Last updated: 2019-03-15
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.
The Website is not intended for children (those aged 13 and under) and we do not knowingly collect data relating to children.
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.
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.
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:
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.
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.
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:
email@example.com. If you would like to send us a letter, you can address it to: Match2One AB, Stureplan 6, 114 35 Stockholm, Sweden. Alternatively, you can use the “Chat” option available on our Website or app.
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.
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:
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:
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:
We may process your personal data for the following reasons on the basis of a ‘legitimate interest’:
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.
Depending on how and why you provide us with your personal data. We may share it in the following ways:
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.
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.
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.
If you would like further information about the specific mechanism, used by us when transferring your personal data out of the EEA., please contact: firstname.lastname@example.org
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.
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.
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.
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.
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 our contact details 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.
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 our contact details 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.
Where we process your personal data on the basis of a legitimate interest, 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 our contact details 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.
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.
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
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.
You have the right to lodge a complaint regarding our processing of your personal data. Such a complaint may be directed towards us (email email@example.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].
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.
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.