Privacy Policy

At Feelment, we understand that privacy is important for our customers. We are committed to respecting and safeguarding our customers' privacy. As our customer, you trust us with your confidential information, and we are obligated to act in accordance with this trust every day.

In this Privacy Policy, we disclose:

1. How we collect your personal information.
2. What types of personal information we process about you.
3. For what purposes we process your personal information.
4. How we protect and secure your personal information.
5. To whom we disclose your personal information.
6. How long we retain your personal information.
7. What rights and choices you have regarding the processing of your personal information.

We comply with EU and Finnish legislation applicable to Viihdeväylä in the processing of your personal information, as well as with instructions and guidelines from authorities. This Privacy Policy applies to the processing of personal information of natural persons, whether you are a consumer or a business customer.

Definitions

In this Privacy Policy, the following terms are used as follows:

Anonymized data refers to information that can no longer be associated with you as an individual because all identifying elements have been removed.

Customer is a subscriber, buyer, or user of our services. A customer in a contractual relationship with Viihdeväylä is responsible for ensuring that all users (e.g., employees using the same Feelment® license) are aware of and understand the content of the Privacy Policy.

Personal data is information that can be directly or indirectly linked to you as an individual. The types of personal data we process are described below in the Privacy Policy.

Services refer to all products and services offered by Viihdeväylä.

1. How do we collect your personal information?

We may collect personal information from the following sources:

Directly from you, when you interact with us, make purchases or orders for our Services and products, register or log in to our Services, visit our website, subscribe to our newsletter, respond to customer satisfaction surveys, or contact us.

Observed data generated during the use of the Service. We process this data within the limits allowed by law, for example, when you use our websites or the Feelment® service.

Derived data that we have created from your personal data, such as conclusions drawn from analytics for targeted marketing purposes to identify potential areas of interest.

Explicitly from other sources, such as other service providers or publicly available registers, e.g., from the population register center, Posti's registers, Suomen Asiakastieto, or Fonecta.

The provision of personal data to Viihdeväylä (Feelment®) is not mandatory, but if you choose not to provide your personal data, we may not be able to provide our Services to you.

User Tracking with Leadoo

We use Leadoo's user tracking to monitor how our users navigate our websites and combine this data with user information collected, for example, through chat interactions. Leadoo uses ETag tracking, which differs from cookie-based tracking by combining information from multiple user sessions. Please review Leadoo Marketing Technologies Ltd.'s privacy policy (https://leadoo.com/privacy-policy/) to learn more about what is tracked in the system. In terms of GDPR, we act as the data controller, and Leadoo processes the data. If you do not want to be tracked, you can clear your browser's cache. More information about how Leadoo operates can be found at: https://leadoo.com/privacy-policy-processor/

2. What types of personal information do we process about you?

We may process the following types of personal information:

a) Basic information such as name and contact details, preferred method of contact, responsibility/title, social media identifiers.

b) Information collected when registering and logging in to Viihdeväylä services, such as user IDs and passwords.

c) Information related to customer relationship and contractual matters, such as information related to services, products, and orders, customer and user information, billing, credit monitoring, and payment information, bank contact details, customer contacts and related recordings (such as email and chat messages received by our customer service).

d) Information related to direct marketing campaigns, permissions and prohibitions related to direct marketing, interests, subscriptions to newsletters and event invitations, information related to targeting direct marketing.

e) Other information collected with your explicit consent, specifically defined at the time of requesting consent.

3. For what purposes do we process your personal information?

a) Based on contractual relationship and for the provision of Services

We process your personal information for the provision and delivery of Services. Your personal information is processed to facilitate communication, service delivery, and data security. This is how we operate when transmitting communication over our network, such as forwarding calls, text messages, or emails. Furthermore, providing Services requires the processing of personal information for contract or customer relationship management, customer or user identification, order processing and delivery, billing, quality control of services and products, credit control, collection, customer service, and the handling of various faults and complaints.

The establishment of a contractual relationship and/or the provision of services may require an approved credit decision, which may be made using automated decision-making. We also process personal information for customer communication, such as sending notifications related to the Services and contacting customers regarding matters related to the Services.

When necessary, we may process your personal information to detect or prevent misuse or fraud related to the Services, such as when a paid Service has been used for free. We may also collect information about your use of the Services for security purposes, such as successful and unsuccessful logins to our Services that require registration.

We also create statistics for the development of Services or other analysis needs.

We process your personal information internally for the development and management of our business, Services, and related processes, as well as for quality assurance. This processing may be necessary, for example, when analyzing delivery processes and related complaints to improve our delivery processes and find better and faster ways to serve our customers. We also process personal information to better understand our customers' needs and preferences, such as with regard to the features or content of our Services.

b) Based on legitimate interest

Viihdeväylä may process your personal information based on legitimate interest. Viihdeväylä has a legitimate interest in processing your personal information in situations such as:

Direct marketing: We process and use personal information for marketing purposes and to create marketing target groups within the limits of applicable law. We may also process your personal information to target our marketing efforts to products and services that may be of interest to you. We may use your personal information within the limits of applicable law for marketing our own products and services as well as those of our partners, including direct marketing, market research, and customer satisfaction surveys.

Personalizing Services: We may process personal information to personalize and target Services, such as making recommendations to users, targeting content in our Services or displaying targeted advertisements. We process this personal information within the limits of applicable law.

Customer communication: We process personal information for customer communication and to send notifications related to the Services. We may process personal information to contact customers regarding matters related to the Services.

Improving the quality of services: We process personal information to improve and develop our business, Services, and related processes, as well as for quality assurance. This processing may be necessary, for example, when analyzing delivery processes and related complaints to improve our delivery processes and find better and faster ways to serve our customers. We also process personal information to better understand our customers' needs and preferences, such as with regard to the features or content of our Services.

c) Based on your consent

We may process your personal information based on your explicit consent, provided to us at the time of the collection of your personal information. If you grant your consent, you may withdraw it at any time by contacting our customer service or in the manner specified in the marketing message. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

We process your personal information for the following purposes based on your consent:

Marketing: We process personal information for direct marketing and market research purposes. You can subscribe to and unsubscribe from our newsletter in our online service. You may also receive invitations to our events or satisfaction surveys in connection with using our Services.

4. How do we protect and secure your personal information?

We protect your personal information through appropriate technical and administrative measures. These measures include, among other things, firewalls, encryption, secure device management, personnel training, secure facility management, and access rights management. We regularly assess the adequacy of our security measures, taking into account the state of the art, the sensitivity of personal data, and the risks associated with processing.

We restrict access to personal data to those of our employees, subcontractors, and partners who need to know the data for legitimate purposes. These individuals are subject to confidentiality obligations and may be subject to disciplinary measures or termination of their employment or contract if they fail to meet these obligations.

5. To whom do we disclose your personal information?

We do not disclose your personal information to third parties for marketing purposes without your consent. However, we may share your personal information with the following recipients for legitimate purposes:

Our subcontractors and partners who provide services to us or on our behalf. For example, we may use subcontractors for customer service, direct marketing, IT services, analysis, and other similar services. In such cases, our subcontractors and partners process personal data on our behalf and under our instructions.

Authorities and other third parties, such as telecommunications authorities or credit institutions, in the situations prescribed by law or a court order.

In the event of a merger or acquisition, your personal information may be transferred to the acquiring organization. In such a case, we will ensure the confidentiality of your personal information and give you the option to delete your personal information.

6. How long do we retain your personal information?

We retain personal data for as long as necessary for the purposes set out in this Privacy Policy, taking into account the legal basis for processing and our legitimate interests. We assess the necessity of retaining personal data on a case-by-case basis, taking into account factors such as the nature of the personal data and our legal obligations.

The basic principle is that we do not store personal data for longer than is necessary to achieve the purposes for which the personal data is processed. The criteria for determining the retention period include the duration of the customer relationship, the time elapsed since the last customer contact, and the applicable statutory retention periods.

7. What rights and choices do you have regarding the processing of your personal information?

a) Right of access and rectification

You have the right to access your personal data that we process. You can request information about your personal data and request rectification of inaccurate or incomplete personal data.

b) Right to erasure

You have the right to request the erasure of your personal data if:

the personal data is no longer necessary for the purposes for which it was collected or otherwise processed; you withdraw your consent on which the processing is based, and there is no other legal basis for the processing; you object to the processing, and there are no overriding legitimate grounds for the processing; the personal data has been unlawfully processed; or the personal data must be erased for compliance with a legal obligation.

Please note that we may have a legitimate reason to retain your personal data even if you request its erasure, for example, if we need to retain the data to comply with our legal obligations or to establish, exercise, or defend legal claims.

c) Right to restriction of processing

You have the right to request the restriction of the processing of your personal data if:

you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data; the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead; we no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise, or defense of legal claims; or you have objected to processing, pending the verification whether our legitimate grounds override yours.

If processing has been restricted, we will only process your personal data with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you before the restriction is lifted.

d) Right to object to processing

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data that is based on our legitimate interests. In such cases, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You have the right to object to direct marketing, including profiling related to direct marketing, at any time. If you object to processing for direct marketing purposes, we will no longer process your personal data for such purposes.

e) Right to data portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit those data to another controller if the processing is based on consent or on a contract and is carried out by automated means. In exercising your right to data portability, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

f) Right to withdraw consent

If we process your personal data based on your consent, you have the right to withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.

g) Right to lodge a complaint

If you believe that we have not complied with applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority.

You can exercise your rights by contacting our customer service or using other contact details provided in this Privacy Policy.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time due to various reasons, such as changes in our business operations or applicable laws and regulations. The most recent version of the Privacy Policy is always available on our website. We encourage you to review this Privacy Policy regularly.

If you have any questions or concerns about this Privacy Policy or our processing of your personal information, please contact us at [contact email].

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Rekisterinpitäjä

Viihdeväylä Oy
Pellontie 25
95700 Pello
Y-tunnus 0558698-7

puhelin 029 1234 121

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Viihdeväylä Oy
Pellontie 25
95700 Pello

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