Silex
Data storage 3/3
What the vendor states (our summary):
Infomaniak, Geneva (Swiss-owned), incl. backups; no client data stored on Azure
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):
Self-hosted LLMs on Azure Switzerland North (ephemeral); no data sent to external AI providers
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 2/3 ⚖︎
What the vendor states (our summary):
Data at rest on Swiss-owned Infomaniak; inference on Azure Switzerland North; vendor acknowledges residual CLOUD Act exposure during in-memory inference, Swiss GPUs planned for 2027
⚖︎ Judgment call: Data at rest on Swiss-owned Infomaniak, but processing runs on a US-parent cloud (Azure).
What this means: Swiss storage, but US-parent compute or optional exposure. 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):
Contractual confidentiality expressly covering information protected by Art. 321 SCC and the LLCA, extended to staff and sub-processors; no auxiliary-person status term
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 2/3
What the vendor states (our summary):
DPA agreed with customers (referenced in CGU, sub-processors in its Annex A); acts as processor under the DSG; DPA not public
What this means: GDPR DPA or US framework certification only. 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 3/3
What the vendor states (our summary):
User data never trains or fine-tunes the models
What this means: Contractual no-training, including model providers. 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):
ISO 27001 in progress, targeted Q3 2026 (not yet certified per page)
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
- US Cloud Act exposure Is your company or any sub-processor in the processing chain a US company or a subsidiary of one?
- US Cloud Act exposure How would you respond to a foreign government request for our data, and will you notify us?
- 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?
- 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.