Privacy and Personal
Data Processing
1. Data controller
CEMO.ch SA / EasyLaser
Avenue des Toises 12, 1005 Lausanne, Switzerland
UID CHE-370.261.719
Tel. +41 21 510 31 31
Email: secretariat@cemo.ch
2. Data collected
EasyLaser collects personal data exclusively in the following circumstances:
- Booking request for a diagnostic examination (name, phone, email, chosen clinic)
- Performance of the diagnostic examination and surgery (medical data, corneal topography, pachymetry, aberrometry)
- Communications via email, phone or WhatsApp
- Website browsing (anonymous technical data: IP, browser, pages visited)
3. Purposes of processing
- Management of bookings and patient relationships
- Provision of medical and surgical services
- Sending administrative communications and medical follow-up
- Accounting, tax and insurance obligations
- Improvement of services offered (aggregated and anonymous data)
4. Legal basis
Data processing is based on the consent of the data subject (Art. 6 FADP), the performance of a medical service contract, and the legal obligations applicable in Switzerland.
5. Data retention
Medical data is retained for a minimum of 10 years from the date of the last service, in accordance with Swiss health legislation. Contact data for bookings is retained for the time strictly necessary to manage the relationship.
6. Data sharing
EasyLaser does not sell or transfer personal data to third parties for commercial purposes. Data may be shared exclusively with:
- Medical and paramedical staff directly involved in patient care
- IT service providers (hosting, management software) with adequate contractual guarantees
- Health or judicial authorities in case of legal obligation
7. Rights of the data subject
In accordance with the FADP, each patient has the right to:
- Access their personal data
- Request rectification of inaccurate data
- Request deletion (within the limits of medical retention obligations)
- Object to processing for marketing purposes
- Receive their data in a structured format (data portability)
To exercise these rights: +41 21 510 31 31 or secretariat@cemo.ch
8. Data collected during browsing
Simply browsing the website automatically collects the following technical data, necessary for the correct display of pages and site security (legal basis: Art. 6 para. 1 FADP — legitimate interest):
- IP address
- Date, time and time zone of the request
- Page visited (URL)
- Browser and operating system used
- Referring site (referrer)
This data is not associated with any identified person and is automatically deleted after 30 days.
9. Cookies and tracking technologies
The website uses cookies and similar technologies. Some are essential for operation, others require your consent. You can manage your preferences at any time via the "Cookie settings" link in the footer.
9.1 Essential cookies
Required for the website to function. They cannot be deactivated.
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
| cemo_consent | CEMO.ch SA | Saves privacy preferences | 1 year |
| Google Fonts | Google LLC | Loading of website typefaces | Session |
9.2 Statistical cookies (consent required)
Help us understand how visitors use the website by collecting anonymous data. If you decline this category, the website works normally but we cannot improve your experience based on browsing data.
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
| _ga / _ga_* | Google LLC | Google Analytics 4 — anonymised traffic statistics | 2 years |
| _gcl_au | Google LLC | Google Ads — advertising conversion measurement | 90 days |
| _fbp | Meta Platforms, Inc., USA | Meta Pixel — conversion measurement and remarketing Facebook/Instagram Ads | 90 days |
9.3 Cookies for external media and services (consent required)
Content from external services that enrich your experience: voice assistant, text chatbot, video. If you decline this category, the website works normally but the voice assistant and chatbot will not be available.
| Service | Provider | Purpose | Duration |
|---|---|---|---|
| ElevenLabs | ElevenLabs Inc., USA | Voice assistant for answering patient questions | Session |
| Claude AI | Anthropic PBC, USA | Text chatbot for answering patient questions | Session |
| YouTube | Google LLC, USA | Playback of testimonial videos | 2 years |
For services based in the USA, data may be transferred to the United States. Providers adhere to the EU-US Data Privacy Framework or offer equivalent contractual guarantees.
10. Online eligibility test
The eligibility test on the website collects the selected answers (condition, age, visual stability) to indicate a potentially suitable treatment. The test is anonymous, but your IP address is technically visible to our server. Test data is not stored unless you complete the final contact form. If you complete the form (name, phone, preferred clinic), the data is transmitted to our secretariat for follow-up.
11. Booking form
The diagnostic examination booking form transmits data (name, phone, email, preferred clinic) to our server via a secure connection. Data is archived in our management system to enable the secretariat to contact the patient. Legal basis: performance of pre-contractual measures at the request of the data subject (Art. 6 para. 1 let. b FADP).
12. Links to external websites and social networks
The website contains links to external platforms: Instagram, Facebook, YouTube, WhatsApp. By clicking on these links, the patient leaves our website and accesses platforms operated by third parties (Meta Platforms Inc., Google LLC, WhatsApp LLC) subject to their respective privacy policies. CEMO.ch SA is not responsible for the data processing carried out by these platforms.
13. Google Analytics
The website uses Google Analytics 4, a web analytics service provided by Google LLC. Google Analytics uses cookies ("Statistics" category) that are only activated with the user's consent. The IP address is anonymised (anonymize_ip: true). Google processes the data on our behalf to analyse website usage, compile activity reports and provide other services related to website usage. The user can revoke consent at any time via the "Cookie settings".
Google Privacy Policy: policies.google.com/privacy
14. Google Ads
The website uses Google Ads for advertising conversion measurement. This service is only activated with consent to the "Statistics" category. Google Ads cookies enable verification of whether a user reached the website via an advertisement and completed an action (e.g. booking request). No personally identifiable data is collected through these cookies.
15. YouTube video integration
The website may contain YouTube videos (Google LLC), embedded in enhanced data protection mode. In this mode, no data is transmitted to YouTube until the user starts playback. Videos are only loaded with consent to the "External Media" category.
By starting a video, YouTube receives information that the user has visited the corresponding page of our website, together with their IP address. If the user is logged into their Google account, YouTube may associate the visit with their profile. To prevent this association, the user must log out of Google before starting the video.
YouTube Privacy Policy: policies.google.com/privacy
16. Facebook and Instagram (Meta Pixel)
The site uses the Meta Pixel (Facebook Pixel) by Meta Platforms, Inc. for measurement of advertising conversions and remarketing through Facebook Ads and Instagram Ads campaigns. This service is activated only with explicit consent to the "External media and services" category.
The Meta Pixel allows us to verify whether a user reached the site via an ad on Meta networks, completed an action (e.g. appointment request), and to display personalised ads on Facebook and Instagram to visitors who have interacted with the site.
Data collected via the Pixel is transmitted to Meta Platforms, Inc. (USA) and may be used by Meta according to its own privacy policy: facebook.com/privacy/policy. The transfer is based on the standard contractual clauses approved by the European Commission and integrated into Meta's terms.
The site also contains links to our official pages on Facebook and Instagram. By clicking on these links, the user leaves our site and accesses platforms operated by Meta Platforms, Inc. CEMO.ch SA is not responsible for data processing carried out by Meta on its own platforms.
The user may revoke consent at any time via the site's cookie settings, with immediate effect for future processing.
17. Data security
CEMO.ch SA adopts adequate technical and organisational measures to protect personal data from unauthorised access, loss or disclosure. Medical data is stored on systems compliant with ISO 9001 and ISO 13485 standards. The website is hosted on Infomaniak servers (Switzerland) with SSL certificate.
18. Changes to this policy
CEMO.ch SA reserves the right to update this privacy policy. The current version is always available on this page with the date of last update.
19. Data protection contact
For any questions regarding the processing of personal data or to exercise the rights provided by the FADP:
CEMO.ch SA
Avenue des Toises 12, 1005 Lausanne, Switzerland
Tel. +41 21 510 31 31
Email: secretariat@cemo.ch
Subject: "Data protection"