Privacy Policy

Privacy Policy

Last updated: September 29, 2026

This Privacy Policy describes how SVD Commerce Sàrl (hereinafter “CaviarNoir,” “we”) collects, uses, shares, and protects the personal data of visitors and customers of the website www.caviarnoir.ch, its foreign-language versions (/de/, /en/), and our communication channels (email, phone, WhatsApp, social media).

It is established in accordance with the Federal Data Protection Act of September 25, 2020 (FDP), the Data Protection Ordinance (DPO), and, for individuals located in the European Economic Area (EEA), including the Principality of Liechtenstein, Regulation (EU) 2016/679 (GDPR).

1. Data Controller

SVD Commerce Sàrl
Rue de Carouge 28, 1205 Geneva, Switzerland
Company ID: CHE-320.565.318
Email: sales@caviarnoir.ch
Phone: +41 77 467 71 31

SVD Commerce Sàrl is not required to appoint a data protection advisor (Art. 10 of the Data Protection Act) or a data protection officer (Art. 37 of the GDPR). Any requests regarding personal data may be sent to the contact information provided above.

The processing of data relating to individuals located in the EEA is occasional and does not involve sensitive data on a large scale; therefore, we have not appointed a representative within the meaning of Article 27 of the GDPR.

2. Personal Data Processed

2.1 Information You Provide to Us

  • Identification: last name, first name, title, and company name (if applicable).
  • Contact Information: shipping and billing addresses, email address, phone number.
  • Order details: items ordered, amounts, discount code used, order history, delivery instructions.
  • Payment information: processed exclusively by our payment service providers (Section 5). CaviarNoir does not receive or store any card numbers.
  • Customer account information (if you create an account): login credentials, preferences, saved addresses.
  • Communications: the content of your emails, WhatsApp messages, calls, and social media messages.
  • Product reviews: rating, review text, first name and last initial, photos (if any) (Section 5, Judge.me).
  • Newsletter subscription: email address, first name, language, date, and source of the subscription.

2.2 Automatically Collected Data

  • Technical data: IP address, device identifiers, browser type and version, operating system, screen resolution, language.
  • Browsing data: pages viewed, duration and time of visit, referring website or ad, search keywords, UTM parameters.
  • Purchasing behavior data: products viewed, items added to the cart, orders started or abandoned, purchases made.
  • Email deliverability metrics: opens, clicks, unsubscribes, bounces.
  • Cookies and similar technologies: see Section 8.

2.3 Third-Party Data You Provide to Us

If you order a gift to be delivered to someone else, please provide us with that person's name, address, and, if applicable, phone number. You warrant that you are authorized to provide us with this information. We use it solely for delivery purposes.

We do not collect sensitive data as defined in Art. 5(c) of the Data Protection Act, and we ask that you refrain from providing us with any such data.

3. Purposes of Processing and Legal Bases

Under Swiss law, the processing of personal data is lawful when it complies with the principles set forth in Art. 6 of the Federal Act on Data Protection (FADP); a specific legal basis is not required. The legal bases listed below are provided under the GDPR for individuals located in the EEA.

  • Order fulfillment: processing, payment, preparation, delivery, billing, customer service, and handling of returns and complaints. Legal basis: performance of the contract (Art. 6(1)(b) of the GDPR).
  • Transactional communications: order confirmation, shipment tracking, post-purchase feedback requests. Legal basis: performance of the contract.
  • Customer Accounts: Creating and managing your account. Basis: Performance of the contract.
  • Newsletter and Promotional Offers :
    • to individuals who have registered using our forms (website, events, pop-ups), based on their consent (Art. 6(1)(a) of the GDPR);
    • to our customers, for products similar to those they have already purchased, in accordance with Art. 3, para. 1, subpar. o of the LCD, based on our legitimate interest (Art. 6, para. 1, subpar. f of the GDPR).
    Each email contains an unsubscribe link. You can also opt out at any time by email.
  • Personal communications: We may contact our customers individually (via email, phone, or WhatsApp) to inform them of new products, availability, or special offers. Legal basis: legitimate interest; you may opt out at any time.
  • Product Reviews: Collection and publication of reviews of our products. Legal basis: consent provided when submitting the review.
  • Audience measurement and website improvement: traffic statistics, purchase journey analysis, performance testing. Legal basis: legitimate interest; consent for non-essential cookies in the EEA.
  • Online advertising: serving and measuring ads on Facebook, Instagram, and the Google Network (Google Shopping), including to people who have previously visited our website (retargeting) and to profiles similar to our customers. Legal basis: legitimate interest; consent for non-essential cookies in the EEA.
  • Security and Fraud Prevention: Detection of fraudulent orders, website protection. Legal basis: legitimate interest.
  • Website translation: displaying the website in your language. Legal basis: legitimate interest.
  • Legal obligations: accounting and taxation (Art. 958f of the Swiss Code of Obligations), responding to requests from authorities, CITES traceability of products (excluding customers’ personal data). Legal basis: legal obligation (Art. 6(1)(c) of the GDPR).
  • Defending our rights: debt collection, dispute resolution. Legal basis: legitimate interest.

We do not make any automated individual decisions that produce legal effects with respect to you (Art. 21 of the Data Protection Act, Art. 22 of the GDPR). The anti-fraud analysis conducted by our payment service providers is always followed by a human review before any order is canceled.

4. Profiling

We use browsing and purchase data to tailor our communications and advertisements (segmentation by language, products viewed, purchase history). This profiling does not constitute high-risk profiling within the meaning of Art. 5(g) of the Data Protection Act. You may object to this (Section 9).

5. Recipients of the Data

We do not sell or rent your personal data. We share it only with the service providers listed below, who act on our instructions as data processors or, for certain services, as independent data controllers, strictly within the scope of the purposes set forth in Section 3.

5.1 E-commerce Platform and Payments

  • Shopify International Ltd, Dublin, Ireland, and Shopify Inc., Ottawa, Canada: store hosting and operation, customer accounts, order management, transactional emails, store statistics. Your data is hosted in the European Union; remote access from Canada and the United States is possible. Shopify also uses certain order data—securely and aggregated with data from other stores on its platform—for fraud detection, service improvement, and advertising optimization (“Shopify Network Intelligence”). No other merchants have access to your data.
  • Shopify Payments, operated by Stripe Payments Europe Ltd, Dublin, Ireland, and Stripe, Inc., United States: processing of card payments (Visa, Mastercard, American Express), Apple Pay, Google Pay, and Shop Pay. Shopify and Stripe are jointly responsible for fraud prevention and compliance with their regulatory obligations.
  • TWINT AG, Zurich, Switzerland: TWINT payments.
  • PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg: PayPal payments.
  • Klarna Bank AB, Stockholm, Sweden: Klarna payments. Klarna conducts its own credit assessment as an independent data controller, in accordance with its own privacy policy.
  • Apple Distribution International Ltd, Ireland, and Google Ireland Ltd, Ireland: Apple Pay and Google Pay wallets, subject to their respective terms and conditions.

5.2 Delivery

  • Swiss Post AG, Bern, Switzerland: Swiss-Express “La Lune” delivery in Switzerland and Liechtenstein. Information provided: name, address, phone number, and email address for delivery notification.
  • In-house courier or local courier for deliveries within the canton of Geneva.

5.3 Email Marketing and Reviews

  • Klaviyo, Inc., Boston, United States: management of newsletter subscriptions; sending newsletters, automated sequences (welcome, abandoned cart, post-purchase thank-you), and email communications; tracking of opens and clicks. Certified under the Swiss-U.S. Data Privacy Framework.
  • Judge.me Ltd, London, United Kingdom (data hosted in the United States by Amazon Web Services): sending a review request after each order; collecting, moderating, and publishing product reviews. Published reviews display your first name and the initial of your last name, your rating, your text, and any photos you may have included. You can request that your review be edited or deleted at any time.

5.4 Audience Measurement and Advertising

  • Google Ireland Ltd, Dublin, Ireland, and Google LLC, United States: Google Analytics 4 (web analytics, with IP address anonymization), Google Merchant Center, and Google Ads (delivery and measurement of Shopping and Search ads). Certified under the Swiss-U.S. Data Privacy Framework. Information: policies.google.com/privacy.
  • Meta Platforms Ireland Ltd, Dublin, Ireland, and Meta Platforms, Inc., United States: Meta Pixel and Conversions API (server-side transmission of visit, add-to-cart, and purchase events, including hashed email addresses), custom and lookalike audiences, and campaign measurement on Facebook and Instagram. For data collection via the Pixel, Meta and CaviarNoir are joint controllers; for further processing, Meta is the sole controller. Certified under the Swiss-U.S. Data Privacy Framework. Information: www.facebook.com/privacy/policy.

5.5 Other Technical Service Providers

  • Weglot SAS, Paris, France: Website translation into German and English. Weglot processes the pages viewed and the IP address to serve the translated version.
  • Infomaniak Network SA, Geneva, Switzerland: hosting of the domain name and email addresses sales@caviarnoir.ch (storage of our email correspondence with you).
  • Meta Platforms Ireland Ltd: WhatsApp Business messaging and Instagram/Facebook Pages. Communications through these channels are subject to Meta’s terms and conditions. Meta and CaviarNoir are jointly responsible for page statistics (“Page Insights”).
  • Apps integrated into the Shopify store (promotion management, SEO): These apps access only the data necessary for their function, under a data processing agreement entered into via the Shopify platform.

5.6 Other Recipients

  • Our trustee and our advisors (accounting, legal), who are bound by professional confidentiality.
  • Judicial and administrative authorities, when required by law.
  • Debt Collection Offices and Collection Agencies, in the event of an unpaid invoice.
  • In the event of a restructuring, merger, or sale of the company: the acquirer, subject to this policy.

6. Data Transfers Abroad

Some of the service providers listed above are based outside Switzerland. Data transfers are based on the following safeguards (Art. 16 and 17 of the Swiss Data Protection Act, Art. 44 et seq. of the GDPR):

  • EU and EEA member states, the United Kingdom, and Canada: adequate level of protection recognized by the Federal Council (Annex 1 of the Data Protection Ordinance). No additional safeguards are required.
  • United States: Google, Meta, Klaviyo, and Stripe are certified under the Swiss-U.S. Data Privacy Framework, which the Federal Council has recognized as adequate since September 15, 2024; for individuals located in the EEA, the EU-U.S. Data Privacy Framework applies. Transfers to Shopify Inc. and Judge.me (hosted in the United States) are based on the European Commission’s Standard Contractual Clauses, supplemented for Switzerland, and, for Shopify, on its Binding Corporate Rules.

You can obtain a copy of the applicable warranties upon request at sales@caviarnoir.ch.

7. Shelf Life

  • Order and billing data: 10 years from the end of the relevant fiscal year (Art. 958f CO).
  • Customer account: until the account is deleted by you or by us after 3 years of inactivity.
  • Newsletter data: until you unsubscribe. We retain records of your subscription and unsubscription for 3 years.
  • Product reviews: until you request their removal or until the product is removed from the catalog.
  • Correspondence (email, WhatsApp): 3 years after the last exchange, unless there is a dispute.
  • Google Analytics: 14 months.
  • Meta advertising data (custom audiences): Up to 180 days.
  • Cookies: See Section 8.
  • Data necessary to defend our rights: until the expiration of the statute of limitations (10 years, Art. 127 of the Swiss Code of Obligations).

Once these time limits have expired, the data is deleted or anonymized.

8. Cookies and Similar Technologies

A cookie is a small file stored on your device. We also use pixels and scripts that serve a similar purpose.

8.1 Cookies Used

Category Supplier Examples Duration Purpose
Essentials Shopify cart, _shopify_s, _secure_session_id, localization 2-Week Session Shopping Cart, Session, Security, Language, and Currency
Essentials Weglot wglang 1 year Save the selected language
Audience Measurement Shopify _shopify_y, _landing_page, _orig_referrer Up to 1 year Store Statistics
Audience Measurement Google Analytics _ga, _ga_*, _gid Up to 2 years Traffic Analysis
Marketing Meta _fbp, _fbc 90 days Facebook/Instagram Advertising and Retargeting
Marketing Klaviyo __kla_id 1 year Subscriber Recognition, Abandoned Cart
Functional Judge.me judgeme_* Session Posting and Filing Notices

8.2 Visitors Located in Switzerland

In accordance with Art. 45c of the LTC and the LPD, non-essential cookies are used based on this notice, without a consent banner. You may opt out at any time:

  • by configuring your browser to block or delete cookies (every browser offers this option in its privacy settings);
  • by installing the Google Analytics opt-out module: tools.google.com/dlpage/gaoptout;
  • by managing your ad preferences in your Facebook and Instagram accounts (Settings → Ad Preferences → Activity Outside of Meta);
  • Please email us at sales@caviarnoir.ch to opt out of retargeted advertising.

8.3 Visitors located in the EEA, including Liechtenstein

Non-essential cookies are only placed after you have given your consent via the banner displayed during your first visit. You may withdraw your consent at any time by deleting the cookies from your browser (the banner will then reappear) or by emailing us at sales@caviarnoir.ch. Withdrawing your consent does not affect the lawfulness of any processing that took place prior to your withdrawal.

Blocking essential cookies may prevent the shopping cart and checkout from working properly.

9. Your Rights

You have the following rights, which you may exercise free of charge:

  • Access (Art. 25 of the Data Protection Act, Art. 15 of the GDPR): to obtain confirmation that we are processing your personal data and to receive a copy of it, along with the information required by law.
  • Correction (Art. 32(1) of the Data Protection Act, Art. 16 of the GDPR): having inaccurate or incomplete data corrected.
  • Deletion (Art. 32, para. 2 of the Data Protection Act, Art. 17 of the GDPR): Have your data deleted, subject to our legal retention obligations.
  • Data portability (Art. 28 of the Data Protection Act, Art. 20 of the GDPR): to receive the data you have provided to us in a commonly used electronic format, or to have it transferred to a third party.
  • Right to Object (Art. 30(2)(b) of the Data Protection Act, Art. 21 of the GDPR): You have the right to object at any time to the processing of your data for direct marketing purposes, including profiling related to such marketing, and, for individuals in the EEA, to any processing based on our legitimate interests.
  • Restriction (Art. 18 of the GDPR, EEA data subjects): Request a temporary suspension of processing.
  • Withdrawal of consent: at any time, without affecting the lawfulness of prior processing.

To exercise your rights: sales@caviarnoir.ch or by mail to SVD Commerce Sàrl, Rue de Carouge 28, 1205 Geneva. We may ask you to provide proof of identity. We will respond within 30 days (Art. 25, para. 7 of the Data Protection Act; Art. 12 of the GDPR, extendable by two months for complex requests).

You can also enter a supervisory authority:

  • in Switzerland: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch;
  • in Liechtenstein: Data Protection Authority, Städtle 38, 9490 Vaduz, www.datenschutzstelle.li;
  • in another EEA country: the authority in your place of residence.

10. Data Security

We take appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration, or disclosure (Art. 8 FADP, Art. 32 GDPR): encryption of the entire website (HTTPS/TLS), PCI-DSS-compliant payments processed by our service providers, access to data limited to those who need it, and data processing agreements with each service provider.

In the event of a data security breach that is likely to pose a high risk to you, we will notify the FDPIC as soon as possible (Art. 24 FADP) and, where required by law, the individuals concerned.

11. Minors

Our website is intended for adults. We do not knowingly collect data from individuals under the age of 18. If you believe a minor has provided us with data, please contact us to have it deleted.

12. External Links and Social Media

Our website contains links to third-party websites and our pages on Instagram, Facebook, and YouTube. We are not responsible for the practices of these sites. When you interact with our social media pages, the platform operator processes your data in accordance with its own policy.

13. Changes

We may amend this policy at any time, particularly in the event of changes to the law or to our services. The version published on the website is the official version. The date of the last update appears at the top of the document. In the event of a substantial change, we will notify our customers by email.

14. Contact

SVD Commerce Sàrl — CaviarNoir.ch
Rue de Carouge 28, 1205 Geneva, Switzerland
Email: sales@caviarnoir.ch
Phone: +41 77 467 71 31