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.

Last update: 10 August 2016

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

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

2.1) We use Your Information only for Our business purposes, as described herein, and do not share it with third parties, unless explicitly set out otherwise by Us.

2.2) We share your Information with business partners on an as needed basis to render the Services, i.e. our payment provider for collecting fees payable for the Commercial Services, our accounting service provider, and our mail provider we use to stay in contact with you. The Information we share with these business partners is limited to your name and e-mail address and, with respect to our payment solution providers and accounting provider, your postal address.

2.3) 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.

2.4) 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.

2.5) If you have any question or inquiry relating to Our use of Your Information or in case You want to issue a request to delete, alter or block Your Information, You may contact us by way of e-mail to the following address:

2.6) The data of a user may be transferred to, and stored at, a destination outside the European Economic Area. It may also be processed by staff operating outside the EEA who works for 42matters or for one of its suppliers.

2) What Information We Collect When You Visit Our Website

2.1) We collect the following Information by using 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): browser type and browser language, Your Internet Protocol ("IP") address, and the actions you take on the Website (such as the Web pages viewed and the links clicked).

2.2) We use both session ID cookies and persistent cookies on the Website. We use session cookies to make it easier for you to navigate the Website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive or mobile device for an extended period of time. Most web browsers (including mobile web browsers) are set to accept first party cookies by default. However, some web browsers (including mobile web browsers) are set to not accept third party cookies by default. You can typically remove or reject cookies by following directions provided in your Internet browser's help file or in the "Settings" of your mobile device. However, removing cookies may not allow you to take full advantage of all features on the Website.

2.3) The Website may also contain third party tracking tools from third party service providers, which may enable these third parties to analyze User information. While these third parties may have access to your personal information in connection with the performance of services for 42matters, they will not be permitted to use such information for any purpose other than providing their services.

2.4) The Website uses Google Analytics and Facebook to help Us analyze how visitor use the Website and to improve Our Services. Google Analytics and Facebook uses cookies to collect standard internet log information and visitor behavior Information. The Information generated by Google Analytics and Facebook cookies about Your use of Our Website is transmitted respectively to Google and Facebook. This information is then processed to compile statistical reports on website activity.

2.5) This Policy applies only to Our Website. When you are on the Website you could be directed to other sites beyond our control. For example, if you "click" on a link or an icon provided on our Website, the "click" may take you off the Website onto a different site. These other sites may send their own cookies to you, independently collect data or solicit Information and may or may not have their own published privacy policies. If you visit such a site that is linked to our Website, you should consult that site's privacy policy before providing any Information.

3) Information You Submit to Register an Account

3.1) If you register an Account on our Website which is a prerequisite to subscribe to Our Services, We request your email address, your name, your company, and your website (optional). 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.

4) Information You Submit to Subscribe to Our Commercial Services

4.1) 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. We use a third party payment provider to collect 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, and Your name. 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 payment records will be stored for the term requested by mandatory law applicable to us.

5) Information Submitted to Us via Mobile Applications Integrating our SDK

5.1) If You (End User) use an mobile app which uses our SDK as an integrated component, we will collect (and the publisher of the relevant app has obtained your consent thereto) the following information (unless you have followed the opt-out procedures as described below): operating system, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS® Identifier for Advertising (on iOS only), Android™ Advertiser ID (on Android only), Model, manufacturer and OS version of device, session start/stop time, device uptime, locale (specific location where a given language is spoken), list of ids of installed applications, mobile network code/mobile country code, time zone, network status (WiFi, etc.), memory, disk, CPU and battery usage information. We will not collect any Personal Information, including UDID, Android ID, IMEI, MSISDN, name, email address, phone number, etc.

5.2) Any publisher of apps using our SDK is obliged to enable You to opt-out from 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-out from the collection of information, for instance by providing You a link or through the settings of the app. If You have opted out in such way, We will 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-out.

5.3) 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,

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

(iii) to tune 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 the apps, which helps 42matters to improve existing services or develop new services. 42matters may also share this aggregated data with business partners and third parties.

5.4) We may share the data of a End User, such as the device information and inferred data like the pseudo-anonymized profile, with third parties including advertisers, DMPs and partners, some of whom may use this data for the purposes of demographic and behavioral ad targeting. Any third parties’ use of the data of a user is governed by their own privacy policy. To learn more about behavioral advertising or to opt-out of some types of behavioral advertising for participating ad networks, the user can visit the Network Advertising Initiative or the Digital Advertising Alliance. The mobile operating system of a user 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).