Privacy, security and online safety are important for us, and we process all personal data with due care and in accordance with applicable laws and regulations.
1. IMMERSAL’S CONTACT DETAILS
Name: Immersal Ltd.
Company ID: FI27121857
Correspondence address: Urho Kekkosen katu 4–6 A, 00100 Helsinki, Finland
E-mail address: email@example.com
2. PERSONAL DATA PROCESSED AND SOURCES OF DATA
We collect the following information types of the Users:
(i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data can also be considered to be personal data under applicable laws and we will treat the combined data as personal data.
During the User’s use of the Services, Immersal may collect and process for example the following User Data from Users: (i) first and last name; (ii) e-mail address; (iii) phone number; (iv) Name and information regarding the organization the User represents; (v) information that Users provide when rating our Services or giving feedback on our Services; (vi) any other personal data Users may provide themselves.
The specific kind of User Data collected will depend on the Services used. User Data is received directly from Users.
Technical Data may include for example the following data (i) User’s IP address; (ii) browser type and version; (iii) preferred language; (iv) geographical location using IP address or the GPS, wireless, or Bluetooth technology on your device; (v) operating system and computer platform; (vi) the full Uniform Resource Locator (URL) clickstream to, through, and from our Services, including date and time; and (vii) areas of our Services User has visited.
Our Services use web analytics services to compile Technical Data and reports on visitor usage and to help us improve our Services. For an overview of Google Analytics, please visit Google Analytics.
3. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA
There are several purposes for the processing of personal data by Immersal:
To provide our Services and carry out our contractual obligations
We process personal data in the first place to be able to offer the Services to Users and to run, maintain and develop our business. We process and use personal data for example to provide essential functionalities for customers and Users. In some cases, personal data may be processed in order to carry out our contractual obligations towards the User. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If User contacts our customer service, we will use the provided information for answering questions and solving possible issues.
For customer communication
We may process personal data for the purpose of contacting Users regarding our Services and to inform Users of changes in our Services. Data may also be used for research and analysis purposes in order to improve our Services.
For quality improvement and trend analysis
We may process information regarding the use of the Services to improve the quality of our Services e.g. by analysing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.
For statistical and analytical purposes
Immersal may gather Technical Data and other anonymous and aggregate data in order to generate reports and statistics. We may use statistics and reports for sales and marketing purposes. In addition, we may provide customers and Users with the aforementioned statistics and reports. For clarity, such statistics and reports do not include any personal data.
For other legitimate purposes
We process personal data for the purposes of direct marketing, such as the sending of newsletters or similar marketing material. Users can unsubscribe from receiving such material at any time.
In some parts of the Services, Users may be requested to grant their consent for the processing of personal data. In this event, Users may withdraw their consent at any time.
4. TRANSFER TO COUNTRIES OUTSIDE EUROPE
The data handled within our service platform is stored within the EU/EEA.
For our website functions we use service providers in several geographical locations, such as Google Analytics. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile. We will take steps to ensure that Users’ personal data receives an adequate level of protection in the jurisdictions in which we process it. We provide adequate protection for the transfer of personal data to countries outside of the European Economic Area through a series of intercompany agreements and agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements.
We only share personal data within the organisation of Immersal if and as far as reasonably necessary to perform and develop our Services.
We do not share personal data with third parties outside of Immersal’s organization unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside Immersal’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, properties or safety of Immersal, our Users or the public in accordance with the law. When possible, we will inform Users 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 Immersal’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so.
6. STORAGE PERIOD
Immersal does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services 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.
Typically, we will store User’s personal data for as long as the User is a registered subscriber or a registered user of our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law or reasonably necessary for internal reporting and reconciliation purposes.
In general, personal data of Users are deleted within reasonable time after the User no longer uses any part of the Services or when the User makes a request regarding deletion of User’s personal data.
7. USERS’ RIGHTS
Right to access
Immersal offers access for the Users to the personal data processed by Immersal. This means that Users may contact us and we will inform what personal data we have collected and processed regarding the said User and the purposes such data are used for.
Right to withdraw consent
In case the processing is based on a consent granted by User, User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services.
Right to correct
Users have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about the User corrected or completed.
Right to deletion
Users may also ask us to delete the User’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. We may not immediately be able to delete all residual copies from our servers and backup systems after the active data have been deleted. Such copies shall be deleted as soon as reasonably possible.
Right to object
Users may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to the User or for compliance with a legal obligation.
Users may also object any further processing of personal data after prior given consent. If User objects the further processing of personal data, this may lead to fewer possibilities to use our Services.
Notwithstanding any consent granted beforehand for the purposes of direct marketing, User has the right to prohibit us from using User’s personal data for direct marketing purposes, market research and profiling by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
Right to restriction of processing
Users may request us to restrict certain processing of personal data, this may however lead to fewer possibilities to use our Services.
Right to data portability
Users 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: name, address, phone number and a copy of a valid ID. We may request the provision of additional information necessary to confirm the identity of the User.
We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
8. LODGING A COMPLAINT
In case User considers 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.
9. INFORMATION SECURITY
It is our responsibility to protect our platform and data with best possible solutions.
We take all reasonable and appropriate security measures to protect the personal data we store and process from unauthorised access or unauthorised alteration, disclosure or destruction. Measures include for example, end-to-end TLS communication encryption and encryption of sensitive user information. We monitor data security threats and solutions, and take them into account in our platform solutions and architecture.
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, and availability. We regularly test our websites, data centres, 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 the privacy of Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible.
For more information, contact our CTO Tatu Blomberg, +358 40 933 6070 or firstname.lastname@example.org.