Finwe Ltd.

Privacy Policy

February 04, 2021

Privacy Policy

Last updated: 2021-02-04

Finwe is committed to respect Your privacy and personal data, and to comply with applicable data protection and privacy laws. The purpose of this Privacy Policy is to explain how Finwe and its authorised partners and affiliates ("Finwe", “We” or “Us”) process Your personal data related to Finwe’s websites and internet services ("Site").

"Personal data" means any information that can be directly or indirectly used to identify You or another individual. Finwe processes Your personal data in accordance with the General Data Protection Regulation (EU 2016/679) and other applicable personal data legislation.

The Site, Finwe’s products or services may contain links to other companies’ websites and services that have their own privacy policies, and/or the services of third parties installed on Your device may allow access to information on Your device. Finwe advises You to read carefully the privacy policies of such third parties. Finwe is not responsible for such third party service providers’ privacy practices or contents.

By using the Site and/or by submitting personal data to Finwe, You understand and agree that Your personal data may be processed as explained in this Privacy Policy. If You do not accept this Privacy Policy, Finwe advises You not to use the Site or submit any personal data to Finwe.

In the following, we provide information on the kinds of data we collect on these websites and the purposes for which we use such data.

Collected Personal Data

Data provided by You

In connection with registration to our services, contact inquiries, subscriptions, surveys, polls, support requests, bug reports, or other such relationship, we collect personal data that You have provided to us at the time of the operation with Finwe, including e.g.:

  • Contact details (e.g. name, address, telephone number, e-mail address, city of residence, and country of origin)
  • Username and password in relation to Finwe services that You use via a user account provided by Finwe
  • Possible feedback and inquiry messages provided by You
  • Any other information that may be provided by You

Observed data about Your online usage

When visiting Finwe's websites, observed data about Your online usage is collected. The data includes statistics and analytics e.g.:

  • Data collected using cookies and other similar technologies, such as the pages browsed by the user, the sites the user accessed Finwe's websites from, the device model, individual device and/or cookie identifier, the channel through which the service is accessed (web browser, mobile browser, application), browser version, IP address, session identifier, session time and duration, geographical location data, date and time, screen resolution, operating system, clicks, scrolling and mouse movements.

Purpose of the processing of personal data

The purpose of processing Your personal data is to

  • Ensure an efficient and secure use of our websites and services
  • Develop our websites for a better quality and broader scope of services
  • Provide customized services and content recognizing your specific needs and interests
  • Enable access to Your user accounts
  • Communication between us and You and reply to Your contact requests, inquiries and feedback
  • Provide marketing information for Finwe products or services via targeted e-mails or interpersonal communication
  • Conduct research and collect statistics (e.g. what sections of our websites the users visit and how much time they spend on the websites)

Information related to job applications is submitted and saved separately via email.

Legal basis for processing

  • Legitimate Interest of Finwe (e.g. observing Your website usage in order to ensure an efficient and secure use of our websites, to develop our services, to provide customised content to make our services more relevant to You, to provide marketing material and to collect statistics)
  • Your consent. Your consent will be asked in relation to using website cookies. You will find additional information on how cookies are used in the Cookie Policy. If You are not a business contact person, Your consent will be asked before providing any e-mail marketing material to You.
  • Performance of a contractual relationship between You and us (e.g. contacting You in relation to subscriptions and registrations and sending newsletters based on Your subscription)

Regular sources of data

Your personal data is either collected from You at the time of registration, contact inquiry or subscription etc. We may also access personal data that You have provided to Finwe by other means, e.g. through online customer portal, since our online systems may be connected to each other.

Furthermore, Your personal data may be received from online technologies, such as cookies, in order to apply filtering, observe usage and develop our websites and services.

You will find additional information on how cookies are used in the Cookie Policy.

Storing personal data

The personal data will be mainly stored electronically. The personal data is stored in locked premises with restricted access and protected by a participant ID and a password. All physical copies of the personal data, if any, will be stored in locked premises. Only persons who need to process the personal data as part of their duties have access to and the right to process the information stored in the register.

We handle personal data that You have provided to us (such as profile and contact details) separately from observed data about online service use and derived data, typically in separate databases. Observed or derived data about service usage is always stored using identifiers that are typically randomly generated and thus users cannot be personally identified from the identifiers.

Your personal data is stored as long as necessary in relation to the purposes for which the personal data was collected, unless there is a legal obligation to retain the personal data longer (e.g. in case of an ongoing legal proceeding).

Regular disclosure of data and the transfer of data outside the EU or the EEA

Processing of personal data may be outsourced to our service providers to enable the performance of services for us. Furthermore, personal data can be disclosed to third parties in the following situations:

  • We may disclose to our advertisers segment data about observed users for the purpose of targeting advertisements. Advertisers shall not combine this data to an identified user’s personal data without the user’s consent
  • We may also disclose personal data to authorities or to other parties based if required to do so by law
  • In the case of mergers, acquisitions, or other kinds of re-arrangements of our business operations, personal data may be transferred to buyers and their advisors
  • In accordance with the service specific descriptions of personal data files information may be disclosed for direct marketing purposes, as well as opinion polls and market research studies and other similar studies in accordance with applicable personal data provisions

In some cases, the recipients of personal data may be located outside of EU/EEA, in which case we will ensure that sufficient level of data protection is maintained through appropriate safety measures, e.g. by using EU commission’s standard contractual model clauses.

Finwe may further conduct marketing and other communication jointly with Finwe’s partners and in connection with this, Finwe may combine information Finwe has collected about You with information Finwe’s partners have collected about You to e.g. avoid unnecessary communication and tailor Finwe’s message to You.

Your rights

Right of access

You are entitled to inspect Your personal data and to receive a written copy of the personal data. The inspection is free of charge.

Right to data portability

To the extent Finwe processes Your personal data based on Your consent, or for the purposes of a contract between You and Finwe, You are entitled to receive Your personal data, which You have provided to Finwe, in a structured, commonly used and machine-readable format and, when technically feasible, have the right to transmit those data to another controller without hindrance from Finwe.

Right to object

You are entitled to object at any time to processing of Your personal data for direct marketing purposes.

Right to request rectification, erasure or restriction

You are entitled to ask Finwe to rectify or erase Your personal data in case it is obsolete, irrelevant, incorrect, incomplete, otherwise inaccurate or due to other legally acceptable ground. You are also entitled to request restriction of processing of Your personal data.

Right to file a complaint

While Finwe hopes to resolve any issue You may have with how Finwe processes Your personal data, You do also have the right to lodge an official complaint with Your local national data protection supervisory authority.

If You wish to exercise Your rights, please present a written request to the address stated here:

Finwe Ltd., Teknologiantie 11, FI-90570 Oulu, Finland

Use of Cookies

A cookie is typically a small piece of data sent to Your computer device from a website and stored in Your web browser while You are browsing a website. When You browse the same website again, the data stored in the cookie may be retrieved by the website to notify the website of Your previous activity. To read more about these technologies and how they work, please see for example http://www.allaboutcookies.org.

For more information and details, we advice You to read our separate Cookies Policy document. It is linked to the footer of every page on the Site.

Website Analytics and Visitor Information

The Site uses a web analytics service provided, for example, by Google, Inc (“Google”). To read a statement on the web analytics service by Google, please click here. By accepting all cookies when requested from You by the Site, You consent to the processing of data about You by Google in the manner and for the purposes set out in the above statement.

Third parties, such as advertisers, advertising networks and providers of tracking services, may set cookies on Your device when You are visiting the Site, for example to provide You with targeted advertising or to compile statistics on the number of visitors on the Site. Since Your web browser must request these advertisements from third parties’ servers, these third parties may view, modify or set their own cookies as if You had requested a webpage from the third parties’ website directly.

The Site may use social media plugins. The content of the social media plugins on the Site is from such social network(s) directly. When You visit the Site while logged into a social network, Your browser establishes a direct connection with the social network’s servers. If You are logged out from the social network(s) while visiting Site, Your browser sends the social network(s) a more limited information. The social media plugins on the Site are subject to the privacy terms and other terms and conditions of the relevant social media sites. The information collected by the social network(s) is not disclosed to Finwe without Your explicit consent.

Processing of Forms

The Site uses forms for querying information in a structured manner from its users. When You send us a contact request, support request, or a bug report, a form will be used for querying many required and optional data items from You. The data typically includes both personal and non-personal data.

The Site uses a form processing service provided, for example, by Formspree, Inc ("Formspree"). When You click a form's "Send" button, Formspree receives all the data that You entered into the form, and sends it to Finwe in a structured form. To read Formspree's Privacy Policy, please click here.

The Site uses a spam-prevention mechanism to reduce the amount of automatically created marketing messages. Such messages are typically generated by bots that search for forms on the Internet and fill them with unwanted marketing messages ("spam"). The Site uses an external service, for example, by Google, Inc ("Google"), that attempts to distinguish whether a form user is a human or a bot. In order to send a form, You must perform a small task created by this spam-prevention service. Your answer to this test will be sent to Google. To read how Google processes Your data, please click here.

By sending us data via a form, You consent to the processing of data about You by Formspree and Google in the manner and for the purposes set out in the above linked policies. If You do not accept these terms, please do not send us any data via the forms on the Site. Alternatively, You can always contact us directly by writing to us:

Finwe Ltd., Teknologiantie 11, FI-90570 Oulu, Finland

Controller of Personal Data

The controller for Your personal data is Finwe Ltd. (“Finwe”). You can reach the data controller at:

Finwe Ltd., Teknologiantie 11, FI-90570 Oulu, Finland

Changes to this Privacy Policy

Please be aware that Finwe may change this Privacy Policy from time to time. However, in the event of any material, adverse changes, Finwe will post a notice informing of such changes both at the beginning of this Privacy Policy and on the Site’s home page. Finwe advises You to visit this Privacy Policy from time to time to be aware of such changes.

Should You have any additional questions, please don’t hesitate to contact us by writing us to:

Finwe Ltd., Teknologiantie 11, FI-90570 Oulu, Finland