Match2One AB – Privacy and Cookie Policy

This Privacy Policy was last updated on 2018-05-15 and historic versions are archived here or can be obtained by contacting us.

 

Introduction

Match2One AB (“Match2One” or “we”, “our”, “us”), a company incorporated under the laws of Sweden with reg. no. 559036-6836 operates the website Match2One.com (the “Website”) and its services (the “Services”).

Unless stated otherwise, we are the “controller” of your personal data under Swedish and EU legislation. This means that we are responsible for our processing of your personal data. However, we may also process your personal data on behalf of your employer, when asked to do so for your employer’s own purposes. In such cases, your employer is the controller of your personal data and responsible for the processing thereof.

 

Important information

We are committed to protecting the privacy of our users and website visitors. This Privacy and Cookie Policy (“Privacy Policy”) informs you of our policy regarding the collection, use, disclosure and protection of your personally identifiable information. Please read this Privacy Policy carefully before using the Services provided through the Website.

The Website is not intended for children (those aged 13 and under) and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

Contact Details

Ted Sahlstrom: data.privacy@match2one.com

 

Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

For ease of reading, we have divided this Privacy Policy into several sections:

 

1. What information do we collect about you?

 

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you (or other living people) from which you could be identified – such as your name, your contact details and even your IP address.

 

Data we collect from you

Depending on how you interact with us, Match2One may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, last name, username or similar identifier, title.
  • Company Data: includes name, company website.
  • Contact Data: includes e-mail address, billing address, postal address, telephone number; and mobile number.
  • Financial Data: includes details for invoicing.
  • Transactional Data: includes details about payments to and from you and other details of products and Services you have purchased from us.
  • Technical Data: includes IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences and feedback.
  • Usage Data: includes information about how you use our Website, products and services.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

 

Updating your information

If you want to update the information you have previously given to us (e.g. if you have recently moved office or changed your email address), you can contact Match2One at:

support@match2one.com. If you would like to send us a letter, you can address it to: Kommendörsgatan 30,
114 48 Stockholm, Sweden. Alternatively, you can use the “Chat” option available on our Website or app.

 

Match2One product

In relation to users to whom ads are shown (and most of whom never come to the Website):

We process information, correlated with advertising campaign data such as clicks, impressions and supplemental data such as user’s country, browser language settings, the time of various events and information about the site, such as its type of content and location. We also keep track of user behaviour linked to anonymous user ID’s to record which site the user went to, what ad banners they clicked on and on which customer sites they made a purchase. The data is used to show more relevant ad banners to existing and new users.

In relation to uses who are Match2One customers:

We do not use personal customer data in the Match2One product. Only company and campaign data, as provided by the customer, is used. For example, the type of product to be advertised, budget goals and other such information. The Match2One system will send notifications about the customers campaigns to the customer at the specified email address from time to time so the customer is aware of what is happening with their campaign.

When we do that we are a ‘Data Processor’. We only process data supplied to us by our clients and the advertising networks on which we serve adverts. Any personal data collected by these third parties is collected under their privacy policies and we process such personal data on a transient basis solely on the basis on which we have been instructed.

 

 

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, e-mail, live chat or otherwise. This includes personal data you provide when you:
    • apply for our products or services;

    • create an account on our website;

    • request marketing to be sent to you;

    • give us feedback.

  • Automated technologies or interaction. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section on cookies for further details.

  • Third parties. We may receive personal data about you from various third parties as set out below:

    • Technical Data from analytical providers, such as Google, HotJar, Intercom and Visual Website Optimiser, all of which are based outside the EU.
    • Technical Data from advertising solutions such as Match2One based in Europe, Google AdWords based outside Europe, Facebook based outside Europe.

 

 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your consent as a legal basis for processing to send you any direct marketing from us or third parties via email. You have the right to withdraw consent to marketing at any time by contacting us at data.privacy@match2one.com .  

We may process your personal data for the following reasons on the basis of a ‘legitimate interest’:

  • To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
  • To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
  • Asking you to leave a review or take a survey (to keep our records updated and to study how customers use our products/services);
  • Collect and recovery money owed (to recover debts due to us);
  • To administer and protect our business and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restricting exercise)
  • To make suggestions and recommendations to you about goods or services that may be of interest to you (to develop our products/services and grow our business)

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

 

4. Disclosures of your personal data

Depending on how and why you provide us with your personal data. We may share it in the following ways:

  • We may analyse and disclose aggregated statistics about our Website visitors and users of our Service in order to describe our Services to prospective partners and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

  • We may disclose personal data if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the Website or its visitors.

  • We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Service Providers

We will use third party service providers to undertake processing operations on our behalf, and this may require us to share your personal data with them. These service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

 

 

5. International Transfers

Depending on how and why you provide us with your personal data. We may share it in the following ways:

Please note that some of our service providers are based outside of the European Economic Area (the “EEA”). Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld.

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

If you would like further information about the specific mechanism, used by us when transferring your personal data out of the EEA., please contact: data.privacy@match2one.com 

 

 

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

 

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

8. Cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are.

A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number.

A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

  • Session cookie. Temporary cookie that remains in the cookie file of your browser until you leave the website.

  • Persistent cookie. This remains in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

As for the domain to which it belongs, there are either:

  • First-party cookies. These cookies are issued from the website you have accessed and often serve to give memory about your data and preferences.

  • Third-party cookies. These are stored by a different domain to the visited page’s domain.

Find out more about cookies by contacting us at data.privacy@match2one.com or visit www.allaboutcookies.org.

How we use cookies on our Website and what information we collect

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-billing services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie NameTypePurposeExpiry
__cfduidHTTPUsed by the content network, Cloudflare, to identify trusted web traffic.1 year
langHTTPRemembers the user’s selected language version of a websiteSession
_gaHTTPRegisters a unique ID that is used to generate statistical data on how the visitor uses the website.2 years
_gatHTTPUsed by Google Analytics to throttle request rateSession
_gidHTTPRegisters a unique ID that is used to generate statistical data on how the visitor uses the website.Session
__hsscHTTPCollects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising.Session
__hssrcHTTPCollects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising.Session
__hstcHTTPCollects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising.2 years
__ptq.gifPixelSends data to the marketing platform Hubspot about the visitor’s device and behaviour. Tracks the visitor

across devices and marketing channels.

Session
__stidHTTPRegisters a unique ID that identifies the user’s device for return visits.1 year
__unamHTTPSaves the user’s navigation on the website including what pages have been viewed and how long the

browser has been used to view each page.

9 months
_hjIncludedInSampleHTTPDetermines if the user’s navigation should be registered in a certain statistical placeholder.Session
anjHTTPRegisters a unique ID that identifies a returning user’s device. The ID is used for targeted ads.3 months
bcookieHTTPUsed by the social networking service, LinkedIn, for tracking the use of embedded services.2 years
BizoIDHTTPLinkedIn insights and ads tags179 days
bscookieHTTPUsed by the social networking service, LinkedIn, for tracking the use of embedded services.2 years
frHTTPUsed by Facebook to deliver a series of advertisement products such as real time bidding from third party

advertisers.

3 months
hsfirstvisitHTTPUsed by the marketing platform Hubspot to determine if it is the user’s first visit to the website.Session
hubspotutkHTTPKeeps track of a visitor’s identity. This cookie is passed to the marketing platform HubSpot on form

submission and used when de-duplicating contacts.

10 years
lidcHTTPUsed by the social networking service, LinkedIn, for tracking the use of embedded services.Session
r/collectPixelUsed by Google DoubleClick for insights and advertising tagsSession
sessHTTPUsed to check if the user’s browser supports cookies.Session
trPixelThe purpose of this cookie shall be uploaded’. If you have any questions in the meantime, please e-mail.: data.privacy@match2one.comSession
UserMatchHistoryHTTPUsed by LinkedIn to gather insights and advertising intelligence179 days
uuid2HTTPRegisters a unique ID that identifies a returning user’s device. The ID is used for targeted ads.3 months
_mkra_ctxtHTTPSupport system on Match2Ones website and application. This tool allows users to have conversations with Match2One represantatives and support staff, while remembering your details if you return to improve your experience with Match2Ones support team.Session
_vwo_uuid_v2HTTPWebsite optimisation and tracking of user behaviour. Used to improve and optimise the online experience on website.1 year
crosspixelPixelUsed by Crosspixel for crossdevice performance dataSession
intercom.played-notificationsHTMLSupport system on Match2Ones website and application. This tool allows users to have conversations with Match2One represantatives and support staff, while remembering your details if you return to improve your experience with Match2Ones support team.Session
intercom-id-tj2vas7mHTTPSupport system on Match2Ones website and application. This tool allows users to have conversations with Match2One represantatives and support staff, while remembering your details if you return to improve your experience with Match2Ones support team.20 years
intercom-stateHTMLSupport system on Match2Ones website and application. This tool allows users to have conversations with Match2One represantatives and support staff, while remembering your details if you return to improve your experience with Match2Ones support team.Persistent

 

As noted in the table above, we use Google Analytics to collect information about you in aggregated form to help Match2One understand how the Website is being use and to help Match2One customise the Website for you. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

Disabling or enabling cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.

 

 

9. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

 

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

 

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

 

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the section of this Privacy Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data: (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

 

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

 

Your Right to Stop Receiving Communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us.

 

Your Right to Object to Automated Decision Making and Profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

 

Your Right to Lodge a Complaint

You have the right to lodge a complaint regarding our processing of your personal data. Such a complaint may be directed towards us (email data.privacy@match2one.com ) or the relevant supervisory authority, e.g. the Swedish Data Protection Agency (Datainspektionen/Integritetsskyddsmyndigheten). Contact details for national data protection authorities are available [here].

 

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For our contact details, please see here.

 

 

10. Jurisdictional issues

Match2One makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of Sweden, Ukraine England and Australia. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.