The SDK collects no direct identifiers such as name, e-mail address or phone number; data is linked only to random IDs. As QuantActions has no means reasonably likely to re-identify users (GDPR, Recital 26), it considers this pseudonymised data non-personal in its hands. In QuantActions’ assessment, the GDPR and the Swiss FADP therefore do not apply to its processing of this data.
For customers, the data may be personal, depending on how they onboard app users. Each customer is responsible for assessing this, for complying with applicable data protection law, and for informing its users that data is shared with QuantActions.
Customers must not send QuantActions information that could identify users, such as names or e-mail addresses in journal entries or support requests.