical data integrity

5.5 Service Improvements

Legal basis: Legitimate interest

  • Usage analysis to improve user experience

  • Development of new memorial features

  • Optimisation of notice search and navigation

  • Improving accessibility for bereaved families

5.6 Security and Abuse Prevention

Legal basis: Legitimate interest and legal obligation

  • Protection against fraudulent or inappropriate publications

  • Prevention of abusive use of memorial services

  • Maintaining platform security and dignity

  • Respecting the memory of the deceased

5.7 Legal Compliance

Legal basis: Legal obligation

  • Retaining transaction records

  • Responding to legal requests from authorities

  • Meeting accounting and tax obligations

  • Compliance with donation regulations

6. Disclosure of Personal Data to Third Parties

We treat your data with the utmost care, particularly given their sensitive nature. We never sell personal data relating to memorial services. We share certain data with trusted providers who help us deliver our services.

6.1 Payment Services - Stripe

Stripe processes payments for notice publications, premium condolences, and donations. Your payment details are transmitted directly to Stripe. We only receive payment confirmation and basic details for record-keeping.

6.2 Authentication - Clerk

Our platform uses Clerk for secure user account management. Clerk manages your email address, encrypted password, and authentication tokens for secure logins.

6.3 Web Analytics - Google Analytics

We use Google Analytics with IP anonymisation to understand site usage and improve user experience. Data is processed in a privacy-respectful manner.

6.4 Platform Analytics - Vercel Analytics

Our host Vercel provides analytics on performance and usage to help us maintain quality service for bereaved families.

6.5 Testing and Improvements - PostHog

We use PostHog to test and improve features, with pseudonymous identifiers to analyse usage without compromising privacy.

6.6 Email Communications - Brevo

Brevo manages sending verification emails, important notifications, and newsletters. Only your email address and name are shared according to your preferences.

6.7 Hosting and Storage - AWS

All our application data, including death notices and memorial content, are stored on secure AWS servers located in the European Union, with encryption and appropriate protection measures.

6.8 Publication Partners

For publication in partner newspapers, we transmit only information necessary for publishing the death notice according to your instructions.

6.9 Charitable Associations

For memorial donations, we transmit to beneficiary associations the information necessary according to applicable regulations and your privacy preferences.

Legal Requirements: We may disclose data if required by law or in response to legitimate requests from authorities.

Business Transfers: In case of merger or acquisition, data may be transferred subject to equivalent protections.

7. Data Storage, International Transfers, and Security

7.1 Storage Location

Your data is primarily stored in secure AWS data centres within the European Union. This location ensures protection according to standards compliant with Swiss and European law.

7.2 International Transfers

Some providers (Google Analytics, Stripe, Clerk) may process data in the United States or other jurisdictions. We take measures to ensure their protection:

  • Use of approved Standard Contractual Clauses

  • Encryption in transit and at rest

  • Additional security measures according to risks

7.3 Data Security

Given the sensitivity of memorial information, we implement enhanced measures:

Encryption:

  • HTTPS/TLS for all communications

  • Encryption of sensitive data at rest

  • Cryptographic protection of passwords

Access Controls:

  • Access restricted to authorised personnel only

  • Multi-factor authentication for administrative access

  • Data separation according to sensitivity levels

Monitoring and Backup:

  • Continuous monitoring of access and activities

  • Regular backups with loss protection

  • Alert systems for security anomalies

Staff Training: Our team is trained in best practices for protecting sensitive data and the specificities of memorial services.

In case of data breach, we will follow legal procedures to notify authorities and affected persons within required timeframes.

8. Cookies and Tracking Technologies

8.1 Types of Cookies Used

Essential Cookies: Necessary for proper site functioning, particularly to maintain your login session when viewing death notices or managing your account.

Preference Cookies: Remembering your preferences (region of interest for notices, display settings, notification preferences).

Analytics Cookies: Google Analytics, Vercel Analytics, and PostHog to understand site usage and improve experience for families and visitors. These cookies collect aggregated and anonymised information.

Communication Cookies: If you subscribe to newsletters, cookies may measure communication effectiveness (email opens, link clicks).

8.2 Third-Party Cookies

  • Google Analytics: ga, gid cookies for usage analysis (with IP anonymisation)

  • Clerk: Session cookies for secure authentication

  • Vercel Analytics: Performance cookies for site optimisation

  • Brevo: Tracking pixels in emails (only with subscription)

8.3 Cookie Management

During your first visit, you can configure your cookie preferences. You can modify them at any time via your browser settings. Note that disabling certain cookies may affect access to basic functionality.

For Google Analytics, you can install the specific opt-out browser add-on.

9. Data Retention

Given the memorial nature of our services, our retention periods reflect the importance of preserving memory whilst respecting your rights.

9.1 Account Data

Retained whilst your account remains active. After closure, deletion or anonymisation within reasonable time, except legal retention obligations.

9.2 Death Notices and Memorial Content

Permanent preservation: Published death notices and associated memorial content are generally retained permanently to preserve collective memory and historical interest.

Family control: Families may request modification or deletion of notices via our contact form, with legitimacy verification.

Respectful archiving: Content may be archived in a way that preserves memory whilst respecting privacy of relatives.

9.3 Condolences and Testimonials

Retained with the associated death notice to maintain integrity of tributes paid. Possibility of deletion upon legitimate request.

9.4 Payment and Donation Records

Retained according to Swiss legal obligations (typically 10 years) for financial transactions and donations to associations.

9.5 Analytics Data and Communications

  • Aggregated analytics data: long-term retention (anonymised)

  • Support communications: several years to ensure service continuity

  • Technical logs: several weeks to months according to security needs

After retention periods expire, secure deletion or anonymisation of personal data.

10. Your Rights as Data Subject

Under Swiss and European law, you have specific rights concerning your personal data, with particular considerations for memorial data.

10.1 Right of Access

You may request a copy of data we hold about you, including information about processing purposes and recipients.

10.2 Right to Rectification

Correction of incorrect or incomplete data. You can update most of your information via your Wolky account.

10.3 Right to Erasure

Request deletion of your personal data, subject to our legal obligations and legitimate interest in memorial preservation. For death notices, requests are evaluated case by case.

10.4 Right to Data Portability

Retrieval of your data in structured format for transfer to another service, when technically possible.

10.5 Right to Object

Opposition to processing based on legitimate interest, particularly for direct marketing. We will examine each request individually.

10.6 Right to Withdraw Consent

If processing is based on your consent (newsletters, optional cookies), you may withdraw it at any time.

10.7 Posthumous and Family Rights

Important: For data relating to deceased persons, close family members or legal representatives may exercise certain rights concerning published information.

10.8 Right to Lodge a Complaint

You may lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland (https://www.edoeb.admin.ch). We encourage you to contact us first to resolve your concerns.

10.9 Exercising Your Rights

Contact us via https://www.wolky.ch/en/contact or the postal address in Section 2. For certain requests, we may verify your identity. We respond within legal timeframes, generally without charge except for manifestly unfounded requests.

11. Privacy Policy Updates

We may update this Policy to reflect changes in our practices or legal requirements. Important changes will be notified by email or visible notice on the site.

The "Last updated" date indicates the latest modifications. We encourage you to regularly review this Policy.

For significant changes affecting your data, we will obtain new consent if necessary. Continued use of the service after update means acceptance of revised terms (to the extent permitted by law).

12. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data:

Wolky SA, c/o Alessandro Soldati, Strada Regina 41, 6991 Neggio, Switzerland

Contact form: https://www.wolky.ch/en/contact

We are here to help and will handle all your questions with the respect and sensitivity appropriate to memorial services.


This policy reflects our commitment to protecting your privacy whilst preserving the memory of your loved ones with dignity. For any specific questions, our team is at your disposal.

    ObituariesPublishMemoriesAccount