Ketl
Data storage 3/3
What the vendor states (our summary):
Swiss datacentres in Geneva and Zurich, operated by Swiss companies
What this means: Switzerland only, or customer on-premises. Where data rests decides which law and which authorities can reach it. Swiss firms often require Swiss residency for client matters.
Where the AI runs / sub-processors 3/3
What the vendor states (our summary):
Proprietary models developed, trained and hosted in Switzerland; no third-party LLM
What this means: Switzerland only, own or non-US models. Storage and AI processing are often in different places. A tool can store data in Zurich and still send prompts to models in another country.
US Cloud Act exposure 3/3 ⚖︎
What the vendor states (our summary):
Swiss vendor; Swiss infrastructure (Exoscale, Infomaniak) per vendor
⚖︎ Judgment call: Swiss company on Swiss-owned infrastructure with no US LLM in the chain, per vendor statements; not independently audited.
What this means: Non-US vendor, non-US infrastructure and models. The US CLOUD Act lets US authorities require US providers to disclose data in their possession, custody or control, wherever it is stored. This score is always an editorial judgment call.
Art. 321 SCC auxiliary terms 2/3
What the vendor states (our summary):
Claims Art. 321 SCC compliance 'built into technical architecture'; no contractual auxiliary-person term found
What this means: General confidentiality claim, no auxiliary-person term. Under Art. 321 SCC, auxiliaries of a lawyer are bound by professional secrecy, and Art. 13 para. 2 BGFA/LLCA makes the lawyer responsible for ensuring they respect it. Written auxiliary terms help document that.
revFADP / GDPR processing agreement not disclosed
What the vendor states (our summary):
not disclosed
What this means: Art. 9 revFADP and Art. 28 GDPR require a contract (or legal basis) when a processor handles personal data on your behalf.
No training on customer data not disclosed
What the vendor states (our summary):
not disclosed
What this means: If customer data trains a model, confidential content could surface elsewhere. Look for a contractual ban that also binds model providers.
ISO 27001 / SOC 2 1/3
What the vendor states (our summary):
No vendor certification stated; host Infomaniak is ISO 27001
What this means: Infrastructure-only or planned. Independent audits (ISO 27001, SOC 2 Type II) give evidence that security controls exist and are tested.
What to ask this vendor
- Art. 321 SCC auxiliary terms Will you contractually accept auxiliary-person (Hilfsperson) status under Art. 321 SCC and pass it to sub-processors?
- Art. 321 SCC auxiliary terms Who at your company or at sub-processors can access our content in clear text?
- revFADP / GDPR processing agreement Please send your DPA. Does it reference the Swiss revFADP as well as the GDPR?
- revFADP / GDPR processing agreement Which transfer mechanism covers any processing outside Switzerland/EEA?
- No training on customer data Is it contractually excluded that our data trains or fine-tunes any model, including the model providers’ models?
- No training on customer data What is retained by model providers (abuse monitoring, logs), and for how long?
- ISO 27001 / SOC 2 Please send your current ISO 27001 certificate and scope, or SOC 2 Type II report.
- ISO 27001 / SOC 2 When was your last independent penetration test?
Informational only, not legal advice. Results reflect vendors’ public statements on the date checked and our scoring rules. Verify contracts yourself before using any tool with client data.