Privacy policy

Last updated: 5 October 2026

1. Data controller

acaem-change.com is published by Grégoire Willommet, GWRC Advisory (sole proprietorship), Cheseaux-sur-Lausanne, Switzerland.

For any question about your data, write to info@acaem-change.com.

We process your data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).

2. Data we process and why

Visiting the site

When you visit the site, our hosting provider records technical data: IP address, date and time, pages viewed, browser type. This data is used only to run and secure the site. We use no audience measurement or advertising tools.

Contact form

When you write to us, we receive your name, your email address and your message. We use this data to answer your request and follow up on our exchanges. It is sent to us by email and stored in the site's database.

SuccessScoreCard©

To access the SuccessScoreCard©, you provide your name, your email address, your organisation and, if you wish, your phone number. At the end of the assessment, this information is emailed to us together with your answers and your score. We use it to contact you about your results and, where relevant, about our support. The PDF report is generated directly in your browser.

Spam protection

The contact form is protected by Google reCAPTCHA v3. This service analyses browsing signals to tell a human visitor from a bot, and sends technical data to Google, including your IP address. The SuccessScoreCard© form is protected by an in-house mechanism, with no third-party service.

3. Legal bases

Where the GDPR applies, this processing is based on:

• your request, to answer your messages and give you access to the SuccessScoreCard© (Art. 6(1)(b) GDPR);
• our legitimate interest in contacting you about your results, and in securing the site and protecting it against spam (Art. 6(1)(f) GDPR).

4. Service providers and recipients

We do not sell or rent your data. We use the following service providers:

• Infomaniak Network SA, Switzerland: website hosting, database and email delivery. Data is stored in Switzerland.
• Google (Google Ireland Limited and Google LLC, United States): reCAPTCHA, spam protection for the contact form.
• Web3Forms, operated by Web3Creative, India: email delivery of SuccessScoreCard© data. Web3Forms relies in particular on Amazon Web Services, Cloudflare and Hetzner, and keeps submissions for up to three years.
• Cloudflare, United States (cdnjs service): delivery of two technical libraries used by the SuccessScoreCard© (charts and PDF generation). Your IP address is sent to Cloudflare when they load.

5. Transfers abroad

Some of these providers process data outside Switzerland. These transfers rely on an adequacy decision of the Swiss Federal Council, in particular the Swiss-US Data Privacy Framework for certified US companies, or on standard contractual clauses.

6. Retention

Messages and SuccessScoreCard© data are kept for as long as needed to handle your request and follow up on our exchanges, then deleted, subject to legal retention obligations. The hosting provider's technical data is kept for a limited period.

7. Cookies

This site uses no audience measurement, advertising or social media cookies. This is why no consent banner is displayed.

Only technical cookies and storage, needed to run and secure the site, may be used:

• reCAPTCHA (Google) may set a technical cookie for spam protection;
• the site uses your browser's session storage for display purposes. This data is cleared when you close the tab.

You can block or delete cookies in your browser settings. The contact form may then stop working.

8. Your rights

You can at any time request access to your data, its correction or deletion, object to its processing or request its portability. Write to us at info@acaem-change.com. We may ask you to confirm your identity.

You can also contact the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, if you live in the European Union, the data protection authority of your country.

9. Changes

We may update this policy. The version in force is the one published on this page, with its update date.