Swappie Oy Privacy Policy

1. Name of the Register

Swappie Oy Customer Register

2. Data Controller

Swappie Oy (“us” or “Swappie”) processes personal data for the purpose of maintaining customer relationships, enabling customer communications, carrying out contracts and direct marketing. In addition, we collect analytical data on our website visitors.

In addition to private customers, Swappie Oy has corporate customers and partners whose representatives’ personal data may be processed as part of this register. The data of corporate customers’ representatives is used only for carrying out communications and marketing directed at said corporations.

Swappie Oy is committed to respecting and protecting your privacy and thus we want you to know how we process your personal data. We will describe the processing of your personal data in more detail below.

Please note that this Privacy Policy is only applicable to the processing of personal data done by Swappie Oy as the data controller.

3. Contact Information

Data controller contact information:

Business ID: 2692328-4

Address: Itämerenkatu 15, 00180 Helsinki, Finland

Telephone number: +358104063821

Email address: privacy@swappie.com

Website: www.swappie.com

Person responsible for the register:

Sami Marttinen

sami@swappie.fi

Itämerenkatu 15, 00220 Helsinki, Finland

4. Data Collected

  • First and last name
  • Contact information
  • Marketing-related consent, prohibitions or other information, or additional information provided
  • For corporate customer representatives, the organisation, position and other information related to the corporate customer relationship
  • IP address
  • Browser session identifiers
  • URL trail on the website and time spent
  • Time of visit
  • Browser type and version
  • Device type
  • Name and email address of newsletter subscribers
  • Changelog for information important to assignments

5. Data Sources

Data received from the data subject

We primarily receive the data processed in accordance with this Privacy Policy from the data subjects themselves.

The data collected from our website is stored on the server during a visit.

The data can also be obtained through other service providers, if possible and in accordance with regulations.

Cookies

We use various technologies for collecting analytical data when users visit out Swappie Oy services, including cookies and Web Beacon technology.

A cookie is a small text file sent to and stored on the user’s computer, which enables the website administrator to identify frequent visitors visiting the site, facilitate the visitors’ use of Swappie Oy services and enable compiling aggregate data on visitors. This feedback helps us continuously improve our Swappie Oy services and better serve our users. Cookies do not harm the users’ computers or files. We use them in order to provide our customers with information and services tailored to their individual needs.

You can disable the use of cookies in your browser or set your browser to alert you when attempting to install cookies. The following links, for example, provide information on changing cookie preferences in some of the most used browsers:

Safari

Google Chrome

Internet Explorer

Mozilla Firefox

Please note that some parts of our Swappie Oy services may not work correctly if cookies are disabled.

“Web Beacon” is a technology that enables the identification of readers of web pages and emails, for example, by identifying whether an email has been read.

Web analytics services

Our Swappie Oy services use Google Analytics and other web analytics services to gather analytical data and reports on our visitors use of our website, so that we can improve our Swappie Oy services. For more information on Google Analytics, visit the Google Analytics website. To opt out of data collection by Google Analytics, download the following add-on for your browser: Google Analytics opt-out add-on.

6. Purpose of Data Processing

Personal data may also be used for the following purposes, in accordance with the law and consent: marketing, provision and completion of services, development and execution of customer service, analysis and compiling statistics, developing services, customer service and business, and any other activity relevant to sales or services.

Customer communications and maintaining customer relationships  

Personal data is used for handling, managing, maintaining and developing customer relationships and communication between Swappie Oy and its customers. If you contact us, we will use the information provided to answer your questions, resolve any issues you may have and process your message.

Marketing purposes

If you have given your consent to receive direct marketing, we may send you information about Swappie Oy’s activities and other direct marketing material.   

The data subject always has the right to prohibit us from using personal data for direct marketing, marketing research or profiling by contacting us via the contact details listed above, or by using the unsubscribe option provided in connection with direct marketing messages or the newsletter.

7. Data Retention

We only retain personal data for as long as the law requires or for as long as they are necessary for the above-mentioned purposes.

8. Transfer of personal data outside the European Economic Area

We may process personal data in systems that transfer information outside the European Union and the European Economic Area. If the European Commission has not considered the destination country’s level of data protection adequate, we will ensure an adequate level of data protection for your personal data through our contractual practices (e.g. the European Commission’s model clauses on transferring personal data to third countries) or other measures.

9. Personal Data Recipients

We may disclose information to authorities regulating business, such as the Regional State Administrative Agencies, Tax Administration, Office of the Data Protection Ombudsman or any other party required by law, to the extent described in this Privacy Policy.

For legal reasons

We may disclose personal data to parties outside the Swappie Oy organisation if access to personal data is reasonably deemed necessary in order (i) to comply with applicable laws, regulations or a court decision; (ii) to detect, prevent, or otherwise address fraud, money laundering, terrorism financing, or technical or data security problems; or (iii) to ensure the safety and protect the assets of Swappie Oy or its customers, or for the purposes of public interest in accordance with the law.

Authorised service providers

We may disclose personal data to authorised service providers providing services for us. Our agreements with our service providers include commitments under which the service providers commit to restrict the use of personal data and to comply with at least the privacy and data security standards of this Privacy Policy.

With your express consent

We may disclose personal information to third parties outside of the Swappie Oy organisation for reasons other than those previously mentioned when we have the express consent of the data subject. The data subject has the right to revoke such consent at any time.

10. Rights of the Data Subject

Right to access data

The data subject has the right to access their personal data processed by Swappie Oy. If you wish, you can contact us to find out which personal data we process and for what purpose this data is used.

Right to demand correction of data

You have the right to demand that we correct or complete incorrect, inaccurate, incomplete, outdated or unnecessary personal data that we store. You can update, for example, your contact information or other personal data by contacting us..

Right to demand deletion of data

You can ask us to delete your personal data. We will perform the actions you have requested if we have no legitimate reason not to delete the data.

Right to object and right to restrict processing

You have the right to object to the processing of your data, or profiling if your data is processed for direct marketing. You have the right to demand the processing of your personal data be restricted, if, among other reasons, the data about you is incorrect. In addition, you have the right to object to the processing of your personal data under certain specific circumstances on the basis of specific personal circumstances.

Right to transfer data from one system to another

The data subject has the right to obtain their personal data from us in a structured and widely used form and to independently transfer the data to a third party.

Using the rights

If you want to use one of the above rights, please send the following information to Swappie Oy by post or email: name, address, telephone number and a copy of a valid form of identification. We may request that you provide more information for identity verification. We may reject requests that are repeated unreasonably often, are excessive or which are clearly unjustified.

11. Data Security

We have implemented administrative, organisational, technical and physical safeguards to protect the personal data we collect and process. Our security measures have been designed to maintain an appropriate level to ensure the confidentiality, integrity and availability of the data.

Personal data can only be processed by those persons whose job functions justify it. The use of personal data is protected by the appropriate user-specific credentials, passwords and access rights.

12. Making Complaints

You have the right to file a complaint with the Supervisory Authority if you believe Swappie Oy’s processing of personal data is not in accordance with data protection regulation.