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Privacy Notice
moxxis AG
Version: 09.09.2026
1.About this Privacy Notice
This Privacy Notice explains how moxxis AG processes your personal data in connection with foot and gait analysis and the manufacture of your individual insoles. It applies to the processing of personal data in Switzerland under the Swiss Federal Act on Data Protection (FADP) and, where you are located in the EU or EEA, under the General Data Protection Regulation (GDPR).
2. Controller
The controller responsible for the data processing described in this Privacy Notice is:
moxxis AG, Mellingerstrasse 1, 5400 Baden, Switzerland | Email: info@moxxis.com
Allocation of responsibilities if you purchase your insoles through an authorised moxxis distributor: your specialist retailer (distributor) is independently responsible for data relating to its customer relationship with you (e.g. appointment scheduling, advice, correct measurements, purchase agreement, payment in store, monitoring manufacture by means of 3D printing, post-processing of the insoles and handover of the insoles). moxxis AG is responsible for all data processing within the moxxis platform, from defining the measurements and carrying out the analysis through to creating the manufacturing data (print files).
3. EU Representative
(Art. 27 GDPR)
​As moxxis AG has no establishment in the EU, we have appointed the following representative in the EU. She serves as the contact point for data subjects and supervisory authorities in the EU:
Monica Schuricht, Schramberger Straße 24, 13467 Berlin, Germany | Email: moxxis@datenschutzkonform.ch
4. Data We Process
• Master and contact data: name, date of birth, email address
• Measurement data (health data): 3D scan of the feet, dynamic pressure measurement, leg axes and rearfoot axes
• Derived data: biomechanical analyses, AI-assisted evaluations, Foot Report, production and print data (e.g. manufacturing files for your insole, including any personal engraving you choose)
• Usage and configuration data: shoe type, intended use, personalisation (engraving and colour)
• Order, payment and fulfilment data for orders and repeat orders via the moxxis portal
(payment processing through our payment service provider, Section 7)
The measurement data and the analyses derived from them constitute health data within the meaning of Art. 9(1) GDPR and sensitive personal data within the meaning of Art. 5(c) FADP.
5. Purposes and Legal Bases
Purpose | Legal Basis GDPR (EU) | Legal Basis (Switzerland) |
|---|---|---|
Conducting the foot and gait analysis, calculation and manufacture of your insoles, Foot Report, documentation | Explicit consent (Art. 9(2)(a) in conjunction with Art. 6(1)(a)); performance of a contract (Art. 6(1)(b)) | Explicit consent (Art. 6(7) FADP) |
Repeat orders, support requests, customer service | Performance of a contract (Art. 6(1)(b)) | Art. 6 FADP (proportionality, purpose limitation) |
Quality assurance and improvement of our system | Legitimate interests (Art. 6(1)(f)) | Art. 6 FADP |
Product development, research, training of our algorithms and AI, in anonymised and, exceptionally, pseudonymised form | Your separate, voluntary consent (Art. 6(1)(a), Art. 9(2)(a)) | Consent; anonymised data is not personal data |
Product and service information by email (e.g. service reminders, repeat-order notices, news) | Your separate, voluntary consent (Art. 6(1)(a)); Section 7 UWG (Germany) | Your consent; Art. 3(1)(o) UWG |
Compliance with legal obligations (e.g. retention, product safety) | Legal obligation (Art. 6(1)(c)) | Statutory retention obligations |
6. Your Consents
Before the measurement, we obtain your consents individually and actively in the application:
• Required (analysis and insoles): without this consent, the measurement and manufacture
cannot be carried out because processing your health data is technically essential for these
purposes.
• Optional (product development and research): has no effect on the analysis or manufacture.
• Optional (product and service information by email).
You may withdraw any consent at any time with effect for the future (an email to info@moxxis.com is sufficient). The lawfulness of processing carried out before withdrawal remains unaffected. Data that has already been anonymised is not affected by withdrawal because it can no longer be attributed to an individual. If you withdraw the required consent, we can no longer provide the service (including repeat orders).
7. Recipients of Your Data
We do not sell your personal data. Access is limited to:
• Your specialist retailer (distributor): may view your data in the application insofar as required for advice, sale and handover; the retailer is contractually bound by
confidentiality and data-protection obligations and may not use the data for its own
purposes.
• Processors (Art. 28 GDPR): service providers that process data solely on our instructions,
in particular:
• Hosting: Infomaniak SA, Geneva (Switzerland); Amazon Web Services, Frankfurt Region (EU)
• Development, operation and support of the platform: a specialised IT service provider
• Email delivery: Mailchimp and Mandrill (The Rocket Science Group LLC / Intuit Inc., USA), as
well as delivery via Amazon Web Services
• Error analysis: Sentry (Functional Software, Inc., USA)
• Application usage statistics: Fathom Analytics (Canada), a cookie-free web analytics service
• Payment service provider: for payments via the platform, Stripe (Stripe Payments Europe,
Ltd., Dublin, Ireland) processes some of your payment data under its own responsibility and
in accordance with its own privacy notice.
• Public authorities, where we are legally required to disclose data.
8. International Data Transfers
Your data is stored in Switzerland (Infomaniak, Geneva) and in the EU (AWS, Frankfurt). For persons in the EU: Switzerland is covered by an adequacy decision of the European Commission, so transfers to moxxis AG in Switzerland are permitted without additional safeguards. For persons in Switzerland: the EU ensures an adequate level of data protection according to the decision of the Swiss Federal Council.
Certain service providers also process data in the USA (email delivery via Mailchimp/Mandrill, error analysis via Sentry, payment processing via Stripe) and in Canada (Fathom Analytics). Canada is covered by an adequacy decision of the European Commission and is recognised by the Swiss Federal Council. Transfers to the USA are based on the EU-U.S. Data Privacy Framework or the Swiss-U.S. Data Privacy Framework where the provider is certified; otherwise, we rely on the European Commission’s Standard Contractual Clauses. You may request a copy of the Standard Contractual Clauses at info@moxxis.com.
9. Retention Period
We retain your data for as long as necessary for manufacture, repeat orders, customer support and quality assurance, i.e. for the duration of the customer relationship, but no longer than 10 years after your last order or delivery. In addition, we retain data where and for as long as statutory retention and documentation obligations require this (for example under accounting, product-safety or product-liability law). Thereafter, the data is deleted or fully anonymised. Fully anonymised data can no longer be attributed to an individual and may therefore be used without time limitation for quality assurance, product development and research.
10. Data Security
We protect your data through technical and organisational measures, in particular encrypted transmission, access restrictions based on the need-to-know principle, contractually bound specialist retailers with trained staff, and vetted hosting providers in Switzerland and the EU. Apart from any personal engraving you choose (e.g. your first name), the manufacturing data for your insole contains no direct identifiers such as names or email addresses.
The application uses only technically necessary cookies (session and security); we do not use tracking or marketing cookies.
11. Use of the Platform by Specialist Retailers
For operation of the platform, we also process personal data of users employed by our specialist retailers: account data (name, business email address), login and activity data, and technical log data (IP address, access times). The legal basis is performance of the contract with the specialist retailer and/or our legitimate interest in secure and stable operation (Art. 6(1)(b) and (f) GDPR; Art. 6 FADP). We use cookie-free web analytics for usage statistics (Section 7).
12. Use of AI; No Automated Individual Decision-Making
We use AI-assisted methods in the analysis. The results are used to manufacture your insoles and are always accompanied and reviewed by qualified professionals. No automated decision is made that produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR, Art. 21 FADP).
13. Your Rights
You have the right to access, rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interests (Arts. 15–21 GDPR; Art. 25 et seq. FADP). You may withdraw your consents at any time (Section 6).
To exercise these rights, contact info@moxxis.com or, if you are located in the EU, our EU representative (Section 3). We may request proof of identity in order to process your request.
Right to lodge a complaint: you may contact a data-protection supervisory authority; in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch), and in the EU, the supervisory authority for your place of residence, work or stay (Art. 77 GDPR).
14. Changes
We may amend this Privacy Notice. The current version available in the application and on www.moxxis.com is authoritative. We will inform you in an appropriate manner of material changes.
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