Your data,
plainly.

Data Controller

The entity responsible for the processing of your personal data is:

CHUNNWERK, Einzelfirma
Trevis Chunn
Windisch, Aargau, Switzerland
Email: info@chunnwerk.ch

What Data We Collect

Depending on the service requested, we may collect the following categories of personal data:

• Contact Information: name, email address, phone number, Instagram handle
• Photographs: facial and full-body images, at least 20 photos per client (10 close-ups, 6 half-length, 4 full-length), submitted for visual identity production
• Biometric Data: facial geometry extracted by our AI pipeline for the sole purpose of visual identity production; not used for identification or surveillance
• Application & Intake Data: questionnaire responses, self-identified gender, selected category or project type
• Technical Data: browser type, IP address, portal access logs

Why We Process Your Data

Service Delivery: We process your data to evaluate your application, develop creative concepts, deliver final visual assets, and communicate with you throughout the project.

The legal bases we rely on are:

• Contract performance (Art. 6(1)(b) GDPR / Swiss nFADP): processing necessary to perform the service you requested
• Consent (Art. 6(1)(a) GDPR / Swiss nFADP): for biometric data and any sensitive processing, we obtain your explicit consent
• Legitimate interest (Art. 6(1)(f) GDPR / Swiss nFADP): for technical security, portal logs, and fraud prevention

Data Retention

• Applications (not accepted): deleted after 1 year
• Photographs, intake data, and generated visual outputs: retained for 30 days post-delivery, after which they are permanently deleted from our systems
• Final delivered images: retained for up to 5 years with your consent, for portfolio or quality reference purposes
• Portal login data (passcode, session info): retained only for the duration of your active project plus 30 days
• Technical logs: deleted after 90 days
• Email correspondence: retained for 2 years

You may request earlier deletion of your data at any time by contacting info@chunnwerk.ch. Deletion requests are honoured within 30 days.

Biometric Likeness Processing

The CHUNNWERK creative pipeline uses your photographs to train identity-locked AI agents (personas) that generate your visual identity outputs. This process involves biometric data under Swiss nDSG Art. 5(c) and EU GDPR Art. 9.

Specifically:

• Your uploaded photographs are used to train a personalised AI persona that recognises and preserves your likeness.
• Generated images are produced from this persona and will resemble you.
• The persona training data remains linked to your project folder and is subject to the 30-day retention period described in Section 6.
• Trained persona agents are not shared across clients. Each client has a dedicated, isolated persona tied only to their project.

By submitting photographs through our application or intake forms, you provide explicit consent for CHUNNWERK to:

• Process your biometric data (photographic likeness) for the purpose of visual identity creation.
• Transfer biometric data to the international service providers listed in Section 8 (International Data Transfers).
• Generate likeness-bearing outputs that you receive as the end deliverable.

You may withdraw this consent at any time by emailing info@chunnwerk.ch. Withdrawal results in immediate cessation of processing and deletion of biometric data and trained personas within 30 days.

CHUNNWERK services are not offered to minors. If you are under 18, do not submit photographs through our application or intake forms.

AI Processing

CHUNNWERK operates a proprietary AI pipeline to create your visual identity. This pipeline uses third-party AI services for specific tasks, including image analysis, content classification, creative text generation, and identity-locked image generation. The full list of service providers is disclosed in Section 5 (Third-Party Processors) and Section 8 (International Data Transfers).

No AI-generated content is published or delivered to you without prior human review by the CHUNNWERK creative director.

Your photographs are used exclusively to train a dedicated, isolated AI persona for your project. This persona generates your visual identity outputs and is not shared with any other client. Full details of this biometric processing are described in Section 7 (Biometric Likeness Processing).

Third-Party Processors

We share data with the following sub-processors under appropriate data processing agreements:

Processor	Purpose	Location
Google Workspace	File storage, project management	EU / US
Google Cloud (Gemini)	Image analysis and classification	EU / US
Anthropic Claude	Creative text generation (no photos transmitted)	US
Netlify	Website and portal hosting	US
Resend	Transactional email delivery	US
OpenAI	Image generation, persona agents	US
Higgsfield	Identity-locked image generation	US
Artlist	Licensed creative assets	US / Israel

International Data Transfers

CHUNNWERK is based in Switzerland (Einzelfirma, Aargau). Your data is processed by Swiss-based CHUNNWERK and may be transferred to the following service providers:

• Google Workspace (Drive, Gmail, Apps Script): file storage, project management, email (United States)
• Google AI (Gemini): image analysis and classification (United States)
• Anthropic (Claude): creative text generation, no photos transmitted (United States)
• OpenAI: image generation, persona agents (United States)
• Higgsfield: identity-locked image generation (United States)
• Artlist: licensed creative assets (United States / Israel)
• Netlify: website and portal hosting (United States)
• Resend: transactional email delivery (United States)

These transfers are conducted under the Swiss–US Data Privacy Framework (DPF) and, where applicable, Standard Contractual Clauses (SCCs) approved by the European Commission. Processing occurs under contractual data protection guarantees equivalent to Swiss law (nDSG Art. 16–17).

If you do not consent to this cross-border transfer, please do not submit your application.

Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• TLS/HTTPS encryption for all data in transit
• Passcode-protected client portals
• Restricted access: only the project team accesses client files
• Regular review of security practices and processor relationships

Your Rights

Under the Swiss nFADP and, where applicable, the GDPR, you have the right to:

• Access: request a copy of the personal data we hold about you
• Rectification: request correction of inaccurate or incomplete data
• Deletion: request erasure of your personal data, subject to legal retention obligations
• Portability: receive your data in a structured, machine-readable format
• Objection: object to processing based on legitimate interest
• Withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior processing
• Lodge a complaint: with the Federal Data Protection and Information Commissioner (FDPIC)

To exercise any of these rights, contact us at info@chunnwerk.ch. We will respond within 30 days.

Marketing Communications

We only send marketing communications to individuals who have explicitly opted in. You may unsubscribe at any time by emailing info@chunnwerk.ch or by clicking the unsubscribe link in any marketing message.

Children

CHUNNWERK services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently received data from a minor, please contact us immediately and we will delete it.

Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be published at this URL with the updated date shown at the top. If changes are material, we will notify affected clients by email.

Cookies & Tracking

CHUNNWERK uses session storage only: exclusively to persist your portal passcode within a single browser session. This data is not transmitted to any server and is cleared when you close your browser tab.

We do not use advertising cookies, tracking pixels, or analytics services of any kind.

Contact

CHUNNWERK
Trevis Chunn
Windisch, Aargau, Switzerland
info@chunnwerk.ch

Supervisory Authority

Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1, 3003 Bern, Switzerland
edoeb.admin.ch