Privacy Policy

This is the complete privacy policy. You can download the same text as a PDF below. It was written in German; the English, French and Italian versions are translations of that text.

Download the privacy policy as a PDF

Privacy policy of Finsler Customs GmbH

1. What is this privacy policy about?

Finsler Customs GmbH (also referred to as «we» or «us») collects and processes personal data relating to you or to other people («third parties»). We use the term «data» here as a synonym for «personal data». «Personal data» means data relating to an identified or identifiable person, i.e. conclusions about their identity can be drawn from the data itself or in combination with additional data. «Sensitive personal data» is a category of personal data that applicable data protection law protects in particular. Section 3 sets out the data we process under this privacy policy. «Process» means any handling of personal data, for example collecting, storing, using, adapting, disclosing and deleting it.

In this privacy policy we describe what we do with your data when you use fleximoto.ch or other websites of ours (together the «website»), our online platform fleximoto.ch (the «platform»), our services or products, when you are otherwise in contact with us under a contract, when you communicate with us or otherwise deal with us. Where necessary we will inform you in good time and in writing about additional processing activities not mentioned in this privacy policy. In addition we may inform you separately about the processing of your data, for example in consent declarations, contractual terms, additional privacy notices, forms and notices.

If you send us data about other people, such as family members or work colleagues, we assume that you are authorised to do so and that the data is accurate. By transmitting data about third parties you confirm this. Please also make sure that those third parties have been informed about this privacy policy.

2. Who is responsible for processing your data?

Finsler Customs GmbH (company ID CHE-416.189.052), Rebbergstrasse 6, CH-8240 Thayngen, is the controller for the processing described in this privacy policy, unless communicated otherwise in an individual case.

For every processing operation there are one or more bodies responsible for ensuring that the processing complies with data protection law. That body is called the controller. It is responsible, for example, for answering requests for information (Section 11) and for ensuring that personal data is secured and not used unlawfully.

Other bodies may share responsibility for the processing described here if they jointly decide on its purpose or design. If you would like details about the individual controllers for a specific processing operation, you may request that information from us under your right of access (Section 11). Finsler Customs GmbH remains your primary point of contact even where other joint controllers exist.

Sections 3, 7 and 12 contain further details about third parties we work with and which are themselves responsible for their own processing. For questions or to exercise your rights towards those third parties, please contact them directly. You can reach us on data protection matters and to exercise your rights under Section 11 as follows:

Finsler Customs GmbH
Rebbergstrasse 6
CH-8240 Thayngen
E-Mail: info@finsler-customs.ch

3. What data do we process?

We process various categories of data about you. The most important categories are the following:

Technical data: When you use our website, our platform or other electronic offerings, we collect the IP address of your device and further technical data in order to ensure the functionality and security of these offerings. This data also includes logs recording the use of our systems. To ensure functionality we may also assign an individual code to you or your device (for example in the form of a cookie, see Section 12). Technical data on its own generally does not allow conclusions about your identity. In connection with user accounts, registrations or the performance of contracts, however, it can be linked to other categories of data and thus possibly to you personally.
Technical data includes, among other things, the IP address and details about your device's operating system, the date, region and time of use, and the type of browser you use to access our electronic offerings. The IP address tells us which provider you use to access our offerings, and therefore the approximate region, but as a rule we cannot deduce who you are from it. That changes if, for example, you create a user account, because personal data can then be linked to technical data. Logs generated in our systems, such as the record of sign-ins on our website or platform, are also examples of technical data.
Registration data: Certain offerings and services can only be used with a user account or a registration, which can be created directly with us or through our external sign-in providers. You have to provide certain data for this, and we collect data about your use of the offering or service. Registration data includes the details you provide when creating an account on our website or platform (for example user name, password, name, email address).
Communication data: When you are in contact with us via the contact form, by email, telephone or chat, by letter or through other means of communication, we record the data exchanged between you and us, including your contact details and the metadata of the communication. If we want or need to establish your identity, for example when you make a request for information, we collect data to identify you (such as a copy of an identity document).
Communication data means your name and contact details, the manner, place and time of the communication and, as a rule, its content as well (that is, the content of emails, letters, chats and so on). This data may also contain information about third parties.
Master data: Master data means the basic data which, alongside contract data, we need in order to handle our contractual and other business relationships or for marketing and advertising purposes: name, contact details and information about your role and function, your bank details, your date of birth, your customer history, signing authorities and consent declarations. We process your master data if you are a customer or other business contact, or work for one. We receive master data from you (for example when concluding a contract or registering), from bodies you work for, or from third parties such as our contractual partners and from publicly accessible sources such as public registers or the internet.
As a rule we keep this data for ten years from the last exchange with you, but at least from the end of the contract. That period may be longer where this is necessary for evidentiary reasons, to comply with legal or contractual requirements, or for technical reasons.
Master data includes, for example, name, address, email address, telephone number and other contact details, gender, date of birth, nationality, details of related persons, photographs, copies of identity documents; further, details about your relationship with us, your status with us, allocations and distribution lists, details of our interactions with you, and official documents concerning you (such as commercial register extracts). As payment details we collect, for example, your bank details and account number. Consent and blocking notes are also part of master data.
We delete the copy of your identity document, which we need for the import and registration of your vehicle, as soon as the order is completed.
Contract data: This is data arising in connection with the conclusion or performance of a contract, for example details about contracts and the services to be provided or provided, data from the run-up to a contract, and the details required to carry it out. We generally collect this data from you, from contractual partners and from third parties involved in performing the contract, such as customs offices, road traffic authorities, carriers and inspection bodies. As a rule we keep this data for ten years from the last contractual activity, but at least from the end of the contract.
Contract data includes details about the conclusion of the contract, such as its type and date, details from the ordering process, and details about the contract and its performance and administration (for example invoicing, customer service, support on technical matters and the enforcement of contractual claims). It also includes details about defects, complaints and amendments to a contract as well as details about reminders and debt collection.
Behavioural and preference data: When you view a vehicle listing, we count how often and how long it is viewed and how many pictures are looked at. Section 12 describes how this works. If you save a vehicle to your watchlist or save a search, we record those details in your account so that we can notify you about price changes and matching new arrivals; you can switch these notifications off in your account at any time. We do not analyse your behaviour in order to evaluate your personal characteristics (Section 6).
Listing and platform data: If you use our platform fleximoto.ch as a dealer, we process data relating to the vehicle listings you publish, your dealer profile and your use of the platform functions.
Other data: We also collect data about you in other situations. In connection with official or judicial proceedings, for example, data arises (such as files and evidence) that may also relate to you. The retention period for this data depends on the purpose and is limited to what is necessary.

You provide much of the data mentioned in this Section 3 yourself, for example via forms, in the course of communicating with us, in connection with contracts or when using the website or platform. You are not obliged to do so, subject to individual cases with a legal obligation. If you wish to conclude contracts with us or obtain services, you must provide us with data under your contractual obligations, in particular master, contract and registration data. When you use our website or platform, the processing of technical data is unavoidable.

Where this is not unlawful, we also take data from publicly accessible sources (such as the commercial register, media or the internet) or receive data from authorities and other third parties.

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information about the online area can be found in Sections 12 and 13. These purposes and the underlying aims constitute legitimate interests of ours and, where applicable, of third parties. Further details about the legal bases for our processing can be found in Section 5.

We process your data for purposes connected with communicating with you, in particular to answer enquiries, to give effect to your rights (Section 11) and to contact you with follow-up questions. For this we use communication data and master data in particular, and registration data in connection with offerings you use. We keep this data in order to document our communication with you, for quality assurance and for follow-up questions.

We process data for entering into, managing and performing contractual relationships. We conclude various types of contract with our business and private customers, with dealers, suppliers and other contractual partners. In doing so we process master data, contract data and communication data in particular and, depending on the circumstances, registration data as well. This also covers the import, customs clearance, inspection and registration of the vehicle you have ordered.

We further process data for operating and developing the fleximoto.ch platform, in particular to administer accounts and to publish vehicle listings.

We process data for marketing purposes and to maintain relationships, for example to inform you about our vehicles and services. You can refuse such contact at any time, or refuse or withdraw consent to it. If you save a vehicle to your watchlist or save a search, we notify you about matching new arrivals and price changes; you can switch these notifications off in your account. Section 12 explains how we measure the success of our advertising.

We also process your data for market research, to improve our services and our operations, and for product development.

We process personal data in order to comply with laws, instructions and recommendations of authorities and with internal rules («compliance»), in particular in customs, vehicle registration, accounting and VAT law.

We also process data for the purposes of our risk management and prudent corporate governance, including business organisation and corporate development, as well as for our internal processes and administration.

5. On what basis do we process your data?

Where we ask for your consent for particular processing, we inform you separately about the relevant purposes. You may withdraw consent at any time in writing or, unless stated or agreed otherwise, by email, with effect for the future; our contact details are in Section 2. Where you have a user account, a withdrawal may also be possible there. Once we have received notice of your withdrawal, we will no longer process your data for the purposes you originally consented to, unless we have another legal basis for doing so. Withdrawal does not affect the lawfulness of the processing carried out up to that point.

Where we do not ask for your consent, we base the processing of your personal data on the fact that it is necessary for entering into or performing a contract with you (or with the body you represent), or that we or third parties have a legitimate interest in it, in particular in order to pursue the purposes described in Section 4. Our legitimate interests also include compliance with legal requirements.

We may also process your data on other legal bases, for example in the event of disputes because processing is necessary for proceedings or for asserting or defending legal claims. In individual cases other legal grounds may apply, which we will communicate separately where necessary.

6. What about profiling and automated individual decisions?

We do not evaluate your personal characteristics automatically. There are no personalised prices with us: every visitor sees the same price for the same vehicle. Delivery costs depend solely on the distance between Thayngen and the postcode you enter, not on who you are. Nor do we tailor the selection of vehicles we show you to individual people.

We do not make automated individual decisions that would have legal consequences for you or affect you significantly. A purchase, a reservation or a financing arrangement is always decided by a person.

Our affordability check on fleximoto.ch is purely a calculator: it runs in your browser, and the figures you enter are neither transmitted to us nor stored. No credit agency is queried and no entry is created.

7. To whom do we disclose your data?

In connection with our contracts, the website, our platform, our services and products, our legal obligations or otherwise to protect our legitimate interests and the further purposes listed in Section 4, we also transmit your personal data to third parties. We disclose to these service providers only the data required for their service, and we conclude contracts with them containing provisions on data protection where such protection does not already follow from the law. Specifically, we work with the following bodies:

Bexio AG (Rapperswil, Switzerland) – accounting and invoicing: As soon as you sign a purchase contract digitally, we create a contact in our accounting software and generate the invoice from it. We transmit your name or company, email address, postal address and the invoice items. Information on data protection at Bexio: www.bexio.com/de-CH/richtlinien/datenschutz
Supabase via Lovable Labs (Stockholm, Sweden / Delaware, USA) – database, sign-in and file storage: Your account, your orders, purchase contracts and the documents you upload are stored in this environment. Identity documents and signed contracts are kept in areas that are not publicly accessible. When you sign a purchase contract digitally, we also record your IP address, the time and the version of the contract documents with the order as proof of consent. We read that address from your request ourselves; no third-party service is involved. Information on data protection at Lovable: lovable.dev/privacy
Hetzner Online GmbH (Falkenstein, Germany) – vehicle images: Images for vehicle listings are stored in Germany and can be retrieved publicly via their address so they can be shown on the website and in the app. Personal documents are not stored there.
Google Ireland Ltd. / Google LLC – measurement and reviews: On the website we use Google Ads to measure how our advertising performs. This measurement service is only loaded once you have agreed in the consent banner (Section 12); without your agreement no request goes to Google. In our App Store app it is not loaded at all. We no longer fetch fonts from Google; they sit on our own server and are delivered from there, so your browser no longer turns to Google for them. Separately from this, we retrieve opening hours and reviews for locations. Information on data protection at Google: policies.google.com/privacy
Apple Inc. – sign-in and notifications: If you sign in with Apple, Apple verifies your identity. Push notifications in our app are delivered through Apple's service.
Microsoft Corporation – email and internal accounting: Our business correspondence runs through Microsoft 365. For bookkeeping we also transfer cost breakdowns of orders into a workbook on OneDrive containing the order number, customer name, amounts and receipt details. Information on data protection at Microsoft: privacy.microsoft.com/en-us/privacystatement
OpenStreetMap Foundation – map tiles: On the contact page and on cantonal pages with a map we load map tiles from openstreetmap.org – but only once you start the map yourself with the «Load map» button. Only then is your IP address transmitted to that service.
Authorities and service providers involved in the process: For customs clearance, transport, inspection and registration we pass on the necessary details to customs offices, road traffic authorities, carriers and inspection bodies. We may also pass personal data to offices, courts and other authorities in Switzerland and abroad where we are legally obliged or entitled to do so. Those bodies process the data under their own responsibility.
Banks, insurers and debt collection: For handling payments, for insurance cover and in the event of outstanding claims we pass the necessary details to banks, insurers and debt collection companies.

All of these recipients may in turn call on third parties, so that your data may become accessible to them as well. We can contractually limit the processing by certain third parties (for example IT service providers) but not by others (for example authorities or banks).

8. Is your personal data also transferred abroad?

As explained in Section 7, we also disclose data to other bodies. These are not located only in Switzerland. Your data may therefore be processed in Europe and in the USA, and in exceptional cases in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we contractually oblige that recipient to comply with applicable data protection, unless it is already subject to a legally recognised set of rules ensuring data protection and unless we can rely on an exception. An exception may apply in particular to legal proceedings abroad, but also in cases of overriding public interest, where performing a contract requires such disclosure, where you have consented, or where the data concerned has been made generally accessible by you and you have not objected to its processing.

Many countries outside Switzerland, the EU and the EEA currently do not have laws that ensure an adequate level of data protection from the perspective of the Swiss DPA or the GDPR. The contractual measures mentioned can partly compensate for this weaker or absent statutory protection. Contractual measures cannot, however, eliminate all risks, in particular state access abroad. You should be aware of these residual risks, even if the risk may be low in an individual case and we take further measures to reduce it.

Please also note that data exchanged over the internet is often routed through third countries. Your data may therefore end up abroad even where sender and recipient are in the same country.

9. How long do we process your data?

We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidentiary purposes require, or for as long as storage is technically necessary. Further details on the respective storage and processing periods can be found with the individual data categories in Section 3 and with the types of storage in Section 12. Unless legal or contractual obligations prevent it, we delete or anonymise your data after the storage or processing period has expired, as part of our usual procedures.

We delete the copy of your identity document, which we need for import and registration, as soon as the order is completed. You can delete your user account yourself at any time, on the website as well as in the app under «My area».

10. How do we protect your data?

We take appropriate security measures to preserve the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to counter the risks of loss, unintended alteration, unwanted disclosure or unauthorised access.

Technical and organisational security measures include, for example, access restrictions, the storage of backups, instructions to our staff, confidentiality agreements and controls. We protect the data you transmit via our website and platform in transit using appropriate encryption. Identity documents and signed purchase contracts are kept in areas that are not publicly accessible. We can, however, only secure areas that we control. We also require our processors to take appropriate security measures. Security risks can generally not be ruled out entirely; residual risks are unavoidable.

11. What rights do you have?

Applicable data protection law grants you, in certain circumstances, the right to object to the processing of your data, in particular processing for direct marketing purposes and for other legitimate interests.

To make it easier for you to control the processing of your personal data, you also have the following rights, depending on the applicable data protection law:

The right to request information from us about whether and what data we process about you;
the right to have data corrected if it is inaccurate;
the right to request the deletion of data;
the right to request that we hand over certain personal data in a commonly used electronic format or transfer it to another controller;
the right to withdraw consent where our processing is based on your consent;
the right to receive, on request, further information needed to exercise these rights.

If you wish to exercise one of these rights, please contact us in writing or, unless stated or agreed otherwise, by email; our contact details are in Section 2. If there is doubt about your identity in an individual case, we may request suitable proof of identity in order to prevent misuse.

Please note that conditions, exceptions or limitations apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where relevant.

If you are not satisfied with how we handle your data or your rights, please tell us (Section 2). You may also contact the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Bern; its contact details are available at www.edoeb.admin.ch. If you are in the EEA or the United Kingdom, you may also contact the data protection supervisory authority of your country.

12. Do we use online tracking and advertising technologies?

This section concerns our website only. None of the services mentioned here is loaded in our App Store app; what applies in the app is set out in Section 13.

For everything that is not technically necessary we ask first. On your first visit a banner appears at the bottom of the screen with three ways forward: «Accept», «Decline» and «Settings». Under «Settings» you see the individual items; the box for advertising measurement is empty from the outset, you have to tick it yourself. As long as you have not agreed, no measurement service is loaded – not even if you simply leave the banner standing. All we store is your answer itself, so that we do not have to ask again on every page.

Your decision does not stand for ever: in the footer of every page the item «Privacy settings» opens the same banner again, and you can change your choice there at any time. A withdrawal takes effect for the future; what happened with your consent up to that point remains lawful. A script that has already been loaded cannot be removed from the page as it stands – reload the page once after withdrawing and it is gone.

Necessary storage on your device: So that the website works, your browser stores small amounts of data (cookies and comparable storage). The necessary ones keep you signed in, remember your language setting, retain your filters and your watchlist and prevent entries from being lost when you move between pages. Without them the website does not work properly. This information stays with us and is not passed on to third parties.
Our own visit counter: We count ourselves how often a vehicle listing is called up, how long it is viewed, how many pictures are looked at and how the visit came about. For this your device is given a random identifier on the first visit which remains stored there; in addition we record your IP address only as a non-reversible checksum, along with your browser identification and the country. This evaluation serves solely to align our stock better with what people are looking for. We do not pass it on and do not combine it with data from other providers.
Google Ads (only with your consent): A measurement service from Google (Google Ads) tells us whether our advertising reaches people who are actually looking for a vehicle. The only legal basis for this is your consent: the script is not put into the page until you have agreed in the banner. If you decline or leave the banner unanswered, nothing is loaded and no request goes to Google either. If you have agreed, Google processes technical details such as device type, browser and approximate location, and receives your IP address in the process. The provider is Google Ireland Ltd., based in Ireland, which relies on Google LLC in the USA; your data may therefore end up in the USA. You can take your agreement back at any time via «Privacy settings» in the footer. Information on data protection at Google: policies.google.com/privacy
Hosting by Lovable: Our website is built and hosted on the platform of Lovable Labs. On access, Lovable automatically collects technical data such as IP address, browser type, operating system, device identifiers, pages visited, timestamps and error logs, and keeps log data for up to 90 days. Your data may be transferred to the USA and to Sweden. Information on data protection at Lovable: lovable.dev/privacy

Regardless of the banner, you can set your browser to block or delete cookies and add extensions that block such measurement services. You will find details on your browser's help pages, usually under the heading of privacy. You can also contact us at any time using the details in Section 2.

13. What applies additionally to our app?

Our iPhone app shows the same vehicles as the website. You only need an account for the watchlist, orders and notifications; searching and browsing works without signing in.

Notifications: With your consent we store an identifier for your device so that we can tell you the status of an order or notify you of a price reduction. Both kinds can be switched off separately in your account; without consent nothing happens.
Camera and photos: The app accesses your camera or photos only when you upload something yourself – a profile picture, documents for your order or, for the purchase contract, an image of your identity document. It does not go through your photos on its own.
Location, contacts and other apps: The app does not access your device's location services (no GPS), does not access your contacts and does not read data from other apps. So that we can show you vehicles and delivery costs near you, we estimate your region from your IP address. You can override that estimate at any time by entering a postcode.
Advertising: No advertising measurement service is loaded in the app. We do not track you across other apps or websites and pass nothing on to advertising networks.
Deleting your account: Any account you create in the app can also be deleted there – under «My area – Delete account», without going through support.

14. Can this privacy policy be changed?

This privacy policy is not part of a contract with you. We may amend it at any time. The version published on this website is the current one.

Last updated: 11 September 2026