TRUSTMARY PRIVACY POLICY

Last Updated: June 1st, 2020

This Privacy Policy is applicable to the personal data processed by Trustmary Group Oy (“Trustmary” or “we”) relating to the visitors of the Trustmary website and the users of the Trustmary online service (website and online service hereinafter jointly referred to as “Service”). This Privacy Policy describes the types of information Trustmary may collect from you or you may provide to Trustmary when you access or use the Service, and Trustmary’s practices for collecting, using, and disclosing that information. This Privacy Policy also applies to the processing of personal data of the representatives of our current or prospective customers, marketing contacts and contractors. All Service users and business representatives are hereinafter collectively referred to as “Data Subjects” or “you”.

Additionally, the purpose of this Privacy Policy is to provide Data Subjects with information about the processing of their personal data in accordance with the information obligations set out in Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR). 

Please note that this Privacy Policy only applies to processing carried out by Trustmary as a data controller. This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.

By accessing or using the Service, you agree to this Privacy Policy and consent to your data being collected, processed, disclosed and maintained in accordance with the terms herein. If you do not agree with this Privacy Policy, do not access or use the Service. This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website. We will not make substantial changes to this Privacy Policy or reduce the rights of Data Subjects under this Privacy Policy without providing a notice thereof.

CONTACT DETAILS

Name: Trustmary Group Oy
Business ID: FI27258474
Correspondence address: Ahjokatu 12, 40320 Jyväskylä
Contact: [email protected]
Website: trustmary.com

PERSONAL DATA PROCESSED AND SOURCES OF DATA

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

COOKIES AND ANALYTICS TOOLS

We use various technologies to collect and store analytics data and other information from our Service, including cookies.

Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites and facilitate the use of our Service and to create aggregate information of our visitors. This helps us to improve our Service. The cookies will not harm your device or files. We use cookies content personalization and tailoring. Cookies are also used to integrate our social media accounts onto our website.

Data Subjects may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Safari
Google Chrome
Internet Explorer
Mozilla Firefox

Please note that some parts of our Service may not function properly if the use of cookies is refused.

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 and legitimate grounds of processing

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.

INTERNATIONAL TRANSFERS

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.

PERSONAL DATA RECIPIENTS

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:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to perform the Service, Trustmary has taken appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

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

We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and support services). Our agreements with our service providers include commitments requiring the service providers to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.

For other legitimate reasons

If Trustmary is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Data Subjects concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

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.

STORAGE PERIOD

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.

DATA SUBJECTS’ RIGHTS

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.

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, 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.

INFORMATION SECURITY

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.

Children Under the Age of 13

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.

Canadian Privacy Notice 

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. 

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 local supervisory authority for data protection.

In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).

Privacy Policy version history
Name of the document Valid from Valid until Date updated
Trustmary Privacy Policy, 01062020 June 1st 2020 Until further notice June 1St 2020
Trustmary Privacy Policy