[← Back to home](https://wattmatch.ch/) Legal document # Privacy policy WattMatch Platform: Local Electricity Community services Version 2.2, 11 August 2026 **Data controller** **Entity** WattMatch SA **Address** PO Box, 1701 Fribourg **E-mail** privacy@wattmatch.ch **Legal basis** Federal Act on Data Protection (FADP); art. 17j para. 1 ElA for metering data ## 1. Purpose and scope This Privacy Policy describes how WattMatch SA (hereinafter “WattMatch”) collects, processes, retains and protects the personal data of persons using the WattMatch Platform (hereinafter the “Platform”), in particular in connection with the creation and management of Local Electricity Communities (LEC) within the meaning of articles 17d et seq. of the Electricity Supply Act (ElA). It applies to all Participants—whether Producers, Consumers or Prosumers—as well as to any person browsing the Platform or contacting WattMatch. This policy supplements the General Terms of Use (Terms) and the WattMatch Usage Contract, with which it forms a single contractual set. In the event of any contradiction between these documents, the following order of precedence applies without exception: (1) the Contract; (2) the Terms; (3) this Privacy Policy; (4) the tariff annex. ## 2. Applicable legal framework The processing of personal data by WattMatch is governed by: - the Federal Act on Data Protection (FADP) of 25 September 2020 and its implementing ordinances (DPO); - article 17j para. 1 ElA, which declares the FADP applicable to the processing of data relating to smart metering systems and extends it by analogy to data concerning legal entities. Article 17j para. 2 ElA, which authorises a processing operation, concerns the operator of the central data exchange platform within the meaning of articles 17f to 17i ElA and does not apply to WattMatch. The FADP protects only the data of natural persons. However, in accordance with article 17j para. 1 ElA, metering data relating to legal entities enjoys analogous protection in the LEC context. Where a consumption site belongs to a condominium (PPE) or to a legal entity, this Policy applies by analogy to the data concerned. ## 3. Personal data collected WattMatch collects and processes the following categories of data depending on the Participant's profile and interactions: ### 3.1 Identification data - Surname and first name - Full postal address - E-mail address - Telephone number ### 3.2 Location and connection data - Address of the electricity connection point(s) - Postal code and municipality - Number(s) of the metering point(s) (MP) assigned by the Distribution System Operator (DSO) - Connection capacity (kVA) ### 3.3 Technical data relating to the installation - Type and characteristics of the production installation (e.g. PV peak power, orientation) - Characteristics of any storage system - Operating status of the installation ### 3.4 Energy metering data - Load curves at 15-minute intervals - Aggregated and detailed consumption and production data - Data transmitted by the DSO in accordance with the ElA ### 3.5 Billing and financial data - Amounts invoiced and paid in respect of LEC Electricity and WattMatch service fees - History of transactions and payments - Bank or payment details, where applicable ### 3.6 Platform usage data - Connection data (identifier, date, time, IP address) - History of interactions with the Platform (views, settings) - Preferences and account settings ### 3.7 Communication data - Exchanges by e-mail, contact form or via the Platform - Notifications and acknowledgements of receipt ### 3.8 Audience measurement of shared presentations When a person opens a link to a WattMatch commercial presentation (“pitch deck”) that WattMatch has sent them, the Platform records anonymous reading statistics: time spent per section, progress through the presentation and, where applicable, the referring website. No cookie or other tracker is placed on the recipient's device. In order to estimate the number of distinct networks that have viewed a given link, a pseudonymised indicator is computed from the IP address (a salted cryptographic fingerprint specific to each link). The IP address itself is never retained. This processing is based on WattMatch's legitimate interest (art. 31 FADP) in measuring the effectiveness of its presentations. ### 3.9 Advertising measurement data When a visitor reaches the Platform from an online advertisement, a click identifier is placed on their device and, where applicable, linked to the sign-up or enquiry that results from it. On its own, this identifier does not allow WattMatch to identify the visitor, and it is never associated with their account data. The details and the right to object are described in section 10.3. ## 4. Purposes and legal bases of processing Each processing operation is based on a clearly identified legal basis: | **Purpose** | **Data concerned** | **Legal basis** | | --- | --- | --- | | Creation and management of the LEC | Identification, location, technical, metering | Performance of the contract and statutory obligations (ElA; art. 31 para. 2 let. a FADP) | | Representation vis-à-vis the DSO | MP, technical, entries/exits | Statutory obligation of the representative (art. 19g para. 1 ElO) | | Invoicing of LEC Electricity | Metering, billing | Performance of the contract | | Provision of the dashboard | Metering, platform usage | Performance of the contract / legitimate interest | | Communication with Participants | Identification, communication | Performance of the contract | | Legal and tax compliance | Billing, identification | Statutory obligation | | Platform security | Connection data, IP | Overriding legitimate interest (art. 31 para. 1 FADP) | | Audience measurement of shared presentations | Reading statistics, pseudonymised IP fingerprint | Overriding legitimate interest (art. 31 para. 1 FADP) | | Measuring the effectiveness of advertising campaigns | Advertising click identifier, page visited, technical connection data | Overriding legitimate interest (art. 31 para. 1 FADP) | ### 4.1 Profiling The processing of load curves at 15-minute intervals (section 3.4) constitutes profiling within the meaning of article 5 let. f FADP: it makes it possible to evaluate certain personal aspects of the Participant, in particular their consumption habits and periods of presence. This processing is necessary for the allocation of LEC Electricity and the internal settlement of the LEC, and is limited to those purposes. Insofar as this processing is liable to constitute high-risk profiling within the meaning of article 5 let. g FADP, the Participant expressly consents to it upon registration, in accordance with article 6 para. 7 let. b FADP. This consent may be withdrawn at any time, under the conditions set out in article 6.11 of the Terms. ## 5. Sharing data with third parties ### 5.1 Transmission to the Distribution System Operator (DSO) As LEC Representative, WattMatch is required to transmit the following data to the competent DSO (Groupe E, Romande Energie, SIG, etc.), in accordance with the ElA: - the complete list of the Participants' metering points (MP); - the technical data of the production and storage installations; - notifications of entries and exits of Participants (within the statutory one-month deadline); - applications for the creation, modification and dissolution of the LEC (statutory deadline of 3 months); - any other data required by the DSO or by the regulations. This transmission constitutes a statutory and contractual obligation. The Participant expressly consents to it upon registration. ### 5.2 Visibility between Participants of the same LEC Subject to the Participant's prior, separate and explicit consent, disabled by default (opt-in), the following information may be made visible to the other Participants of the same LEC and, where applicable, to users of the WattMatch Platform located in the same geographical area: - First name and initial of the surname; - Role within the LEC (Producer, Consumer or Prosumer); - Municipality and location; - Participation status (registered, pending, active). Aggregated and anonymised data relating to the LEC (number of participants, volume of energy exchanged, savings achieved) may be published on the Platform and used for communication purposes by WattMatch and the municipality concerned. The Participant may at any time enable or disable their public visibility, and withdraw their consent, from their personal area or by contacting WattMatch, without this affecting the data necessary for the operation of the LEC transmitted to the DSO. ### 5.3 Service providers WattMatch may call on third-party providers (hosting, IT maintenance, accounting, etc.) who process personal data on its behalf. These providers are bound by processing agreements compliant with the FADP and may use the data only for the expressly defined purposes. ### 5.4 Authorities and statutory obligations WattMatch may be required to disclose data to the competent authorities (tax authorities, regulators, courts) where this is required by law or by a court decision. ### 5.5 No sale or transfer of data WattMatch does not sell, rent or transfer for consideration any personal data to third parties for commercial or advertising purposes. ### 5.6 Advertising campaign measurement As part of measuring its advertising campaigns (section 10.3), WattMatch transmits an advertising click identifier, the address of the page visited and the technical connection data to Google Ireland Limited. Google acts in this respect as a separate controller for its own purposes, within the limits of the Google Ads data processing terms accepted by WattMatch. No identification, energy metering or billing data is transmitted to it. ## 6. International data transfers Participants' personal data is hosted in Switzerland or in the European Economic Area (EEA), in infrastructure located in States which the Federal Council has found to provide an adequate level of protection (article 16 para. 1 FADP and annex 1 DPO). In the event of a transfer to a third country not benefiting from an adequacy finding, WattMatch implements the appropriate safeguards (standard contractual clauses, etc.) in accordance with the requirements of the FADP. By way of exception to the above, the advertising measurement data described in section 10.3 may be processed in the United States by Google LLC. That company is certified under the Swiss-U.S. Data Privacy Framework, which the Federal Council has recognised as providing an adequate level of protection (art. 16 para. 1 FADP and annex 1 FADPO). ## 7. Data retention periods | **Data category** | **Retention period** | | --- | --- | | Identification and contact data | Duration of participation + 10 years (accounting and tax obligations) | | Energy metering data | 5 years from collection; however, data serving as supporting evidence for the invoicing of LEC Electricity is retained, in a frozen or aggregated form limited to that purpose, for 10 years (accounting obligations) | | Billing data | 10 years (accounting and tax obligations) | | Platform usage data | 3 years from the last active login | | Communication data | 5 years | | Data transmitted to the DSO | According to the DSO's rules and the ElA | | Presentation audience statistics | Retained for the duration of WattMatch's legitimate interest (measurement and historisation of engagement) | | Advertising click identifier | 90 days | Upon expiry of these periods, the data is irreversibly deleted or anonymised. ## 8. Rights of data subjects In accordance with the FADP, the Participant has the following rights concerning their personal data: ### 8.1 Right of access (art. 25 FADP) The Participant may ask at any time whether WattMatch processes data concerning them and, if so, obtain a copy of that data as well as information on the purposes and recipients of the processing. ### 8.2 Right to rectification (art. 32 FADP) The Participant may request the correction of inaccurate or incomplete data. ### 8.3 Right to erasure The Participant may request the deletion of their personal data, subject to statutory retention obligations and to data essential for the operation of the LEC. ### 8.4 Right to data portability The Participant may request to receive their data in a structured, commonly used and machine-readable format. ### 8.5 Right to object The Participant may object to processing based on WattMatch's legitimate interest, within the limits permitted by law. ### 8.6 Exercising rights To exercise any of these rights, the Participant shall send a written request to WattMatch: **By e-mail** privacy@wattmatch.ch **By post** WattMatch SA—PO Box, 1701 Fribourg WattMatch will respond within 30 days. This period may be extended by a further 30 days in the case of complex requests, with prior notification to the Participant. If the response is unsatisfactory, the Participant may lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC): www.edoeb.admin.ch ## 9. Data security WattMatch implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with art. 8 FADP and the provisions of the DPO: - Encryption of data in transit (TLS/HTTPS) and at rest; - Strict access control (strong authentication, role-based rights management); - Logging of access and changes; - Regular backups and business continuity plan; - Periodic security assessments and audits; - Staff training in good data protection practices. In the event of a data breach liable to give rise to a high risk to the rights and freedoms of data subjects, WattMatch will notify the FDPIC as soon as possible, in accordance with article 24 FADP, and will inform the Participants concerned where this is necessary for their protection. ## 10. Cookies and trackers ### 10.1 Technical cookies The WattMatch Platform uses technical cookies and trackers necessary for its proper functioning: session and authentication management, security, and storage of the selected language. These cookies are essential to the operation of the Platform and cannot be disabled from within it. ### 10.2 Audience measurement WattMatch measures Platform traffic using a self-hosted Matomo instance, configured without cookies and with IP address anonymisation. These statistics are not shared with any third party. ### 10.3 Advertising cookies for measurement purposes When WattMatch runs online advertising campaigns, the Platform places a measurement cookie provided by Google on the visitor's device. The sole purpose of this cookie is to attribute a sign-up or an enquiry to the advertising campaign it originated from, so that WattMatch can measure the effectiveness of its advertising spend. This processing is strictly limited to measurement. WattMatch enables neither ad personalisation, nor advertising retargeting, nor the building of audiences from browsing behaviour. No behavioural profile is created. No data from the Participant's account, in particular their identity, address, energy metering data and billing data, is transmitted to Google for this purpose. The data processed on this occasion is limited to an advertising click identifier, the address of the page visited and the technical data inherent to any internet connection (IP address, browser type). It is transmitted to Google Ireland Limited and may be processed by Google LLC in the United States, under the conditions described in section 6. This processing is based on WattMatch's overriding legitimate interest (art. 31 para. 1 FADP) in measuring the effectiveness of its advertising campaigns. | **Cookie** | **Issuer** | **Purpose** | **Duration** | | --- | --- | --- | --- | | \_gcl\_au | Google | Attribute a conversion to the advertising campaign that generated it | 90 days | | wm\_ads\_optout | WattMatch | Store the refusal of advertising measurement | 12 months | ### 10.4 Right to object Visitors may object at any time, without giving reasons, to the placing of the advertising measurement cookie, using the « Refuse advertising measurement » button at the end of this section. The objection takes effect immediately and has no consequence on access to the Platform, on the features available, or on the Participant's rights. It is stored on the device used: it must be renewed if the visitor changes device or browser, or clears their browser cookies. Visitors may also configure their browser to refuse all or some cookies, on the understanding that certain features of the Platform may then no longer be available. Refuse advertising measurement ## 11. Minors The WattMatch Platform is intended for persons of legal age (18 years and over) or for legal entities. WattMatch does not knowingly collect personal data relating to minors. If WattMatch finds that a minor has registered without the consent of their legal representatives, the data concerned will be deleted. ## 12. Amendments to the privacy policy WattMatch reserves the right to amend this Privacy Policy at any time in order to reflect legislative, regulatory or service-related developments. Amendment of this Policy is governed by article 7.7 of the Contract. Amendments are notified to Participants by e-mail and/or via the Platform at least thirty (30) days before they enter into force. Any amendment affecting the scope of the data processed is deemed substantial within the meaning of article 7.7 of the Contract and gives rise to the right to terminate the Contract free of charge provided for therein. The date of the last update is indicated at the top of the document. Continued use of the Platform after the amendments enter into force constitutes acceptance of the amended policy. ## 13. Data protection contact For any question relating to this Privacy Policy or to the processing of your personal data, you may contact WattMatch: **WattMatch SA** PO Box, 1701 Fribourg **E-mail** privacy@wattmatch.ch **Website** www.wattmatch.ch **Related documents** [Terms of service](https://wattmatch.ch/conditions-generales)[Contract](https://wattmatch.ch/contrat)