Europe Privacy Addendum

This addendum supplements the Privacy Policy for people in the European Economic Area, the United Kingdom, and Switzerland. If there is a conflict for that processing, this addendum controls.

1. Controller

The controller is the Operator doing business as 141 software, based in the United States. Privacy contact: privacy@141.software. We currently have no establishment in the EEA or the UK. We have not appointed a representative under GDPR Article 27 or the UK equivalent. Whether that appointment is required depends on the nature and scale of processing. If we appoint a representative, we will identify that representative on this page.

2. Purposes, data, and legal bases

We process personal information only as needed for the purposes below. We do not need every category for every person.

• Waitlist, accounts, and providing the Services — account and waitlist data, and usage needed to operate the product. Legal basis: contract (GDPR Art. 6(1)(b)).
• Paid plans and billing — billing contact and transaction records, when you purchase. Legal basis: contract.
• Security, abuse prevention, fraud, and debugging. Legal basis: legitimate interests (Art. 6(1)(f)).
• Tax, accounting, and responding to lawful requests. Legal basis: legal obligation (Art. 6(1)(c)).
• Product or access mail you have not opted out of. Legal basis: legitimate interests, or consent where required.
• Optional measurement cookies on 141.software. Legal basis: consent (Art. 6(1)(a)). Withdraw it at any time via the cookie banner; withdrawal does not affect prior lawful processing.

We have carried out a legitimate-interest balancing test for security and ordinary product-operation processing. Email privacy@141.software if you want a summary.

3. Transfers

Personal information is processed in the United States and in other countries where our processors operate. Where a restricted transfer requires a safeguard, we rely on Standard Contractual Clauses with processors (including UK and Swiss addenda where required), an adequacy decision, or another lawful mechanism. We are not currently certified under the EU-US Data Privacy Framework. We do not treat continued browsing as consent to a transfer.

Categories of recipients are described on the Processors page.

4. Your rights

You may request access, rectification, erasure, restriction, or portability, object to processing based on legitimate interests, and withdraw consent. Email privacy@141.software. We will not charge a fee unless a request is manifestly unfounded or excessive. We do not make solely automated decisions with legal or similarly significant effects about you.

You may complain to your supervisory authority (an EEA data-protection authority, the UK Information Commissioner's Office, or the Swiss FDPIC). We ask that you contact us first so we can try to resolve it.

5. Instructions after death (France)

If French law applies, you may give us instructions about your personal information after death by emailing privacy@141.software.