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Privacy Policy

Last updated: 9 April 2026

This Privacy Policy explains how TMN Société Anonyme (“ApexGuard,” “we,” “us,” or “our”) collects, uses, protects, discloses, stores, and deletes your personal data when you access or use our websites, applications, customer portals, APIs, support channels, and related services where this Privacy Policy is posted (collectively, the “Services”), regardless of the device you use.

Please note that we seek to collect and process only the personal data reasonably necessary to provide, secure, support, improve, and market our Services. ApexGuard is privacy-focused by design. Where a specific ApexGuard service has additional data handling rules, those will be described in a service-specific notice, product interface, contract, or supplemental policy.

Unless otherwise defined here, capitalized terms have the meanings given to them in our General Terms or other applicable service terms.

Introduction

Key points of this Privacy Policy are summarized below.

  • This Privacy Policy explains how ApexGuard handles personal data.
  • ApexGuard is a Swiss company and this policy is grounded primarily in Swiss law.
  • We aim to provide clear information so users can understand how their data is processed.

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please refrain from using the relevant Services.

The company responsible for processing your personal data is:

TMN Société Anonyme
Rue du Grand-Chêne 5
1003 Lausanne
Switzerland

For purposes of Swiss data protection law, we act as the controller for the processing activities described in this Privacy Policy unless stated otherwise. The revised FADP protects the personality and fundamental rights of natural persons whose personal data is processed.

Please note that Swiss law requires data controllers to provide data subjects with adequate and comprehensible information about the collection of their personal data and the purposes of processing. This Privacy Policy is intended to help satisfy that duty.

Service-specific privacy notices

Service-specific privacy notices are summarized below.

  • Different ApexGuard services may involve different categories of personal data.
  • Product-specific notices, contractual terms, onboarding materials, or in-app disclosures may supplement this Privacy Policy.

Certain ApexGuard services, applications, account features, partner channels, or promotional campaigns may be subject to additional privacy terms, notices, or disclosures. Where that is the case, those additional materials supplement this Privacy Policy and should be read together with it.

Personal data we process

The categories of personal data we process are summarized below.

  • We may process account, billing, technical, support, security, and communication data.
  • The exact categories depend on how you interact with ApexGuard.
  • Some data is provided by you, some is collected automatically, and some may come from third parties.

To provide and operate our Services, we may process information that identifies you or relates to an identified or identifiable natural person (“personal data”).

Depending on how you interact with us, we may collect personal data in the following ways:

  • directly from you;
  • automatically through your use of our Services or Websites;
  • from payment providers, resellers, app stores, referral partners, or other third parties involved in delivering the Services; and
  • from communications, support requests, and other interactions with us.

3.1 When you create an account

When you create an ApexGuard account, start a subscription, or register for a service, we may process data such as:

  • email address;
  • name or username;
  • password credentials or authentication-related records;
  • selected country or region;
  • subscription preferences; and
  • account creation metadata.

3.2 When we provide our Services and communicate with you

When we provide the Services, we may process data needed to deliver them, such as:

  • account identifiers;
  • service entitlements and subscription status;
  • transaction references;
  • configuration settings;
  • customer communications;
  • service-related notices; and
  • limited technical metadata needed to operate and secure the service.

Where ApexGuard products are designed around privacy-preserving principles, we aim to minimize the collection of unnecessary activity data. Any product-specific limitations on collection, including no-logs or minimal-logs descriptions where applicable, should be set out in the relevant product documentation or service-specific privacy notice.

3.3 When we handle payments

If you purchase a subscription or other service, we may process:

  • billing name;
  • billing address or country;
  • VAT-relevant information where applicable;
  • payment status;
  • payment method metadata;
  • transaction amount;
  • subscription term; and
  • refund-related records.

We generally rely on third-party payment processors for payment execution and do not need to store full payment card details ourselves, except to the extent reflected in processor-provided transaction records or required accounting documentation.

3.4 When you interact with our Services

When you use our websites, applications, or customer interfaces, we may process:

  • device and browser data;
  • app version and operating system;
  • language preferences;
  • approximate technical location derived from service interactions;
  • session and diagnostic data;
  • crash reports and performance metrics;
  • fraud-prevention and abuse-detection signals; and
  • cookie or similar technology data where applicable.

3.5 When we provide customer support

If you contact support, we may process:

  • your contact details;
  • support case contents;
  • attachments or screenshots you choose to provide;
  • troubleshooting logs or diagnostic information you approve or submit;
  • communication history; and
  • resolution status.

3.6 When we improve our Services

We may process limited usage, diagnostic, analytics, security, or feedback data to maintain, improve, and develop our Services, provided that such processing is appropriate to the service context and compatible with applicable law.

3.7 When we carry out marketing and advertising activities

If permitted by law and your choices, we may process:

  • email address;
  • marketing preferences;
  • campaign engagement data;
  • referral source data;
  • cookie or tracking data; and
  • event participation information.

3.8 When we administer social media accounts and public-facing channels

If you interact with ApexGuard through social media, forums, or public channels, we may process information you make available there, such as usernames, profile information, public comments, and message contents.

3.9 When we maintain the security of accounts and Services

We may process personal data where necessary to:

  • verify account ownership;
  • detect account compromise;
  • investigate abuse, fraud, and malicious use;
  • protect our infrastructure and users;
  • enforce our terms; and
  • maintain service continuity and resilience.

Purposes of processing

The purposes for which we process personal data are summarized below.

  • We process personal data only where there is a defined purpose.
  • The main purposes are service delivery, support, security, billing, compliance, and improvement.

We may process personal data for the following purposes:

  • creating and administering accounts;
  • providing subscriptions and other Services;
  • authenticating users and securing accounts;
  • processing payments, renewals, and refunds;
  • communicating with you about the Services;
  • responding to support and rights requests;
  • monitoring, maintaining, and improving service performance and reliability;
  • detecting, preventing, and investigating fraud, abuse, and violations of our terms;
  • complying with legal, tax, accounting, regulatory, and contractual obligations;
  • defending or exercising legal claims; and
  • conducting marketing and business communications where permitted.

Legal basis and Swiss law framing

The legal basis for processing and Swiss law framework are summarized below.

  • This policy is primarily grounded in Swiss law.
  • We process data where needed to provide services, protect legitimate interests, comply with legal obligations, or where consent is obtained.

This Privacy Policy is drafted primarily with reference to Swiss law, including the FADP and its implementing ordinance. The FADP requires transparency when personal data is collected and gives individuals specific rights, including the right to request information about whether data concerning them is being processed and, if so, which data, for what purpose, to whom it may be disclosed, and how long it is retained or the criteria used to determine retention.

Depending on the context, our processing may be justified because it is:

  • necessary to provide the Services you requested;
  • necessary to protect our legitimate operational, security, and commercial interests in a proportionate manner;
  • necessary to comply with legal obligations;
  • necessary to establish, exercise, or defend legal claims; or
  • based on your consent, where consent is appropriate or required.

Where we rely on consent, you may withdraw it for future processing at any time, subject to legal or technical limits applicable to the relevant service or feature.

Sharing your personal data

How we share personal data is summarized below.

  • We may share personal data with service providers, partners, and authorities where justified.
  • We aim to limit disclosures to what is necessary.
  • We use contractual and organizational safeguards where appropriate.

We may share personal data in the following situations:

6.1 With service providers

We use third-party providers to support certain operations, such as:

  • payment processing;
  • email delivery and transactional messaging;
  • customer support systems;
  • infrastructure hosting and service delivery;
  • analytics and diagnostics;
  • fraud prevention and security tooling; and
  • document or workflow systems.

Those providers may process personal data on our behalf and under appropriate instructions or contractual arrangements, depending on their role.

6.2 With partners, resellers, distributors, and app platforms

If you purchase or access ApexGuard through a partner, reseller, affiliate, app marketplace, or bundled service arrangement, relevant parties may process certain data necessary to activate, manage, support, or account for the service. In some cases, such third parties act as independent controllers under their own terms and privacy notices.

6.3 Within our corporate structure

We may share data with affiliated entities or internal business units where reasonably necessary to operate, support, secure, or improve ApexGuard services, manage subscriptions, or conduct legitimate business operations.

6.4 Business transfers

We may disclose personal data to prospective or actual purchasers, investors, lenders, advisers, or counterparties in connection with a merger, acquisition, financing, restructuring, asset transfer, liquidation, or comparable transaction, subject to appropriate confidentiality measures.

6.5 Protection of our rights and safety

We may disclose personal data where necessary to:

  • establish, exercise, or defend legal claims;
  • investigate or prevent fraud, abuse, or unlawful conduct;
  • enforce our contracts and policies; or
  • protect the rights, safety, or property of ApexGuard, our users, or third parties.

6.6 Legal requests and official disclosures

We may be required to disclose limited personal data to competent authorities where legally required.

As a Swiss company, ApexGuard handles such requests in accordance with Swiss law and applicable Swiss legal procedure. Requests from Swiss authorities must follow the relevant legal basis and procedural route under Swiss law. Requests from foreign authorities must generally be submitted through appropriate recognized cross-border procedures, such as mutual legal assistance, letters rogatory, or other valid legal mechanisms, where required under Swiss law and international process.

We do not disclose data voluntarily outside a valid legal basis. Each request is reviewed for jurisdiction, validity, scope, and proportionality. Where appropriate and permitted, we may challenge, narrow, or reject requests that are defective, overbroad, or inconsistent with applicable law.

6.7 With your consent

In addition to the situations above, we may share your personal data for specific purposes where you have consented to that sharing.

Cross-border transfers

Cross-border transfers of personal data are summarized below.

  • Some providers or systems may process personal data outside Switzerland.
  • We seek appropriate protections for international transfers.

Because ApexGuard may use international infrastructure and specialized service providers, personal data may be processed outside Switzerland, including in countries that may not provide an equivalent level of statutory protection.

Where we transfer personal data abroad, we take appropriate measures under applicable law to ensure an adequate level of protection, such as contractual safeguards, organizational controls, technical protections, and transfer assessments where appropriate.

Your privacy rights

Your privacy rights are summarized below.

  • You may have rights to access, correct, delete, and object.
  • Rights are subject to applicable law and justified limitations.
  • You may also contact the FDPIC.

Under the FADP, you may have the right to request information as to whether personal data concerning you is being processed and, where applicable, to receive information including the identity of the controller, categories of personal data processed, purposes of processing, recipients or categories of recipients, and storage period or relevant criteria.

Subject to applicable law, you may also have the right to:

  • request correction of inaccurate personal data;
  • request deletion or destruction of personal data where appropriate;
  • object to certain processing;
  • withdraw consent for future processing where consent is the basis;
  • receive a copy of certain information; and
  • challenge unlawful processing.

Swiss public guidance also recognizes that individuals may request information and, where appropriate, correction or destruction of personal data.

Rights requests

To exercise your rights, submit a question, or make a complaint about our privacy practices, please contact us using the details in the “Contact us” section.

To protect the security of accounts and personal data, we may require verification appropriate to the nature of the request before responding. If you are acting on behalf of another person, we may require proof of authorization.

Account deletion

How account deletion works is summarized below.

  • You may request account deletion.
  • Some data may still need to be retained for legal, security, or accounting reasons.

You may request deletion of your ApexGuard account or associated personal data through the account interface where available or by contacting us.

Deletion requests are subject to applicable legal, contractual, technical, fraud-prevention, and record-retention obligations. Deleting your account may terminate access to associated subscriptions, services, settings, and support history.

Certain information may need to be retained after deletion where required for legal compliance, billing, dispute resolution, fraud prevention, security, or enforcement purposes.

Your marketing choices

Your marketing choices are summarized below.

  • You control whether you receive marketing messages.
  • Service messages may still be necessary.
  • Cookie and tracking choices can be managed separately.

You may opt out of marketing communications by:

  • using the unsubscribe link in the message;
  • adjusting account or app notification settings where available; or
  • contacting us.

Please note that service-related and transactional communications may still be sent where necessary to provide the Services, administer your account, or comply with legal obligations.

For information about cookies and similar technologies, please refer to our Cookie Policy. Swiss guidance on privacy statements for websites and transparency requirements supports providing users with clear information about online data collection and related choices.

Data security

Our data security practices are summarized below.

  • We use technical, organizational, and physical safeguards.
  • No system can promise absolute security.
  • If you believe your account or interaction is no longer secure, contact us.

We maintain administrative, technical, and organizational measures designed to protect personal data against unauthorized access, accidental loss, alteration, misuse, destruction, and unlawful disclosure. Depending on the context, these measures may include:

  • access controls and role-based permissions;
  • encryption in transit and at rest where appropriate;
  • authentication controls;
  • logging and monitoring;
  • secure development and patching practices;
  • vulnerability management;
  • vendor review procedures; and
  • incident response processes.

No system can guarantee absolute security. If you believe your interaction with ApexGuard is no longer secure, please contact us promptly.

Data retention and deletion

Our data retention and deletion practices are summarized below.

  • We retain data only as long as reasonably necessary.
  • Some records may need to be kept longer to comply with law.
  • Swiss accounting records are generally retained for 10 years.

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or justified by law, regulation, dispute resolution needs, security requirements, or legitimate operational necessity.

11.1 Information retained while your account remains active

We may retain core account and subscription data while your account is active so we can provide the Services, support your use of the platform, and maintain security and continuity.

11.2 Retention for specific purposes

We may retain certain categories of data for longer periods, such as:

  • billing, invoicing, tax, and accounting records;
  • fraud prevention and security logs;
  • records relating to rights requests or disputes;
  • customer support communications; and
  • records needed to enforce terms or defend legal claims.

Under Swiss record-keeping rules, accounting-related business records are generally subject to a 10-year retention period.

11.3 Secure deletion and anonymization

When personal data is no longer needed, we may delete it, irreversibly anonymize it, or otherwise dispose of it using reasonable and appropriate measures.

Country-specific provisions

Country-specific privacy provisions are summarized below.

  • This policy is primarily Swiss-law based.
  • Users in other jurisdictions may also have additional rights under applicable local laws.

This Privacy Policy is designed primarily around Swiss law because ApexGuard is a Swiss company. However, depending on where you are located and how you interact with the Services, additional local privacy laws may apply to specific processing activities.

Nothing in this Privacy Policy is intended to limit any mandatory rights you may have under applicable law.

Children’s data

How children’s data is handled is summarized below.

  • ApexGuard services are not intended for children.
  • We do not knowingly collect personal data from children where prohibited.

Our Services are not intended for children under the age permitted by applicable law, and we do not knowingly solicit personal data from children in violation of applicable law.

If you believe that a child has provided us personal data unlawfully, please contact us so we can review and address the matter.

Other terms

Other privacy-related terms are summarized below.

  • Users remain responsible for how they use the Services.
  • Third-party websites are governed by their own rules.
  • The English version governs unless stated otherwise.

Limitation of responsibility

You are responsible for using our Services lawfully and appropriately. ApexGuard is not responsible for unlawful or abusive conduct by users, or for events beyond our reasonable control, to the extent permitted by applicable law and our contract terms.

Links to third-party websites and services

Our Services may contain links to third-party websites, services, or integrations not controlled by ApexGuard. If you follow those links or engage with those services, your data may be handled under their own terms and privacy notices.

Prevailing language

Unless stated otherwise, the English language version of this Privacy Policy is the governing version. Any translation is provided for convenience.

Updates to this Privacy Policy

Updates to this Privacy Policy are summarized below.

  • We may update this policy from time to time.
  • Material changes will be reflected in the updated version and effective date.

We may amend this Privacy Policy from time to time to reflect changes in our Services, legal obligations, vendors, technical environment, or business practices.

When we make material changes, we will update the “Last updated” date and, where appropriate, provide additional notice through the Website, app, account interface, or email.

Contact us

How to contact us about privacy matters is summarized below.

  • Contact us for privacy questions, requests, or complaints.
  • You may also contact the Swiss FDPIC.

If you have questions, concerns, or requests regarding this Privacy Policy or our processing of personal data, please contact us at:

TMN Société Anonyme
TVA CHE-256.320.417
Rue du Grand-Chêne 5
1003 Lausanne
Switzerland

Privacy contact: privacy@apexguard.com

You may also have the right to contact the Federal Data Protection and Information Commissioner (FDPIC), which is the Swiss supervisory authority for data protection matters.