Website Privacy & Cookie Policy
Lucerne International School
Effective Date: 1 June 2025
Last Updated: 23 June 2025
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1. Introduction
Welcome to the Lucerne International School website. We are committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your personal information when you visit our website at https://lucerneinternationalschool.ch/
This privacy and cookie policy explains how we handle your personal data in accordance with the Swiss Federal Act on Data Protection (FADP), the EU General Data Protection Regulation (GDPR) where applicable, and other relevant privacy laws. It also includes digital advertising standards including Google Consent Mode and social media platforms.
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2. Who We Are
Data Controller:
Legal Entity: International School of Personalised Learning GmbH
Trading as: Lucerne International School
Address: Park 8, 6039 Root D4, Switzerland
Email: info@ispl.ch
Phone: +41 44 594 8280
Data Protection Enquiries:
For any questions about how we use your personal data, please contact us using the details above or email us directly at: info@ispl.ch
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3. Scope of this Policy
This privacy policy applies to:
• Our website: https://lucerneinternationalschool.ch/
• All associated web pages and digital platforms
• Data collected from website visitors, prospective students and parents
• Online advertising and social media interactions
• Cookie usage and tracking technologies
Legal Framework:
• Primary: Swiss Federal Act on Data Protection (FADP)
• Secondary: EU General Data Protection Regulation (GDPR) for EU residents
• Additional: Swiss Telecommunications Act for electronic communications
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4. Information we Collect
4.1 Information you Provide Directly
When you use our website or contact us, we may collect:
Enquiry and Contact Forms:
• Full name and contact details
• Email address and telephone number
• Current school information and academic background
• Student age/year group and gender
• Parental/guardian contact details
• How you heard about Lucerne International School
• Specific questions or information requests
Newsletter and Communications:
• Email address and communication preferences
• Name and preferred language
• Areas of interest (admissions, events, school news)
4.2 Information we Collect Automatically
Technical Data:
• IP address and approximate location
• Device type, browser, and operating system
• Pages visited and time spent on our website
• Referring website and search terms used
• Click-through rates and user interactions
Cookies and Tracking Technologies:
• Essential website functionality cookies
• Analytics and performance tracking
• Advertising and marketing cookies
• Social media integration pixels
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5. How we Use your Information
5.1 Website Functionality and Communication
Responding to Enquiries:
• Processing and responding to your questions about our school
• Providing requested information about admissions, programmes, and services
• Following up on your interest to ensure we’ve answered your questions adequately
Website Operations:
• Ensuring our website functions properly and securely
• Providing personalised content and improved user experience
• Technical support and website maintenance
5.2 Marketing and Advertising
Direct Marketing:
• Sending school newsletters and updates (with your consent)
• Inviting you to open days, events, and school activities
• Providing information about new programmes or services
Online Advertising:
• Displaying relevant advertisements on Google and social media platforms
• Retargeting website visitors with relevant school content
• Measuring advertising effectiveness and campaign performance
• Creating lookalike audiences for advertising purposes
Social Media Engagement:
• Sharing content and interacting on Facebook, Instagram, LinkedIn, and other platforms
• Analysing social media engagement and reach
• Building our online community and school presence
5.3 Analytics and Improvement
Website Analytics:
• Understanding how visitors use our website
• Identifying popular content and user journeys
• Improving website design and functionality
• Measuring conversion rates and engagement
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6. Legal Basis for Processing
6.1 Under Swiss FADP
We process your personal data based on:
• Consent: Marketing communications, advertising cookies, newsletter subscriptions
• Contract: Responding to enquiries about educational services
• Legitimate Interest: Website analytics, security, improving our services
• Legal Obligation: Compliance with Swiss regulations and legal requirements
6.2 Under EU GDPR (for EU Residents)
• Article 6(1)(a): Consent for marketing, advertising, and non-essential cookies
• Article 6(1)(b): Contract performance for enquiry responses and service provision
• Article 6(1)(f): Legitimate interests for analytics, security, and service improvement
• Article 6(1)(c): Legal obligation for regulatory compliance
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7. Cookies and Tracking Technologies
7.1 Types of Cookies we Use
Necessary Cookies (Always Active)
Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
Cookie: wpEmojiSettingsSupports
Duration: Session
Purporse: WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly.
Cookie: cookieyes-consent
Duration: 1 year
Purpose: CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors.
Analytics Cookies (Require Consent)
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
Cookie: _ga
Duration: 1 year 1 month 4 days
Purpose: Google Analytics – tracks unique visitors
Cookie: _ga_*
Duration: 1 year 1 month 4 days
Purpose: Google Analytics – stores page view counts
Cookie:_gcl_au
Duration: 3 months Google conversion tracking for advertising
Purporse: Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.
Marketing/Advertising Cookies (Require Consent)
Advertisement cookies are used to provide visitors with customised advertisements based on the pages you visited previously and to analyse the effectiveness of the ad campaigns.
Cookie: IDE
Duration: 1 year 24 days
Purpose: Google DoubleClick IDE cookies store information about how the user uses the website to present them with relevant ads according to the user profile
Cookie: test_cookie
Duration: 15 minutes Tests if browser supports cookies
Purpose: doubleclick.net sets this cookie to determine if the user’s browser supports cookies.
7.2 Third-Party Services and Tracking
Google Services:
• Google Analytics: Website usage analysis and reporting
• Google Ads: Online advertising and remarketing campaigns
• Google Tag Manager: Managing website tags and tracking codes
• YouTube: Embedded videos and content
Social Media Platforms:
• Facebook/Meta: Advertising, analytics, and social media integration
• Instagram: Content sharing and social media advertising
• LinkedIn: Professional networking and targeted advertising
• Twitter/X: Social media engagement and content sharing
Other Services:
• Hotjar: User behaviour analytics and feedback (if implemented)
• Microsoft Clarity: Website analytics and user session recordings (if implemented)
7.3 Cookie Consent Management
Consent Banner:
• Displayed prominently on your first visit
• Clear options to accept, reject, or customise cookie settings
• Information about what each cookie category does
Your Cookie Choices:
• Accept All: Enable all cookies for full functionality and personalised experience
• Reject Non-Essential: Only essential cookies for basic website operation
• Manage Preferences: Choose specific cookie categories
• Change Anytime: Update your preferences through our cookie settings
Consent Withdrawal:
• Easy access to cookie preferences at any time
• Clear instructions for opting out of advertising cookies
• Contact details for additional support
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8. Online Advertising and Social Media
8.1 Google Advertising
Google Ads Campaign:
• We run targeted advertising campaigns through Google Ads
• Ads are shown to people searching for international schools in Switzerland
• We may retarget website visitors with relevant school information
• Geographic targeting focuses on families in Central Switzerland and internationally
Conversion Tracking:
• We track which ads lead to website visits and enquiries
• This helps us improve our advertising effectiveness
• No personally identifiable information is shared with Google without consent
8.2 Social Media Advertising
Facebook and Instagram:
• Targeted advertising to parents and families interested in international education
• Lookalike audiences based on existing community members
• Event promotion and school news sharing
• Community building and engagement
LinkedIn:
• Professional networking for international families
• Targeted content for expatriate professionals
• Alumni and staff networking
Privacy Protection:
• We do not share personally identifiable information with social media platforms without explicit consent
• Social media tracking is based on anonymous user behaviour
• You can opt out of targeted advertising through platform settings
8.3 Advertising Data Usage
Anonymous Analytics:
• Aggregate website usage statistics
• Advertising campaign performance metrics
• Demographic insights (age ranges, general location, interests)
Personalised Advertising:
• Only with your explicit consent through cookie preferences
• Based on website pages visited and content engaged with
• Respectful of your stated interests and preferences
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9. Data Sharing and International Transfers
9.1 Third-Party Service Providers
We share data with trusted service providers who help us operate our website and marketing:
Google (USA):
• Analytics, advertising, and email services
• Adequacy protection through EU-US Data Privacy Framework
Meta/Facebook (USA):
• Social media advertising and analytics
• Standard Contractual Clauses for data protection
Microsoft (USA):
• Cloud services and productivity tools
• EU Data Boundary commitments for data protection
9.2 Data Transfer Safeguards
For Swiss Residents:
• Transfers only to countries with adequate protection levels
• Standard Contractual Clauses where adequacy decisions don’t exist
• Your consent for specific transfers where required
For EU Residents:
• EU Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• GDPR Article 49 derogations for specific situations
9.3 No Third-Party Marketing
We never sell, rent, or share your personal information with third parties for their own marketing purposes. Your data is only shared with service providers who help us deliver our services to you.
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10. Data Retention
Data Type Retention Period Reason
Website enquiries 2 years after last contact Follow-up and service improvement
Marketing consents Until withdrawn + 2 years Legal compliance and consent records
Website analytics 26 months maximum Google Analytics standard retention
Email communications Until unsubscribed + 1 year Communication preferences
Cookie preferences 1 year Respect your choices on repeat visits
Automatic Deletion:
• Data is automatically deleted when retention periods expire
• You can request earlier deletion by contacting us
• Essential records may be retained longer for legal compliance
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11. Your Privacy Rights
11.1 Rights Under Swiss FADP
Right to Information:
• Know if your personal data is being processed
• Understand the purposes and legal basis for processing
• Information about data recipients and retention periods
Right of Access:
• Obtain a copy of your personal data
• Information about data sources and automated decision-making
• Free access within 30 days (unless disproportionate effort required)
Right to Rectification:
• Correction of inaccurate personal data
• Completion of incomplete information
Right to Erasure:
• Deletion when data is no longer necessary
• Deletion when processing is unlawful
• Deletion when consent is withdrawn
Right to Object:
• Object to direct marketing (always)
• Object to automated decision-making
• Object to processing based on legitimate interests
11.2 Additional Rights Under GDPR (EU Residents)
Right to Data Portability:
• Receive your data in a machine-readable format
• Transfer data to another service provider
Right to Restriction:
• Temporarily limit processing in specific circumstances
• Dispute resolution during complaint processes
11.3 Special Rights for Children
Under 16 Years:
• Parental consent required for data processing under GDPR
• Enhanced protection for sensitive information
• Right for parents to access and control child’s data
16-18 Years:
• Students may exercise their own privacy rights
• Parents may still be consulted on important matters
• Clear, age-appropriate privacy information provided
11.4 How to Exercise Your Rights
Contact Methods:
Email: dpo@ispl.ch or info@ispl.ch
Post: Data Protection Officer, Lucerne International School, Park 8, 6039 Root D4, Switzerland
Phone: +41 44 594 8280
In Person: Visit our school office during business hours
Response Time:
• Initial response within 30 days
• May be extended by 2 months for complex requests
• We’ll keep you informed of any delays
Identity Verification:
• We may request additional information to verify your identity
• This protects your data from unauthorised access
• We’ll explain what verification is needed
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12. Data Security
12.1 Technical Safeguards
Website Security:
• SSL/TLS encryption for all data transmission
• Regular security updates and patches
• Secure hosting with reputable providers
• Firewall protection and intrusion detection
Data Protection:
• Encryption of sensitive data at rest and in transit
• Access controls and authentication systems
• Regular security audits and vulnerability assessments
• Secure backup and recovery procedures
12.2 Organisational Measures
Staff Training:
• Regular privacy and data protection training
• Clear procedures for handling personal data
• Confidentiality agreements for all staff
• Incident response procedures
Vendor Management:
• Data processing agreements with all service providers
• Regular review of vendor security practices
• Due diligence on third-party data handling
12.3 Privacy by Design
Built-in Protection:
• Data minimisation – we only collect what we need
• Purpose limitation – data used only for stated purposes
• Privacy-friendly default settings
• Regular review of data processing activities
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13. Data Breach Response
13.1 Our Commitment
In the unlikely event of a data breach:
1. Immediate Response: Contain the breach and assess the risk
2. Investigation: Determine scope, cause, and potential impact
3. Notification: Inform authorities and affected individuals as required by law
4. Support: Provide assistance and guidance to affected individuals
5. Prevention: Implement measures to prevent future incidents
13.2 Notification Requirements
Swiss FDPIC: Within 72 hours for high-risk breaches
EU Authorities: Within 72 hours for GDPR-covered data
Affected Individuals: Direct notification for high-risk breaches
What we’ll Tell You:
• Nature of the breach and data involved
• Likely consequences and risks
• Measures taken to address the breach
• Steps you can take to protect yourself
• Our contact details for further information
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14. Children’s Privacy
14.1 Age Requirements
Under 13 Years:
• We do not knowingly collect personal data from children under 13 without parental consent
• If we discover such data, we will promptly delete it or obtain parental consent
• Parents may contact us to review or delete their child’s data
13-16 Years:
• Parental consent may be required under GDPR for EU residents
• We provide age-appropriate privacy information
• Enhanced protection for sensitive data
16+ Years:
• Students may generally provide their own consent
• Parents may still be informed of data processing activities
• Full privacy rights available to the student
14.2 Parental Controls
What Parents Can Do:
• Review the personal data we hold about their child
• Request correction or deletion of inaccurate data
• Withdraw consent for marketing communications
• Ask questions about how we use their child’s data
Our Safeguards:
• Enhanced security for children’s data
• Limited data collection focused on educational purposes
• No marketing to children without parental consent
• Clear, age-appropriate privacy notices
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15. Updates to This Policy
15.1 Policy Changes
We may update this privacy policy to reflect:
• Changes in applicable laws and regulations
• New website features or services
• Improvements to our privacy practices
• Feedback from users and regulatory authorities
15.2 How We Notify You
Minor Changes:
• Updated policy posted on our website
• New effective date clearly displayed
Significant Changes:
• Email notification to users who have provided contact details
• Website banner notification for 30 days
• New consent requested where required by law
15.3 Previous Versions
All previous versions of this policy are retained for compliance purposes and are available upon request.
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16. Contact Us and Complaints
16.1 Questions and Concerns
General Enquiries:
• Email: info@ispl.ch
• Phone: +41 44 594 8280
Privacy-Specific Enquiries:
• Email: info@ispl.ch
• Subject Line: “Privacy Enquiry” for faster processing
16.2 Complaint Process
Step 1: Contact Us
• Email us with details of your concern
• We’ll acknowledge your complaint within 2 business days
• Investigation and response within 30 days
Step 2: Escalation
• If unsatisfied with our response, request review by school leadership
• Additional investigation and response within 30 days
Step 3: External Complaint If you remain unsatisfied, you may complain to:
Swiss Residents:
• Federal Data Protection and Information Commissioner (FDPIC)
• Website: www.edoeb.admin.ch
• Email: info@edoeb.admin.ch
EU Residents:
• Your National Data Protection Authority
• Directory: www.edpb.europa.eu
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17. Additional Information
17.1 Marketing Opt-Out
Easy Unsubscribe:
• Click “unsubscribe” in any marketing email
• Contact us directly to opt out of all marketing
• Update your preferences through our website (when available)
• Your opt-out will be processed within 5 business days
17.2 Website Accessibility
This privacy policy is available in:
• English (primary version)
• German and French (translations available on request)
• Alternative formats for accessibility needs
17.3 Third-Party Links
Our website may contain links to other websites. This privacy policy only applies to our website. We encourage you to read the privacy policies of any linked websites you visit.
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Document Information
Document ID: LIS-PRIVACY-WEB-2025-001
Approved By: School Director
Next Review: June 2026
Language Versions: English (primary), German and French available upon request
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Contact for Policy Enquiries:
Email: info@ispl.ch
Post: Data Protection Officer, Lucerne International School, Park 8, 6039 Root D4, Switzerland
This policy was last updated on 23 June 2025 and is reviewed annually to ensure continued compliance with applicable laws and best practices.