Privacy Policy for our Website & Services

This Privacy Policy ("Policy") describes how We, 42matters AG, a company registered in Switzerland under the company number CHE-224.961.109 and having its registered office at Rötelstrasse 84, 8057 Zürich, Switzerland ("42matters", "We", or "Us") handle personal data of natural persons ("You" or "User") collected or otherwise processed when using Services (as defined below) of 42matters.

1) Meaning of Terms used in this Privacy Policy

1.1) When this Policy uses the term "Information" or "Personal Information" in capital letters, we mean information that identifies a particular individual, such as your full name, email address or IP Address.

1.2) When this Policy uses the term "Website", We mean the content provided under the URL https://42matters.com.

1.3) When this Policy uses the term "Account", We mean the user interface on the Website where You can register. Such registration is a prerequisite to subscribe to Our Commercial Services.

1.4) When this Policy uses the term "SDK", We mean a software tool which is published by us for the inclusion into applications for mobile devices published by our customers.

1.5) When this Policy uses the term "Commercial Services", We mean any Service provided by Us against the payment of fees, when we speak of "Services" we refer to all of what we provide to our Users free of charge or against remuneration, i.e. the Website and our Commercial Services.

1.6) When this Policy uses the term "End User", We mean any end user of a Mobile Application where our SDK is integrated into.

2) Responsible Entity, Contact Details, How We Deal With Your Information in General

2.1) The responsibility for data processing lies with Us, i.e.

42matters AG
Rötelstrasse 84
8057 Zürich, Switzerland
Tel: +41 44 586 77 42
E-Mail: privacy@42matters.com

If you have any question or inquiry relating to Our use of Your personal data or in case You want to issue a request for access, rectification, restriction on processing, portability, objection to processing, or deletion of personal information, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), You may contact us as identified in Section 10 below.

2.2) We use Your Information for the purposes described herein below, and do not share it with third parties, unless explicitly set out otherwise by Us in this Privacy Policy.

2.3) We share your Information with business partners on an as needed basis to render the Services, e.g. our payment provider (Stripe) for collecting fees payable for the Commercial Services, our accounting service provider (Freeagent), our mail provider we use to stay in contact with you (Mailchimp), our customer support platform to help you with your request (Intercom), as further described below in more details. The Information we share with these business partners is limited to your name, surname, company name, industry, phone number, your website (optional), and e-mail address and, with respect to our payment solution providers and accounting provider, your postal address.

2.4) In the event that we sell our business, i.e. all or substantially all of our assets are sold or transferred to or merged with another party, all Information that has been collected and stored may be one of the business assets we transfer.

2.5) In the event we are required to respond to subpoenas, court orders or other legal process your Information may be disclosed pursuant to such subpoena, court order or legal process, which may be without notice to You.

2.6) The data of a user may be transferred to, and stored or otherwise processed at, a destination outside the European Economic Area (EEA), as further identified in this Privacy Policy.

3) What Information We Collect When You Visit Our Website

3.1) Our Websites and some of our Services use cookies (a small text file that is stored on a user's computer or mobile device for record-keeping purposes) and web beacons (electronic images that deliver cookies and help to count visits) to uniquely identify your browser and to gather information about how you interact with the Websites and Services. Please consult our Cookie Policy for more information about the type of cookies and tracking technologies that we use on this Website the purposes thereof, and how to accept and reject them.

4) Information You Submit to Register an Account

4.1) If you register an Account on our Website which is a prerequisite to subscribe to Our Services, We request your name, surname, company name, industry, phone number, your website (optional), and e-mail address. We collect this Information to be able to verify your account and contact you and to send you information relating to the use of our Services. We do not rent or sell your Personal Information to anyone.

4.2) We may share and disclose information (including Your personal information) to third party services in order to help operate our Services. With these third party services we share the minimum amount of Information (as mentioned in Paragraph 4.1) required to provide you with our Services, offer you support and other business activities related to our Services. We provide your information to such third party service providers to enable us to fulfill our contractual duties as per Art. 6 para 1. A a), on the basis of our legitimate interests according to Art. 6 para. 1 f) GDPR and, where necessary, subject to the conclusion of data processing agreements according to Art. 28 Para. 3 S. 1 GDPR. The primary third party services we use are:

You will find more details with respect to our third party service providers in the relevant privacy policy linked above.

5) Information You Submit to Subscribe to Our Commercial Services

5.1) If you wish to subscribe to one or more of our Commercial Services, we request your billing address as well as your VAT ID (optional) in order to be able to invoice You correctly. Your payment records will be stored for the term requested by mandatory law applicable to us. We may use, share and disclose information (including Your personal information) to third party services in order to process payments for our Services as identified below on the basis of our legitimate interests according to Art. 6 para. 1 f) GDPR and, where necessary, subject to the conclusion of data processing agreements according to Art. 28 Para. 3 S. 1 GDPR:

a) We use a third party payment provider (Stripe, USA - Privacy Policy - Certified under the EU-US Privacy Shield) to collect credit card payments to be made for our fees and refer you during the payment process to the third party payment provider. The only Information we share with the payment provider is your e-mail address, postal address, Your name, invoice amount and currency, along with the information provided during the order process. Any additional information, such as credit card details, will be requested from You directly from the payment provider and provided by You directly to the payment provider. We have no access to such data and do not store your credit card details. Your data will only be passed on for the purpose of payment processing.

b) We use a third party accounting software (FreeAgent, United Kingdom - Privacy Policy) to issue invoices and manage wire transfer payments to be made for our fees. The only Information we share with the accounting software is your e-mail address, postal address, Your name, Your company name and VAT ID (optional).

c) We use a third party revenue reporting software (ChartMogul, United Kingdom - Privacy Policy) for reporting of revenues for our subscription businesses. The only Information we share with the revenue reporting software is your e-mail address, postal address, Your name, Your company name and VAT ID (optional).

6) Information Submitted to Us via (third-party) Mobile Applications Integrating our SDK

6.1) If You (End User) use a (third-party) mobile application which uses our SDK as an integrated component, we will collect (and the publisher of the relevant app has obtained your opt-in consent thereto) the following information (unless you have followed the opt-out procedures as described in section 5.2): operating system, SDK version, timestamp, API key (identifier for application), application version, iOS® Identifier for Advertising (on iOS only), Android™ Advertiser ID (on Android only), device model, manufacturer and OS version of device, session time, locale (i.e. specific location where a given language is spoken), list of IDs of installed applications (e.g. com.facebook.katana), mobile network code/mobile country code, time zone, network status (WiFi, etc.), memory, disk, CPU and battery usage information. The only Personal Information we collect are the iOS® Identifier for Advertising (on iOS only) and/or Android™ Advertiser ID (on Android only). For sake of clarity, We do not collect the following Personal Information from an End User: UDID, Android ID, IMEI, MSISDN, name, email address, phone number.

6.2) Any publisher of apps using our SDK is obliged to enable You to opt-in for the collection of the information as described above or applying other measures required by local privacy laws applicable to the Service. Therefore, the publisher of Your app must, as a minimum, enable You to opt-in before the collection of information, for instance by integrating the possibility of an opt-in for the data collection in the starting screen of the app and by providing an opt-out link in the Settings of the app. If You have opted out, We will delete your data and not continue to collect such information. Please turn to the publisher of Your app in case You are unable to find the mechanism for such opt-in and opt-out.

You (End User) can also opt-out of the data collection by 42matters from our website. To do so You have to click the opt-out link below and follow the steps described in the opt-out page. The opt-out will allow the user to add his or her iOS® Identifier for Advertising (on iOS only) and/or Android™ Advertiser ID (on Android only) to an opt-out list. Opting out will not stop advertising from the mobile app(s) integrating our SDK, but will cause 42matters to no longer collect and analyze data from the device of a user: link to opt-out page.

6.3) We may use the data collected through our SDK for the following purposes:

(i) to provide the user with customized services and the display of customized content and products and targeted advertising both on the app of the developer and on other third party apps and websites,

(ii) to ensure the technical functioning of the services of 42matters,

(iii) to improve the algorithms used by 42matters for inferring profile information and other analytics.

42matters may also aggregate the data with other users' data in order to create statistics about the general use of mobile applications, which helps 42matters to improve existing services or develop new services.

6.4) We may share, on the basis of our legitimate interests according to Art. 6 para. 1 f) GDPR, the data of an End User, such as the device information (see section 5.1) and inferred data (e.g. profiled data), with third parties including advertisers, DMPs and partners, some of whom may use this data for the purposes of (i) create segments for targeted advertising and marketing purposes, (ii) internal system improvements, product improvement, statistical analysis, and research and development, and (iii) demographic and behavioral ad targeting. Any third parties’ use of the data of a user is governed by their own privacy policy which you might visit for further details on how your data is dealt with. In particular, we may share the data of an End User with the following partners:

  • Oracle Marketing Cloud & Oracle Data Cloud, USA - Oracle Marketing Cloud is a data management platforms (DMP) provided by Oracle America Inc. - Privacy Policy - Certified under the EU-US Privacy Shield
  • eXelate A Nielsen Company, United Kingdom - eXelate is a data management platforms (DMP) provided by Nielsen Holdings PLC - Privacy Policy
  • Adsquare, Germany - Adsquare is a data management platforms (DMP) provided by adsquare GmbH - Privacy Policy
  • zeotap, Germany - zeotap is a data management platforms (DMP) provided by zeotap GmbH - Privacy Policy
To learn more about behavioral advertising or to opt-out of some types of behavioral advertising for third-party ad networks, the user can visit the Network Advertising Initiative or the Digital Advertising Alliance. Additionally, the mobile operating system of a user (e.g. iOS or Android) should also give the user the option to manage his or her advertising preferences (this may be found in the "Settings" function on the respective device).

6.5) If you have any question or inquiry relating to Our use of Your personal data or in case You want to issue a request for access, rectification, restriction on processing, portability, objection to processing, or deletion of personal information, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), You may contact us by way of e-mail to the following address: privacy@42matters.com or using our web form.

7) Information We Collect from Publicly Available Sources and Third Party Services

We may collect publicly available data about mobile apps ("Third Party Content") and access certain meta-data ("Data") about such Third Party Content, as publicly available on Google Play Store, Apple App Store and Tencent MyApp as described in Section 3 of our Terms of Service. We might also collect publicly available contact information ("Third Party Contact Information") of third party companies (e.g. support email address, company name, company address) as described in Section 3 of our Terms of Service. Upon request, We will inform you in writing as soon as possible whether and which of your personal data is stored by Us. If, despite our efforts to ensure that the data is correct and up to date, incorrect data is stored, it will be rectified by us accordingly. In addition to this right to correction, you also have the right to request to block and delete personal data we have collected. In addition, you have the right to request that we transmit the data to you as a structured, standard and machine-readable format or, at your express request, forward it to a third party. You may object to the use of your data for future purposes. In particular, you may object to the use of your data for advertising and marketing purposes. You also have the right to request only a restriction of data use for certain purposes. If you have any further questions regarding the collection, processing and use of personal data or the correction, deletion or blocking of such data, please contact Us by way of e-mail to the following address: privacy@42matters.com or using our web form.

8) Hosting, Data Retention and Security

8.1) We use, on the basis of our legitimate interests according to Art. 6 para. 1 f) GDPR and, where necessary, subject to the conclusion of data processing agreements according to Art. 28 Para. 3 S. 1 GDPR, the following third party services to host Our Websites, Services, data (including Personal Information) and files:

8.2) We only retain Personal Information for as long as the related account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, security, and enforce our agreements as follows:

  • The contents of closed accounts are deleted within 30 days of the date of closure
  • Backups are kept for 3 months
  • Billing information is retained for a period of 7 years as of their provision in accordance with 42matters' local accounting and taxation laws

8.3) We use reasonable organizational, technical and administrative measures to protect Personal Information within our organization (for example: data transfer encryption over HTTPS, and account authentication and data rest encryption for our computer and databases storing Personal Information). Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately by way of e-mail to the following address: privacy@42matters.com or using our web form.

9) Changes to This Policy

We may edit this policy from time to time. Please check this policy regularly for any changes. We will post all changes here, and if we make any substantial changes we may also notify you by email.

10) Contact Us

If You have any questions about this Privacy Policy, please contact us at privacy@42matters.com, using our web form, or at:

42matters AG
Rötelstrasse 84
8057 Zürich
Switzerland