Privacy policy.
1. Privacy Policy Statement
Forty Two respects your right to privacy. This policy summarises what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.
It is Forty Two’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.
This policy applies to all internet sites and mobile applications (apps) operated by or on behalf of Forty Two. It also applies to personal information Forty Two may otherwise collect:
through our products and services;
when you interact with us by means other than a Forty Two internet site or app, for example, in person, by telephone, or at a trade show; and
from our customers, distributors, suppliers, vendors, and other business partners (collectively ‘Business Partners’).
2. General principles
To the extent required by applicable law, whenever Forty Two collects personal information, Forty Two will:
provide timely and appropriate notice to you about our data practices;
collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
not use your personal information for direct marketing purposes without giving you an opportunity to ‘opt-out’; and
take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Forty Two.
3. Personal information Forty Two collects
Forty Two collects the following types of personal information:
Information you provide
Forty Two collects personal information you provide us, which may include:
contact information, such as your name, company name, job title, address, e-mail address, and phone number;
additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products or services, and demographic information;
comments, questions, requests and orders you may make;
financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number;
log-in information, including, if applicable, social media account information for login purposes;
information about your preferences, such as your preferred methods of communication and product/service types in which you are interested.
Information automatically gathered from your device
Device and browser information
Forty Two may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. Forty Two collects this information automatically from your device and web browser through cookies and similar technologies.
Information about how you interact with us
Forty Two may collect technical data about your usage of the Forty Two internet site and apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Forty Two promotional emails opened, and dates and times of interactions. Forty Two collects this information using cookies and similar technologies.
Location information
Forty Two may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. The Forty Two internet site and apps will not access precise-real time location information from your device unless you grant permission to do so.
Cookies and similar technologies
A ‘cookie’ is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalising your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.
The Forty Two internet site uses ‘session cookies’. A session cookie does not identify you personally and expires after you close your browser. For example, when you use the Forty Two internet site, we place a session cookie to note what pages you have viewed. We can use this information to provide you recommendations for other products or services that may be of interest.
The Forty Two internet sites also uses ‘persistent cookies’. These cookies do not expire when you close your browser. Persistent cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits.
Certain countries require your consent to the use of cookies when you visit the Forty Two internet site. If you access the Forty Two internet site, you will be presented with information regarding your options, including the option to accept or reject certain categories of cookies. You will be able to change these settings on subsequent visits. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you.
Although you are not required to accept cookies when you visit the Forty Two internet site, you may be unable to use all of the functionality of the site if you reject certain cookies.
In addition, your browser may allow you to adjust settings to accept or reject cookies, or to alert you when a cookie is placed on your computer.
Analytics and advertising
Forty Two may use third party analytics services to better understand how users engage with the Forty Two internet site and apps, including services provided by Google. Please use the following links for more information about how Google collect and use data when you visit their partners’ websites or apps:
www.google.com/policies/privacy/partners/
Forty Two may also use third party advertising services to provide advertisements for Forty Two products or services that may be of interest to you when you visit websites or other online services.
Forty Two may allow selected third parties, including these analytics and advertising services, to place cookies on our internet site. These third parties may collect information about your online activities over time and across third party websites.
These third parties may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA) and European Digital Advertising Alliance (eDAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.
Do Not Track browser settings
Some browsers may transmit “Do Not Track” (‘DNT’) signals to the websites you visit. Because there is no common agreement about how to interpret DNT signals, Forty Two currently does not take action in response to them.
Information from Business Partners and other third parties
Forty Two may collect personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, email address and phone number.
Forty Two may also obtain personal information from other third party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third party sources with information that we collect from you or your device, as described above.
You have choices about the personal information you provide to Forty Two. You may choose not to provide information that we request, but if you do so, we may not be able to provide you with a particular product or service.
4. How Forty Two uses your personal information
Forty Two may use your personal information to:
Develop and manage our relationships with you and our Business Partners. This may include:
delivering services or carrying out transactions that you or our Business Partners have requested;
providing information about Forty Two products, services, and transactions, and advertisements, that may be of interest to you;
providing you and our Business Partners a more consistent experience in interacting with Forty Two, including by learning more about you and how you use and interact with the Forty Two internet site or our products and services; and
planning, managing, and performing under our contractual relationships with you or our Business Partners.
Communicate with you or your company. This may include:
informing you of Forty Two products, services, and promotional activities that may be of interest to you or your company;
providing information about relevant Forty Two products, services, and transactions, including, for example, pricing information, technical data, invoices or service information;
responding to questions or inquiries that you make, including customer service requests; and
inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
Provide and improve our internet site and services. This may include:
customising them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use;
maintaining the security of and otherwise protecting them; and
developing new Forty Two internet sites, apps and services.
Address legal issues. This may include:
complying with our obligations to retain certain business records for minimum retention periods;
establishing, exercising, or defending legal claims;
complying with laws, regulations, court orders, or other legal process;
detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of the Forty Two internet sites or services; and
protecting Forty Two’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
Forty Two may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.
Forty Two may anonymise or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.
5. When Forty Two may share your personal information
Forty Two will not disclose your personal information except as described here:
Forty Two may share your personal information with other Forty Two entities, including those in different countries. When we do so, these other Forty Two entities will use your information in a manner consistent with this policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
Forty Two may also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
In some cases, Forty Two may share your personal information with third parties who partner with us to provide products and services to our customers. If so, we will require our Business Partners to use that information in a manner consistent with this policy, any applicable specific privacy policies and statements, and all applicable privacy and data protection laws.
Forty Two may share your personal information with third parties when we have a good faith belief that disclosure is necessary:
to comply with a law, regulation, court order, or other legal process;
to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of the Forty Two internet site or services;
to protect Forty Two’s rights or property or yours or others’ health, safety, welfare, rights, or property; or
under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
Forty Two may share your personal information with third parties in connection with the sale, purchase, merger, reorganisation, liquidation or dissolution of Forty Two. If such an event occurs, we will take appropriate steps to protect your personal information.
Forty Two may share your information with your permission or at your request.
Forty Twomay share anonymised or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
6. Security of your personal information
Storage
Your personal information will generally be stored in Forty Two databases or databases maintained by our service providers. Forty Two takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Forty Two.
Forty Two maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorised disclosure, misuse, or alteration, as is the case with all computer networks linked to the internet, we cannot guarantee the security of information provided over the internet and will not be responsible for breaches of security beyond our reasonable control.
Links to third party internet sites and plugins
The Forty Two internet site and apps may contain links to other internet sites or apps that are not operated by Forty Two and plugins from social media platforms and other third parties. An example of a social media plugin is the Linked-In link button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.
Access to your personal information
You may review, correct and update personal information you provide to us by contacting us.
Retention of your personal information
How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.
Children
The Forty Two internet site is not intended for children under 13 years of age. Forty Two will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.
Additional Information for EU residents
Data controller and contact information
The controller for personal data collected under this Privacy Policy is Forty Two Limited.
You can find the contact details of Forty Two Limited on our internet site.
Forty Two lawful basis for processing your personal data
The lawful basis for Forty Two’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for Forty Two’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law.
Processing on the basis of legitimate business interests
When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include:
providing, improving, and promoting the Forty Two internet sites and our services;
communicating with current and potential customers, other Business Partners, and their individual points of contact;
managing our relationships with our customers and other Business Partners, and their individual points of contact;
other business development purposes;
sharing information within Forty Two, as well as with service providers and other third parties; and
maintaining the safety and security of our products, services and employees, including fraud protection.
Processing on the basis of performance of a contract
Examples of situations in which we process personal information as necessary for performance of a contract include the provision of Forty Two’s services.
Processing on the basis of consent
Examples of processing activities for which Forty Two uses consent as its legal basis include:
collecting and processing precise location information from your mobile device;
sending promotional emails when consent is required under applicable law; and
processing personal data on the Forty Two internet site through cookies and similar technologies when consent is required by applicable law.
Processing because Forty Two is under a legal obligation to do so
Examples of situations in which Forty Two must processes personal data to comply with its legal obligations include:
payment of taxes and other government levies;
providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws;
retaining business records required to be retained by applicable laws; and
complying with court orders or other legal process.
Additional information about the retention of your personal data
To determine the period for which your personal data will be retained in accordance with this policy, Forty Two considers criteria such as:
any applicable legal requirements to retain data for a certain period of time;
any retention obligations related to actual or potential litigation or government investigations;
any retention requirements in relevant agreements with our Business Partners;
the date of your last interaction with Forty Two (including with the Forty Two internet sites, communications, etc.);
the length of time between your interactions with Forty Two;
the sensitivity of the data; and
the purposes for which the data was collected.
7. GDPR and your individual rights
In accordance with the applicable laws in the UK, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. You can exercise your rights by contacting us.
Right of access
You have the right to ask Forty Two to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information
the purposes of the processing;
the categories of personal data we process;
the recipients or categories of recipients of your personal data;
the envisaged retention period of the data where possible, or the criteria we use to determine the retention period;
your right to request rectification or erasure of your personal data, or restriction of the processing of such data;
your right to file a complaint with a supervisory authority;
if we have not collected the data from you, any information we have available about the source of the data; and
whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.
Right to rectification
You have the right to have Forty Two correct your personal data if it is inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to Forty Two.
Right to object to processing for Forty Two’s legitimate business interests
You have the right to object to Forty Two processing your personal data when that data is processed on the basis of Forty Two’s legitimate business interests. Forty Two will honour your objection and stop processing the relevant personal data unless:
we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or
we need to continue processing your personal data to establish, exercise, or defend a legal claim.
Right to object to processing for direct marketing
If Forty Two processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, Forty Two will stop processing your personal data for direct marketing purposes.
Right to restrict processing
You have the right to request that Forty Two restricts the processing of your personal data in the following circumstances:
for the period of time Forty Two needs to verify the accuracy of your personal data when you contest its accuracy;
when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that Forty Two restrict the use of the data;
when Forty Two no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or
for the period of time Forty Two needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for Forty Two’s legitimate business interests.
If following your request Forty Two restricts the processing of your personal data, Forty Two will store your data, and otherwise process it only with:
your consent;
to establish, exercise, or defend a legal claim;
to protect the rights of another natural or legal person; or
for reasons of important public interest.
Forty Two will also inform you before lifting the restriction of processing.
Right to erasure
The right to erasure is also called the ‘right to be forgotten’. You may ask Forty Two to delete your personal data. This right not absolute. Forty Two is required to delete your personal data upon your request only in the following circumstances:
your personal data is no longer necessary for the purposes for which Forty Two collected or processed them;
if Forty Two processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for Forty Two to continue processing your personal data;
if Forty Two processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for Proctimise to continue processing your personal data;
if Forty Two has processed your personal data unlawfully; or
the personal data must be erased to comply with a legal obligation under the laws to which Forty Two is subject.
Forty Two is not required to erase your personal data to the extent that Forty Two needs to process them to:
exercise its right of freedom of expression and information;
comply with a legal obligation under the law to which Forty Two is subject; or
to establish, exercise, or defend a legal claim.
Right to data portability
You have the right to receive personal data you provided to Forty Two when:
the processing of the data is based on your consent or is necessary for the performance of a contract between you and Forty Two;
Forty Two’s processing of your personal data is carried out by automated means; and
complying with your request will not adversely affect the rights and freedoms of others.
If you have the right to receive such personal data and request that Forty Two provide it, Forty Two will provide it to you in a structured, commonly used, and machine-readable format.
Right to lodge a complaint with a supervisory authority
Forty Two will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.
8. Questions about this Policy or our Privacy Statements
If you have any questions about this Policy or our use of your personal information, please contact Forty Two. Our contact details are provided on our internet site.
9. Changes to this Policy and our Privacy Statements
Changes to this Privacy Policy will be posted on the Forty Two website, along with information on any material changes. Forty Two reserves the right to update or modify this policy at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.