Effective from 25 May 2018. Updated on 23 May 2018.
In order to serve you to the best of our abilities, we need to collect and process some personal information about you.
We value your privacy and are committed to protecting it in accordance with this Privacy Notice, existing legislation and good business practices.
This Privacy Notice follows the requirements of the EU General Data Protection Regulation and explains what type of information we collect, on what grounds we process it, and what rights you have concerning your own data.
Note! This Privacy Notice applies to the processing of data carried out by Pulse247 Oy. If you need information regarding the processing of personal data by our customers in their online stores, please contact the company maintaining the said store.
Pulse247 Oy (business ID 2131570-6) processes your personal data in accordance with this Privacy Notice and applicable legislation. We ask you to read this notice carefully.
By using our services or our website or by contacting us you consent to us processing your data according to this Privacy Notice. If you do not agree to these terms and conditions, we are probably not able to serve you in the best possible way.
2. For what purposes is my personal information collected and processed?
We collect, retain and process your personal data only for the following predefined purposes:
- customer relationship management and customer communication
- customer service and responding to contact requests
- implementing and developing our services
- monitoring and analyzing the use of our products and services
- customer segmentation in order to provide personalized content in products and services
- ensuring the safety of our products and services and investigating misuse
- customer surveys, opinion polls and market research
- business development
- targeted marketing and advertising
- direct marketing
We do not profile data subjects based on their personal characteristics or process data for automated decision-making purposes.
3. What type of personal data is collected and from which sources?
We mainly collect personal data from you directly when you contact us or use our website or services. We also collect information manually; for example, over the phone while providing customer service or making sales.
In addition to the information submitted by you, we use and analyze cookies to improve our website and services and provide targeted advertising and marketing.
We also collect information from public sources, such as trade and business registers and other sources providing information on corporate decision-makers. The data collected from these sources include company and contact information, such as the decision-makers' name, email address and phone number.
4. On what grounds is the personal data processed?
Our personal data processing is based on the law. The legal basis of the processing depends on our relationship with you. The table below lists the different legal grounds and provides examples of the processing operations.
|LEGAL BASIS||EXAMPLE OF PROCESSING|
|Contractual relationship or pre-contract measures||We process customer data based on the contractual relationship for all purposes defined in Paragraph 2.|
|Legal obligation||We retain and process customer data under, for example, the Accounting Act.|
|Legitimate interests of the data controller or third parties||If we do not have a contractual relationship with you, data processing is based on legitimate interests. These include, for example, customer service provision and responding to contract requests, monitoring the number of visitors on our website, site development, ensuring data security of our services, and investigating possible misuse. Collecting company representatives' contact information and processing them for marketing purposes is also based on a legitimate interest.|
|Consent||When you as a private person order a guide or a newsletter from our website, personal data processing is based on your consent. During data collection, we ask for your permission to use it for direct marketing.|
5. Who processes my data and is the data transferred to third parties?
Your data is processed by our staff as part of their duties. We do, however, use third-party data systems for storing and processing the data. In this case, we ensure by contracts and other means that the data is handled confidentiality and according to applicable legislation.
We disclose data to our partners in IT, payment forwarding, shipment and accounting for the provision of their services. You may, for example, decide to include payment or logistics services or other such third-party services in your online store, and order them via our website or service. If the ordered service involves data transfer to third parties, this is mentioned when placing the order.
We may also release information in order to fulfil other contractual obligations or upon request of a competent authority. We may also disclose your information if we are a party in a company or business acquisition.
6. Is my data transferred outside the EU?
We prefer service providers whose servers are located in the EU. We do, however, also use reputable and reliable external service providers, whose servers are located outside the EU, in which case data is transferred outside the EU/EEA in a limited way.
When personal data is transferred outside the EU/EEA, the transfer takes place under the EU-U.S. Privacy Shield arrangement, using the EU Commission's standard contractual clauses or other transfer mechanism permitted by law. The confidentiality and legitimate processing of the information is ensured with contracts and other means.
7. How long will my personal data be stored?
We will retain your personal information only for as long as is necessary for its intended purpose or as required by a contract or the law.
We try to update the data and delete unnecessary information on a regular basis. As a general rule, data that has not been used in over two years is removed unless it is needed to, for example, ensure the safety of our services, or there are legal reasons that prevent the removal.
The Accounting Act, for example, dictates that accounting records must be retained for a minimum of six (6) years from the end of the fiscal year.
8. How is the data stored and protected?
Your data is stored in our service providers' servers that are protected following common industry practices. We have taken appropriate action to ensure that the processing complies with the requirements of applicable legislation and security measures in order to prevent accidental or unlawful destruction, loss or alteration of the data, or unauthorized disclosure or access.
The personal data we collect and process will be kept confidential, and access is restricted to those who need the data in order to perform their work. Additionally, we undertake to disclose or convey the data only to employees or other individuals (including any subcontractors) who need the data for an agreed purpose and who under an employment contract or other agreement are legally obligated to maintain the confidentiality of the information. Access to your personal data is protected with user-specific IDs, passwords and access rights.
9. Obligation to provide information and consequences of non-provision?
If you refuse to provide your personal data or prohibit us from processing it according to the principles presented in this Privacy Notice, we will probably not be able to serve you and fully meet the purpose of our operations. If you do not want us to process your information in accordance with this Privacy Notice, we ask you to refrain from providing the information altogether.
Cookies are small text files stored by the network server on the user’s terminal. Cookies provide us with information about how visitors are using our website and services. We use this information to develop our services and the site, to analyze usage, and to target and optimize marketing and advertising.
You may enable or disable cookies from your browser settings. Most browsers allow cookies automatically. Please note that blocking cookies may limit the functionality of our website and services.
11. What rights do I have?
|DATA SUBJECT RIGHT||WHAT DOES IT MEAN?|
|Withdrawal of consent||If data processing is based on your consent, you may at any time withdraw the consent by notifying us of the matter. You can also prohibit the use of your data for direct marketing purposes at any time by clicking the "Cancel order" link at the end of each marketing email.|
|Access to data||You have the right to receive confirmation from us as to whether we process your personal data and to know exactly what data the processing entails. In addition, you have the right to receive supplementary information about the grounds for the processing.|
|Right of rectification||You have the right to request that we correct any inaccurate, outdated or otherwise incomplete personal data.|
|Right of removal||You have the right to request the removal of your data if, for example, the data is no longer needed for the purpose for which it was originally collected, or you wish to withdraw the consent on the basis of which we have processed the data.|
|Right to prohibit direct marketing||You can prohibit the processing of your personal data for direct marketing purposes at any time by clicking the "Exit mailing list" link at the end of our emails, or by contacting our customer service. If you are our customer and prohibit the use of your data for direct marketing, we will only send you messages necessary for maintaining the customer relationship.|
|Right to object to processing||If data processing is based on a general or legitimate interest, you have the right to object to the processing as long as it is not based on compelling legitimate grounds that override your rights, or the processing is not necessary to meet a statutory obligation. Please note that this will probably prevent us from providing you the service you requested.|
|Right to restrict processing||Under certain circumstances, you have the right to request restrictions on the ways we process your personal data. For example, if you believe there are errors in the data, we may restrict the processing until verification, or if you find the processing to be contrary to law and do not want your data to be removed.|
|Right of have data transferred||If processing is based on your consent or fulfilling contractual obligations, you have the right to receive the data submitted to us electronically in a commonly used machine-readable format, so that the data can be transferred to another service provider, if technically possible.|
|Right to object to automated processing and profiling||We do not profile data subjects based on their personal characteristics or process data for automated decision-making purposes.|
12. How can I exercise my rights?
If you wish to exercise any of the rights described above, you can contact us, for example, by sending an email to email@example.com. More detailed contact information is given at the end of this document. Please be prepared to prove your identity if your request concerns personal data processing.
If you feel that the way we process your personal data does not conform to law, you can file a complaint with the competent supervisory authority. Contact information for the Finnish Data Protection Ombudsman can be found on the DPO website.
13. Can this Privacy Notice be updated?
We may update the content of this Privacy Notice as our operations develop and/or there are changes in the relevant legislation. Please revisit this page from time to time for updates. The date of the latest version is located at the beginning of this document. In the case of significant changes made to the Privacy Notice, we try to communicate them to data subjects in the context of terms and conditions updates.
14. Who should I contact in matters related to data protection?
The easiest way to contact us is by sending an email to firstname.lastname@example.org. Messages sent to this address will be handled confidentially by our data protection team.
+35820 741 9174