Last update: SEPTEMBER 6th 2021
1. ABOUT THIS POLICY
- What personal data we collect when you browse on this site
- How we may use and share your personal data
- Your legal rights and how to exercise them
2. OUR CONTACT INFORMATION
Business ID / VAT number: FI22516868
Viikinkaari 4, 00790 Helsinki, Finland
GDPR & Compliance Officer: Arja Frejborg
3. WHAT PERSONAL DATA DO WE PROCESS?
The data collected on this site can be categorized into two groups: Customer data and Analytics data. Although we do not normally use Analytics data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with Customer data. In such situations, Analytics data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data. Ductor may collect and process the following Customer data:
- Your name and contact details
- Phone number
- E-mail address
- Possible communication with us
- Direct marketing opt-outs and opt-ins
We may also process details about your interaction with our emails (such as whether the email is opened and which links are clicked in the email).
Analytics data may include for example the following data:
- IP address
- Device type
- Operating system
- Time of visit
- Search terms used to reach our websites
- Browser type and version
- Browsing patterns on the site
- Unique cookie identifiers
- Language settings
4. DATA SOURCES
Your Customer data is primarily received directly from you in connection with your registration. We may also receive data directly from you if you contact us with a question or complaint. Analytics data is automatically collected when you visit the site. We may also track transactions data as well as details of your browsing patterns on the site.
5. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING
Purposes of processing
Customer communication: We may process personal data for the purpose of communicating with Customers. If you contact our customer service, we will use the provided information to answer your questions and for solving any issues you may have.
Analytics and service improvements :We may process information regarding the use of our site to improve our service quality. This may involve the use of analytics or the assessment of any trends on our website. When possible, we will do this using only aggregated, non-personally identifiable data.
Direct Marketing: With your consent we may send you marketing material, such as newsletters.
Legal grounds for processing
We process personal data to perform our contractual obligations towards Customers or to facilitate their entry into a contract at their request. We also process certain information to comply with legal obligations, such as accounting legislation.
Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business, for analytics and trend detection, direct marketing and to create and maintain customer relationships. We may also process data for responding to consumer claims, cases regarding product warranty and similar situations. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.
6. COOKIES AND ANALYTICS
7. DATA TRANSFERS TO COUNTRIES OUTSIDE EEA
Ductor stores the Customers’ personal data primarily within the European Economic Area and/or Switzerland. However, we have service providers in several geographical locations. As such, we or our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area, Switzerland or the Customer’s domicile. We will take steps to ensure that the Customers’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area and Switzerland through a series of agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements.
8. SHARING YOUR PERSONAL DATA
For legal reasons: We may share personal data with third parties outside Ductor’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests or safety of Ductor or our Customers in accordance with the law. Where possible, we will inform Customers about such transfer and processing.
With your explicit consent :We may share personal data with third parties outside Ductor’s organization for other reasons than the ones mentioned before, when we have the Customer’s explicit consent to do so. You have the right to withdraw this consent at all times.
To other data controllers: In certain cases we may also process and transfer your personal data to our third party partners with whom you have an existing contractual relationship with, if such transfer is necessary for providing you with certain benefits or to ensure the full performance of the Ductor products and the Ductor service. For example, if you purchase our products in connection to a bonus scheme campaign or in connection to another service provided by our third party partner, we may provide such partners with the personal data necessary for them to acknowledge and calculate your accrued bonus or to provide you with the service involving the use of Ductor products. Please note that such partners shall process your personal data as independent data controllers in accordance with their own privacy policies.
9. HOW LONG DO WE KEEP YOUR DATA?
Ductor does not store personal data longer than is legally permitted and necessary for the purposes specified above. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. Storage periods reflect the time frames we may need data for accounting, claims handling, internal reporting or reconciliation purposes.
10. YOUR RIGHTS
Right to access: You have the right to access your personal data processed by us. You may contact us and we will inform you what personal data we have collected and processed regarding you.
Right to withdraw consent: In case the processing is based on your consent, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our site. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to correct: Customers have the right to have incorrect or incomplete personal data we have stored about the Customer corrected or completed. You can correct or update some of your personal data through your account.
Right to erasure: Customers may also ask us to erase the Customer’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object: Customers may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the provision of the site to the Customer or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.
Right to restriction of processing: Customers may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our site.
Right to data portability: Customers have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights: The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, company name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the Customer. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
11. DIRECT MARKETING
Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes by contacting us or by using the unsubscribe possibility offered in connection with our newsletter.
12. SAFEGUARDING YOUR DATA
We do our best to keep your data safe and secure. We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures may include, for example, where appropriate, encryption, pseudonymization and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you and relevant authorities as required by applicable data protection laws.
13. LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the data protection supervisory authority.