Privacy Policy

Last updated 13.08.2025

 his privacy notice for MoreThanDigital International GmbH (doing business as MoreThanDigital) (“we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

• Visit our website at https://morethandigital.info, or any website of ours that links to this privacy notice
• Download and use one of our mobile applications (e.g. MoreThanDigital), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at .

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. This can include account registration details, professional information you provide for your profile, and data you input into our analytics and educational platforms. Learn more about personal information you disclose to us in Section 1.

• Do we process any sensitive personal information? The definition of “sensitive information” varies by jurisdiction. Under laws like the GDPR, we do not routinely process “special categories of personal data” (e.g., health, religion, race). However, under other laws, such as in certain US states, information like precise geolocation or financial account details may be considered “sensitive.” We will only process such information where necessary, and typically with your explicit consent, which we will request at the time of collection. Learn more about sensitive information we process in Section 1.

• Do we receive any information from third parties? Yes, we may receive information from public sources, social media providers if you choose to log in via those services, and our partners, such as payment processors. Learn more about information collected from other sources in Section 1.

• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information in Section 2.

• In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. These include:

  • Service Providers who perform services on our behalf, such as cloud hosting and payment processing.

  • Affiliates within our corporate group for administrative purposes and to provide integrated services.

  • Analytics and Marketing Partners to help us understand service usage and deliver relevant communications, subject to your choices and consent.

  • Other Users when you choose to share information publicly on our platforms. Learn more about when and with whom we share your personal information in Section 4.

• How do we keep your information safe? We have implemented a system of organizational and technical security measures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe in Section 9.

• What are your rights? Depending on where you are located geographically, applicable privacy laws grant you certain rights regarding your personal information, such as the right to access, correct, or delete your data. Learn more about your privacy rights in Section 11.

• How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject access request form or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Learn more about exercising your rights in Section 17.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. SPECIFIC PRIVACY RIGHTS FOR OTHER REGIONS (e.g., Switzerland, Canada)
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following, categorized by Service:

• User Account (SSO for all services): Names, language preferences, general location (country), phone numbers, email addresses, usernames, passwords, and other contact or authentication data.

• Publication Platform: Names, email addresses, professional profile information (such as employment history, educational qualifications, job titles), and content you create (such as articles, posts, and messages).

• MoreThanDigital Insights (Business Analytics Platform): Company data you provide for analytics and benchmarking, which may constitute personal information if it relates to an identifiable natural person (e.g., a sole proprietor). This can include financial data, industry information, employee headcount, and survey responses.

• MoreThanDigital Academy (Education Platform): Information related to your educational progress, such as courses enrolled in, test scores, grades, skills acquired, and certificates earned.

• MoreThanDigital App: Data about your activity and preferences, such as reading patterns, topics of interest, learning progress, and interactions with app features.

Sensitive Personal Information

In Short: Depending on your jurisdiction and the choices you make, we may process certain information that is considered “sensitive.” We will only do so with your explicit consent or as otherwise permitted by law.

Data protection laws in different regions define “sensitive information” differently.

• Special Categories of Personal Data (as defined by GDPR in the EEA, UK, and Switzerland): This is a specific list of data types, including information revealing racial or ethnic origin, political opinions, religious beliefs, or data concerning health or a person’s sex life. We do not intentionally collect or process this type of data unless you voluntarily provide it in a public forum (e.g., in an article you write).

• Sensitive Personal Information (as defined by certain US State laws): This is a broader category that may include your account login credentials, financial account or debit/credit card numbers, and precise geolocation data.

Where we need to process sensitive personal information according to the relevant legal definition, we will request your explicit consent at the point of collection and provide specific notice about how it will be used.

Payment Data

We use Stripe as our third-party payment processor. When you make a purchase, your payment data is provided directly to Stripe. We do not store your full payment instrument number (e.g., credit card number) on our servers. We may receive and store transaction-related information from Stripe, such as a transaction ID, payment status, and the last four digits of your payment instrument, which is necessary for order fulfillment, accounting, and customer support. You can find Stripe’s privacy notice here: https://stripe.com/privacy.

Social Media Login Data

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X (formerly Twitter), or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track precise location-based information from your mobile device to provide certain location-based services. This is considered sensitive personal information in some jurisdictions, and we will request your explicit consent. You may change our access or permissions in your device’s settings at any time.

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your calendar, camera, and storage. If you wish to change our access or permissions, you may do so in your device’s settings.

• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). You may turn these off in your device’s settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://legal.morethandigital.org/cookie-policy/.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.

• Location Data. We collect imprecise location data (e.g., country-level) based on your IP address. As noted above, we will only collect precise geolocation data from your mobile device with your explicit consent.

2. HOW DO WE PROCESS YOUR INFORMATION?

n Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason (i.e., legal basis) to do so.

We process your personal information for a variety of reasons, depending on how you interact with our Services. The purposes for our processing and the legal bases we rely upon are detailed below. For more information on these legal bases, please see Section 3.

• To facilitate account creation, authentication, and management. We process your information to enable you to create and log in to your account and to keep your account in working order.

  • Legal Basis: Performance of a Contract.

• To deliver the Services you have requested. We process your information to provide you with our core services, such as publishing your content, providing educational courses, or delivering business analytics.

  • Legal Basis: Performance of a Contract.

• To fulfill and manage your orders and subscriptions. We process your information to manage payments, returns, and exchanges made through the Services.

  • Legal Basis: Performance of a Contract.

• To provide certificates that validate your achievements. For users of our Academy, we process your data to issue certificates recognizing the skills and knowledge you have acquired.

  • Legal Basis: Performance of a Contract.

• To send administrative and service-related communications. We may process your information to send you details about our products and services, changes to our terms and policies, and other essential information about the Services.

  • Legal Basis: Legitimate Interests (to keep you informed about your service) and in some cases, Legal Obligations.

• To respond to user inquiries and provide support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • Legal Basis: Legitimate Interests (to provide effective customer support).

• To enable user-to-user communications. We process your information if you choose to use any of our offerings that allow for communication with another user (e.g., messaging on the platform).

  • Legal Basis: Legitimate Interests (to facilitate communication features chosen by users).

• To request feedback. We may process your information to contact you about your use of our Services and request feedback.

  • Legal Basis: Legitimate Interests (to improve our services).

• To protect our Services and prevent fraud. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

  • Legal Basis: Legitimate Interests (to protect our business and users) and Legal Obligations.

• To identify usage trends and improve our Services. We process information about how you use our Services to better understand how they are being used so we can improve them. This involves aggregated or pseudonymized data where possible.

  • Legal Basis: Legitimate Interests (for internal analytics and service improvement).

• To offer personalized content and recommendations. We may process your interaction data to offer you content and recommendations that are relevant to your interests.

  • Legal Basis: Legitimate Interests (to enhance your user experience). You have the right to object to this processing.

• To deliver marketing and promotional communications. We may process your information to send you marketing communications about our products and services.

  • Legal Basis: Consent. You can unsubscribe at any time.

• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

  • Legal Basis: Vital Interests.

• To comply with legal obligations. We may process your information to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.

  • Legal Basis: Legal Obligations.

If you use our business analytics platform, we use your company data to:

• Provide customized benchmarks comparing your company to industry peers.

• Offer analytics and insights about your business based on the information collected.

• Make platform improvements based on usage data and feedback.

• Share aggregated and/or irreversibly anonymized data externally for industry research and analysis. If data is pseudonymized (meaning it can be re-identified with additional information), it remains personal data and is processed under strict safeguards as outlined in this policy. Company data will only be visible to users you explicitly invite to your account. We ensure appropriate anonymization or pseudonymization techniques are applied to any data shared externally to protect confidentiality.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law. The specific legal basis we rely on depends on the processing purpose, as detailed in Section 2 above.

If you are located in the EU, UK, or Switzerland, this section applies to you.

The General Data Protection Regulation (GDPR), UK GDPR, and Swiss FADP require us to explain the valid legal bases we rely on to process your personal information. We rely on the following:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose, such as for sending marketing emails. You have the right to withdraw your consent at any time.

• Performance of a Contract. We process your personal information when it is necessary to fulfill our contractual obligations to you, such as creating your account and providing our core Services.

• Legitimate Interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests, provided those interests do not outweigh your interests and fundamental rights and freedoms. For example, we rely on legitimate interests to analyze how our Services are used for improvement, provide customer support, and for security purposes. Where we rely on this basis, we have conducted a balancing test to protect your rights. You have the right to object to processing based on legitimate interests.

• Legal Obligations. We may process your information where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency.

• Vital Interests. We may process your information where it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent. A list of these exceptions is available upon request but includes, for example, situations where collection is for investigations and fraud prevention or to comply with a court order.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the categories of third parties detailed below.

We may need to share your personal information with the following categories of third parties:

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://legal.morethandigital.org/cookie-policy/.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own, including the United States. We use legally recognized mechanisms to ensure your data is protected.

Our servers are located in Switzerland, the United States, Finland, France, and Germany. If you are accessing our Services from outside these countries, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see Section 4), in these and other countries.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please note that some of these countries may not have data protection laws as comprehensive as those in your country. However, we take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. We rely on the following legal mechanisms for international transfers:

• Adequacy Decisions. The European Commission, UK Government, and Swiss Federal Council have determined that certain countries provide an adequate level of data protection. We may transfer your data to these countries without any further safeguards. This includes transfers to our facilities and partners in Switzerland and the UK.

• The EU-U.S. and Swiss-U.S. Data Privacy Frameworks. For transfers of personal information to service providers in the United States, we rely on the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. MoreThanDigital International GmbH complies with these frameworks as set forth by the U.S. Department of Commerce. We verify that our U.S.-based data recipients are certified to the DPF before transferring personal information. To learn more about the Data Privacy Framework (DPF) program, and to view the certifications of our partners, please visit https://www.dataprivacyframework.gov/.

• Standard Contractual Clauses (SCCs). For transfers to third parties in countries that do not have an adequacy decision and where the DPF is not applicable, we use Standard Contractual Clauses approved by the European Commission, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner. These clauses contractually require the recipient to protect your data to the high standards of European, UK, and Swiss law. We also implement supplementary measures, where necessary, to ensure the data remains protected in the destination country.

For more detailed information on our international data transfer practices, you may contact us using the details provided in Section 16.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, or for as long as required or permitted by applicable law (such as tax, accounting, or other legal requirements). This means that retention periods may vary depending on the type of data and the purpose for which it was collected. For example, data related to financial transactions may be kept for longer periods due to tax regulations, while certain usage data may be deleted sooner.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We are committed to protecting the privacy of children. We do not knowingly solicit data from or market to children under the age of 13. The age at which a user can provide their own valid consent for our Services varies by country, and we have processes in place to address these requirements.

Our Services are not directed to children under 13 years of age, and we do not knowingly collect personal information from them.

For users aged 13 and older, the age at which an individual can provide their own consent for online services (“age of digital consent”) varies by jurisdiction. Under the EU/UK General Data Protection Regulation (GDPR), this age is between 13 and 16.

When you register for our Services, we may ask for your date of birth to determine your age. If you are under the applicable age of digital consent in your country of residence, we will require verifiable consent from your parent or legal guardian before we can create your account and process your personal information. If we learn that we have collected personal information from a user under the applicable age of consent without the requisite parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

The table below outlines the age of digital consent in some of our key operating regions.

If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us at .

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

(i) Right of confirmation: To obtain confirmation as to whether personal data concerning them is being processed.

(ii) Right of access: To obtain free information about their stored personal data and a copy, including processing purposes, data categories, recipients, storage period criteria, existence of rectification/erasure/restriction/objection rights, right to lodge a complaint, information on data source (if not from data subject), and information on automated decision-making/profiling. Also, information on transfers to third countries or international organizations and appropriate safeguards.

(iii) Right to rectification: To obtain without undue delay the rectification of inaccurate personal data and to have incomplete data completed.  

(iv) Right to erasure (Right to be forgotten): To obtain erasure of personal data without undue delay if no longer necessary for purposes collected, consent is withdrawn (and no other legal ground), data subject objects (and no overriding legitimate grounds), data unlawfully processed, or required for legal compliance. If data has been made public, the controller must take reasonable steps to inform other controllers of the erasure request.

(v) Right of restriction of processing: To obtain restriction of processing if accuracy is contested, processing is unlawful but erasure is opposed, data is no longer needed by controller but required by data subject for legal claims, or data subject has objected pending verification of legitimate grounds.    

(vi) Right to data portability: To receive personal data provided to a controller in a structured, commonly used, and machine-readable format, and to transmit those data to another controller without hindrance, where technically feasible and not adversely affecting others’ rights and freedoms.    

(vii) Right to object: To object, on grounds relating to their particular situation, to processing based on public interest or legitimate interests (including profiling). If data is processed for direct marketing, the data subject has the right to object at any time.    

(viii) Automated individual decision-making, including profiling: Not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects them, unless necessary for a contract, authorized by law (with safeguards), or based on explicit consent. If necessary for a contract or based on consent, suitable measures to safeguard rights and legitimate interests are implemented, including human intervention, expressing point of view, and contesting the decision.    

You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below, or by submitting a request via our dedicated privacy web form (if available).

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below, or by using the notification settings in the account (if available).

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://legal.morethandigital.org/cookie-policy/.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. SPECIFIC PRIVACY RIGHTS FOR US RESIDENTS

In Short: If you are a resident of certain US states, such as California, Colorado, or Virginia, you have specific rights regarding your personal information, including the right to opt out of targeted advertising and the “sale” or “sharing” of your data.

This section applies to you if you are a resident of a US state with a comprehensive privacy law.

Your Rights with Respect to Your Personal Data

Depending on your state of residence, you may have the following rights:

• The right to know what personal information we collect, use, disclose, and sell or share.

• The right to request deletion of your personal information.

• The right to correct inaccurate personal information.

• The right to opt out of the “sale” or “sharing” of your personal information.

• The right to opt out of targeted advertising.

• The right to limit the use and disclosure of your sensitive personal information.

• The right to not be discriminated against for exercising your privacy rights.

Sale and Sharing of Personal Information

We do not “sell” your personal information in the traditional sense for monetary payment. However, some of our activities may be considered “sharing” under the California Consumer Privacy Act (CCPA) or “targeted advertising” under other state laws. For example, we may use third-party advertising cookies and similar technologies that provide information about your interaction with our Services to our advertising partners to make ads on other sites more relevant to you.

You have the right to opt out of this “sharing” and targeted advertising. You can exercise this right by clicking the “Do Not Sell or Share My Personal Information” link in the footer of our website or by enabling a legally recognized opt-out preference signal, such as the Global Privacy Control (GPC), in your browser.

How to Exercise Your Rights

To exercise any of your rights, please submit a request by:

• Emailing us at

• Submitting a request through our data subject access request form [link].

We will need to verify your identity before processing your request and may ask for additional information to do so. You may also designate an authorized agent to make a request on your behalf.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender and date of birth	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	YES
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal Information	Account login information, contents of email or text messages and debit or credit card numbers	YES

We will use and retain the collected personal information as needed to provide the Services or for the retention periods described in Section 8.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a “resident” as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

• Right to request deletion of the data — Request to delete You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

• Right to be informed — Request to know Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;

  • the categories of personal information that we collect;

  • the purposes for which the collected personal information is used;

  • whether we sell or share personal information to third parties;

  • the categories of personal information that we sold, shared, or disclosed for a business purpose;

  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

  • the business or commercial purpose for collecting, selling, or sharing personal information; and

  • the specific pieces of personal information we collected about you.

• Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights.

• Right to Limit Use and Disclosure of Sensitive Personal Information You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the Services.

• Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us.

• Other privacy rights

  • You may object to the processing of your personal information.

  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA): “Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. “Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. “Sale of personal data” means the exchange of personal data for monetary consideration. If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. Your rights with respect to your personal data:

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at . Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

For Residents of Switzerland (under FADP): The revised Federal Act on Data Protection (FADP), effective September 1, 2023, grants individuals in Switzerland enhanced rights regarding their personal data. These rights are similar to those under GDPR and include:

• Right to Information: You have the right to be informed about the collection of your personal data, including the identity of the data controller, the purpose of processing, categories of recipients, retention periods, and data origin.

• Right of Access: You can request access to your personal data.

• Right to Rectification: You can request the correction of inaccurate personal data.

• Right to Erasure (Right to be forgotten): You can request the deletion of your personal data.

• Right to Restriction of Processing: You can request the restriction of processing under certain conditions.

• Right to Data Portability: You can request to receive your personal data in a standard electronic format and transmit it to another controller.

• Right to Object: You can object to certain processing activities.

• Rights related to Automated Decision-Making: You have rights concerning decisions based solely on automated processing.

For Residents of Canada: If you are located in Canada, we may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations.

For residents of Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

For residents of Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: 

Complaints (complete POPIA/PAIA form 5):  & 

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) and our privacy team. Our designated DPO is Benjamin Talin.

• By email:

• By phone: +41 79 873 3853

• By post:
  MoreThanDigital International GmbH
  Attn: Data Protection Officer
  Zugerstrasse 77 c/o Helveticorp
  6340 Baar, Zug
  Switzerland

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.