Schutzengelstrasse 36
6340 Baar/ZG

UID-Register: CHE‑446.131.459


represented by: Andrij Sytnyk (CEO)
Responsible for webcontent: Marcel Strothmann

Privacy Policy

Privacy Policy regarding the Ambitorio application Ambitorio.SEND

AMBITORIO AG, Schutzengelstrasse 36, CH-6340 Baar, email: (hereinafter referred to as “AMBITORIO”) provides with the product Ambitorio.SEND an application for secure data exchange.

AMBITORIO is the controller of your personal data under the General Data Protection Regulation. Signing up for and using our service is performed via our website or by using our applications. The term app, application or applications is used to refer to all forms with Ambitorio’s software products and the product Ambitorio.SEND. The protection of your data is important to AMBITORIO AG.

The German version of this Privacy Policy controls.

Table of Contents

A – Type of Data Processed.

B – Processing of Personal Data of Children under 16 Years of Age.

C – Purposes of the Processing of Personal Data.

D – Legal Basis for the Processing of Personal data, the compulsory/voluntary provision of Personal Data and the Consequences of Nonprovision.

E – Disclosure of Data.

F – Data Transmission.

G – Storage Period of Personal Data.

H – Rights of Data Subjects.

I – Google Analytics.

J – Modification of the Privacy Policy.


For any concerns regarding our applications, please contact our data protection officer at

A – Type of Data Processed

We collect the following types of personal data:

1. Identification-, contact- or other personal data

If you use an account previously provided by CORELEDGER via the Identity Server* to log into the Application, AMBITORIO will be able to view the following information about you according to your specifications: first name, last name, gender, contact details, month and year of birth, shipping address, payment method and age of the recipient in case of purchasing of goods and/or services. Other data could be generated in the management of all relationships through the use of the Application.

*CORELEDGER AG – im alten Riet 102 – LI- 9494 Schaan, Tel. +423 770 01 97 (hereinafter “CORELEDGER”) provides a service for user authentication with its Identity Services.

2. Personal data stored exclusively on servers of AMBITORIO

AMBITORIO designs its products to minimize the amout of personal data collected. In order to enable and simplify the operation of the application, the following data can be stored on the servers of AMBITORIO according to the information provided: user name, images used as avatars, e-mail addresses, generic UUIDs, generic cryptographic keys, first name, last name, gender, contact details, month and year of birth, shipping address, payment method, as well as the names of uploaded files and possibly their metadata such as: additional names, file size, timestamps, hashes, IDs and numbers, and nature (type of file).

3. Uploads by users

The main purpose of the application is to enable data transfer. For this purpose, users perform uploads which are encrypted locally on the sending systems and then transferred to AMBITORIO. While the actual files cannot be viewed without the uploader’s consent, the associated metadata can be deliberately viewed by third parties. This information is not collected by AMBITORIO in order to be assigned to data subjects; nevertheless, by its very nature, it could contribute to the identification of data subjects.

4. Identification-, contact- or other personal data

When you create an account to log into the application, AMBITORIO may ask you for the following information: First name, last name, gender, contact details, month and year of birth, shipping address, payment method, and age of the recipient in the event of purchasing goods and/or services; Additional information may be collected in the management of all relationships through the use of the application.

5. Navigation Data and logfiles

The computer systems and software used for the Application, collect data that is included due to the use of Internet communication protocols. This information is not collected by AMBITORIO in order to be associated with data subjects; nevertheless, by its nature it could contribute to the identification of data subjects. This category of data includes the IP addresses or domain names of the computers used by users when they connect to the application, URI (Uniform Resource Identifier) addresses, addresses of the services requested, the time of the request, the method used to direct the request to the server, the size of the file received in response, the numerical code indicating the status of the response sent by the server (good result, error, etc.) and other parameters related to the user’s operating system and computer.

From this data, we collect anonymous statistical information regarding the use of the application, to verify its proper functioning and to identify anomalies and/or misuse.

B – Processing of Personal Data of Children under 16 Years of Age

Children under the age of 16 or under the age set by national legislation at which they can give their consent to the processing themselves, or in any case no younger than 13 years of age, may not register for the applications in order to access the areas reserved for the registered user.

Users who do not indicate their age will be treated as minors under the age of 16 or in accordance with the laws of the country they indicated when registering and may therefore not access the areas reserved for the registered user of the Applications. Children under the age of 18 may not purchase any goods or services on our application.

C – Purposes of the Processing of Personal Data

We will process your data for the following purposes:

Fulfilling the contractual obligations that we have towards you and you towards us, such as carrying out procedures relating to the management of our relations with you (e.g. managing responses to enquiries received via the contact forms; releasing password-protected areas in the applications; assisting with the loss of the login/password data of your personal account for the applications).
Fulfilling the contractual obligations that we have towards the partners of AMBITORIO, such as identifying and authenticating you as the legitimate user of the services of our Partner or multiple partners.
Operation our Application and ensuring the security of our Application.
Compliance with legal requirements.
Communicating concerning our business relationship.
Marketing of similar products or services if you use or have used a service in an application, or if you purchase or have purchased a product or service through the application.

D – Legal Basis for the Processing of Personal data, the compulsory/voluntary provision of Personal Data and the Consequences of Nonprovision.

We have various legal bases for processing your personal data

processing is necessary for the execution of a contractual relationship
processing is necessary for AMBITORIO to fulfill its legal obligations
processing is necessary for the purpose of our legitimate interests of AMBITORIO
processing is based on your consent

If you do not provide your personal data or provide inaccurate personal data, AMBITORIO cannot provide its service.

The provision of data and related processing for marketing purposes is based on your explicit consent, which you need to check on the specific checkbox. You are not obliged to give this consent to AMBITORIO and you are free to withdraw it at any time without consequences. You can revoke your consent for this purpose in accordance with the section “Rights of the data subjects”.

E – Disclosure of Data

Your personal Data may be disclosed to the employees of AMBITORIO or their contractors who are responsible for the development and administration of the applications as to partners, which contracted services from AMBITORIO. These employees, who are bound to secrecy or have received a corresponding legal obligation, are entitled to process this data in order to pursue the aforementioned objectives.

Data may be passed on, used and transferred for accounting and administrative purposes within the companies belonging to AMBITORIO or participating in AMBITORIO.

Data will be communicated to third parties who are used as data processors and process data on behalf of AMBITORIO (e.g. companies responsible for the administration and processing of customer orders, suppliers such as hosting providers with whom it is necessary to cooperate for the purpose of providing services, platform providers for sending e-mails or suppliers who carry out technical maintenance, suppliers who develop interactive games and competitions).

Data may also be disclosed to third parties with whom AMBITORIO has an ongoing contractual relationship regarding services necessary for the performance (delivery services for the delivery of products, audit firms, persons or companies that support and advise us in this area).

Finally, data will be disclosed on request to the competent tax authorities or to other public bodies in accordance with the legislation in force.

F – Data Transmission

Some of your data may be passed on to recipients outside the European Economic Area (EEA). If your personal data is transferred out of the EAA, AMBITORIO will use the following safeguards to protect your personal data – adequacy decisions, or standard contractual clauses.

G – Storage Period of Personal Data

The data processed for the purpose of providing services and fulfilling contractual obligations will be stored by AMBITORIO only for the period of time necessary for the performance of the requested service and for the correct fulfillment of the contractual relationship with you. As these data are processed in order to provide you with the service and to fulfil the contract, AMBITORIO may store them for a longer period of time, in particular as long as may be necessary to protect AMBITORIO’s interests against possible claims arising from the provision of the service.

AMBITORIO will store data concerning orders and purchases for 24 months. AMBITORIO  will store your authentication data for the services of the application for up to 48 months from the last login. After the end of this period, the autentication data will be anonymized.

Your requests and the data they contain, collected through the Contacts/Customer Service section of the Applications, will be stored for one year after the request has been completed so that AMBITORIO can process any additional requests received after the request has been completed. At the end of this period, data enabling the identification (including indirect identification) of a natural person (such as first name, surname, e-mail) will anonymized and  stored only in the form of aggregated data for statistical purposes. The data processed for the purpose of complying with legal regulations (e.g. Datenschutzgesetz, Personen- und Gesellschaftsrecht (PGR), Allgemeines Bürgerliches Gesetzbuch (ABGB) or Steuergesetze and Steuerabkommen) will be stored by AMBITORIO for the period stipulated by law.

The data processed for marketing and profiling purposes will be stored by AMBITORIO until the date of revocation of consent. As soon as you have withdrawn your consent, AMBITORIO will no longer use your data for these purposes, but may restrict data processing, in particular for as long as may be necessary to protect AMBITORIO’s interests against possible claims arising from the provision of the service.

AMBITORIO informs you that in order to comply with the storage limitation, the data processed for marketing and profiling purposes will be retained for the purpose of calculating compliance with authentication data for a maximum of 48 months after the last login.

H – Rights of Data Subjects

As a data subject, may have one or more of the following rights:

to request information about your data (and/or a copy of such data).
to request the correction or updating of your data processed by AMBITORIO if they are incomplete or out of date.
to request the deletion of your data from AMBITORIO’s databases if their processing is unnecessary or unlawful.
to request AMBITORIO to limit the processing of your data if the data is inaccurate, unnecessary or unlawfully processed, or if you have already refused to do so.
to exercise data transferability (i.e. the right to obtain a copy of the personal data you have provided to AMBITORIO).
to refuse to process your personal data by using a legal basis relating to your particular situation which, in your opinion, prevents AMBITORIO from processing your personal data.
to withdraw your consent for marketing and profiling purposes and refuse processing for marketing purposes. We remind you that your explicit consent to send promotional communications for marketing and profiling purposes extends not only to automated systems without operator intervention (e.g. e-mail), but also to traditional contact methods such as postal mail. It is possible to withdraw consent to such processing at any time, even in separate ways. For example, you may decide to receive such communications only by post and not through automated systems such as e-mail.

Please note that the data you have provided to AMBITORIO can be changed at any time via the “Change data” section of the Application, alternatively via the “Account details” section of the Ambitorio App or by written notice to:

You may file a complaint with the competent supervisory authority if you believe that the processing of your personal data does not comply with the currently applicable legislation.

Should you require further information, you may contact AMBITORIO in writing at the following address:

I – Google Analytics

The Ambitorio Application uses the Firebase technology by Google. Firebase uses Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies.

The information generated by a cookie about the use of a website by a user is usually transferred to a Google server in the USA and stored there.

Google is certified under the US – EU and US – Switzerland Privacy-Shield-Agreements. (

Google will process thie cookie information on behalf of AMBITORIO to evaluate the use of the application by its users, to compile reports on the activities within the application and to provide AMBITORIO with further services related to the use of the application and the use of the Internet. The processed data can be used to create pseudonymous user profiles of the users.

AMBITORIO also uses Google Analytics with IP anonymization. This means the IP address of users is shortened by Google within member states of the EEA. Only in exceptional cases is the full IP address transferred to a Google server in the USA before being shortened.

The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link:

Further information on the use of data by Google, setting and objection options, can be found in Google’s privacy policy ( and in the settings for the display of advertising by Google  (

The personal data of users will be deleted or anonymized after 14 months.

J – Modification of the Privacy Policy

This version 1.1 of the privacy policy is valid starting 19. April 2020.

AMBITORIO reserves the right to partially or completely modify or update its content. AMBITORIO will inform you about these changes as soon as they are introduced.

Terms of Services

General Information

The use of the application “Ambitorio” and its (integrated or online downloaded) contents (hereinafter Ambitorio app ) requires the prior consent to the following usage agreement between Ambitorio AG, Schutzengelstrasse 36, 6340 Baar (hereinafter Ambitorio) as provider of the Ambitorio app and the user. We therefore ask you to read the user agreement for the Ambitorio app carefully before navigating on the Ambitorio app and using the services it offers.


The Ambitorio app is provided by the Ambitorio AG. The Ambitorio app is a platform for mobile devices (mobile phones, tablets) and is aimed at users residing inside and outside of Switzerland.

The terms and conditions of this user agreement shall also apply to any updates, upgrades or updates of the Ambitorio app provided by Ambitorio AG which replace or supplement the originally licensed version of the Ambitorio app, unless such update or upgrade or such agreement is subject to a separate license agreement.

Acceptance of the user agreement is effected by downloading and/or using the Ambitorio app. The user declares that he has read, understood and accepted the user agreement.

The respective App Store operator is not a party to this agreement. However, it is a third-party beneficiary with the right to enforce this user agreement against the user.

License and use of the App

After agreeing to the terms and conditions of the user agreement and as far as permitted by the additional terms and conditions of use and guidelines of the respective App Store operator, Ambitorio AG grants the user the non-exclusive, personal, non-transferable, revocable right to install and use the Ambitorio app for private and commercial purposes exclusively on your own (i.e., in the property of the user or his employer or otherwise under the control of the user or his or her employer) and as authorized by the App Store operator

However, the user is prohibited from using the Ambitorio app in any way not provided for in this user agreement without the prior written consent of Ambitorio AG or from transferring or lending it to third parties. Furthermore, you are not entitled to show the Ambitorio app in whole or in part within the framework of a public performance or representation, even if no fee is charged for it. Furthermore, you may not sell, rent, lease, copy, modify, adapt, redistribute, publicly display, transmit, transmit, modify, decompile, reverse engineer, disassemble, obtain the source code, sublicense or transfer the Ambitorio app to third parties for use or for any of the aforementioned purposes or transfer or assign your rights to third parties without authorization.

Ambitorio AG does not charge you for the download, installation or use of the Ambitorio app . However, costs may be incurred in accordance with the tariffs of the parties, domestic or foreign telecommunications providers chosen by you. Individual functions of the Ambitorio app may cause the transmission of large amounts of data, so that high transmission fees may be incurred for the transmission of this content via a data connection. Individual actions performed by the Ambitorio app may cost the user costs in the form of cryptographic tokens. These costs are referred to in detail in point 4.

If you are not the payer of the mobile device used for the Ambitorio app, Ambitorio AG assumes that you have the payer’s permission to use the application.

Cryptographic keys and their storage

The Ambitorio app allows you to manage and use cryptographic key pairs. These key pairs are needed to execute transactions on a blockchain. More about transactions, their purpose and meaning in point 4. A key pair consists of a public key and a private key. The public key is used in the form of a blockchain address as the holder of cryptographic tokens or as the owner of rights for specific actions on the blockchain. The private key is used to manage these tokens or to exercise these rights. The private key is stored exclusively on the Ambitorio app. Ambitorio will never make copies of the private key or copies of other data that will enable Ambitorio to recover the user’s private keys. Having control over a private key means technically being able to manage all tokens and exercise rights. The Ambitorio app can both – generate key pairs and import existing key pairs (or restore a backup of previously generated key pairs by the Ambitorio app). For key pairs generated by the Ambitorio app, the user is offered the option of a backup. The user of the Ambitorio app is solely responsible for the possibility of backing up the key pairs. During a backup, the user will be presented with a sequence of 24 words that will restore the key pairs generated by the app. The user is solely responsible to keep the 24 recovery words of his cryptographic key pairs secret in a safe place. Ambitorio has no way to replace lost keys. Ambitorio has no means of restoring or recovering any cryptographic tokens associated with the keys or any rights granted to the cryptographic keys. With installing and using the Ambitorio app the user confirms, that he is aware of the importance of the key pairs and that he deals with the keys and any backups with due care.

Ambitorio has no influence beyond the Ambitorio app on how the smartphone’s operating system, the smartphone’s hardware, or any other installed apps or features interact with the Ambitorio app, and their ability to keep and store cryptographic keys secure and save.

Malicious hardware or software as well as malicious code from different sources can lead to the loss or theft of cryptographic key pairs.

Ambitorio disclaims all warranties – implicit and explicit – for damages caused to the user by the loss or theft of cryptographic key pairs by third parties due to a hardware or software error in the smartphone or malicious code in the operating system of the smartphone, other apps or data.


The user of the Ambitorio app can sign any cryptographic transaction. Only a valid private-key-signed cryptographic transaction can modify data on the blockchain. Such a transaction may instruct the passing or management of cryptographic tokens at the associated cryptographic address or the execution of rights granted to the cryptographic address.

These cryptographic transactions are prepared by the user himself via a Ambitorio web application and are then sent to the Ambitorio app for signing. The user is responsible for the correct and careful preparation of the transactions.

Ambitorio assumes no responsibility or liability for the content of the transactions, the way in which the rights granted to the cryptographic addresses are executed, or the distribution or management of cryptographic tokens by the user.

With the Ambitorio app the user can check the transactions before signing. It is the sole responsibility of the user to verify this information. Ambitorio believes that the user makes use of this opportunity before a transaction is signed.

Cryptographic transactions change data in the blockchain. Data in the blockchain is not stored in one place, but exists on many different devices of a blockchain network. The network decides, based on internal rules, whether transactions are valid and whether the changes triggered by them are included in the blockchain data or not. The user is a participant in this blockchain network. Only valid transactions of the user and other users of the Blockchain network can modify this data.

Ambitorio has no possibility to modify or influence this data at its own initiative in any way. All changes to the data come about through valid transactions, which were previously signed by the user by means of his private key and after thorough examination by the user.

Ambitorio has no option to cancel, recall or invalidate signed transactions. Ambitorio therefore disclaims any liability for the outcome of the transactions in the Blockchain.

The transmission of blockchain transactions may cause processing fees (called gas costs) owed to the network which the user authorizes with his signature. The nature of blockchain networks makes an exact estimation of gas costs impossible. Ambitorio provides an estimate of +/- 10% accuracy for each of these transactions. If you sign a transaction and send it to the network for processing, Ambitorio assumes that you have reviewed the processing costs and explicitly approved them with your signature.

Blockchains and transaction times

With the Ambitorio app, the user has the opportunity to manage cryptographic key pairs for different blockchains and to sign cryptographic transactions for the blockchain provided with the appropriate private key.

By using the Ambitorio app, the user acknowledges that he understands the purpose and use of a blockchain and understands that blockchains differ in their nature, cost, and transaction time. He confirms that he knows that the data is stored in blocks and that these blocks are created and validated by third parties. Ambitorio has no influence on the formation and validation of the blocks.

Transactions that change data in the blockchain are processed asynchronously. Ambitorio can not give any guarantees as to when a transaction will be processed. Ambitorio assumes no liability if transactions are processed too late or not at all.

Support, Updates and Deactivation of the App

Ambitorio AG reserves the right to update the Ambitorio app at its own discretion. However, Ambitorio AG is under no circumstances obliged to update the Ambitorio app.

As a matter of principle Ambitorio AG does not provide any support, maintenance and/or servicing services in connection with the Ambitorio app. In the event of defects, functional problems or complaints in connection with the Ambitorio App, these can be reported via the corresponding e-mail address (

Ambitorio AG can provide the Ambitorio app with a function that deactivates it completely or partially, temporarily or permanently. Ambitorio AG is entitled to this right without prior notice, without giving reasons and without any compensation to the user. There is therefore no entitlement to continued use of the Ambitorio app.

Exclusion of warranty and liability

Ambitorio AG provides you with the Ambitorio app as seen, i.e. “as-is”. Downloading, installing and using the Ambitorio app is entirely at your own risk. Both Ambitorio AG and the App Store operators hereby completely exclude (both tacit and explicit) warranty for the Ambitorio app and make no other (tacit or explicit) promises, warranties or assurances with regard to the Ambitorio app.

In particular, you do not warrant that: (i) the Ambitorio app functions or is available without errors or interruptions at all times or that errors are corrected; (ii) the downloading, installation and use of the Ambitorio app will not lead to losses, data damage, attacks by third parties, infestation with viruses or other malicious software, unwanted interventions, hacking or other security-relevant disruptions (e.g. reading or changing of data by third parties). You as the user are solely responsible for the data backup of your system, including the Ambitorio app stored on your system.

The liability of Ambitorio AG for direct, indirect or special damages or consequential damages arising from the use of this application or linked pages and applications, including without limitation damages such as loss of profit or revenue, interruption of business or professional activities, loss of programs or other data stored on your device is hereby waived to the extent permitted by law.

The Ambitorio app is offered via mobile networks and nodes that are not controlled or operated by Ambitorio AG. For this reason, Ambitorio AG is not liable for a failure of the application or for difficulties or non-functioning of downloads or content or other errors resulting from third party networks or nodes not functioning. The operators of the nodes are also not liable to the user for a failure of the application or for difficulties or the non-functioning of downloads or content or other errors.

Intellectual property rights

All copyrights, trademark rights and other intellectual property rights in connection with the Ambitorio app are the exclusive property of Ambitorio AG and its licensors. In particular, the entire content of the Ambitorio app is protected by copyright. All rights with regard to the Ambitorio app, which are not expressly granted to you within the framework of the user agreement, remain with Ambitorio AG and its licensors. The unauthorized use, reproduction or reproduction of the content or parts of the content of the Ambitorio app is prohibited. No legal, copyright, trademark or other notices may be removed from the Ambitorio app.

Transmission of Data and Data Protection

In your capacity as a user, you agree that Ambitorio AG may obtain, collect, process and use anonymous tracking data for the purpose of optimizing the Ambitorio app and for statistical purposes when using the Ambitorio app. The tracking data does not allow any conclusions to be drawn about the user and is merely intended to provide general information about the user’s behaviour. These data form the basis for statistical, anonymous evaluations and serve the continuous improvement of the Ambitorio app. In order to be able to offer user-specific and market-driven offers, they agree that Ambitorio AG may collect and process their necessary data on the use of the Ambitorio app. Our data protection declaration is available at:


The license is valid until the user or Ambitorio AG can cancel it at any time. Your rights as a user under this License will terminate automatically or immediately without notice from Ambitorio AG if you violate this User Agreement. After termination or automatic termination of the license, you are obligated to cease all use of the Ambitorio app and to destroy any copies thereof.

Current version

For the use of the Ambitorio app, the current version of the user agreement applies (current version: 20.04.2020). Ambitorio AG reserves the right to change or amend these Terms of Use at any time and without prior notice. The continued use of this application after publication shall be deemed acceptance of these changes.

Applicable law and place of jurisdiction

The user agreement as well as the use of the Ambitorio app are subject to swiss law. The cantonal court of Zug, shall have jurisdiction over any disputes arising from or relating to the existence of this agreement. Ambitorio AG may also sue the other party before any other competent court.

Applicable Terms and Conditions

The terms and conditions in german, are applicable. They are located on the following page:

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The author assumes no liability for the correctness, accuracy, timeliness, reliability and completeness of the information.

Liability claims against the author due to material or immaterial damage resulting from the access or use or non-use of the published information, misuse of the connection or technical faults are excluded.

All offers are non-binding. The author expressly reserves the right to change, supplement or delete parts of the pages or the entire offer without separate announcement or to temporarily or permanently cease publication.

Liability for links

References and links to third party websites are outside our area of ​​responsibility. It rejected any responsibility for such websites. Access to and use of such websites is at the user’s own risk.


The copyright and all other rights to content, images, photos or other files on the website belong exclusively to AMBITORIO AG or the specifically named right holders. The written consent of the copyright holder must be obtained in advance for the reproduction of any elements.

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