Sininen Polku Oy is committed to processing all personal data appropriately and in accordance with applicable data protection legislation. In this document you will find a description of our policies with respect to processing of personal data related to our customers, potential customers and users of our website.
Please note that Sininen Polku’s website www.sininenpolku.fi may include links to other websites. Sininen Polku does not take responsibility for any external services nor is this policy applicable to them.
1. We are the Data controller:
Sininen Polku Oy
Business ID: 2726697-6
Address: Ahkiokatu 2, 20780 Kaarina
Phone number: +358 40 595 7478
2. What kind of personal data do we process?
Sininen Polku processes two types of personal data:
- Directly identifiable personal data: Full name, email, phone number, job title, employer, industry, areas of responsibility, newsletter clicks and opens, orders, contracts, billing information, feedback and marketing preferences.
- Automatically collected pseudonymised* data: Browsing data (time, clicks, duration, visit source, pages viewed, search terms) and technical data (device type, browser, IP-address, geographical location, operator and operating system). You will find more information about what is collected through cookies in paragraph 6 below.
*Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific person without the use of additional information.
3. Where is personal data obtained from?
4. For what purposes is personal data used and what is our legal basis of processing?
We process personal data for following purposes and on following legal basis:
- Consent. In case you register to our event, give permission to email marketing or subscribe our newsletter, we process your personal data based on your consent. You are entitled to withdraw your consent at any time. However, if you withdraw your consent, you may not be able to take part in the event we organize or receive our marketing information or newsletters.
- Contracts. We process your personal data to fulfil our contractual obligations regarding a service ordered from Sininen Polku. This includes orders, billing, customer feedback and other service-related communication. Unless you provide certain personal data, such as your contact details, we are not able to contract with you or with the organization you represent.
- Legitimate interest. Our aim is to offer our services to professionals who are likely to be interested in our services based on their position or responsibilities in the organization they represent. For this purpose, we may collect personal data of relevant prospects based on our legitimate interest and process such data for marketing purposes. You are entitled to object marketing at any time. We also use personal data to develop our business operations based on our legitimate interest. Based on the nature of data, the purposes of use and the information and choices available to you, we have assessed that your interests and fundamental rights and freedoms do not override our legitimate interests.
- Legal obligation. Sininen Polku may be obligated to store certain personal data in order to fulfil its accounting obligations or other legal obligations arising from applicable legislation.
We do not process personal data to make automated decisions which produce legal effects or would otherwise significantly affect you.
5. How is personal data shared or disclosed to third parties and where is it stored?
Sininen Polku does not sell or rent any personal data to third parties. We may share personal data for relevant legal purposes, such as analytics, marketing and marketing research. We may also disclose personal data if requested by authorities based on legislation and in connection with business transaction.
Third parties may collect data about use of our services as described below on paragraph 6.
We will primarily store our data in EU and EEA. However, we may under certain circumstances transfer personal data outside EU and EEA. In such cases we ensure that a legal basis for such a transfer exists and that adequate protection for personal data is provided as required by applicable law. This can be done for example by using standard contractual clauses approved by the European Commission.
Sininen Polku collects information about the usage of its web services through cookies and other similar technologies, such as for example pixel tags. A cookie is a small text file that is stored on the user’s terminal device, including an anonymous code which allows the identification of website visitors. Cookies or other similar technologies such as pixel tags do not harm users’ devices or files.
We use both persistent and session cookies. Persistent cookies remain stored until they reach an expiration date set for them or you delete them. Session cookies are automatically deleted when you leave our website.
We use both first-party and third-party cookies. First-party cookies are set directly by the website you are visiting. Third-party cookies are set by a domain other than the one you are visiting, such as our advertising partners (for example Google, Facebook and LinkedIn).
On Sininen Polku’s website, cookies are used for the following purposes:
- Advertising cookies are used for tracking how users navigate on websites, with the purpose of targeting users with personalized ads.
- Analytics cookies are used for improving the website’s functionality by tracking how users interact with our web pages. The collected data is used to analyse how users navigate our websites and make sure that the website is working properly. For example, Sininen Polku utilizes Google Analytics to measure and analyze website traffic. Pseudonymised data collected by Google Analytics may be sent to servers located outside EU.
- Essential cookies make basic website functions possible. This includes saving users’ cookie preferences.
You can manage your cookie preferences as described below on paragraph 9.
7. How is personal data protected?
Personal data is protected carefully with due organizational and technical security measures. Databases are protected with firewalls, passwords and other applicable measures. Backups, contracts and other physical documents are stored in locked facilities with strictly limited access. Sininen Polku makes sure that access to personal data is strictly limited to Sininen Polku personnel for legitimate business purposes. Access to Sininen Polku’s office is restricted and supervised with clearances. In the case of third parties’ access, data security and appropriate processing is guaranteed with applicable contracts.
8. How long do we store your personal data?
We will only retain your personal data in identifiable form as long as it is necessary to fulfil the abovementioned purposes or as long as we have a legal obligation to keep your personal data. After that it will be deleted or anonymised.
We retain the personal data of our customers’ contact persons for at least the time the customer relationship exists and the data remains current. After the customer relationship ends, we retain personal data for approximately 3 years. After that, we may retain your personal data for direct marketing purposes for as long as you hold a relevant position unless you have objected to it. We retain invoicing and payment information for 7 years after the relevant transaction.
You may request your personal data to be deleted in accordance with paragraph 9.
9. What rights do users have?
- Access and correction of personal data. You are entitled to accessing and correcting your personal data. Upon your request, Sininen Polku commits to deleting or correcting any outdated or incorrect data.
- Deletion of personal data. You can request your personal data to be deleted at any time by contacting us.
- Objection and restriction of processing. You have the right to object to processing we carry out on the basis of legitimate interest on grounds relating to your particular situation, unless we have compelling legitimate interests for the processing which override those interests. You also have the right to request the restriction of the processing of your personal data, for example, in case you object to processing or contest the accuracy of your personal data.
- Opt-out of and withdrawal of consent to direct marketing. You can opt-out of or withdraw consent to direct marketing at any time by contacting us or by using the automatic opt-out link in Sininen Polku’s marketing emails.
- Data portability. You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when we process your data automatically based on a contract or your consent.
- Cookie preferences:
- Accepting or declining cookies. You can accept or decline non-essential cookies when entering our website. You can withdraw your consent at any time by clicking “cookie settings” on the footer of our website.
- Blocking and deleting cookies. You can block or delete cookies by using your browser’s settings. Please note that if you block cookies, it can hinder some functionalities of our website
- Google Analytics opt-out. To prevent your data from being used by Google Analytics you can install the browser plug-in from Google which is available via following link: https://tools.google.com/dlpage/gaoptout?hl=en
To use your rights described above, please send your request to the address show on paragraph 1. Please note that we will ask you to verify your identity when using your rights.
Sininen Polku continuously develops its services and updates this policy when necessary. Changes can also be made when applicable legislation is changed. Please revisit this policy from time to time to notice any such changes.