Last Updated: June 1st, 2020
Name: Trustmary Group Oy
Business ID: FI27258474
Correspondence address: Ahjokatu 12, 40320 Jyväskylä
Contact: [email protected]
Personal data is primarily received directly from you in connection with your use of the Service. Personal data may also be provided to us by the company or organization on behalf of which you are using the Service. For business representatives and marketing contacts personal data may also be obtained from other sources, such as public registers.
Analytics data is collected automatically as you use the Service. Although we do not normally use such data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with personal 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.
The personal data collected and processed by Trustmary includes:
– Full name
– Email address
– Phone number
– Organization name and work title
– User account information, content, activity and settings
– Any direct correspondence with Trustmary (e.g. feedback, questions)
– Financial or payment card information
Additionally we may collect and process following analytics data:
– IP address
– Browser type and version
– Device type and model
– Operating system
– Time of visit
– High level location data
– Browsing patterns within the Service
We use various technologies to collect and store analytics data and other information from our Service, including cookies.
We also use Google Analytics to compile Analytics data and reports on visitor usage. For an overview of Google Analytics, please visit Google Analytics.
It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Hotjar is used on the site for tracking the cursor movements and keypresses of website visitors and for the collection of associated analytics.
Purposes of processing
To provide our Service and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
We primarily process personal data to be able to offer the Service to you and to run and maintain our business. We may use the data for example to offer essential functionalities of the Service and to provide access to the Service. Personal data may be processed in order to carry out our contractual obligations towards you or towards the organization you represent. The personal data of representatives of business customers is processed on the basis of our legitimate interests whilst fulfilling our contractual obligations towards the customer organization.
For our legal obligations (legal ground: compliance with a legal obligation)
We may process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our accounting obligations and providing information to relevant authorities.
For security, claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the detection or prevention of fraud, misuse of our Service and for activities aimed at ensuring the security of our data, systems and networks.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting you regarding our Service and for informing you of changes in our Service. We may also process personal data to market our Service, for example in the form of sending newsletters.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding the use of the Service to improve the quality of our service, for example by analysing any trends in the use of our Service. Where possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
The legal grounds for the processing of your personal data depend on the nature and purpose of processing. The specific legal grounds are elaborated above in connection to each purpose for which we process personal data for.
We may process personal data to take care of our contractual obligations towards you or to facilitate pre-contractual steps at your request. Certain data may be processed in order to comply with our legal obligations, such as accounting legislation.
We may also process personal data on the basis of consent when you have given your consent for the processing of personal data. In such case you have the right to withdraw your consent at any time by contacting us.
Personal data is further processed on the grounds of our legitimate interests to maintain and develop our business, for example for the purposes of collecting website analytics. When processing personal data on the basis of our legitimate interests, we carefully weigh our interests against your right to privacy.
Trustmary stores your personal data primarily within the European Economic Area. 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 or outside of your domicile.
We will take steps to ensure that your 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 through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
We may use or disclose aggregated information and/or de-identified information that does not specifically identify any individual without restriction.
We do not share personal data with third parties outside of Trustmary’s organization (which includes all Trustmary affiliates and subsidiaries) unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside Trustmary’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, property or safety of Trustmary, the users of our Service or the public in accordance with the law. When possible, we will inform you about such transfer and processing.
To authorized service providers
For other legitimate reasons
With explicit consent
We may share personal data with third parties outside Trustmary’s organization for other reasons than the ones mentioned before, when we have the your explicit consent to do so. You have the right to withdraw this consent at all times.
Trustmary does not store personal data longer than is legally permitted and necessary for the purposes of providing the Service or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
We will store analytics data relating to the Service for as long as we deem appropriate and reasonable.
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you. Where possible, you should primarily use the Service functionalities to access your own account information.
Right to withdraw consent
In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Service. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. Where possible, you should primarily use the Service functionalities to correct your own account information.
Right to erasure
You may also ask us to erase your 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
You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the our Service.
Right to restriction of processing
You 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 Service.
Right to data portability
You have the right to receive your 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. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
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, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Details above.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. 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 on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
The Service is not intended for children under 13 years of age. No one under age 13 may provide any information to or via the Service. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information via the Service or access or use the Service. If you believe we might have any information from or about a child under 13, please contact us at the Contact Details above.
Certain Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5), provide certain rights to Canadian residents including the right to request information from an organization about the existence, use or disclosure of such resident’s personal information, to request access to that information, and to challenge the accuracy and completeness of the information and have it amended as appropriate. If you are a Canadian resident and would like to make a request regarding your information that under our control, please contact us at the Contact Details above.
We will attempt to respond to your request within a reasonable time. Such response will be at minimal or no cost to you.
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 local supervisory authority for data protection.
In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
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