Creation date 12.6.2020

1. DATA CONTROLLER

Jutel Ltd.
Elektroniikkatie 4
90590 Oulu
Finland

2. PERSON TO CONTACT IN MATTERS RELATED TO THE PRIVACY POLICY AND DATA FILE

Reijo Kivelä, CEO
Email: reijo.kivelä@jutel.fi

3. DATA FILE NAME AND DATA SUBJECTS

Jutel | Customer and marketing data file

In the data file, we process the personal data of our customers, potential customers and their representatives.

4. HOW DO WE PROCESS AND USE YOUR PERSONAL DATA?

We use your information to market, produce and develop the services provided by Jutel. We collect, store and process personal information only for pre-defined purposes.

5. WHAT KINDS OF PERSONAL DATA DO WE COLLECT AND STORE?

The following information may be stored about the data subject:

6. FROM WHICH SOURCES DO WE COLLECT PERSONAL DATA?

We collect personal data concerning you mainly from you yourself when you contact us or later in connection with the use of our services. We may also collect customer related information from public sources or registers or public social media profiles.

7. ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

We will see to it that we always have legal grounds for processing your personal data.

We process data saved into the marketing data file on the basis of our legitimate interest (e.g. direct marketing to our customers or product developement of our services) or based on your consent.

We process our customer data according to the agreement with the customer.

8. WILL YOU PERSONAL DATA BE TRANSFERRED OR DISCLOSED?

Your data is mainly processed by our company’s personnel as part of their work.

In some cases, your personal data may be disclosed confidentially to our partners or our subcontractors who process personal data on the basis of a written commission agreement. Such cases include, for instance, data centre and cloud services intended for storing data, providers of the IT systems we use and external services acquired to support sales and marketing.

Our subcontractors and partners process personal data as agreed, according to our written guidelines and only for agreed, legal purposes.

9. IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EU OR ETA REGION?

We don’t transfer your personal data outside the EU or ETA region.

The website analytics service we use (Google Analytics) might transfer analytics data outside the EU region. Google has agreed to the Privacy Shield-agreement, which guarantees an agreeable level of information security approved by the European Commission.

The social media channels we use might also transfer your data outside the EU and ETA region in accordance with the Privacy Shield-agreement.

10. FOR HOW LONG IS YOUR PERSONAL DATA STORED?

We store your personal data only for as long as is required for the purposes described in this policy. Data that is no longer required is erased regularly, at least once a year.

11. HOW IS YOUR PERSONAL DATA SECURED?

We respect the confidentiality of your personal data.

Personal data is protected from use by third parties with firewalls, antivirus software, personal user IDs and passwords. Personal data can only be accessed by persons authorized by Jutel whose work duties require them to process personal data. We disclose personal data to our partners, such as our subcontractors, only in a confidential and restricted manner on the basis of agreements. Our partners must commit to ensuring adequate information security and the legal processing of personal data in all aspects of the processing. The persons who process personal data are bound by an obligation of secrecy.

Our website uses a TLS-encrypted HTTPS connection, which ensures the protection of all electronic personal data. In the browser, this is indicated by the green lock icon on the left in the address bar. If there is data in a manual format, they are stored in locked premises that cannot be accessed by third parties and they are destroyed securely if needed.

12. HOW DO WE USE COOKIES?

Cookies are small text files that are automatically stored on your computer/terminal device when you visit different websites. Our web service uses cookies so that we can provide a high-quality service which is as user-friendly as possible.

We may use cookies to develop our services and website, to analyse the use of the website (Google Analytics) and to target and optimise marketing (with e.g. Facebook Pixel). With the aid of website traffic monitoring, we develop our website to improve it and to create a better user experience.

If you do not wish the online service to collect data through cookies, you can prevent cookies (most browser software allow the user to disable cookies). You can prevent Google Analytics from collecting data about you. Read more about this on Google’s website. However, please note that in this case, it is possible that the online service does not function properly.

13. WHAT RIGHTS DO YOU HAVE?

13.2 Right of access (right of review)

Everyone has the right to know what kinds of data concerning them is stored in a personal data file. You can request your data from us for review as described in Section 14.

13.3 Right to demand rectification or erasure of data (right to be forgotten)

Jutel erases, rectifies or supplements, on its own initiative or at the request of the data subject, any data that is erroneous, unnecessary, incomplete or obsolete with regard to the processing.

13.4 Right to restriction of processing

The data subject has the right to request the restriction of the active processing of their personal data when, for instance, the data subject contests the accuracy of their personal data and requests the rectification or erasure of the data. In this case, the personal data in question may only be stored, not otherwise processed. The restriction of processing is ensured by technical means.

Before the restriction of processing is lifted, Jutel informs the data subject of this.

13.5 Right to object to the processing of personal data

You have the right to object the processing of personal data concerning you provided that there is no compelling reason for the processing of the data, overriding your rights, or that the processing is not required for handling a legal claim.

13.6 Right to data portability

As far as the data subject has provided data to the customer data file themselves and the data is processed on the basis of the data subject’s consent or commission, the data subject has the right to receive this data in a machine-readable format, as a rule, and the right to transmit this data to another data controller.

13.7 Withdrawing consent

If personal data is processed on the basis of the data subject’s consent, the data subject has the right to withdraw their consent by informing Jutel of this. You can withdraw your consent as described in Section 14.

13.8 Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with a competent supervisory authority if the data controller has not complied with the applicable data protection regulations in their operations.

14. REQUESTS RELATED TO THE RIGHTS

Any enquiries and requests related to the data file can be submitted either in person by presenting an identity document or contacting us via sales@jutel.fi. We will be in touch after your contact to ensure your identity.

We deliver the data to your email address as a password-protected document, with the password sent as an SMS to your phone.

Jutel responds to requests within one (1) month of the submitting of the request unless there are special reasons for a longer response time. We may also refuse to fulfil your request on grounds defined in applicable law.

Exercising your rights is free of charge per se.

15. IS THE PROVISION OF INFORMATION OBLIGATORY?

If you do not approve of the processing of your personal data within the framework of the purposes and rights described in this Privacy Policy, it is likely that we cannot serve you and fully realise the purpose of our operations. Consequently, if you do not wish us to process your personal data according to these principles, we would like to request you not to provide any information to us.

16. WHERE CAN I FIND THE LATEST PRIVACY POLICY?

We will always update the latest Privacy Policy to this web address.